IR 05000440/2020004

Integrated Inspection Report 05000440/2020004

ML21043A176
Person / Time
Site:	Perry
Issue date:	02/12/2021
From:	Billy Dickson NRC/RGN-III
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2020004
Download: ML21043A176 (28)

Text

February 12, 2021

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2020004

Dear Mr. Penfield:

On December 31, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On January 28, 2021, 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.

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

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Perry Nuclear Power Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; 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,

/RA/

Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440 License Number: NPF-58 Report Number: 05000440/2020004 Enterprise Identifier: I-2020-004-0031 Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant Location: Perry, OH Inspection Dates: October 01, 2020 to December 31, 2020 Inspectors: S. Bell, Health Physicist J. Nance, Operations Engineer T. Ospino, Resident Inspector G. Roach, Senior Operations Engineer J. Steffes, Senior Resident Inspector Approved By: Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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 Close Valve During Surveillance Procedure Causes Inoperability and Unavailability of the Standby Liquid Control System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems NCV 05000440/2020004-01 Complacency Open A finding of very low safety significance (Green) and associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed for the licensees failure to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstances. Specifically, during performance of PTI-C41-P0001, Standby Liquid Control Transfer System Pump and Valve Operability Test,

Revision 10, operators failed to shut transfer line isolation valve, 1C41-F522, causing an unplanned eight-hour limiting condition for operation (LCO) entry and unavailability of both trains of the standby liquid control system.

Additional Tracking Items

None.

PLANT STATUS

The plant began the inspection period at rated thermal power. On October 31, 2020, reactor power was lowered to 66 percent to perform a rod sequence exchange and control rod scram time testing. The unit was returned to rated thermal power on November 11, 2020. On November 14, 2020, reactor power was lowered to 65 percent to perform a rod pattern adjustment. The unit was returned to rated thermal power the same day. On December 14, 2020, reactor power was lowered to 69 percent to perform turbine control valve testing. The unit was returned to rated thermal power on December 15, 2020. The unit remained at, or near, rated thermal power until December 23, 2020, when the unit entered into coastdown operations to refueling outage 1R18. The plant was at 97 percent power on December 31,

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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) External flooding walk down inspection Service Building on December 2, 2020

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Emergency closed cooling system (ECCS) valve alignment October 18, 2020

(2) Low pressure core spray venting and valve lineup October 22, 2020

(3) A residual heat removal (RHR) system lineup verification on November 18, 2020 (4) "A" standby liquid control (SLC) system alignment verification on December 3, 2020

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the high-pressure core spray system on November 10 to 20, 2020.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Intermediate building, elevation 620-foot, fire zone (FZ) 0IB-3 on November 7, 2020

(2) Fuel handling building, elevation 620-foot, FZ 0FH-3 on November 7, 2020

(3) Diesel generator building, 620- and 646-foot elevations, FZs 1DG-1C and DG-1D on November 7, 2020

(4) Auxiliary building, 620- and 599-foot elevations on November 7 to 10, 2020

(5) Unit 1 Division 3 Switchgear 620-6 FZ 1CC-3c on November 9, 2020

(6) Emergency Service Water pumphouse FZ 0EW on November 10, 2020

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (2 Samples)

The inspectors evaluated internal flooding mitigation protections in the: (1) "C" RHR system room on December 29, 2020

(2) ECCS system on December 30, 2020

71111.07A - Heat Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Division 1 emergency diesel generator (EDG) jacket water heat exchanger review on December 7 to 17, 2020

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance

Requalification Examination Results (IP Section 03.03) (1 Sample)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification program biennial written examination and annual operating test administered between October 26 and December 7, 2020.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Requalification Program (IP Section 03.04) (1 Partial)

(1) (Partial)

Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on December 10, 2020.

Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.

Administration of an Annual Requalification Operating Test Due to the COVID-19 PHE, the inspectors could not by direct observation, evaluate the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives. Specifically, the inspectors did not observe the administration of simulator scenarios and Job Performance Measures (JPM) during the conduct of an annual requalification operating test required by 10 CFR 55.59(a)(2).

Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.

Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.

Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.

Control Room Simulator The inspectors evaluated the adequacy of the facility licensees Control Room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.

Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during down power for rod sequence exchange and scram time testing on October 31, 2020.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the simulator on October 28, 2020.

(2) The inspectors observed and evaluated licensed operator performance in the simulator on November 4, 2020.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (6 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) SLC system unavailability due to dilution event on August 20, 2020

(2) Emergency service water (ESW) radiation monitoring spiking on October 19 to 22, 2020

(3) Work associated with "A" reactor protection system motor generator on November 12, 2020

(4) Meteorological tower work after Quincy lane was down for weather-related event on November 17, 2020

(5) Combustible gas mixing compressor "A" failure on December 22, 2020

(6) Unit 2 startup transformer modification issues on December 22, 2020

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Plant risk evaluation and assessment while "A" ESW, "A" ECCS system, and "A" RHR inoperable and unavailable for maintenance work window on October 20 to 22, 2020

(2) Emergent work evaluation and risk assessment associated with reactor vessel level perturbation due to reactor feed pump "A" speed oscillations on November 5, 2020

(3) Licensee response to feedwater system transient event on November 5, 2020

(4) Emergent activities associated to the reactor protection system motor generator "A" work on November 12, 2020

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Division 1 EDG operability determination associated with CR 2020-08482 on November 9, 2020

(2) Meteorological tower operability check following weather-related event on November 17, 2020

(3) Functional test of the FLEX emergency service water pump B based on CR 2020-09317 on December 9, 2020

(4) Unit 2 startup transformer disconnect failure on December 16 to 17, 2020

(5) Division 1 EDG jacket water circulating pump failure due to a blown fuse on December 31, 2020

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(2 Samples)

The inspectors evaluated the following permanent modification:

(1) Main steam line isolation valve nuclear steam supply shutoff system isolation logic "C" test jack modification on October 6, 2020

(2) Unit 1 startup transformer modification implementation 19-0203-001 on November 12, 2020

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) The replacement of filters on "A" hydraulic power unit recirculation system on September 17 to 21, 2020

(2) The replacement of the cable on the A ESW radiation monitor on October 7, 2020

(3) The replacement of "A" electro-hydraulic control pump discharge filter on October 8, 2020

(4) The replacement of the ECCS pump room cooler AGASTAT E7000 TD relay on October 18, 2020 (5) "A" ESW system loop flow and differential pressure test following maintenance work window on October 26, 2020 (6) "A" low pressure core spray room cooler time delay relay replacement October 21, 2020 (7) "A" RHR room cooler time delay relay replacement on October 28, 2020 (8) "A" RHR surveillance following motor operated valve test and adjustment on October 29, 2020

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) Main steam line high flow C functional test on October 6, 2020

(2) Main steam line low condenser vacuum channel A calibration on October 19, 2020 (3) "A" ESW flow and differential pressure test on October 24, 2020

(4) Channel "A" drywell high-pressure calibration for 1C71-N050A on

September 21, 2020 Inservice Testing (IP Section 03.01) (1 Sample)

(1) High-pressure core spray pump and valve operability test, work order 200771908

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Test of the FLEX lake water pumps on June 6, 2020

71114.04 - Emergency Action Level and Emergency Plan Changes

Inspection Review (IP Section 02.01-02.03) (1 Sample)

(1) The inspectors completed an evaluation of submitted Emergency Action Level and Emergency Plan changes on December 11, 2020. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (2 Samples)

The inspectors evaluated:

(1) Inspectors observed and evaluated the emergency response organization tabletop drill on October 29, 2020.

(2) Inspectors observed and evaluated simulator-based licensed operator requal training on November 4,

71124.05 - Radiation Monitoring Instrumentation

Calibration and Testing Program (IP Section 03.02) (11 Samples)

(1) Thermo Scientific PCM-3 personnel contamination monitor, serial number L70L004E, calibrated on December 13, 2019

(2) JL Shepherd Model 89 Irradiator calibrated on January 10, 2020

(3) Canberra Fastscan Whole Body Counter calibrated on February 5, 2020

(4) Mirion telepole survey instrument, serial number L70L074A, calibrated on February 11, 2020

(5) Ludlum model 12 survey instrument, serial number L70L096D, calibrated on February 26, 2020

(6) Eberline model RM20 survey instrument, serial number L70L020K calibrated on April 1, 2020

(7) Eberline R02 survey instrument, serial number L70L030H, calibrated on May 15, 2020

(8) Eberline model SAC-4 survey instrument, serial number L70L003E, calibrated on July 16, 2020

(9) Bicron RSO-50 survey instrument, serial number L70L0045Z, calibrated on August 24, 2020

(10) Thermo Scientific SAM9 small article monitor, serial number L70L504L, calibrated on September 9, 2020

(11) Thermo Scientific SPM-906 portal monitor, serial number L702009L calibrated on September 25, 2020 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (2 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Unit 1 Off-Gas Vent Pipe Noble Gas Calibration for 1D17-K836

(2) Unit 1 ESW Loop A Radiation Monitor Channel Calibration for 1D17-K604

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) ===

(1) October 1, 2019 through September 30, 2020

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) July 1, 2019 through September 30, 2020

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) October 1, 2019 through September 30, 2020

71152 - Problem Identification and Resolution

Semiannual Trend Review (IP Section 02.02) (1 Sample)

(1) Human performance trend June through December 2020

Annual Follow-up of Selected Issues (IP Section 02.03) (3 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) CR 2020-06561, Standby Liquid Control Hi/Lo Level Alarm During SLC Transfer Pump and Valve"

(2) CR 2020-06471, "Timeliness of General Emergency Classification During August 8, 2020, Dry Run Drill"

(3) Loss of Feedwater Heating Results in Loss of Safety Function

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 2019-004 and LER 2019-004-001, Loss of Feedwater Heating results in Loss of Safety Function on August 6, 2019.

The inspectors determined that the cause of the condition described in the LER was not reasonably within the licensees ability to foresee and correct, and, therefore, was not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified.

INSPECTION RESULTS

Failure to Close Valve During Surveillance Procedure Causes Inoperability and Unavailability of the Standby Liquid Control System Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.12] - Avoid 71152 Systems NCV 05000440/2020004-01 Complacency Open A finding of very low safety significance (Green) and associated non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed for the licensees failure to perform activities affecting quality in accordance with an approved procedure appropriate for the circumstances. Specifically, during performance of PTI-C41- P0001, Standby Liquid Control Transfer System Pump and Valve Operability Test, Revision 10, operators failed to shut transfer line isolation valve, 1C41-F522 causing an unplanned eight-hour limiting condition for operation (LCO) entry and unavailability of both trains of the SLC system.

Description:

On August 20, 2020, during the performance of PTI-C41-P0001, Standby Liquid Control Transfer System Pump and Valve Operability Test, Revision 10, the licensee received the SLC storage tank level HI/LO alarm shortly after starting the SLC transfer pump. The evolution resulted in the unintended addition of approximately 226 gallons of water to the SLC storage tank. The licensee reviewed system response, interviewed personnel, and reviewed procedure PTI-C41-P0001 and determined that the normally locked open transfer line isolation valve, 1C41-F522, had not been shut.

The licensee completed Surveillance Requirement 3.1.7.5 to sample SLC storage tank concentration within 24-hours following the inadvertent water addition. Based on boron concentration, the licensee determined that both the SLC system trains were inoperable and entered LCO 3.1.7 Condition B to restore one train to operable status within eight hours. The licensee returned SLC storage tank concentration to the correct specification about three hours after the initial tank solution test.

Corrective Actions: Immediate corrective actions included determination and correction of SLC storage tank concentration and restoring the SLC system to operable. Additionally, the licensee made procedural changes to add an independent verification step to the closure of the transfer line isolation valve, 1C41-F522.

Corrective Action References: CR 2020-06561, Standby Liquid Control Hi/Lo Level Alarm During SLC Transfer Pump and Valve, 08/20/2020; CR 2020-06563, Leakby Observed Through SLC Transfer Line Isolation Valve, 08/20/2020; and CR 2020-07110, Misposition Plant Status Control Event During SLC Transfer System Pump and Valve Operability Test, 09/11/2020.

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensees failure to implement Section 5.1.3, Step 3, of PTI-C41-P0001, Standby Liquid Control Transfer System Pump and Valve Operability Test, Revision 10, was a performance deficiency. Specifically, the failure to close the transfer line isolation valve 1C41-F522 in accordance with the procedure directly led to the inoperability and unavailability of the SLC system.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human 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. The inspectors determined the performance deficiency was more than minor because it was associated with the Human 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, an operator failed to close the transfer line isolation valve 1C41-F522, which allowed water to be added to the SLC storage tank, thus negatively impacting the availability of the SLC system.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspector assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the finding against the Mitigating Systems screening questions in Exhibit 2 and answered NO to all screening questions. Therefore, the finding screened to very low safety significance (Green).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risks, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, the operator failed to implement error reduction tools to ensure both actions contained with the step were performed in accordance with written procedures.

Enforcement:

Violation: Title 10 CFR 50 Appendix B, Part V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, on August 20, 2020, while performing an activity affecting quality, operators did not accomplish a surveillance procedure in accordance with the procedure and incorrectly performed a step in surveillance procedure PTI-C41-P0001, and failed to close a valve. Specifically, operators failed to close the transfer line isolation valve 1C41-F522, resulting in an unplanned entry into Technical Specification 3.1.7, Condition B, and adversely affected the availability of the SLC system.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Observation: Human Performance Trend June to December 2020 71152 During the second half of 2020, while performing reviews associated with the daily corrective action program, the inspectors identified 17 corrective action documents with human performance-related issues. Examples of human performance issues were spread across different working groups and resulted in various consequential outcomes. These examples included, but were not limited to, a chemistry department individual loss of attention to detail and dropped a glass vial containing a source resulting in a spill, electrician personal not implementing human performance tools (peer check) resulting in the miswiring during modification to the Unit 2 startup transformer and an increase in the out of service time, and the failure to close a valve between the SLC and standby liquid control transfer systems resulting in the inoperability and unavailability of the SLC system. Following their review, the inspectors concluded that the Human Performance attributes associated with the issues were associated with a lack of attention to detail, supervisors' failure to challenge performance and enforce standards and requirements, and individuals not following their processes and procedures. The inspectors engaged the licensee and expressed their observations through meetings and other methods. The inspectors expressed their concern with the upward negative trend in licensee performance and its impacts to plant safety.

Due in part to previous inspector observations, the licensee developed a "critical coaching initiative" to analyze performance gaps and perform training for the site supervisors as documented in CR 2019-09164, "2019 INPO E&A AFI LF.1: Leadership." Following the critical coaching initiative institution, the inspectors observed a temporary reduction in human performance issues. However, considering the most recent human performance issues, the inspectors have concerns about the licensee's corrective actions' effectiveness and longevity.

Additionally, the inspectors noted as a consequence of the most recent supervisor coaching; the licensee wrote five condition reports for supervisors failing the "critical coaching lab in site supervisor training," as documented in CR 2020-08703, CR 2020-08696, CR 2020-08008, CR 2020-08007, and CR2020-07767. The inspectors concluded that while the licensee had begun to address human performance gaps site-wide, but as demonstrated by the most recent supervisor failures of the critical coaching lab, more work was required to ensure performance improvement.

The inspectors did not identify any findings or violations of NRC requirements in the course of their review.

Observation: Emergency Preparedness Drill General Emergency Classification 71152 Timeliness Review The inspectors performed a detailed review of CR 2020-06471, "ERO-Drill: Timeliness of General Emergency Classification During August 8, 2020, Dry Run Drill." The purpose of emergency preparedness drill performance and evaluation, in part, is to determine the licensee's ability to identify and classify events based on plant conditions and communicate emergency action level declarations promptly to state and local authorities. Title 10 CFR 50 Appendix E requires, in part, that "licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15-minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency conditions as soon as possible following the identification of the appropriate emergency classification level." To assess the timeliness of licensee notification, a "time zero" is identified in drill scenarios when plant conditions change, which should be recognized by plant staff followed by event classification.

The inspectors noted that CR 2020-06471 documented a drill controller issue that the scenario "time zero" was different than what occurred during drill execution. Specifically, the scenario guide stated, "time zero" was 11:35 am, and "time zero" during drill debrief was determined to be 11:40 am. The inspectors noted this distinction to be important because event classification occurred at 11:54 am. The inspectors noted that "Perry Emergency Response Organization Integrated Drill Scenario Guide," Revision 1, stated that at 11:35 am a catastrophic body-to-bonnet failure of the "B" main steam line isolation valve occurred resulting in the rapid increase in steam tunnel temperatures, as well as turbine building/heater bay and Unit 1 plant vent radiation monitor readings. The Perry Emergency Response Organization Integrated Drill Scenario Guide controller notes stated that, "this is the indication for a General Emergency FG 1.1, loss of any two fission product barriers and the loss or potential loss of the third barrier." For this Problem Identification and Resolution sample, the inspectors focused on the licensee's evaluation and assessment of event classification timeliness and associated corrective actions.

The inspectors noted through review of licensee evaluation that upon insertion of the body-to-bonnet failure, the simulator errantly showed flow through the off-gas system.

The Perry Nuclear Power Plant construction is such that both outboard main steam isolation valves and main steam stops are contained in the steam tunnel. Therefore, an indication of off-gas flow in conjunction with the rise in steam tunnel temperatures and vent radiation monitor readings led the operations crew to believe the failure and steam leak had occurred downstream of the main steam stops. The operations crew shut the main steam stops and noted no change in steam tunnel temperature trend or turbine building/heater bay and Unit 1 plant vent radiation monitor readings. The operations crew determined that the leak was unisolable and constituted a loss of a fission product barrier. This information was not promptly communicated to the Emergency Director in the Emergency Operations Facility (EOF) due to conference bridge communications issues. The inspectors challenged the licensee as to why 11:40 am was "time zero" and not 11:35 am, as stated in the drill guide and when plant conditions first presented themselves. The inspectors reviewed PSI-0019, "Emergency Action Level (EAL) Bases Document," Revision 21, Attachment 2 fission product barrier loss/potential loss matrix and bases for an unisolable direct downstream pathway to the environment exists after containment isolation signal guidance. The inspectors noted that the threshold is considered met if the breach is not isolable from the Control Room or an attempt for isolation from the Control Room has been made and was unsuccessful. The licensee stated that based on the off-gas flow indications, even though erroneous and emergency action level basis guidance, it was reasonable for the operations crew to attempt to shut the main steam stops before declaring an unisolable leak.

The inspectors noted three contributors to the event classification almost exceeding the regulatory time frame:

1. Communication issues between the Control Room and EOF Emergency Director delayed recognition of the leak in the final fission product barrier and a General Emergency declaration. The licensee changed its process to require the Control Room and Emergency Director to maintain an open communication line rather than connecting to the bridge to relay information.

2. The EOF Emergency Director had noted and focused solely on rising Unit 1 plant vent radiation levels as the indicator to determine a General Emergency had occurred.

The Director was slow to recognize the unisolable leak condition in the Emergency Action Level matrix also applied until prompted by the Control Room.

3. Recent simulator software upgrades resulted in the unintended off-gas flow indications encountered during the drill. The licensee had validated the scenario before the software upgrades going into effect and had not revalidated before the licensee performing the drill. The licensee changed its process to ensure simulator fidelity before drill execution following software upgrades.

The inspectors did not identify any findings or violations of NRC requirements in the course of their review.

Observation: Loss of Feedwater Heating results in Loss of Safety Function 71152 The inspectors reviewed the associated causal evaluation and corrective actions associated with loss of feedwater heating due to heater 5B isolation during heater alignment. The inspectors noted that the apparent cause was inadequate communication within the Perry organization associated with heater tuning strategies and implications to operating procedures. Specifically, the licensee tuned the heater normal controller for steady-state operations to dampen heater level oscillations at 100 percent power. This strategy restricts the ability to transfer level control from alternate to normal at power levels greater than 62 percent power. The inspectors noted that the operations procedure did not include mitigating actions to reduce power based on the tuning strategy and resulted in heater isolation. Corrective actions included, but were not limited to, revising IOI-0003, "Power Changes," to provide a caution note to operations about heater drain control based on power level, which would incorporate level control restrictions based on tuning strategy. The inspectors did not identify any findings or violations of NRC requirements in the course of their review.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 28, 2021, the inspectors presented the integrated inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

• On December 10, 2020, the inspectors presented the radiation protection baseline inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

• On December 11, 2020, the inspectors presented the Perry Biennial Licensed Operator Requalification Program Inspection Results inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

• On December 11, 2020, the inspectors presented the emergency action level and emergency plan changes inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

• On January 28, 2021, the inspectors presented the integrated inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Engineering FENOC Perry Flood Hazard Reevaluation Report 12/4/2020

Evaluations

71111.04 Drawings 302-0701-00000 High-Pressure Core Spray System KK

Procedures SVI-C41-T2001-A Standby Liquid Control 22

SVI-P42-T5326 Emergency Closed Cooling System Valve Position Check 9

VLI-E22A High-Pressure Core Spray 10

Work Orders 200753720 SVI-E12-T1182A RHR A PLCI Vlv L/U (31D) RHR A LPCI 11/18/2020

Valve Lineup Verification and System Venting

200754601 SVI-P42-T5326 ECCS Vlv Position Check (31D) Emergency 10/18/2020

Closed Cooling System Valve Position Check

200754975 SVI-E21-T11 LPCS Venting and Vlv L/U (31D) LPCS 10/22/2020

Venting and Valve Lineup Verification

71111.05 Fire Plans FPI-0FH Fuel Handling Building 6

FPI-0IB Intermediate Building 10

FPI-1AB Auxiliary Building Unit 1 4

FPI-1DG Diesel Generator Building 9

Procedures FPI-0CC Unit 1- Division 3 Switchgear 620 - 6 Elevation Fire Zone 12

1CC-3c

FPI-0EW Emergency Service Water Pumphouse 7

71111.06 Calculations JL-083 Flooding Analysis of Control Complex Building, Intermediate 3

Building, and Fuel Handling Building - Floor Elevation 574

Feet - 10 Inches

Corrective Action 2013-05625 Corrective Action Generated to Track Closure of Prompt 10/23/2015

Documents Functionability Assessment for CR 2013-05625

71111.07A Calculations R46-023 Division 1 Diesel Generator Jacket Water Heat Exchanger 4

Performance Testing Results

71111.11A Miscellaneous Perry Nuclear Power Plant Annual LORT Exam Information 12/14/2020

71111.11B Corrective Action CR 2019-08949 Recombiner A/B TEMP HI / LOW Alarm in the Control Room 10/26/2019

Documents Label Does Not Match the Alarm Response Instruction or

Simulator Alarm Window

CR 2019-10283 Simulator Hardware Failure During Annual Exam Job 12/10/2019

Performance Measures

Inspection Type Designation Description or Title Revision or

Procedure Date

CR 2020-02702 Simulator Hardware Issue Caused Short Training Delay 03/27/2020

Corrective Action CR 2020-09365 Inaccurate Information Provided to the NRC 12/07/2020

Documents

Resulting from

Inspection

Miscellaneous 2019 LORT Attendance Records

20 LORT Attendance Records

100% Simulator Steady-State Test 08/28/2020

75% Simulator Steady-State Test 07/27/2019

75% Simulator Steady-State Test 08/28/2020

43% Simulator Steady-State Test 07/27/2019

43% Simulator Steady-State Test 08/28/2020

Operator Remediation Plan; Various Operators 12/31/2019

100% Simulator Steady-State Test 07/27/2019

2019 01-05 Requalification Training Schedule 12/31/2019

20 06-10 Requalification Training Schedule 12/01/2020

20-13 RO Written Exam Week 7

20-14 SRO Written Exam Week 7

B2.2.1.1 Transient Testing, Manual SCRAM 03/27/2019

B2.2.1.10 Transient Testing, Main Steam Isolation Valve Closure with 07/24/2020

One Safety Relief Valve Stuck Open

B2.2.1.2 Transient Testing, Trip All Reactor Feed Pump Turbines 03/27/2019

B2.2.1.3 Transient Testing, Main Steam Isolation Valve Closure 07/23/2020

B2.2.1.4 Transient Testing, Simultaneous Trip of All B33 Recirc 03/27/2019

Pumps

B2.2.1.5 Transient Testing, Trip Single B33 Recirc Pump 07/24/2020

B2.2.1.7 Transient Testing, Maximum Rate Power Ramp (100% to 07/24/2020

75% to 100%) Using Flow Control Valves

B2.2.1.9 Transient Testing, Main Steam Line Rupture in Drywell 03/27/2019

Credit for Position BOP Operator 12/31/2019

Report

Credit for Position ATC Operator 12/31/2019

Report

Inspection Type Designation Description or Title Revision or

Procedure Date

Credit for Position Shift Manager 12/31/2019

Report

Credit for Position Unit Supervisor 12/31/2019

Report

Credit for Position BOP Operator 12/01/2020

Report

Credit for Position ATC Operator 12/01/2020

Report

Credit for Position Unit Supervisor 12/01/2020

Report

Credit for Position Shift Manager 12/01/2020

Report

Cycle 18 Real Time Annual Testing 03/26/2019

OT-3070-PC1E Simulator Scenario Guide PC1E 0

OT-3070-001- Simulator Scenario Guide PC5D 0

PC5D

OT-3070-005- Simulator Scenario Guide RP2A 0

RP2A

OT-3070-RP1D Simulator Scenario Guide RP1D 0

OT-3701-ADM- SRO Admin JPM Week 4

25SRO

OT-3701-ADM- SRO Admin Job Performance Measure (JPM) Week 2

24SRO

OT-3701C11- Simulator JPM Week 7

514RO

OT-3701C41- In Plant JPM Week 7

008RO

OT-3701C61- In Plant JPM Week 7

501RO

OT-3701C71- Simulator JPM Week 7

003RO

OT-3701G43- RO Admin JPM Week 7

001RO

71111.11B Miscellaneous OT-3701P57- In Plant JPM Week 4

Inspection Type Designation Description or Title Revision or

Procedure Date

001RO

OT-3701R10- In Plant JPM Week 4

2RO

OT-3701R43- Simulator JPM Week 6

501RO

OTLC- Scenario Based Testing 0

3058202006-PY-

SGA

OTLC- Scenario Based Testing 0

3058202006-PY-

SGB

OTLC- Scenario Based Testing 0

3058202006-PY-

SGC1

OTLC- Scenario Based Testing 0

3058202007-PY-

SGA

OTLC- Scenario Based Testing 0

3058202008-PY-

SGA-HIT

Simulator Post Turbine Valve Closure 05/28/2019

Event Testing

Simulator Post Loss of Two Circulating Water Pumps 02/17/2020

Event Testing

Procedures NOBP-TR-1271, Inactive License Retraining Program Records; Various 11

Operators

NOP-OP-1013-04 Time Critical Operator Actions Tracking Sheet 0

NOP-TR-1240-06 Remediation Training 0

NOP-TR-1280 Simulator Configuration Management 2

Self-Assessments 2020 Nuclear Oversight Quality Assessment of Operations 03/31/2020

Department

2019 Nuclear Oversight Quality Assessment of Training 02/27/2020

Department

Simulator Review Meeting Minutes 02/20/2019

Inspection Type Designation Description or Title Revision or

Procedure Date

Committee

Simulator Review Meeting Minutes 04/17/2019

Committee

Simulator Review Meeting Minutes 01/30/2020

Committee

Simulator Review Meeting Minutes 04/16/2020

Committee

Simulator Review Meeting Minutes 08/17/2020

Committee

Work Orders 19-0002 DFWCS Reactor Feed Pump Trip and Swap to Single 05/02/2019

Element

19-0003 ECP 04-0145 RFP Min Flow Controller Modification 02/21/2019

19-0004 ECP 18-0081 Implement Stroke Time Changes for 02/21/2019

1G33F0039 & 1G33F0040

19-0006 Implement Cycle 18 Core Files for All Three Exposures 03/05/2019

(BOL, MOL, EOL)

19-0007 Implement ECP 18-0274 to Eliminate Automatic High Shaft 03/12/2019

Vibration Trip from Main Turbine Protection System

19-0012 Div 2 EH12 Undervoltage ECP 16-0336-002 03/18/2019

19-0019 Install ECP 04-0113-001 Fire Computer in Control Room 08/28/2019

19-0030 Install ECP 12-0238 Diesel Fire Pump Switch on P970 10/01/2019

20-0015 Install Div 3 DG RM Vent CO2 Injection Bypass Switch on 02/24/2020

P800

20-0044 Implement ECP 17-0220 in the Simulator (MSIV Bypass 10/20/2020

Jacks)

20-0045 Implement ECP 15-0517 for Div 3 in the Simulator 08/17/2020

71111.11Q Miscellaneous Evolution Specific Perry Nuclear Power Plant October 2020 Pattern Adjustment 0

Reactivity Plan

OT-3070-003- Scenario Guide 0

RP1C

OT-3070-PC1B Scenario Guide 1

OT-3070-RP5A Scenario Guide 5

71111.12 Corrective Action 2020-06482 Emergency Service Water Radiation Monitor Spiking 08/17/2020

Documents 2020-08558 Reactor Protection System (RPS) MG SET a Tripped During 11/04/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

PMT

20-08868 MET Tower Instrumentation Not Restored Upon Restoration 11/17/2020

of Quincy Power

20-09476 Unit 2 Startup Transformer Manual Disconnect Stuck Open 12/15/2020

20-09635 Combustible Gas Mixing Compressor Suction Valve Would 12/22/2020

Not Reopen Following Compressor Start

Work Orders 200840084 Replace Power Supply CR 2020-08986 11/23/2020

71111.13 Corrective Action 2020-08567 Uncertainty of Proper Motor starter Overload Settings for 11/04/2020

Documents Reactor Protection System (RPS) Motor Generator (MG) Set

A

20-08575 Feedback System Transient - Steamflow/Feedflow 11/05/2020

Mismatch

Procedures NOP-ER-3001-03 Simple Troubleshooting Plan 4

NOP-OP-1007 Risk Management 33

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

Work Orders 200093606 Replace Relays in RPS "A" MG set 11/27/2020

200835639 ECP 20-0179-001 Disable LS6/7 Linkage TM 11/18/2020

71111.15 Corrective Action 2008-50767 Less Than Adequate Documentation for USAR Technical 12/12/2008

Documents Basis

2014-10996 60dpm Leak Shaft Div 2 Jacket Water Circ Pump Prompt 06/27/2014

Operability Determination Test

20-08868 MET Tower Instrumentation not Restored upon Restoration 11/17/2020

of Quincy Power

20-09317 Rheostat on FLEX Lake Pump for ESW "B" Doesnt Work 12/09/2020

Correctly Acts as On Off Switch

20-09535 As Found Condition of the Unit 2 Startup Transformer 12/17/2020

Manual Disconnect 2S11-S290 Gearing

20-09640 Division 1 Diesel Generator Jacket Water Circulation Pump 12/22/2020

Blown Fuse

Operability 2020-07870 Plan for Actions for Operation Challenge, Degraded Division 10/16/2020

Evaluations 1 D/G Circulating Jacket Water Pump/Motor

Procedures R45-025 Division 1 and 2 Emergency Diesel Generator Jacket Water 03/09/2010

Available Net Positive Suction Head

Work Orders 200841352 Unit 2 Main Transformer Troubleshooting for Unexpected 12/18/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

Results Upon Installation of a Modification

71111.18 Corrective Action 2020-06562 During Development of the Open Phase Modification 08/20/2020

Documents ECP-19-203, an Engineer Walkdown of the Startup

Transformer Relay Panel (1H13P0809) was Not Performed

20-08701 Failed PMT Unit 1 Startup OPPS Modification 11/10/2020

Engineering ECP 17-0220-003 Main Steam Line Isolation Valve Nuclear Steam Supply 0

Changes Shutoff System Isolation Logic C Test Jack Installation

ECP 17-0220-003 Main Steam Line Isolation Valve Nuclear Steam Supply 1

Shutoff System Isolation Logic C Test Jack Installation

Engineering 601293470 Engineering Evaluation Request 11/11/2020

Evaluations

Procedures IP-ENG-001 Form 19-0203-000 Dedicated Open Phase Control Room 0

Annunciators - Unit-1

NOP-WM-1001-0 Addendum # A-4 TEST Functional WO 200803505 3

SVI-E31-T0074-C MSL High Flow Channel "C" Functional for 1E31-N686C and 8

1E31-N688C

Work Orders 200737101 Implement ECP 17-0220-003 05/10/2020

200751207 SVI-E31-T0074C (92D) MSL High Flow Channel "C" 06/10/2020

Functional for 1E31-N686C and 1E31-N688C

71111.19 Corrective Action 2020-07809 Steam Bypass and Pressure Regulating Pump A 10/08/2020

Documents Discharge Filter Failed Post-Maintenance Testing

Work Orders 200750868 Emergency Service Water Loop "A" Flow and Differential 10/24/2020

Pressure Test

200752301 Replace 3.0 Micron Filter 10/08/2020

200752959 Replace Fullers Earth Filters 09/12/2020

200762832 Replace High-Pressure Filter, HPU A 09/17/2020

200773294 SVI-D17-T8041 ESW Loop A Radiation Monitor Channel 10/07/2020

Calibration For 1D17-K604

200778768 Replace Time Delay Relay 1M39Q7004 10/21/2020

200778768 Replace Time Delay Relay 1M39Q7004 10/22/2020

200778769 Replace Time Delay Relay 1M39Q7008 10/22/2020

200791518 Inspect/Replacement Filters, LPCS Room A 10/21/2020

200794100 Perform Static Motor Operated Valve Test 10/22/2020

200832456 A Rad Monitor Cable Replacement 09/23/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.22 Miscellaneous NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) 4

Implementation Guide

Procedures FSG 60.1 Supply ESW A Header from a FLEX Pump at the ESW 0

PTI-P45-P0001 ESW System Loop A Flow Differential Pressure Test 18

SVI-B21T0077A MSL Low Condenser Vacuum Channel "A" Calibration For 11

1B21-N075A

SVI-C71-T0043-A Drywell High-Pressure Channel A Calibration For 9

1C71-NN050A

SVI-R43-T1317 Diesel Generator Start and Load Division 1 25

Work Orders 200737101 IMPLEMENT ECP 17-0220-003 10/05/2020

200750868 PTI-P45P0001 1 (92D) EWS System Loop A Flow and 10/24/2020

Differential Pressure Test on

200751027 SVI-E31T0074C-1 (92D) MSL High Flow Channel "C" 10/06/2020

Functional for 1E31-N668C and 1E31-N688C

200752684 FLEX Water Pump Functional Testing 06/15/2020

200770447 SVI-B21-T0077-A MSL Low Condenser Vacuum "A" 10/19/2020

Calibration For 1B21-N0

200773288 SVI-C71-T0043-A Drywell High-Pressure Channel A 09/21/2020

Calibration

71114.04 Miscellaneous Perry Station 10 CFR 50.54(q) Evaluator Qualification and 05/19/2020

Training Records Spreadsheet

NRC Letter Subj: Perry Nuclear Power Plant, Unit No. 1 - Issuance of 08/14/2019

ML19163A023 Amendment No. 186 Concerning Changes to Emergency

Response Organization Staff

PY-2019-017-00 10 CFR 50.54(q)2 Analysis for Perry Nuclear Power Plant 08/07/2019

Emergency Plan Revision

PY-2019-017-00 10 CFR 50.54(q)3 Evaluation for Perry Nuclear Power Plant 09/06/2019

Emergency Plan Revision

PY-2019-039-00 10 CFR 50.54(q)2 Analysis for Perry Nuclear Power Plant 11/04/2019

Emergency Plan Revision

PY-2019-039-00 10 CFR 50.54(q)3 Evaluation for Perry Nuclear Power Plant 11/06/2019

Emergency Plan Revision

PY-2019-044-00 10 CFR 50.54(q)2 Analysis for Perry Nuclear Power Plant 12/17/2019

Emergency Plan Revision

Inspection Type Designation Description or Title Revision or

Procedure Date

PY-2019-044-00 10 CFR 50.54(q)3 Evaluation for Perry Nuclear Power Plant 01/06/2020

Emergency Plan Revision

Procedures Emergency Plan for Perry Nuclear Power Plant 54

Emergency Plan for Perry Nuclear Power Plant 55

Emergency Plan for Perry Nuclear Power Plant 56

Emergency Plan for Perry Nuclear Power Plant 57

NOP-LP-5002 Evaluation of Changes to Emergency Plans and Supporting 7

Documents 10 CFR 50.54(q)

71114.06 Miscellaneous 2020 4th Quarter ERO Tabletop Drill TSC-EOF 0

71124.05 Calibration Abacos 2000 Whole Body Counter Calibration 02/05/2020

Records JL Shepherd Irradiator Calibration and Verification 01/10/2020

L702009L Thermo Scientific SPM-906 Portal Monitor 09/25/2020

L70L003E Eberline SAC-4 Survey Instrument 07/16/2020

L70L0045Z Bicron RSO-50 Survey Instrument 08/24/2020

L70L004E Thermo Scientific PCM-2 12/13/2019

L70L020K Eberline RM-20 Survey Instrument 04/01/2020

L70L030H Eberline RO2 Survey Instrument 05/16/2020

L70L074A Mirion Telepole Survey Instrument 02/11/2020

L70L096D Ludlum Model 12 Survey Instrument 02/26/2020

L70L504L Thermo Scientific Small Article Monitor 09/22/2020

WO 200773294 ESW Loop A Radiation Monitor Channel Calibration for 10/07/2020

1D17-K604

Corrective Action CR-2020-05336 Procedure Adherence During WBC Calibration 06/29/2020

Documents CR-2020-05337 Input Error in Creating WBC Calibration File 06/29/2020

CR-2020-05376 Pre NRC Assessment SA-BN-2020-1920 Identified 06/30/2020

Deficiency: Incorrect Source Information Contained in

SVI-D19-T1356A

Engineering D19 Containment Hi Range Radiation Monitor Evaluation 4

Evaluations

Procedures HPI-J0054 Calibration of the Abacos 2000 Whole Body Counting 4, 6

System

NOP-OP-4401 Radiation Protection Instrumentation Program 3

Work Orders 200767227 Off-Gas Vent Pipe Noble Gas Radiation Monitor Calibration 09/17/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

200773294 ESW Loop A Radiation Monitor Channel Calibration for 10/07/2020

1D17-K604

71151 Corrective Action CR-2020-06028 NRC ID: Door 1P54X0202A High-Pressure Core Spray 07/29/2020

Documents Pump Room Found Unsecured

Miscellaneous Reactor Coolant System Dose Equivalent Iodine Various

Determination Summary Data from 10/01/2019 Through

09/30/2020

Procedures TSR Modes Technical Specification Rounds Modes 1, 2, and 3 10/01/2019 -

1,2&3-19 01/19/2020

TSR Modes Technical Specification Rounds Modes 1, 2, and 3 01/20/2020 -

1,2&3-20 09/30/2020

71152 Corrective Action 2019-06618 Entered ONI-N36 Loss of Feedwater Heating and ONI-C51 08/16/2019

Documents due to Heater 5B Isolation during Startup while Aligning

Heater Normal Drains Unplanned Limiting Condition of

Operation Entry

Drawings 302-0691-00000 Standby Liquid Control System AA

2-0692-00000 Standby Liquid Control Transfer System V

Miscellaneous LER 2019-004 Loss of Feedwater Heating Results in Loss of Safety 06/08/2019

Function

Procedures PTI-C41-P0001 Standby Liquid Control Transfer System Valve Test 11

71153 Miscellaneous LER 2019-004 Loss of Feedwater Heating Results in Loss of Safety 06/08/2019

Function

LER 2019-004-01 Loss of Feedwater Heating Results in Loss of Safety 11/06/2019

Function

25