IR 05000440/2018003
| ML18313A054 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/08/2018 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Hamilton D FirstEnergy Nuclear Operating Co |
| References | |
| IR 2018003 | |
| Download: ML18313A054 (20) | |
Text
ber 8, 2018
SUBJECT:
PERRY NUCLEAR POWER PLANTNRC INTEGRATED INSPECTION REPORT 05000440/2018003
Dear Mr. Hamilton:
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline inspection at your Perry Nuclear Power Plant. On October 9, 2018, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Based on the results of this inspection, no findings or violations were identified.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Billy Dickson, Chief Branch 2 Division of Reactor Projects Docket No. 50-440 License No. NPF-58
Enclosure:
Inspection Report 05000440/2018003
REGION III==
Docket No: 50-440 License No: NPF-58 Report No: 05000440/2018003 Enterprise Identifier: I-2018-003-0019 Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Perry Nuclear Power Plant Location: North Perry, Ohio Dates: July 1 through September 30, 2018 Inspectors: J. Steffes, Senior Resident Inspector J. Nance, Resident Inspector N. Peterka, Acting Resident Inspector R. Ng, Project Engineer T. Briley, Fermi Senior Resident Inspector M. Holmberg, Senior Reactor Inspector J. Park, Reactor Inspector Approved by: B. Dickson, Chief Branch 2 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting an integrated quarterly inspection at Perry Nuclear Power Plant, Unit 1, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations No findings or violations were identified.
Additional Tracking Items Type Issue Number Title Report Status Section URI 05000440/2018003-01 Application of ASME Code IP 71152 Open Case N-513-3 for the Emergency Service Water Piping Degradations URI 05000440/2016008-01 Coincidence Logic to IP 71153 Closed Preclude Spurious Trips of the Offsite Power Source
TABLE OF CONTENTS
PLANT STATUS
INSPECTION SCOPES
............................................................................................................
REACTOR SAFETY
.................................................................................................................
OTHER ACTIVITIES - BASELINE
...........................................................................................
INSPECTION RESULTS
..............................................................................................................
EXIT MEETINGS AND DEBRIEFS
............................................................................................ 14
DOCUMENTS REVIEWED
......................................................................................................... 14
PLANT STATUS
The plant began the inspection period at rated thermal power. On August 25, 2018, reactor
power was lowered to 60 percent to perform a rod sequence exchange. The unit was returned
to rated thermal power on August 26, 2018. On September 15, 2018, reactor power was
lowered to 79 percent to perform a load line adjustment. The unit was returned to rated thermal
power on September 15, 2018. The unit remained at, or near, rated thermal power for the
remainder of the inspection period with the exception that on several occasions, power was
reduced to maintain condensate demineralizer outlet temperature and/or high condenser
circulating water outlet temperatures at or below their respective upper limits due to
environmental conditions. The power reductions varied between 1 and 14 percent of rated
thermal power and lasted from a few hours to several days.
On March 28, 2018, FirstEnergy Solutions (FES)/ FirstEnergy Nuclear Operating Company
(FENOC) verbally notified the NRC that they intended to shut down all four of their operating
nuclear power units. Perry Nuclear Power Plant, Unit 1, is scheduled to be shut down
May 31, 2021. On March 31, 2018, FES, FirstEnergy Nuclear Generation (FENGEN), and
FENOC filed for bankruptcy. The NRC continues to maintain focus on public health and safety
and the protection of the environment. This will include a continuous evaluation by inspectors to
determine whether the licensees financial condition is impacting safe operation of the plant.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.04Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Division 1 diesel generator on August 15, 2018;
(2) Motor control center, switchgear, and miscellaneous electrical equipment area heating,
ventilation and air conditioning system train A on September 27, 2018; and
(3) Annulus exhaust gas treatment system train A on September 28, 2018.
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the
emergency closed cooling system on July 2 through 11, 2018.
71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
(1) Service building 604 and 620 foot elevations on July 19 through 20, 2018;
(2) Auxiliary building 599 foot elevation, fire zone 1AB-2 on September 20, 2018;
(3) Intermediate building 620 foot elevation fire zones 0IB-3; FHB 620-3 on
August 18, 2018;
(4) Control complex and diesel building fire zones 1DG-1c and 1CC-3c on
August 15, 2018; and
(5) Emergency service water (ESW) pump house on August 8 through 9, 2018.
71111.06Flood Protection Measures
Internal Flooding (2 Samples)
(1) The inspectors evaluated internal flooding mitigation protections in the control complex
on August 17 through 29, 2018; and
(2) The inspectors evaluated internal flooding mitigation protections in the intermediate
building on August 28 through 30, 2018.
Cables (1 Sample)
The inspectors evaluated cable submergence protection in:
(1) Review of safety-related cables in manholes 1, 2, 3 and 4 on August 6 and 7, 2018.
71111.07Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated B residual heat removal (RHR) heat exchanger performance on
September 10 through 13, 2018.
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated an operations crew-evaluated scenario in the plant
training simulator on September 17, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated operations crew performance during plant
manipulations for rod sequence exchange on August 25, 2018.
71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Average power range monitor system on August 21, 2018.
71111.13Maintenance Risk Assessments and Emergent Work Control (3 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) Work week risk assessment to include diving activities, reactor core isolation cooling
(RCIC) system inoperability due to surveillance, severe weather and increase in A
essential service water system leakage on July 25 through 27, 2018;
(2) Emergent work on the B ESW pump due to an oil leak August 15 through 16; and
(3) Emergent work on the Division 1 diesel generator on September 26 through 30, 2018.
71111.15Operability Determinations and Functionality Assessments (4 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) 'B' ESW motor oil leak operability determination on August 6 and 7, 2018;
(2) High pressure core spray ESW piping and elbow wall thinning downstream of the HPCS
diesel heat exchanger ESW outlet valve on July 10 through 11, 2018;
(3) Low pressure core spray, RHR A and containment isolation valves operability
determination due to failed fuse in Division 1 loss of coolant accident actuation circuitry;
and
(4) RCIC suppression pool suction isolation valve failed to open during surveillance.
71111.18Plant Modifications (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1) Temporary flooding barriers on August 22, 2018.
71111.19Post Maintenance Testing (3 Samples)
The inspectors evaluated the following post maintenance tests:
(1) High pressure core spray operability test following system maintenance on
September 13, 2018;
(2) A ESW operational test following a piping through wall leak repair on
September 5, 2018; and
(3) B standby liquid control pump and valve operability test following pump internal and
coupling inspections on August 3, 2018.
71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (3 Samples)
(1) SVI-C11-T1006: Control rod maximum scram insertion time testing on August 25, 2018;
(2) C RHR pump and valve operability test on August 1 through 2, 2018; and
(3) Remote shutdown control test - RCIC and RHR routine surveillance testing on
July 25 through 26, 2018.
In-Service (1 Sample)
(1) RCIC pump and valve surveillance testing on July 24, 2018.
OTHER ACTIVITIES - BASELINE
71151Performance Indicator Verification (3 Samples)
The inspectors verified licensee performance indicators submittals listed below:
(1) MS08: Heat Removal Systems - 1 Sample (July 1, 2017-June 30, 2018);
(2) MS09: Residual Heat Removal Systems - 1 Sample (July 1, 2017-June 30, 2018); and
(3) MS10: Cooling Water Support Systems - 1 Sample (July 1, 2017-June 30, 2018).
71152Problem Identification and Resolution
Semiannual Trend Review (1 Sample)
The inspectors reviewed the licensees corrective action program for trends that might be
indicative of a more significant safety issue.
Annual Follow-Up of Selected Issues (3 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Condition Report (CR) 2018-05504, Emergency Service Water (ESW) A Through-Wall
Pipe Leak at RHR A HX Outlet Piping, Aux 574 E, was initiated by the licensee to
document an approximately 0.1 gallon-per-minute through-wall leakage on the 20 ESW
piping. The inspectors selected this CR for annual review because this was the third
through-wall leakage that occurred in their ESW piping system over the past 12 months.
The licensee invoked the requirements of ASME Code Case N-513-3, Evaluation
Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping,
Section XI, Division 1, to evaluate and temporarily accept the flaw without
repair/replacement for a limited period;
(2) CR 2018-06205, Emergency Service Water Pipe Exceeded Minimum Wall Thickness -
Localized Wall Thinning, was initiated by the licensee. This condition report
documented that, from the inspection of five additional locations as required by
Section 5(a) of Code Case N-513-3 due to the condition described in (1) above, a
localized wall thinning was identified on the 8 ESW pipe elbow, which was found not
meeting the minimum wall thickness requirement;
(3) CR 2018-05153, Division 2 DG Fuel Oil Storage Tank Level Indicator 1R45-R0191B
Appears to be Failing, and CR 2018-06869, Water Found in Access Space for Div 2
Diesel Generator Level Transmitter, were selected for annual review because the
instrument provides control room indication of Division 2 diesel generator fuel oil storage
tank level which is checked weekly to ensure the amount of fuel oil stored meets the
required amount for the diesel generator to perform its safety-related function.
As appropriate, the inspectors verified the following attributes during their review of the
licensees corrective actions for the above CRs and other related CRs:
- Complete and accurate identification of the problem in a timely manner
commensurate with its safety significance and ease of discovery;
- Consideration of the extent of condition, generic implications, common cause, and
previous occurrences;
- Evaluation and disposition of operability/functionality/reportability issues;
- Classification and prioritization of the resolution of the problem commensurate with
safety significance;
- Identification of the root and contributing causes of the problem;
- Identification of corrective actions, which were appropriately focused to correct the
problem;
- Completion of corrective actions in a timely manner commensurate with the safety
significance of the issue;
- Effectiveness of corrective actions taken to preclude repetition; and
- Evaluate applicability for operating experience and communicate applicable lessons
learned to appropriate organizations.
The inspectors discussed the corrective actions and associated evaluations with
licensee personnel.
71153Follow-Up of Events and Notice of Enforcement Discretion
The inspectors also reviewed the status of URI 05000440/2016008-01. This did not constitute
an inspection sample.
INSPECTION RESULTS
No findings or violations were identified.
71152Problem Identification and Resolution
Observation IP 71152 - Semi
Annual Trend
Review
During the inspection period the licensee noted an adverse trend in housekeeping. The
licensee documented the observed trend in CR 2018-03308, PA-PY-18-02: Housekeeping
Elevation Letter, and CR 2018-03269, Commitment and Accountability to the Perry
Housekeeping Program Needs to be Strengthened Across the Site. The licensee developed
actions associated with the housekeeping trend to include, but not limited to, site wide
communications, paired observations, and supervisor training. The inspectors monitored
licensee progress to address the issue.
After a couple of months and further evaluation, the licensee determined that the continued
issues with housekeeping was due to a lack of understanding and compliance with the site
configuration management process. The inspectors assessed that the licensees evaluation
and identification that configuration management contributed to the housekeeping issues was
appropriate as they had independently identified a trend in procedure use and adherence.
The NRC identified examples associated with procedure use and adherence include, but were
not limited to:
- On July 24, 2018, the licensee failed to follow the Precaution and Limitation section in
surveillance procedure SVI-E51-T2001, RCIC Pump and Valve Operability Test,
after the required response was not obtained for the stroke of the RCIC suppression
pool suction valve until questioned by the inspectors. (CR 2018-06615 and CR 2018-
06788);
- On July 25, 2018, during a pre-job brief, the licensee stated that they intended to
perform all sections of surveillance SVI-C61-T1200, Remote Shutdown Control
Test - RCIC and RHR, in parallel. The inspectors questioned the staff, and the
licensee explained that the notes contained within the procedure were interpreted such
that all sections could be performed in parallel. The notes being referenced stated
that, Sections 5.1.2 through 5.1.8 may be performed in any order. Steps within each
individual section must be performed in order, unless otherwise specified, and Steps
5.1.2.2 through 5.1.2.6 may be performed in any order or in parallel.
Additional examples identified by the licensee or were self-revealed and documented in the
corrective action program include, but were not limited to:
- On May 12, 2018, a non-licensed operator did not exit the radiologically controlled
area when required by radiation work permit and received an electronic dosimetry
dose alarm (CR 2018-04447);
- On September 12, 2018, a contract worker did not exit the radiologically controlled
area when required by the radiation work permit and received an electronic dosimetry
dose alarm (CR 2018-08066 and CR 2018-08068);
- On August 2, 2018, an employee opened a protected area portal without security
present contrary to site procedures (CR 2018-06886).
Although the issues reviewed by the inspectors individually did not result in any significant
consequences or violations, the examples represent a larger trend in individual contributor
behaviors which requires further scrutiny. The licensee documented the inspectors concerns
and licensee observations in CR 2018-08694. A causal evaluation was ongoing at the end of
the inspection period.
Observation IP 71152 - Annual
Sample Review
Division 2 Diesel Generator Fuel Oil Storage Tank Level Indicator Failing
The inspectors performed a selected review of the licensees correction action program
documents; specifically, CR 2018-05153, Division 2 DG Fuel Oil Storage Tank Level
Indicator 1R45-R0191B Appears to be Failing, and CR 2018-06869, Water Found in
Access Space for Div 2 Diesel Generator Level Transmitter. The inspectors performed
walkdowns and assessed the adequacy of the corrective actions taken in response to the
failed level transmitter for the Division 2 diesel generator fuel oil storage tank.
This level transmitter provides remote indication of the fuel oil level in the main control
room. Annunciator alarms are provided when levels are less than 17 percent and
80percent. Tank level can also be monitored by direct measurement with a dip stick. This
method of measurement has been proceduralized, equipment was staged and can be used to
satisfy Technical Specification requirement of verifying fuel oil level.
Although there is no preventative maintenance associated with the level transmitter other
than a calibration of the channel every nine years, the inspectors noted that the level
instrumentation is not safety related and is not needed for the emergency operation
procedures.
The inspectors reviewed the maintenance history of the transmitter and did not identify any
recent failures. The licensee removed the water, replaced the failed transmitter, and sealant
was applied to the seams of the cover to prevent future water intrusion. Given the safety
significance of the issue, the inspectors determined that the licensees actions were
appropriate.
Unresolved Item Application of ASME Code Case N-513-3 for the IP 71152 -
(Open) Emergency Service Water (ESW) Piping Annual Sample
Degradations05000440/2018003-01 Review
Description:
The inspectors identified an Unresolved Item concerning the Title 10 of the Code of Federal
Regulations (10 CFR), Part 50, Appendix B, and ASME Code requirements for the ESW
piping systems with regards to the licensees application of ASME Code Case N-513-3,
Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3
Piping,Section XI, Division 1.
Updated Safety Analysis Report (USAR) Section 9.2.1 describes that the function of ESW
system is to provide a reliable source of water to safety-related components required for
normal and emergency reactor operation. USAR Table 3.2-1, Equipment Classification,
delineates that the ESW piping system is safety-related and designed in accordance with the
requirements of ASME Section III, Subsection ND (Class 3). The regulation in 10 CFR 50.55a(g) requires, in part, that Class 3 components and their supports meet the requirements
of ASME Section XI of the ASME Boiler and Pressure Vessel (BPV) Code or equivalent
quality standards. The ASME also publishes Code Cases, which provide alternatives to
existing Code requirements. The NRC Regulatory Guide (RG) 1.147 identifies that Code
Case N-513-3 provides acceptable alternatives to applicable parts of Section XI, provided it
is used with any identified conditions or limitations.
Code Case N-513-3, Section 2(d) requires that a flaw evaluation shall be performed to
determine the conditions for flaw acceptance. Section 3 provides accepted methods for
conducting the required analysis. In addition, Section 3 requires, in part, that nonplanar
flaws shall be evaluated in accordance with the requirements in 3.2. Additionally, Section 5
requires that an augmented volumetric examination or physical measurement to assess
degradation of the affected system shall be performed as follows: (a) From an engineering
evaluation, the most susceptible locations shall be identified. A sample size of at least five of
the most susceptible and accessible locations, or, if fewer than five, all susceptible and
accessible locations shall be examined within 30 days of detecting the flaw. (b) When a flaw
is detected, an additional sample of the same size as defined in 5(a) shall be examined. (c)
This process shall be repeated within 15 days for each successive sample, until no significant
flaw is detected or until 100 percent of susceptible and accessible locations have been
examined.
On June 13, 2018, a through-wall leakage on the 20 ESW piping was identified in
CR 2018-05504. As a result, the licensee invoked the Code Case to evaluate this flaw and
permit the degraded ESW piping system to remain in service for a limited period without
repair/replacement. The licensees evaluation involved characterization of this flaw as
nonplanar, and subsequently, the methodology as described in Section 3.2 of the Code Case
was utilized for this nonplanar flaw. Additionally, the licensee identified the five most
susceptible and accessible locations in the ESW system and performed examination in
accordance with Section 5(a).
From the examination of the five additional locations, another localized wall degradation was
identified on the 8 ESW pipe elbow on July 10, 2018. The licensee initiated CR 2018-06205
to document this condition. The licensee characterized this degradation also as a nonplanar
flaw, and this degradation represented approximately 80 percent wall loss from its nominal
thickness. During the review of the licensee evaluation of this degraded pipe elbow, the
inspectors identified that the methodology as described in Section 3.2 of the Code Case had
not been utilized. Instead, the licensee elected to use an alternate methodology to evaluate
and disposition for its acceptability. Furthermore, the inspectors identified that the licensee
essentially redefined the term flaw in the Code Case to reflect the ASME Section XI,
IWA-9000 definition of the term defect. The ASME Section XI, IWA-9000 defines a flaw
as an imperfection or unintentional discontinuity that is detectable by nondestructive
examination. It also defines a defect as a flaw (imperfection or unintentional discontinuity)
of such size, shape, orientation, location, or properties as to be rejectable. With respect to
the Code Case, the licensee essentially restricted the criteria for examination scope
expansion only to the flaws that were rejectable; therefore, the licensee had not expanded the
scope to perform examination of additional locations in accordance with Section 5(b).
In essence, two items are to be further evaluated and addressed: (1) whether the use of
methodology not described in the Code Case Section 3.2 was appropriate for evaluation of
the nonplanar flaw on the 8 ESW pipe elbow, and (2) whether the stopping of scope
expansion for examination as required by the Code Case Section 5(b) was appropriate based
on the licensees redefining of the term flaw.
In response to the inspectors concern, the licensee initiated CR 2018-08483, NRC ID: Code
Case N-513-3 Interpretation, September 26, 2018. The licensee also plans to perform
examination of five additional locations in November of 2018.
This represents an item where the inspectors identified Code interpretation issues that
resulted in a disagreement with the licensee. This will require additional review to determine
whether a violation exists. Therefore, this issue is considered an unresolved item pending
completion of inspector review and evaluation and discussion with the Office of Nuclear
Reactor Regulation.
Licensee Action: The licensee plans to perform examination of five additional locations in
November of 2018.
Corrective Action Reference: CR 2018-08483
71153Follow-Up of Events and Notice of Enforcement Discretion
Unresolved Item Coincidence Logic to Preclude Spurious Trips of the IP 71153 -
(Closed) Offsite Power Source Follow-Up of
05000440/2016008-01 Events and
Notice of
Enforcement
Discretion
Description:
On March 28, 2016, Region Ill staff completed a reactive inspection at PNPP (ADAMS
Accession No. ML16147A437). During the inspection, the Special Inspection Team identified
a concern involving the adequacy of the Perry Nuclear Power Plant (PNPP) under voltage
(UV) relay protection design and licensing bases, which was documented in the NRC SIT
Report as Unresolved Item (URI)05000440/2016008-01, Coincidence Logic to Preclude
Spurious Trips of the Offsite Power Source. The reactive inspection was conducted, in part,
to evaluate the circumstances where a blown fuse in the UV-sensing circuitry resulted in the
loss of the offsite power to a safety bus and precluded the EDG from successfully performing
its safety function.
On February 11, 2016, while the plant was shut down, a fuse failure in a bus voltage detection
scheme resulted in the actuation of associated under voltage relays and a trip of the safety
related EH11 bus. With the under voltage condition locked in, the Division 1 safety-related
equipment remained unavailable when the Division 1 EDG started and powered up the EH11
bus. As a consequence of the under voltage scheme, the ESW pump for the EDG was not
available to provide cooling water and the EDG was manually shut down by operators to
prevent damage to the diesel engine.
During initial licensing, the NRC staff outlined that the purpose of the UV relays is to protect
Class 1E safety related buses from sustained degraded voltage (DV) or loss of offsite power
conditions and explicitly delineated the specific design requirements to satisfy license
condition for PNP
Technical Position (BTP) PSB 1, Adequacy of Station Electric Distribution System Voltages,
Revision 0, dated July 1981 (ADAMS Accession No. ML052350520). The BTP PSB 1
references events at Millstone Power Station and Arkansas Nuclear One that led to the NRC
staff establishing the position. The conformance of PNPP with BTP PSB-1 is documented in
Item a.2 of PNPP USAR Section 8.3.1.1.2.9, Electric Circuit Protection System Network,
(ADAMS Accession No. ML17305A203) which states, in part:
Two levels of undervoltage protection, Degraded Voltage and Loss of Power, are provided
on each Class 1E 4160V bus to conform to the requirements of the NRC Branch Technical
Position PSB 1.
The licensees installed design utilizes a single voltage sensor that is shared between two
relays in the under voltage trip logic. As a consequence of a shared voltage sensor between
both under voltage relays, the overall under voltage protection did not constitute a coincidence
logic as stated in BTP PSB-1. A single malfunction in the voltage sensing circuit resulted in a
trip of the offsite power source and precluded the onsite power source from performing its
safety related functions. As evidence by the February 11, 2016, event, a secondary potential
transformer fuse failure caused the EH11 bus to separate from offsite power (even though
there were no deficiencies in offsite power voltage) and resulted in shutdown of the Division 1
EDG bus due to ESW being unavailable. The inspectors believe that this design is deficient in
that there is no coincident logic to ensure that spurious trips are precluded as delineated in
BTP PSB-1 Section B.1.c.
By memorandum dated August 5, 2016 (ADAMS Accession No. ML16218A474), the NRC
Region III, Division of Reactor Projects, requested assistance from the NRC Office of Nuclear
Reactor Regulation (NRR) to conduct a technical assessment of the licensing basis of the
Perry Nuclear Power Plant, Unit No. 1 (PNPP) undervoltage relay protection scheme, and
to determine whether the methodology used in the PNPP offsite/station electric power
system design meets NRC requirements. By memorandum dated December 20, 2016
(ADAMS Accession No. ML16355A444), RIII revised its request to supersede that provided
on August 5, 2016. Specifically, in Task Interface Agreement (TIA) 2016-01, dated
December 20, 2016, RIII focused its question on compliance with the current licensing basis,
as opposed to compliance with NRC requirements. To assist in determining whether PNPP
offsite/station electric power system design was in compliance with the licensee current
licensing basis the staff review information contained in NRC issued Safety Evaluation
Report (SER) and in the supplemental Safety Evaluation Reports (SSER).
The NRC Office of Nuclear Reactor Regulation response to the TIA concluded that the plant
was in compliance with its current licensing basis (ADAMS Accession No. ML17023A191).
The staff noted that a review of the SSER and correspondence related to Confirmatory Item
No. 34 on the undervoltage protection scheme indicated that the NRC staff reviewers (that
reviewed and approved the original license in 1982/83) had information regarding the final
design and had accepted this final design. Additionally, NRR noted that the current design
was reflective of the accepted final design. Therefore, NRR did not have a basis to determine
that the plants design is not in accordance with its licensing basis.
The NRR staff also noted in its response that a design vulnerability exists, which could defeat
coincident logic. Specifically, the staff noted that a failure of any of the PTs would also result in
separation of the offsite power source from the safety bus. The NRR staff concluded that
modifications to the UV/DV protection system to prevent separation of the offsite power
source from the safety buses were prudent to preclude another event similar to the one that
occurred on February 11, 2016.
The licensee also identified this design vulnerability in the UV relay protection system in a
letter dated June 7, 2016 (ADAMS Accession No. ML16166A197). In this letter, the licensee
committed to modify the design of the UV/DV circuits for all three divisions to prevent a failed
fuse from satisfying the coincident logic and causing a separation of the offsite power source
from the safety bus when no UV/DV condition exists.
Specifically, the licensee has committed to installing a modification to the UV/DV protection
scheme for the division one, two and three 4.16kV safety buses that will prevent a failed fuse
from satisfying the coincident logic and causing a separation of the offsite power source from
the safety bus when no UV/DV condition exists. The design change will be implemented
during the upcoming refueling outage and completed over the next operating cycle.
NRC Inspection Manual Chapter 0611, Power Reactor Inspection Reports, defines a
performance deficiency as an issue that is the result of a licensee not meeting a requirement
or self-imposed standard where the cause was reasonably within the licensees ability to
foresee and correct, and therefore should have been prevented. The NRC has concluded
that the installed 4160-volt UV/DV detection system meets the current licensing bases, and
therefore it was not reasonable to foresee, correct, and prevent the issue since it would have
required FENOC to question the NRCs original approval of the PNPP licensing basis and
therefore is not subject to enforcement action in accordance with the NRCs Enforcement
Policy. This documents the closure of URI 05000440 /2016008-01.
Corrective Action Reference: CR 2016-04016
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure. No proprietary information was documented in this report.
- On October 9, 2018, the inspectors presented the quarterly integrated inspection results to
Mr.
- D. Hamilton, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
71111.04Equipment Alignment
- SOI-M15; Annulus Exhaust Gas Treatment System; Revision 12
- SOI-M23/M24; MCC, Switchgear, and Miscellaneous Electrical Equipment Area HVAC
System; Revision 15
- VLI-P42; Emergency Closed Cooling; Revision 20
- VLI-R44; Division 1 and 2 Diesel Generator Starting Air System Valve Lineup Instruction;
Revision 6
- VLI-R45; Division 1 and 2 Diesel Generator Fuel Oil System (Unit 1) Valve Lineup Instruction;
Revision 5
- VLI-R46; Division 1 and 2 Diesel Generator Jacket Water Systems (Unit 1) Valve Lineup
Instruction; Revision 4
- VLI-R47; Division 1 and 2 Diesel Generator Lube Oil Valve Lineup Instruction; Revision 7
- VLI-R48; Division 1 and 2 Diesel Generator Exhaust, Intake and Crankcase Systems Valve
Lineup Instruction; Revision 6
71111.05AQFire Protection Annual/Quarterly
- FPI-0CC; Control Complex; Revision 10
- FPI-0EW; Emergency Service Water Pumphouse; Revision 6
- FPI-0IB; Intermediate Building; Revision 9
- FPI-1AB; Auxiliary Building Unit 1, Revision 4
- FPI-SB; Service Building; Revision 3
- FPI-1DG; Diesel Generator Building; Revision 8
71111.06Flood Protection Measures
- Drawing 302-0653-00000; Fuel Pool Filter Demineralizer System; Revision U
- Drawing 302-0654-00000; Fuel Pool Cooling and Clean-up System; Revision U
- Drawing 302-0738-00000; LRW - Tanks and Pumps for Handling Backwash Slurries from
Fuel Pool Filter/Demineralizer; Revision DD
- CR 2018-07685; Unexpected Fuel Pool Closed Cooling Surge Tank Level Lowering;
08/28/2018
- Drawing 302-0741-00000; Liquid Radwaste Sumps System - Laundry, Chemical and
Common Floor and Equipment Drain Sumps; Revision AA
- Drawing 911-0628-00000; Intermediate Building Drains; Revision F
- Calculation JL-083; Flooding Analysis of CCB, IB, and FHB - Floor Elevation 574-10;
Revision 3
- WO 200711677; Inspect and Dewater Safety-Related Manholes 1, 2, 3, and 4; 08/06/2018
71111.07Heat Sink Performance
- Calculation E12-089; Required ESW Flow for the RHR HXs; Revision 3
- Calculation E12-102; RHR System Heat Exchanger B Loop Performance Test Evaluation;
Revision 4
- Calculation E12-102; RHR System Heat Exchanger B Loop Performance Test Evaluation;
Revision 4; Addendum 1
- CR 2018-08003; Small Margin Remaining in RHR Heat Exchanger Loop B; 09/10/2018
- Drawing 302-0643-00000; Residual Heat Removal System; Revision CCC
- Drawing 302-0792-00000; Residual Heat Removal System; Revision PP
- PTI-E12-P0003; RHR HX B and D Performance Testing; Revision 12
- WO 200624207; PTI-E12-P0003; 05/31/2018
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
- OTLC-3058201809-PY-SGC1; Cycle 9 2018 Evaluated Scenario C1; 08/25/2018
- NOBP-TR-1151; 4.0 Crew Critique; Revision 6
- Evolution Specific Reactivity Plan; August 2018 Sequence Exchange; 07/30/2018
71111.12Maintenance Effectiveness
- CR 2018-06854; LPRM - Gain Adjust Factor Outside of Technical Specification Acceptance
Criteria Following Calibration; 08/01/2018
- Maintenance Rule System Basis Document C51 - Neutron Monitoring; Revision 0
- SVI-C51-T0027-A; APRM A Channel Functional for 1C51-K605A; Revision 13
- SVI-C51-T0030-A; APRM A Channel Calibration for 1C51-K605A; Revision 13
- SVI-C51-T0250-A; APRM A Response Time for 1C51-K605A; Revision 9
71111.13Maintenance Risk Assessments and Emergent Work Control
- CR 2018-05504; ESW Through-Wall Leak at RHR A Heat Exchanger Outlet Piping Auxiliary
Building 574 Foot Elevation; 06/13/2018
- CR 2018-06921; Emergency Service Water Pump B Oil Leakage; 08/04/2018
- CR 2018-07276; As-Found Condition of ESW Pump B for Oil Leak Condition; 08/16/2018
- CR 2018-07410; As-Found Condition for ESW B Breathers; 08/21/2018
- CR 2018-08510; Division 1 Diesel Generator Trip While Paralleling to the Grid; 09/26/2018
- CR 2018-08511; Abnormal Plant Response Following Electrical Transient; 09/26/2018
- CR 2018-08541; NRC ID: Bent Tubing Discovered on Division 1 Diesel Generator;
09/27/2018
- CR 2018-08546; Division 1 Diesel Generator Air Gaps Found Greater than Allowable
Variance; 09/27/2018
- Drawing 208-0206-00053; 4.16KV Standby Diesel Brk. EH1102 Protective Relaying; Revision
- NOP-OP-1007; Risk Management; Revision 27
- NOP-WM-1001; Order Planning Process; Revision 29
- PAP-1924; Risk-Informed Safety Assessment and Risk Management; Revision 9
- PMI-0096-A; Division 1 Standby Diesel Generator Electrical Maintenance; Revision 5
- WO 200585392; Diesel Generator 1 Perform Generator Inspection; 12/18/2017
- WO 200701673; Megger Division 1 Diesel Generator per PMI-0096-A; 12/11/2017
- WO 200761606; Perform Simple Troubleshooting Plan of ESW B Motor Oil Leakage;
08/16/2018
71111.15Operability Determinations and Functionality Assessments
- ARI-H13-P601-0020-A6; Residual Heat Removal A Out of Service; Revision 21
- ARI-H13-P601-0021-D6; Low Pressure Core Spray Out of Service; Revision 15
- CR 2018-05504; ESW Through-Wall Leak at RHR A Heat Exchanger Outlet Piping Auxiliary
Building 574 Foot Elevation; 06/13/2018
- CR 2018-05997; Received Unexpected RHR A Out of Service Alarm; 06/30/2018
- CR 2018-06205; Emergency Service Water Pipe Exceeded Minimum Wall Thickness -
Localized Wall Thinning; 07/10/2018
- CR 2018-06615; RCIC Suppression Pool Suction Valve did not Stroke on the First Attempt;
07/24/2018
- CR 2018-06788; NRC ID: SVI-E51-T2001 Valve Stroke Timing of the Suppression Pool
Suction Valve 1E51F0031 - Precaution and Limitation 15 not Initially Followed; 07/24/2018
- CR 2018-06921; Emergency Service Water Pump B Motor Oil Leakage; 08/04/2018
- CR 2018-07276; As-Found Condition of ESW Pump B For Oil Leak Condition; 08/16/2018
- CR 2018-07277; Stripped Cover Bolt Motor Upper Reservoir Cover of the Emergency Service
Water Pump; 08/08/2018
- NOP-OP-1009; Operability Determinations and Functionality Assessments; Revision 8
71111.18Plant Modifications
- Advance Change Notice 13-0802-006; Door Barrier; Revision 0
- CR 2013-05625; Calculation for Minor Stream Cannot be Located; 04/11/2013
- CR 2013-07852; Closure Items Not Addressed in CR 2013-05625 Investigation Problem
Statement; 05/20/2013
- CR 2015-08036; Prompt Functionality Assessment Needed for Site Flooding Issues;
06/08/2015
- ECP 0212-001; Site Flooding Sand Bags Temporary Modification; Revision 0
- ECP 0212-002; Site Flooding Sand Bags Temporary Modification - Removal Package;
Revision 1
- ECP 0212-003; Modification Compensatory Measures for Flooding Prompt Functionality
Assessment; Revision 0
- ONI-ZZZ-1; Tornado or High Winds; Revision 30
71111.19Post Maintenance Testing
- WO 200594426; High Pressure Core Spray Condensate Storage Tank Suction Valve Static
Motor Operated Valve Test; 08/15/2018
- WO 200718804; SVI-C41T2001B Standby Liquid Control B Pump and Valve Operability Test;
08/02/2018
- WO 200757942; ECP 18-0158-001 Repair Leak - ESW Piping; 08/22/2018
- SOI-P45/P49; Emergency Service Water and Screen Wash Systems; Revision 32
71111.22Surveillance Testing
- CR 2018-06590; Issues Encountered during the Performance of SVI-E51-T2001; 07/24/2018
- SVI-C11-T1006; Control Rod Maximum Scram Insertion Time; Revision 23
- SVI-E12-T2003; RHR C Pump and Valve Operability Test; Revision 31
- WO 200689395; SVI-C61T1200 (24M) Remote Shutdown Control Test - RCIC and RHR;
07/25/2018
- WO 200718796; SVI-E51T2001 RCIC Pump and Valve Operability Test; 07/24/2018
71151Performance Indicator Verification
- NOBP-LP-4012; NRC Performance Indicators; Revision 6
- NOBP-LP-4012-06; Mitigating Systems Performance Index (MSPI) Unavailability Index (UAI)
and Unreliability Index (URI) for Heat Removal System (RCIC); July 2017 through June 2018
- NOBP-LP-4012-06; Mitigating Systems Performance Index (MSPI) Unavailability Index (UAI)
and Unreliability Index (URI) for Residual Heat Removal (RHR); July 2017 through June 2018
- NOBP-LP-4012-06; Mitigating Systems Performance Index (MSPI) Unavailability Index (UAI)
and Unreliability Index (URI) for Emergency Service Water (ESW); July 2017 through
June 2018
71152Problem Identification and Resolution
- ARI H13-P877-0001-A3; Fuel Storage Tank Level Low (7 Day Level); Revision 14
- ARI H13-P877-0001-A3; Fuel Storage Tank Level Low (1 Day Level); Revision 14
- CR 2003-03033; Through Wall Leak in ESW A Piping Between Valves 1P45F0550A and
1P45F0068A; 05/07/2003
- CR 2011-00861; Division 2 Fuel Storage Tank Level; 08/21/2011
- CR 2011-90473; Division 2 Diesel Generator Fuel Oil Storage Tank Level did not Pass
Channel Check; 03/05/2011
- CR 2017-08106; ESW B Piping Through Wall Leak to ECC HX B; 08/04/2017
- CR 2017-08581; P45 Piping Thru Wall Pin Hole Leak; 08/18/2017
- CR 2018-01035; PA-PY-18-01: Engineering Has Not Developed an Effective Failure
Assessment and Monitoring Plan for Safety Related Piping Systems; 02/05/2018
- CR 2018-03269; Commitment and Accountability to the Perry Housekeeping Program Needs
to be Strengthened Across the Site; 04/10/2018
- CR 2018-03308; PA-PY-18-02: Housekeeping Elevation Letter; 04/11/2018
- CR 2018-04447; Dose Alarm Received during Fuel Pool Filter Demineralizer Evolution;
05/12/2018
- CR 2018-05153; Division 2 DG Fuel Oil Storage Tank Level Indicator 1R45-R0191B Appears
to be Failing; 06/02/2018
- CR 2018-05504; Emergency Service Water (ESW) A Through-Wall Pipe Leak at RHR A HX
Outlet Piping, Aux 574 E; 06/13/2018
- CR 2018-06205; Emergency Service Water Pipe Exceeded Minimum Wall Thickness -
Localized Wall Thinning; 05/01/2018
- CR 2018-06615; RCIC Suppression Pool Suction Valve did not Stroke on the First Attempt;
07/24/2018
- CR 2018-06788; NRC ID: SVI-E51-T2001 Valve Stroke Timing of the Suppression Pool
Suction Valve 1E51F0031 - Precaution and Limitation 15 Not Initially Followed; 07/24/2018
- CR 2018-06869; Water Found in Access Space for Division 2 Diesel Generator Level
Transmitter; 08/02/2018
- CR 2018-06886; Employee Opened a Protected Area Portal without Security Present;
08/02/2018
- CR 2018-08066; Dose Alarm Received by Supplemental Personnel; 09/12/2018
- CR 2018-08068; MG Dose Alarm Received by Individual; 09/12/2018
- CR 2018-08483; NRC ID: Code Case N-513-3 Interpretation; 09/26/2018
- CR 2018-08694; Affinity Analysis of Recent Perry Site Incidents Related to Human
Performance and Leadership Engagement of Workforce Fundamental Behaviors; 10/03/2018
- DSP-P45; ASME Design Specification for ESW System; Revision 5
- NOP-ER-2005; Flow Accelerated Corrosion Management Program; Revision 6
- NOP-ER-2006; Service Water Reliability Management Program; Revision 4
- SOI-R45; Division 1 and 2 Diesel Generator Fuel Oil System; Revision 17
- WO 200758330; EC-71 Cycle 17 Final Package; 07/07/2018
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