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{{#Wiki_filter:June 29, 2023
 
==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. 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, Signed by Benjamin, Jamie on 06/29/23 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: NPF-58 Report Number: 05000440/2023010 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 Enclosure
 
=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      Report Aspect            Section Mitigating            Green                                      None (NPP)        71111.21M Systems              NCV 05000440/2023010-01 Open/Closed 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      Report Aspect            Section Mitigating            Green                                      None (NPP)        71111.21M Systems              NCV 05000440/2023010-02 Open/Closed 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      Report Aspect            Section Mitigating            Green                                      None (NPP)        71111.21M Systems              NCV 05000440/2023010-03 Open/Closed 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      Report Aspect            Section Mitigating            Green                                        None (NPP)        71111.21M Systems              NCV 05000440/2023010-04 Open/Closed 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      Report Aspect            Section Not Applicable        Severity Level IV                            Not Applicable    71111.21M NCV 05000440/2023010-05 Open/Closed 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) ===
{{IP sample|IP=IP 71111.21|count=8}}
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
: (2) Unit 1: HPCS Diesel Generator (DG) (1E22B0001)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
: (5) Unit 1: ESW HPCS Strainer (1P45D0003)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
: (4) Calculation B13-027, Revision 0 - ASME Code NB-3200 Analysis of HPCS Piping Location
: (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)
: (1) SCR 16-01392, Revision 1 - ECP 16-0139 2 Replacement of Valves 1E12F0084A/C
: (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
: (11) SCR 12-01602, Revision 1 - ECP 12-0037: Installation of 18 Inch Tall Flood Curb at
 
===Door IB-103 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    Report Aspect          Section Mitigating            Green                                    None (NPP)      71111.21M Systems                NCV 05000440/2023010-01 Open/Closed 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      Report Aspect              Section Mitigating            Green                                    None (NPP)          71111.21M Systems              NCV 05000440/2023010-02 Open/Closed 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 hours, 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 hours, 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 hours, 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      Report Aspect            Section Mitigating            Green                                    None (NPP)        71111.21M Systems              NCV 05000440/2023010-03 Open/Closed 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      Report Aspect            Section Mitigating            Green                                      None (NPP)        71111.21M Systems              NCV 05000440/2023010-04 Open/Closed 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 Report Aspect          Section Not              Severity Level IV                                Not              71111.21M Applicable        NCV 05000440/2023010-05                          Applicable Open/Closed 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 Type        Designation    Description or Title                                    Revision or
Procedure                                                                                    Date
71111.21M Calculations 1 P45G071A    T: Evaluation of Emergency Service Water Piping and    0
Supports for Package 1 P45G071A
1E22G008A      Analysis of Piping for HPCS Diesel Exhaust              5 and A-01
1P45H0010      Qualification of Emergency Service Water Pipe Support  3
1P45H0010
B13-027        ASME Code NB-3200 Analysis of HPCS Piping Location      0
DRF-A22-00084- Station Blackout                                        10/12/1999
E22-029        SVI-E22-T2001 HPCS Pump Performance Test                7
Acceptance Criteria
E22-042        Division 3 EDG Jacket Water Heat Exchanger Performance  5
Test
E22-043        HPCS System Hydraulic Analysis                          04/13/2006
E22-C10        HPCS Pump Discharge Indicated Flow                      1
ECA-018        Environmental Conditions Analysis                      4
ECA-064        HPCS PRC Load for Steady State Room Temperatures        4
EQ-151        Determine Effects on Safety Equipment for Accident      1
Temperature Increase
GEN-022        Mission Times                                          0
JL-083        Flooding Analysis of CCB, IB, and FHB - Floor Elevation 3 and P-01
574-10
M39-014        HPCS Pump Room Cooler Air Flow Rate and Performance    06/11/2012
Evaluation at Design Conditions
M39-015        HPCS Pump Room Cooler Performance Test Results          4
M39-016        ECCS Pump Room Coolers Design Airflows                  1
M39-017        Minimum Reynolds Number to Verify Turbulence for        0
1M39B0003 Operating Ranges
P45-030        Perry Unit #1 P45 System Operating Temperatures        10
P45-031        SW-ECC Emergency Temperatures                          4
P45-038        Evaluation for Cavitation in Butterfly/Globe Valves    2
P45-051        Composite Bias Uncertainty of HPCS PRC ESW Flow        0
P45-056        ESW Pump Performance Acceptance Criteria for SVI-P45    1
Inspection Type              Designation  Description or Title                                      Revision or
Procedure                                                                                            Date
T2001
P45-057C      ESW System Thermal Hydraulic Model (Loop C)              0
P45-075      Minimum Branch Flow Rates for P45 Surveillance            2
Acceptance Criteria
P45-078      Emergency Service Water Pump "C" as Built Head            01/31/2006
Capacity Curve
P45-081      Evaluation of Net Positive Suction Head (NPSH) and        09/28/2004
Submergence Requirements for the Emergency Service
Water (ESW) Pumps
P45-44        Keep Fill Check Valve Leak Rate Standpipe Draindown      2
Level
P924          Penetration Analysis for P-108, P-310, P-311, and P-409  5
PRDC-0002    Unit 1 Div 1, 2, 3 125 VDC System Coordination            4
PRDC-0012    Evaluation of DC Loads for a 4 Hours Design Basis Station 3 and 3 P-01
Blackout (SBO) and Also for a 24 Hours Beyond Design
Basis Events
PRDC-0016    Division 3, 125 VDC System Load Evaluation, Voltage      3, 3 P-01, 3
Drop, Battery / Battery Charger Sizing Calculation        A-01, and 3
PY-1R45A0005  Final Report on ASME Section III Analysis of Class 3      12/16/1977
Nuclear Safety Related Shop Fabricated Tanks for the
Perry Nuclear Power Plant
R45-003      Diesel Fuel Oil Pumps                                    1
R45-007      Standby and HPCS DG Fuel Oil Day Tank Volume Level        2
R45-012      HPCS and Div. I & II Fuel Oil Day Tank Setpoint Volumes  2
R45-C04      Div. 1, 2&3 DG Fuel Oil Day Tank ITS Volume Calculation  0
R48-10        Standby and HPCS DG Intake Air                            1
SQ-0147      Seismic Qualification for 1P45C0002 (ESW Pump)            1
Corrective Action CR 1996-02889 HPCS DG Left Bank Admission Valve                        09/05/1996
Documents        CR 2003-05065 Track Activities to Completion That are Required to Close 04/15/2005
the Operability Determination
CR 2003-05354 Emergency Service Water Pump Couplings                    12/04/2004
CR 2017-08373 Potential Seismic Bolt Missing from Charger              08/11/2017
CR 2017-08373 Potential Seismic Bolt Missing from Charger              08/11/2017
Inspection Type              Designation  Description or Title                                      Revision or
Procedure                                                                                            Date
CR 2017-08930 NRC ID DBAI Inspection: Calculation SBO-007              08/29/2017
Conservatism and Degraded CST Instrumentation LIne
Insulation
CR 2017-09006 NRC ID DBAI Inspection: The SBO Analysis Requires 150k    08/31/2017
Gallons of Water from the CST Which Affects ONI-R10
Requirements
CR 2017-09033 NRC ID DBAI Inspection: ESW Discharge Strainer            08/31/2017
Differential Pressure Alarms are the Same Value as Design
Maximum Value
CR 2019-00742 Deficient 50.59 Screen for Temporary Insulation Removal  02/22/2019
Spec Change Notice
CR 2019-06875 2019 NRC 50.59 Inspection: Inappropriate 10CFR 50.59      08/15/2019
Exemption Applied for RAD
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      05/09/2022
Maintenance
CR 2022-04902 Division 3 ESW Degradation                                06/16/2022
CR 2022-07882 Division 1 Diesel Right Bank Cylinder 6 Low Exhaust      10/18/2022
Temperature
CR 2023-10157 FME: Division 1 Right Bank #6 Thermocouple Outer Sheath  02/15/2023
Found Missing During Replacement
CR G202-2002- Determine Operability of ESW with an ESWPH Ventilation    01/31/2002
00329        Subsystem out of Service
Corrective Action CR 2023-03504 NRC ID: 2023 CETI Inspection: NRC Identified Material    04/25/2023
Documents                      Cart Not Secured
Resulting from    CR 2023-03570 2023 CETI Inspection: NRC Identified ONI-SPI C-7 Fuses    04/27/2023
Inspection                      Not in Specified Storage Location
CR 2023-03672 2023 CETI Inspection: NRC Identified Equivalent          05/01/2023
Instrument May Not Have Been Used
CR 2023-03714 2023 CETI Inspection: NRC Identified Deficiencies in DC  05/02/2023
Fault Analysis
Inspection Type    Designation    Description or Title                                  Revision or
Procedure                                                                                  Date
CR 2023-03776  NRC ID: 2023 CETI Inspection: EOP Tool Inventory      05/04/2023
Maintenance Plan Needs Clarification.
CR 2023-03889  2023 CETI Inspection: NRC Identified HPCS Dissimilar  05/08/2023
Weld Not Evaluated for License Renewal
CR 2023-03915  2023 CETI Inspection - NRC Identified Measurement      05/09/2023
Uncertainties Potentially Not Fully Evaluated in SVI
Acceptance Criteria Calculation
CR 2023-03918  2023 CETI Inspection - NRC Identified Cable Tie Mount  05/09/2023
Detached on Inside of Division 3 Control Panel
CR 2023-03932  2023 CETI Inspection - NRC Identified Measurement      05/10/2023
Uncertainties Potentially Not Fully Evaluated in SVI
Acceptance Criteria Calculation for LPCS
CR 2023-03938  2023 CETI Inspection - NRC Identified Station Blackout 05/10/2023
Suppression Pool Analysis Input Temperature
CR 2023-03961  2023 CETI Inspection - NRC Identified the Pyrocrete    05/11/2023
Installed on the Div 3 HPCS Fuel Oil Day Tank Was Not
Considered in the Structural Qualification
CR 2023-03964  2023-CETI Inspection: NRC Identified Additional        05/11/2023
Deficiencies in DC Fault Analysis
CR 2023-03970  CETI Inspection: NRC Identified 50.72 Notification Not 05/11/2023
Conducted for CR-2017-08373
Drawings 12-0576-001-020 Division # ED Tube Plugging                            0
206-0018-00000  Class 1E 4.16KV Bus EH13                              AA
206-0020-00000  Electrical Main One Line Diagram 480V                  GG
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      GG
C001
208-0066-00116  High Pressure Core Spray 125V DC Battery Charger      E
1E22-S006 (EFD-1-C)
208-0131-00003  Pump Room Cooling System HPCS Pump Room Cooler        S
1M39-B003
208-0176-00003  Emergency Service Water System HPCS Emergency          U
Inspection Type        Designation    Description or Title                                      Revision or
Procedure                                                                                      Date
Service Water Pump C002
208-0176-00006 HPCS Emergency Service Water Pump Discharge Valve        Z
F140
208-0176-00020 Emergency Service Water System HPCS Discharge            T
Strainer MOV 1P45--F160
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                                              LL
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        M
C001 Manual Override Control
B-208-176      Emergency Service Water System HPCS Discharge            P
Strainer
Engineering DCP 98-0052    Single Feedwater MOV Improvements Modification            1
Changes    EC 04-0146    ESW C Pump Lift Setting                                  0
EC 04-0263    Emergency Service Water Pump (ESW) Upgrade                0
ECP 12-0037    Installation of 18" Tall Steel Flood Curb at Door IB-103  3
EDCR 92-0202  Station Blackout Cross-Tie Between EF IE (DIV. 3) and EF  0
lC07 (DIV. 2)
P45-084        Determine Allowable Silt and Zebra Mussel Accumulation in 0
ESW and SW Intake SSC's
P45-084        Determine Allowable Silt and Zebra Mussel Accumulation in 0
ESW and SW Intake SSC's, Addendum A-01
Engineering 05-03199      10 CFR 50.59 SCXREEN - P45-084 and Other P45 Calcs        08/12/2005
Evaluations 05-06409      10 CFR 50.59 SCREEN - Calculation P-45-078                01/31/2006
06-02235      10CFR 50.59 SVI-E22-T2001 HPCS Pump Test                  0
Acceptance Criteria
Inspection Type          Designation    Description or Title                                      Revision or
Procedure                                                                                        Date
2-01602      Installation of 18 Tall Steel Flood Curb at Door IB-103  1
16-01392      10 CFR 50.59 SCREEN - Replacement of Valves              02/28/2019
1E12F0084A/C
17-01209      10CFR 50.59 Screen ECP-17-0132                            1
18-00926      10 CFR 50.59 SCREEN - Calculation P-45-057 A/B/C          04/05/2020
18-02362      10 CFR 50.59 SCREEN - Insulation of Plant Systems        08/24/2018
18-03530      Emergency Service Water Pump House Ventilation System    0
20-00488      10CFR 50.59 Screen SBO-007                                0
20-00581      10 CFR 50.59 SCREEN - Emergency Service Water            05/11/2020
Operating Data Updates Based on EER601268759
21-00871      SCR 21-00871 00 Calculation AOV-1 0, A-04 Perry Nuclear  06/03/2021
Power Plant Air Operated Valve Functional Evaluation
2-00075      50.59 Screening for ASME Code NB-3200 Analysis of        0
HPCS Piping Location
2-00582      10CFR 50.59 Screen M39-015                                0
Miscellaneous                HPCS Room Air Handling Unit Vendor Manual
HPCS Pump Vendor Manual
Seismic Qualification Reevaluation Class 1E Equipment for 03/01/1985
HPCS Batteries, Rack and Charger
2-316        C&D Technologies KCR Lead-Calcium Specification Sheet    0512/CD
and
20/CD
1P45-C002 ROCA 1P45-C002 Five Point Curve Validation                    07/06/2022
7-4-2022
200864310      SVI-R42T5227 Unit 1, Div 3, Annual Battery Inspections    08/31/2022
                                        (1E22-S005)
200864316      SVI-R42T5225 Unit 1, Div 1, Annual Battery Inspections    07/21/2022
                                        (1R42-S002)
200864319      SVI-R42T5226 Unit 1, Div 2, Annual Battery Inspections    08/23/2022
                                        (1R42-S003)
43368-1        Seismic Simulation Test Report for Battery Charger and    09/12/1976
Battery Rack
600503777      Engineering Evaluation Request                            11/14/2008
ATL-2018-1291- SOI-M32                                                  05/18/2018
Inspection Type Designation      Description or Title                                      Revision or
Procedure                                                                                  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      VII
Fabricated Tanks
DSP-R44-R48-    Design Specification for Standby and High Pressure Core    3
E22-3-4549-00    Spray Diesel Generator Starting Air, Intake and Exhaust
Systems Piping and Pipe Supports
EMARP-0011      Emergency Service Water System Monitoring Program          9
G239-061 D1-D7  Division 3 Battery Charger Vendor Manual: C & D            02/01/1976
Technologies, Inc. Model ARR130HK50
IB 6.1.2.7-1C    BBC Brown Boveri, Inc.; Installation/Maintenance          C
Instructions; I-T-E Low Voltage Power Circuit Breakers;
Type K-225 thru 2000 and K-600S thru 2000S
LER 2011-004    Flooding Calculation Deficiency Results in Unanalyzed      0 and 1
Condition
Maintenance Rule System S99                                                0
System Basis
Document
MRN#5            C&D Technologies, Inc. Supplemental Data for KCR-7        None
Battery Cell
NEDC-32931P      GE Safety Analysis Report for Perry PERFORM - Safety      03/01/2002
System Parameter Relaxations
NEDC-32972P      GE Safety Analysis Evaluations Relative to Measurement    02/01/2001
Uncertainties for the BWR/6 Improved Standard Technical
Specifications
NORM-ER-3302    FENOC: I&C Relays                                          4
NORM-ER-3311    FENOC: I&C Loop Components                                10
NUMARC-8700      Guidelines and Technical Bases for NUMARC Initiatives      11/20/1987
Addressing Station Blackout at Light Water Reactors
OE-2017-0561    Operating Experience Evaluation: IN 1706, Battery and      05/31/2019
Battery Charger Short-Circuit Current Contributions to a
Fault on the Direct Current Distribution System
OE-2017-0561-1-  Review of NUREG/CR-7229, "Testing to Evaluate Battery      11/28/2017
FA002            and Battery Charger Short-Circuit Contributions to a Fault
Inspection Type      Designation      Description or Title                                      Revision or
Procedure                                                                                          Date
on the DC Distribution System."
OTCOMBINEDP45    Emergency Service Water (ESW) System                      15
PHS-IST          Inservice Testing IST - Perry                              02/02/2022
Procurement      Pump Partial Assembly, ESW C                              1, 2, and 3
Package - 1-19201
PRS-3202          Emergency Service Water Partial Pump Assemble              5
Procurement Specification
Pump IST Bases    Pump IST Basis Report - 1P45-C002 ESW Pump C              Various
PY-1Z99          Perry Nuclear Pwr Plt Maintenance Plan Administrative      05/04/2023
Inventory EOP Files, Ladders
RS02098          C&D Technologies Standby Battery Rack Assembly            0114/CD
Instructions
SHR-E22A          System Health Report 2022-22 - System - E22B - High        02/28/2023
Pressure Core Spray Components
SHR-E22B          System Health Report 2022-2 - System - E22B - High        02/28/2023
Pressure Core Spray Diesel Components
SHR-R42          Perry System Health Report: R42 - DC Systems              07/28/2022
SOI-P45/P49      Emergency Service Water and Screen Wash Systems            35
SSC-001          Appendix R Evaluation: Safe Shutdown Capabilities Report  5
TAF 081854        Maintenance Rule Walkdown Confirmation of Personnel        05/28/2020
Qualifications
TD-6694          Time-Current Characteristic Curves For K-Line and K-Don    7
Circuit Breakers; ABB Power T&D Company Inc.
Distribution Systems Division
US-GN-RS-002      EnerSys PowerSafe GN Specification                        02/01/2012
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      Various
Valve
Procedures ARI-H13-P601-    Div 3 Diesel Gen & HPCS                                    23
0016
ARI-H13-P601-    HPCS ESW Disch Strainer Start Diff Press HI                24
0016-G4
ELI-R42          Perry Operations Manual: Electrical Lineup Instruction: DC 8
Systems: Batteries Chargers Switchboards
Inspection Type Designation    Description or Title                                    Revision or
Procedure                                                                                Date
EOP-01          RPV Control                                              I
EOP-02          Primary Containment Control                              G
EOP-SPI-3.2    SPMU Initiation                                          3
EOP-SPI-6.4    HPCS Injection                                          6
FTI-F0036      Post-Maintenance Test Manual                            15
GEI-0029        Testing of Molded Case Circuit Breakers and Overload    24
Heater Relays
GEI-0046        Perry Operations Manual: Generic Electrical Instruction: 5
Division 3 125VDC Relays
GEI-0057-B      Division 3 Normal Battery Charger Maintenance,          1
Calibration, and Functional Testing
GMI-0040        Disassembly and Reassembly of Division 3 Emergency      10
Service Water Pump
GMI-0145        Sluice Gate Maintenance                                  7
NOBP-CC-7007    Part Interchangeability Evaluation                      2
NOBP-ER-3003-02 System Walkdown Check List                              2
NOBP-ER-3902    Component Template Development ER Workbench              8
Module 2
NOBP-OP-1113    Control of Time Sensitive Operator Actions              2
NOBP-SS-3202    Delegation of Authority                                  0
NOP-CC-1002    Drawing Control                                          4
NOP-CC-2003    Engineering Changes                                      28
NOP-CC-2004    Design Interface Reviews and Evaluations                10 and 12
NOP-CC-3002    Calculations                                            8
NOP-CC-7002    Procurement Engineering                                  14
NOP-ER-3203    Snubber Program                                          6
NOP-ER-3204    Inservice Testing Program                                8
NOP-LP-2601    Procedure/Work Instruction Use and Adherence            8
NOP-LP-4003    Evaluation of Changes, Tests and Experiments            9
NOP-OP-1013    Control of Time Critical Operator Actions                3
NOP-OP-1015    Event Notifications                                      10
NORM-ER-3103    Low & Medium Voltage Switchgear and Motor Control        9
Centers
Inspection Type Designation      Description or Title                                    Revision or
Procedure                                                                                Date
OAI-0201        Operations General Instructions and Operating Practices  49
ONI-R10          Loss of AC Power                                        17
ONI-R10-2        Station Blackout (SBO)                                  F
ONI-R42-3        Loss of DC Bus ED-1-C                                    7
ONI-SPI C-7      Division 3 to Division 2 480 Volt Cross-Tie              5
ONI-SPI D-2      Nonessential DC Loads                                    7
ONI-SPI D-3      Cross-Tying Unit 1 and Unit 2 Batteries                  8
ONI-SPI D-6      Containment Closure                                      3
PAP-1115        Snubber Visual Inservice Examination and Testing Program 20
PAP-1705        Diesel Generator Reports and Records                    7
PDB-R0001        Operational Requirements Manual                          47
PMI-0095        Division 3 Diesel Generator Electrical Maintenance      16
PRI-TSR          Technical Specification Rounds                          48
PTI-P45-P0003    ESW System Loop C Flow and Differential Pressure Test    18
PTI-P54-P0041    Semiannual Fire Door Inspection                          18
PYBP-POS-0029    Time Critical Operator Action Validation                5
PYRM-SITE-0007  Drawing Categories                                      2
SOI-E22A        HPCS System                                              41
SOI-E22B        Division 3 Diesel Generator                              35
SOI-G41 (FPCC)  Fuel Pool Cooling and Cleanup System                    43
SOI-M32          Emergency Service Water Pump House Ventilation System    8 and 9
SOI-M43          DG Building Ventilation System                          17
SOI-P45/P49      Emergency Service Water and Screen Wash Systems          35
SOI-R42 (Div. 3) Div 3 Distribution, Bus ED-1-C and ED-2-C: Batteries,    11
Chargers, and Switchgear
SOI-R44/E22B    Division 3 Diesel Generator Starting Air System          12
SOI-R45/E22B    Division 3 Diesel Generator Fuel Oil System              20
SOI-R46/E22B    Division 3 Diesel Generator Jacket Water System          8
SOI-R47/E22B    Division 3 Diesel Generator Lube Oil System              12
SVI-P45-T2003    HPCS ESW Pump and Valve Operability Test                29
SVI-R42-T5225    Unit 1, Div 1, Annual Battery Inspections (1R42-S002)    5
SVI-R42-T5227    Unit 1, Div 3, Annual Battery Inspections (1E22-S005)    6
TAI-0513        Monitoring the Effectiveness of Maintenance Structure    7
Inspection Type        Designation Description or Title                                  Revision or
Procedure                                                                                Date
Monitoring Program
Work Orders 200116472  Replace HVSD & Control Circuit Boards for Battery      07/06/2006
Charger EFD-1-C
200412355  HPCS-Diesel GEN CT & PT Cubicle Panel; Test Molded    05/18/2012
Case Circuit Breakers
200516722  Replace HVSD & Control Circuit Boards, Battery Charger 09/14/2017
EFD-1-C
200727509  Potentiometer Thread Locker Sealant Application and    09/18/2017
Control Card Bracket Screw; Division 3 Battery Charger
200727542  Battery Charger EFD-2-C; Remove Bracket Screw and      09/12/2017
Wing Nut
200730816  Unit 1 Division 3 Charger (EFD-1-C) Load Test          08/12/2019
200739647  PTI-M39P0002 HPCS Pump Room Cooler Performance        12/15/2021
Testing
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              07/05/2022
SVI-P45-T2003
200807329  HPCS ESW Pump and Valve Operability Test              10/04/2022
SVI-P45-T2003
200807330  HPCS ESW Pump and Valve Operability Test              01/03/2023
SVI-P45-T2003
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                  02/10/2023
200882815  1P45-C002 Pump Rebaseline                              07/04/2022
33
}}
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Latest revision as of 09:54, 17 July 2023

Comprehensive Engineering Team Inspection Report 05000440/2023010
ML23178A230
Person / Time
Site: Perry FirstEnergy icon.png
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)
v • d • e


Text

June 29, 2023

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. 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, Signed by Benjamin, Jamie on 06/29/23 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: NPF-58 Report Number: 05000440/2023010 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 Enclosure

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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-01 Open/Closed 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-02 Open/Closed 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-03 Open/Closed 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-04 Open/Closed 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 Report Aspect Section Not Applicable Severity Level IV Not Applicable 71111.21M NCV 05000440/2023010-05 Open/Closed 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) ===

Main article: IP 71111.21

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

(2) Unit 1: HPCS Diesel Generator (DG) (1E22B0001)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

(5) Unit 1: ESW HPCS Strainer (1P45D0003)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
(4) Calculation B13-027, Revision 0 - ASME Code NB-3200 Analysis of HPCS Piping Location
(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)
(1) SCR 16-01392, Revision 1 - ECP 16-0139 2 Replacement of Valves 1E12F0084A/C
(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
(11) SCR 12-01602, Revision 1 - ECP 12-0037: Installation of 18 Inch Tall Flood Curb at

Door IB-103 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-01 Open/Closed 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-02 Open/Closed 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-03 Open/Closed 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 Report Aspect Section Mitigating Green None (NPP) 71111.21M Systems NCV 05000440/2023010-04 Open/Closed 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 Report Aspect Section Not Severity Level IV Not 71111.21M Applicable NCV 05000440/2023010-05 Applicable Open/Closed 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 Type Designation Description or Title Revision or

Procedure Date

71111.21M Calculations 1 P45G071A T: Evaluation of Emergency Service Water Piping and 0

Supports for Package 1 P45G071A

1E22G008A Analysis of Piping for HPCS Diesel Exhaust 5 and A-01

1P45H0010 Qualification of Emergency Service Water Pipe Support 3

1P45H0010

B13-027 ASME Code NB-3200 Analysis of HPCS Piping Location 0

DRF-A22-00084- Station Blackout 10/12/1999

E22-029 SVI-E22-T2001 HPCS Pump Performance Test 7

Acceptance Criteria

E22-042 Division 3 EDG Jacket Water Heat Exchanger Performance 5

Test

E22-043 HPCS System Hydraulic Analysis 04/13/2006

E22-C10 HPCS Pump Discharge Indicated Flow 1

ECA-018 Environmental Conditions Analysis 4

ECA-064 HPCS PRC Load for Steady State Room Temperatures 4

EQ-151 Determine Effects on Safety Equipment for Accident 1

Temperature Increase

GEN-022 Mission Times 0

JL-083 Flooding Analysis of CCB, IB, and FHB - Floor Elevation 3 and P-01

574-10

M39-014 HPCS Pump Room Cooler Air Flow Rate and Performance 06/11/2012

Evaluation at Design Conditions

M39-015 HPCS Pump Room Cooler Performance Test Results 4

M39-016 ECCS Pump Room Coolers Design Airflows 1

M39-017 Minimum Reynolds Number to Verify Turbulence for 0

1M39B0003 Operating Ranges

P45-030 Perry Unit #1 P45 System Operating Temperatures 10

P45-031 SW-ECC Emergency Temperatures 4

P45-038 Evaluation for Cavitation in Butterfly/Globe Valves 2

P45-051 Composite Bias Uncertainty of HPCS PRC ESW Flow 0

P45-056 ESW Pump Performance Acceptance Criteria for SVI-P45 1

Inspection Type Designation Description or Title Revision or

Procedure Date

T2001

P45-057C ESW System Thermal Hydraulic Model (Loop C) 0

P45-075 Minimum Branch Flow Rates for P45 Surveillance 2

Acceptance Criteria

P45-078 Emergency Service Water Pump "C" as Built Head 01/31/2006

Capacity Curve

P45-081 Evaluation of Net Positive Suction Head (NPSH) and 09/28/2004

Submergence Requirements for the Emergency Service

Water (ESW) Pumps

P45-44 Keep Fill Check Valve Leak Rate Standpipe Draindown 2

Level

P924 Penetration Analysis for P-108, P-310, P-311, and P-409 5

PRDC-0002 Unit 1 Div 1, 2, 3 125 VDC System Coordination 4

PRDC-0012 Evaluation of DC Loads for a 4 Hours Design Basis Station 3 and 3 P-01

Blackout (SBO) and Also for a 24 Hours Beyond Design

Basis Events

PRDC-0016 Division 3, 125 VDC System Load Evaluation, Voltage 3, 3 P-01, 3

Drop, Battery / Battery Charger Sizing Calculation A-01, and 3

PY-1R45A0005 Final Report on ASME Section III Analysis of Class 3 12/16/1977

Nuclear Safety Related Shop Fabricated Tanks for the

Perry Nuclear Power Plant

R45-003 Diesel Fuel Oil Pumps 1

R45-007 Standby and HPCS DG Fuel Oil Day Tank Volume Level 2

R45-012 HPCS and Div. I & II Fuel Oil Day Tank Setpoint Volumes 2

R45-C04 Div. 1, 2&3 DG Fuel Oil Day Tank ITS Volume Calculation 0

R48-10 Standby and HPCS DG Intake Air 1

SQ-0147 Seismic Qualification for 1P45C0002 (ESW Pump) 1

Corrective Action CR 1996-02889 HPCS DG Left Bank Admission Valve 09/05/1996

Documents CR 2003-05065 Track Activities to Completion That are Required to Close 04/15/2005

the Operability Determination

CR 2003-05354 Emergency Service Water Pump Couplings 12/04/2004

CR 2017-08373 Potential Seismic Bolt Missing from Charger 08/11/2017

CR 2017-08373 Potential Seismic Bolt Missing from Charger 08/11/2017

Inspection Type Designation Description or Title Revision or

Procedure Date

CR 2017-08930 NRC ID DBAI Inspection: Calculation SBO-007 08/29/2017

Conservatism and Degraded CST Instrumentation LIne

Insulation

CR 2017-09006 NRC ID DBAI Inspection: The SBO Analysis Requires 150k 08/31/2017

Gallons of Water from the CST Which Affects ONI-R10

Requirements

CR 2017-09033 NRC ID DBAI Inspection: ESW Discharge Strainer 08/31/2017

Differential Pressure Alarms are the Same Value as Design

Maximum Value

CR 2019-00742 Deficient 50.59 Screen for Temporary Insulation Removal 02/22/2019

Spec Change Notice

CR 2019-06875 2019 NRC 50.59 Inspection: Inappropriate 10CFR 50.59 08/15/2019

Exemption Applied for RAD

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 05/09/2022

Maintenance

CR 2022-04902 Division 3 ESW Degradation 06/16/2022

CR 2022-07882 Division 1 Diesel Right Bank Cylinder 6 Low Exhaust 10/18/2022

Temperature

CR 2023-10157 FME: Division 1 Right Bank #6 Thermocouple Outer Sheath 02/15/2023

Found Missing During Replacement

CR G202-2002- Determine Operability of ESW with an ESWPH Ventilation 01/31/2002

00329 Subsystem out of Service

Corrective Action CR 2023-03504 NRC ID: 2023 CETI Inspection: NRC Identified Material 04/25/2023

Documents Cart Not Secured

Resulting from CR 2023-03570 2023 CETI Inspection: NRC Identified ONI-SPI C-7 Fuses 04/27/2023

Inspection Not in Specified Storage Location

CR 2023-03672 2023 CETI Inspection: NRC Identified Equivalent 05/01/2023

Instrument May Not Have Been Used

CR 2023-03714 2023 CETI Inspection: NRC Identified Deficiencies in DC 05/02/2023

Fault Analysis

Inspection Type Designation Description or Title Revision or

Procedure Date

CR 2023-03776 NRC ID: 2023 CETI Inspection: EOP Tool Inventory 05/04/2023

Maintenance Plan Needs Clarification.

CR 2023-03889 2023 CETI Inspection: NRC Identified HPCS Dissimilar 05/08/2023

Weld Not Evaluated for License Renewal

CR 2023-03915 2023 CETI Inspection - NRC Identified Measurement 05/09/2023

Uncertainties Potentially Not Fully Evaluated in SVI

Acceptance Criteria Calculation

CR 2023-03918 2023 CETI Inspection - NRC Identified Cable Tie Mount 05/09/2023

Detached on Inside of Division 3 Control Panel

CR 2023-03932 2023 CETI Inspection - NRC Identified Measurement 05/10/2023

Uncertainties Potentially Not Fully Evaluated in SVI

Acceptance Criteria Calculation for LPCS

CR 2023-03938 2023 CETI Inspection - NRC Identified Station Blackout 05/10/2023

Suppression Pool Analysis Input Temperature

CR 2023-03961 2023 CETI Inspection - NRC Identified the Pyrocrete 05/11/2023

Installed on the Div 3 HPCS Fuel Oil Day Tank Was Not

Considered in the Structural Qualification

CR 2023-03964 2023-CETI Inspection: NRC Identified Additional 05/11/2023

Deficiencies in DC Fault Analysis

CR 2023-03970 CETI Inspection: NRC Identified 50.72 Notification Not 05/11/2023

Conducted for CR-2017-08373

Drawings 12-0576-001-020 Division # ED Tube Plugging 0

206-0018-00000 Class 1E 4.16KV Bus EH13 AA

206-0020-00000 Electrical Main One Line Diagram 480V GG

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 GG

C001

208-0066-00116 High Pressure Core Spray 125V DC Battery Charger E

1E22-S006 (EFD-1-C)

208-0131-00003 Pump Room Cooling System HPCS Pump Room Cooler S

1M39-B003

208-0176-00003 Emergency Service Water System HPCS Emergency U

Inspection Type Designation Description or Title Revision or

Procedure Date

Service Water Pump C002

208-0176-00006 HPCS Emergency Service Water Pump Discharge Valve Z

F140

208-0176-00020 Emergency Service Water System HPCS Discharge T

Strainer MOV 1P45--F160

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 LL

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 M

C001 Manual Override Control

B-208-176 Emergency Service Water System HPCS Discharge P

Strainer

Engineering DCP 98-0052 Single Feedwater MOV Improvements Modification 1

Changes EC 04-0146 ESW C Pump Lift Setting 0

EC 04-0263 Emergency Service Water Pump (ESW) Upgrade 0

ECP 12-0037 Installation of 18" Tall Steel Flood Curb at Door IB-103 3

EDCR 92-0202 Station Blackout Cross-Tie Between EF IE (DIV. 3) and EF 0

lC07 (DIV. 2)

P45-084 Determine Allowable Silt and Zebra Mussel Accumulation in 0

ESW and SW Intake SSC's

P45-084 Determine Allowable Silt and Zebra Mussel Accumulation in 0

ESW and SW Intake SSC's, Addendum A-01

Engineering 05-03199 10 CFR 50.59 SCXREEN - P45-084 and Other P45 Calcs 08/12/2005

Evaluations 05-06409 10 CFR 50.59 SCREEN - Calculation P-45-078 01/31/2006

06-02235 10CFR 50.59 SVI-E22-T2001 HPCS Pump Test 0

Acceptance Criteria

Inspection Type Designation Description or Title Revision or

Procedure Date

2-01602 Installation of 18 Tall Steel Flood Curb at Door IB-103 1

16-01392 10 CFR 50.59 SCREEN - Replacement of Valves 02/28/2019

1E12F0084A/C

17-01209 10CFR 50.59 Screen ECP-17-0132 1

18-00926 10 CFR 50.59 SCREEN - Calculation P-45-057 A/B/C 04/05/2020

18-02362 10 CFR 50.59 SCREEN - Insulation of Plant Systems 08/24/2018

18-03530 Emergency Service Water Pump House Ventilation System 0

20-00488 10CFR 50.59 Screen SBO-007 0

20-00581 10 CFR 50.59 SCREEN - Emergency Service Water 05/11/2020

Operating Data Updates Based on EER601268759

21-00871 SCR 21-00871 00 Calculation AOV-1 0, A-04 Perry Nuclear 06/03/2021

Power Plant Air Operated Valve Functional Evaluation

2-00075 50.59 Screening for ASME Code NB-3200 Analysis of 0

HPCS Piping Location

2-00582 10CFR 50.59 Screen M39-015 0

Miscellaneous HPCS Room Air Handling Unit Vendor Manual

HPCS Pump Vendor Manual

Seismic Qualification Reevaluation Class 1E Equipment for 03/01/1985

HPCS Batteries, Rack and Charger

2-316 C&D Technologies KCR Lead-Calcium Specification Sheet 0512/CD

and

20/CD

1P45-C002 ROCA 1P45-C002 Five Point Curve Validation 07/06/2022

7-4-2022

200864310 SVI-R42T5227 Unit 1, Div 3, Annual Battery Inspections 08/31/2022

(1E22-S005)

200864316 SVI-R42T5225 Unit 1, Div 1, Annual Battery Inspections 07/21/2022

(1R42-S002)

200864319 SVI-R42T5226 Unit 1, Div 2, Annual Battery Inspections 08/23/2022

(1R42-S003)

43368-1 Seismic Simulation Test Report for Battery Charger and 09/12/1976

Battery Rack

600503777 Engineering Evaluation Request 11/14/2008

ATL-2018-1291- SOI-M32 05/18/2018

Inspection Type Designation Description or Title Revision or

Procedure 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 VII

Fabricated Tanks

DSP-R44-R48- Design Specification for Standby and High Pressure Core 3

E22-3-4549-00 Spray Diesel Generator Starting Air, Intake and Exhaust

Systems Piping and Pipe Supports

EMARP-0011 Emergency Service Water System Monitoring Program 9

G239-061 D1-D7 Division 3 Battery Charger Vendor Manual: C & D 02/01/1976

Technologies, Inc. Model ARR130HK50

IB 6.1.2.7-1C BBC Brown Boveri, Inc.; Installation/Maintenance C

Instructions; I-T-E Low Voltage Power Circuit Breakers;

Type K-225 thru 2000 and K-600S thru 2000S

LER 2011-004 Flooding Calculation Deficiency Results in Unanalyzed 0 and 1

Condition

Maintenance Rule System S99 0

System Basis

Document

MRN#5 C&D Technologies, Inc. Supplemental Data for KCR-7 None

Battery Cell

NEDC-32931P GE Safety Analysis Report for Perry PERFORM - Safety 03/01/2002

System Parameter Relaxations

NEDC-32972P GE Safety Analysis Evaluations Relative to Measurement 02/01/2001

Uncertainties for the BWR/6 Improved Standard Technical

Specifications

NORM-ER-3302 FENOC: I&C Relays 4

NORM-ER-3311 FENOC: I&C Loop Components 10

NUMARC-8700 Guidelines and Technical Bases for NUMARC Initiatives 11/20/1987

Addressing Station Blackout at Light Water Reactors

OE-2017-0561 Operating Experience Evaluation: IN 1706, Battery and 05/31/2019

Battery Charger Short-Circuit Current Contributions to a

Fault on the Direct Current Distribution System

OE-2017-0561-1- Review of NUREG/CR-7229, "Testing to Evaluate Battery 11/28/2017

FA002 and Battery Charger Short-Circuit Contributions to a Fault

Inspection Type Designation Description or Title Revision or

Procedure Date

on the DC Distribution System."

OTCOMBINEDP45 Emergency Service Water (ESW) System 15

PHS-IST Inservice Testing IST - Perry 02/02/2022

Procurement Pump Partial Assembly, ESW C 1, 2, and 3

Package - 1-19201

PRS-3202 Emergency Service Water Partial Pump Assemble 5

Procurement Specification

Pump IST Bases Pump IST Basis Report - 1P45-C002 ESW Pump C Various

PY-1Z99 Perry Nuclear Pwr Plt Maintenance Plan Administrative 05/04/2023

Inventory EOP Files, Ladders

RS02098 C&D Technologies Standby Battery Rack Assembly 0114/CD

Instructions

SHR-E22A System Health Report 2022-22 - System - E22B - High 02/28/2023

Pressure Core Spray Components

SHR-E22B System Health Report 2022-2 - System - E22B - High 02/28/2023

Pressure Core Spray Diesel Components

SHR-R42 Perry System Health Report: R42 - DC Systems 07/28/2022

SOI-P45/P49 Emergency Service Water and Screen Wash Systems 35

SSC-001 Appendix R Evaluation: Safe Shutdown Capabilities Report 5

TAF 081854 Maintenance Rule Walkdown Confirmation of Personnel 05/28/2020

Qualifications

TD-6694 Time-Current Characteristic Curves For K-Line and K-Don 7

Circuit Breakers; ABB Power T&D Company Inc.

Distribution Systems Division

US-GN-RS-002 EnerSys PowerSafe GN Specification 02/01/2012

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 Various

Valve

Procedures ARI-H13-P601- Div 3 Diesel Gen & HPCS 23

0016

ARI-H13-P601- HPCS ESW Disch Strainer Start Diff Press HI 24

0016-G4

ELI-R42 Perry Operations Manual: Electrical Lineup Instruction: DC 8

Systems: Batteries Chargers Switchboards

Inspection Type Designation Description or Title Revision or

Procedure Date

EOP-01 RPV Control I

EOP-02 Primary Containment Control G

EOP-SPI-3.2 SPMU Initiation 3

EOP-SPI-6.4 HPCS Injection 6

FTI-F0036 Post-Maintenance Test Manual 15

GEI-0029 Testing of Molded Case Circuit Breakers and Overload 24

Heater Relays

GEI-0046 Perry Operations Manual: Generic Electrical Instruction: 5

Division 3 125VDC Relays

GEI-0057-B Division 3 Normal Battery Charger Maintenance, 1

Calibration, and Functional Testing

GMI-0040 Disassembly and Reassembly of Division 3 Emergency 10

Service Water Pump

GMI-0145 Sluice Gate Maintenance 7

NOBP-CC-7007 Part Interchangeability Evaluation 2

NOBP-ER-3003-02 System Walkdown Check List 2

NOBP-ER-3902 Component Template Development ER Workbench 8

Module 2

NOBP-OP-1113 Control of Time Sensitive Operator Actions 2

NOBP-SS-3202 Delegation of Authority 0

NOP-CC-1002 Drawing Control 4

NOP-CC-2003 Engineering Changes 28

NOP-CC-2004 Design Interface Reviews and Evaluations 10 and 12

NOP-CC-3002 Calculations 8

NOP-CC-7002 Procurement Engineering 14

NOP-ER-3203 Snubber Program 6

NOP-ER-3204 Inservice Testing Program 8

NOP-LP-2601 Procedure/Work Instruction Use and Adherence 8

NOP-LP-4003 Evaluation of Changes, Tests and Experiments 9

NOP-OP-1013 Control of Time Critical Operator Actions 3

NOP-OP-1015 Event Notifications 10

NORM-ER-3103 Low & Medium Voltage Switchgear and Motor Control 9

Centers

Inspection Type Designation Description or Title Revision or

Procedure Date

OAI-0201 Operations General Instructions and Operating Practices 49

ONI-R10 Loss of AC Power 17

ONI-R10-2 Station Blackout (SBO) F

ONI-R42-3 Loss of DC Bus ED-1-C 7

ONI-SPI C-7 Division 3 to Division 2 480 Volt Cross-Tie 5

ONI-SPI D-2 Nonessential DC Loads 7

ONI-SPI D-3 Cross-Tying Unit 1 and Unit 2 Batteries 8

ONI-SPI D-6 Containment Closure 3

PAP-1115 Snubber Visual Inservice Examination and Testing Program 20

PAP-1705 Diesel Generator Reports and Records 7

PDB-R0001 Operational Requirements Manual 47

PMI-0095 Division 3 Diesel Generator Electrical Maintenance 16

PRI-TSR Technical Specification Rounds 48

PTI-P45-P0003 ESW System Loop C Flow and Differential Pressure Test 18

PTI-P54-P0041 Semiannual Fire Door Inspection 18

PYBP-POS-0029 Time Critical Operator Action Validation 5

PYRM-SITE-0007 Drawing Categories 2

SOI-E22A HPCS System 41

SOI-E22B Division 3 Diesel Generator 35

SOI-G41 (FPCC) Fuel Pool Cooling and Cleanup System 43

SOI-M32 Emergency Service Water Pump House Ventilation System 8 and 9

SOI-M43 DG Building Ventilation System 17

SOI-P45/P49 Emergency Service Water and Screen Wash Systems 35

SOI-R42 (Div. 3) Div 3 Distribution, Bus ED-1-C and ED-2-C: Batteries, 11

Chargers, and Switchgear

SOI-R44/E22B Division 3 Diesel Generator Starting Air System 12

SOI-R45/E22B Division 3 Diesel Generator Fuel Oil System 20

SOI-R46/E22B Division 3 Diesel Generator Jacket Water System 8

SOI-R47/E22B Division 3 Diesel Generator Lube Oil System 12

SVI-P45-T2003 HPCS ESW Pump and Valve Operability Test 29

SVI-R42-T5225 Unit 1, Div 1, Annual Battery Inspections (1R42-S002) 5

SVI-R42-T5227 Unit 1, Div 3, Annual Battery Inspections (1E22-S005) 6

TAI-0513 Monitoring the Effectiveness of Maintenance Structure 7

Inspection Type Designation Description or Title Revision or

Procedure Date

Monitoring Program

Work Orders 200116472 Replace HVSD & Control Circuit Boards for Battery 07/06/2006

Charger EFD-1-C

200412355 HPCS-Diesel GEN CT & PT Cubicle Panel; Test Molded 05/18/2012

Case Circuit Breakers

200516722 Replace HVSD & Control Circuit Boards, Battery Charger 09/14/2017

EFD-1-C

200727509 Potentiometer Thread Locker Sealant Application and 09/18/2017

Control Card Bracket Screw; Division 3 Battery Charger

200727542 Battery Charger EFD-2-C; Remove Bracket Screw and 09/12/2017

Wing Nut

200730816 Unit 1 Division 3 Charger (EFD-1-C) Load Test 08/12/2019

200739647 PTI-M39P0002 HPCS Pump Room Cooler Performance 12/15/2021

Testing

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 07/05/2022

SVI-P45-T2003

200807329 HPCS ESW Pump and Valve Operability Test 10/04/2022

SVI-P45-T2003

200807330 HPCS ESW Pump and Valve Operability Test 01/03/2023

SVI-P45-T2003

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 02/10/2023

200882815 1P45-C002 Pump Rebaseline 07/04/2022

33

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