IR 05000440/2021002

Integrated Inspection Report 05000440/2021002

ML21224A286
Person / Time
Site:	Perry
Issue date:	08/12/2021
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2021002
Download: ML21224A286 (14)

Text

August 12, 2021

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2021002

Dear Mr. Penfield:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On August 4, 2021, the NRC inspectors discussed the results of this inspection with Mr. D. Benyak, Acting Site Vice President, and other members of your staff.

The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Signed by Dickson, Billy on 08/12/21 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: 05000440/2021002 Enterprise Identifier: I-2021-002-0099 Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant Location: Perry, Ohio Inspection Dates: April 01, 2021 to June 30, 2021 Inspectors: T. Ospino, Resident Inspector J. Steffes, Senior Resident Inspector T. Taylor, 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

The plant began the inspection period shut down for Refueling Outage (RFO) 1R18. On April 7, 2021, at 10:55 p.m., the plant was placed in startup mode and achieved criticality at 1:20 a.m. the next day. On April 8, 2021, at 5:43 p.m., the main generator was synchronized to the grid. The plant reached 100 percent power on April 12, 2021. On May 19, 2021, the licensee reduced power to 90 percent due to the receipt of a main transformer 'B' oil temperature alarm. The licensee returned to full power operations the next day following isolation of the Group 4 cooling fan, which was found grounded. The reactor remained at approximately 100 percent power for the remainder of the inspection period except for rod sequence exchanges, required testing, and in some instances power reductions to maintain condensate demineralizer outlet temperature and/or high condenser circulating water outlet temperature at or below their respective upper limits due to environmental conditions. The power reductions varied between 1 and 10 percent of rated thermal power and lasted from a few hours to several days.

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 (COVID-19), resident and regional 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, increasing the amount of time on site as local COVID-19 conditions permitted.

As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; 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 a portion 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.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) reactor core isolation system while the high-pressure core spray system was unavailable on May 13 to 14, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (9 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) control complex 4160 Volt and 480 Volt switchgear room, 620-foot elevation, on May 14, 2021

(2) Division 3 diesel generator room on May 20, 2021

(3) 125 Volt direct current distribution and battery rooms for Divisions 1 and 2 on May 20, 2021

(4) Divisions 1 and 2 cable spreading rooms, 638-foot elevation, on May 28, 2021

(5) intermediate building, 574-foot elevation, on June 10, 2021

(6) intermediate building, 599-foot elevation, on June 11, 2021

(7) fuel handling building, 620-foot elevation, on June 2, 2021

(8) emergency service water pump house on June 14, 2021

(9) turbine power complex, 582 and 568-foot elevations, on June 15, 2021

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) high-pressure core spray pump room on June 30, 2021

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 plant startup from RFO 1R18 on April 7, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated an operations crew-evaluation scenario in the plant training simulator on May 10, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (4 Samples)

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

(1) failure of the control room annunciator system optical isolator on January 7, 2021

(2) 'A' average power range monitor channel failure resulting in a half scram signal on April 15, 2021

(3) lower containment airlock door failure on April 29, 2021

(4) turbine building/heater bay ventilation exhaust post-accident radiation monitoring system flow transducer failure on May 26, 2021

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 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 assessment while the Division 3 diesel, high-pressure core spray and Division 3 emergency service water systems were unavailable on May 12 to 14, 2021

(2) 'B' main transformer cooling fans emergent work on May 19, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)

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

(1) 'B' inboard main steam isolation valve stroke time failure as documented in Condition Report (CR) 2021-01789 on March 5, 2021

(2) scram discharge vent and drain valve failure to reposition during testing as documented in CR 2021-02291 on March 27, 2021

(3) reactor core isolation cooling system suppression pool water level 'A' channel high transmitter exhibited signs of drift as documented in CR 2021-03134 on April 4, 2021

(4) hydraulic control unit 30-39 operability following testing as documented in CR 2021-02560 on April 6, 2021

(5) lower containment airlock door air leak as documented in CR 2021-02997 on April 29, 2021

(6) local power range monitor 2B-48-49 showed signs of failure as documented in CR 2021-02359 on May 11, 2021

(7) flex lake pump functionality determination following cable testing failure on June 9 to 11, 2021

71111.18 - Plant Modifications

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

(1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) permanent elimination of the 'B' recirculation system drain appendages between March 7 to 31, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

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

(1) Division 1 diesel generator emergency service water relief valve replacements on March 25, 2021

(2) replacement of high-pressure core spray system relays 1E22K0900 and 1E22K0901 on May 14, 2021

(3) 'A' average power range monitor channel Z405 card relay replacement on April 16, 2021

(4) local power range monitor 2B-48-49 relay replacement on May 12, 2021

(5) 'B' main transformer cooling fan replacement on May 21, 2021

(6) turbine building/heater bay ventilation exhaust post-accident radiation monitoring system flow transducer replacement on May 4, 2021

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated RFO 1R18 activities from April 1 to April 8, 2021. Activities evaluated by the inspectors included, but were not limited to, clearance and tagging activities, foreign material exclusion program, electrical power alignment, decay heat removal, inventory control to include reduced inventory times, spent fuel pool cooling, refueling activities, reactivity control, containment closure, startup and heatup, and fatigue management.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) 'A' emergency core cooling system drywell pressure high channel surveillance on March 22, 2021

(2) Division 2 diesel generator run on May 25, 2021

(3) 'A' average power range monitor channel calibration on April 20, 2021

(4) lower containment airlock pneumatic system leak test on May 17, 2021

(5) condensate return line penetration 1P11 test on June 3, 2021

(6) accident monitoring and remote shutdown panel channel checks on April 23, 2021

(7) 'B' channel safety relief valve and low-low set pressure actuation functional on May 25, 2021

(8) 'B' control complex chiller breaker surveillance on June 28,

OTHER ACTIVITIES - BASELINE

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

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

(1) Unit 1 (January 1, 2020 - December 31, 2020)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) Unit 1 (January 1, 2020 -December 31, 2020)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) Unit 1 (January 1, 2020 -December 31, 2020)

71152 - Problem Identification and Resolution

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

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in work order process and execution that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Observation: Work Order Process Trend Review 71152 The inspectors noted an adverse trend in work order development, structure, and execution that warranted a further review of the corrective action program to determine if a trend existed and had negatively impacted plant performance. Issues found during the program review included but were not limited to administrative errors in testing design and process.

Examples reviewed by the inspectors include, but were not limited to:

During the performance of corrective maintenance on hydraulic control unit 58-35, the licensee identified multiple work instruction errors at the point of execution. For instance, the incorrect hydraulic control unit was annotated to be worked, and steps added in the planning process were not required to execute the work. The discrepancies were documented in the work in progress log associated with the work order and further documented in CR 2021-03741, "Deficiencies Identified in the Preparation/Execution of [RFO] 1R18 Work Order 200848382, Control Rod Drive Hydraulic Control Unit 58-35."

The licensee wrote Work Order 200718652 to replace relays associated with the high-pressure core spray system. The relay replacements were a 14-year preventative maintenance item and was the first time to be executed. The work instructions were sequenced out of order, resulting in a relay wire landing on an energized terminal, resulting in a blown fuse but no further equipment damage. As documented in CR 2021-03905, "Work Order Steps Incorrect for Relay Function Test," the steps were written in the opposite order of what the logic had indicated on drawings.

During the performance of SVI-R43-T7000-A, "Division 1 ECCS [emergency core cooling system] Integrated Test," the licensee caused an unexpected start of the Division 1 diesel generator. As documented in CR 2021-02121, "Unplanned Division 1 DG [diesel generator] Start During Integrated LOOP/LOCA [loss of offsite power/loss-of-coolant accident] Test," the work instruction installed a switch that bypassed the local remote switch contacts and simulated a Loss of Coolant Accident signal to start the diesel. The diesel had already been declared inoperable and unavailable due to the ongoing work and did not impact shutdown plant risk.

On June 16, 2021, the licensee declared both FLEX lake water pumps non-functional during the execution of Work Order 200778617, insulation resistance testing. As documented in CR 2021-04577, "FLEX Lake Water Pump Transformer High Side Meggar Readings Below Acceptance Criteria," and Condition Report 2021-04569, "Test Results UNSAT for Flex Lake Water Pump Motor 1X110001," it was determined that the enclosed space of the essential service water pump house during warm months contributed to a high humidity condition, affecting the testing setup. The licensee's failure to account for environmental factors during work instruction development caused the number 2 FLEX lake water pump to be declared non-functional in error. Further testing conducted at lower humidity resulted in satisfactory test results.

The resident inspectors discussed each previously mentioned instance with plant management who agreed with the resident's perspective on potential implications of a negative trend in work management. As was documented in previous inspection reports, the site had dealt with human performance errors in work execution associated with decisions made in the field by individual contributors without resistance from direct oversight. The resident inspectors' review did not identify any findings, violations, or issues with the licensee's evaluation or issue resolution. However, the residents remain concerned that the confluence of work management issues and human performance could lead to a safety-significant issue.

EXIT MEETINGS AND DEBRIEFS

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

On August 4, 2021, the inspectors presented the integrated inspection results to Mr. D. Benyak, Acting Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Drawings 302-0631-00000 Reactor Core Isolation Cooling System HH

2-0632-00000 Reactor Core Isolation Cooling System LL

Procedures ELI-R24 480 Volt MCC 36

VLI-E51 Reactor Core Isolation Cooling System 10

71111.05 Corrective Action CR 2021-04450 NRC ID: NRC Identified Concerns During Walkdown on 06/04/2021

Documents Fuel Handling Building 620

Resulting from

Inspection

Fire Plans 0FH-3 Fuel Handling Building 620-6 Elevation 06/02/2021

FPI-0CC Control Complex 12

FPI-0IB Intermediate Building 10

FPI-1DG Diesel Generator Building 9

OEW-1a Fire Zone OEW-1a Emergency Service Water Pump House 06/14/2021

OEW-1b Fire Zone OEW-1b Diagram 06/14/2021

TP-568 and TP- Fire Zones TP-568 and TP-5826 06/15/2021

26

Procedures FPI-A-C01 Fire Protection Program Control Processes (Hot Work 15

Permits, Transient Combustible Permits, Impairment

Permits, and Fire Watches)

71111.06 Calculations JL-61 Auxiliary Building Flooding Analysis 3

71111.11Q Miscellaneous OIO-001 Cold Startup 56

OTLC- Simulator Evaluation Scenario Cycle 2 05/10/2021

3058202102_PY-

SGC1

71111.12 Miscellaneous NOP-ER-3004-03 Maintenance Rule Failure Review Form 4

Procedures FORM-2021- Maintenance Rule Failure Review Form 04/29/2021

03477-1

NOP-ER-3004-03 Maintenance Rule Failure Review Form 04/15/2021

NOP-ER-304-03 Maintenance Rule Failure Review Form 05/26/2021

71111.13 Miscellaneous Notification Cooler No. 4 Trbl Locked in on 'B' Main/CR 05/19/2021

601316886

Procedures NOP-OP-1007 Risk Management 34

Inspection Type Designation Description or Title Revision or

Procedure Date

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

71111.15 Corrective Action CR 2020-07313 LPRM 2B-48-49 Found Upscale on APRM E 09/19/2020

Documents CR 2021-01359 LPRM 2B-48-49 Showing Signs of Failing 02/28/2021

CR 2021-01789 Two Main Steam Isolation Valves Failed Stroke Time 03/13/2021

Testing

CR 2021-02560 Control Rod 30-39 had no SCRAM Time Test Report 04/05/2021

Following SCRAM

CR 2021-02974 LPRM 2B-48-49 Showing Signs of Failing 02/28/2021 02/28/2021

CR 2021-02997 Air Leak at Fitting on Lower Airlock 04/16/2021

CR 2021-03134 SVI-E51-T1295A Exceeds MMD Drift Limits 04/20/2021

CR 2021-04087 Cooler No. 4 Trouble Locked in Main Transformer B 05/19/2021

CR 2021-04569 Test Results UNSAT for FLEX Lake Water Pump Motor 06/09/2021

1X11C0001

CR 2021-04577 Flex Lake Water Pump Transformer High Side Meggar 06/09/2021

Readings Below Acceptance Criteria

CR-2021-00128 Multiple Alarms Received Coincident with Annunciator 01/07/2021

System Ground

CR-2021-02562 HCU 10-51 Cannot be Speed Adjusted into Required Band 04/05/2021

(OPE)

Procedures SVI-C71-T1034-A RPS Channel A Logic System Functional Test 13

SVI-C71-T1034-C RPS Channel C Logic System Functional Test 13

Work Orders WO 200849416 Received One Half SCRAM A/C (1H13-P680-5A-A9) and 04/20/2021

RPS Neutron Mon Trip

71111.18 Engineering ECP 16-0039-010 Elimination of the Drain Appendage Attached to 1

Changes 1B33F0067B in the B33 Reactor Recirculation System

71111.19 Work Orders WO 200605202 DIV1 Diesel Hx ESW Relief 03/25/2021

WO 200718562 Replace Relays 1E22K0900/K0901 04/14/2021

WO 200845838 LPRM 2B-48-49 03/01/2021

WO 200846416 Received 1/2 SCRAM A/C (1H13-P680-5A-A9) and RPS 04/16/2021

Neutron Mon Trip

WO 200848119 Replace Both SRI Switches and Fuses On 1CD3029 04/01/2021

WO 200848382 Rev 1 EP-123/EP-121 & Pencil Filters 04/07/2021

WO 200851504 TB/HB Post-Accident Radiation Monitor No Sample Flow CR 05/07/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

21-03618

71111.20 Corrective Action CR 2019-02848 Damaged Spring Cans on 1B33F0060A HPU Supply and 03/27/2019

Documents Return Lines

CR 2021-01597 Leak from Seal Area of RHR Pump 'B' 03/07/2021

CR 2021-02217 Drywell Floor Drain Sump Pump 'A' has Low Flow 03/25/2021

Engineering EC 21-0070-001 Coupling Hub Check Nut Modification for RFPT 'A' Pump 0

Changes Shaft

Engineering GAI Report 2329 Control of Heavy Loads Study 2

Evaluations

Miscellaneous 8020 VMT 1F- Technical Manual for Vertical RHR Pump 02/27/1979

7830 (238 RHR)

Procedures GMI-0185B Reactor Vessel Assembly 20

ISI-B21-T1300-1 Reactor Coolant System Leakage Pressure Test 04/03/2021

PTI-GEN-P0012 Total Water Leakage Rate of Primary Coolant from Systems 6

Outside Containment

Radiation 200848382 CR 58-35 Insert Speed Too Slow, Replace EP-123 04/07/2021

Surveys

Work Orders WO 200718562 Replace Relays 1E22K0900/K0901 04/14/2021

WO 200779551 Remove and Install Blind Flange of the Incline Fuel Transfer 04/05/2021

Tube

WO 200802566 Received Multiple Alarms Coincident with Annunciator 01/07/2021

System Ground

WO 200845838 LPRM 2B-48-49 03/01/2021

WO 200849416 Received One Half SCRAM A/C (1H13-P680-5A-A9) and 04/16/2021

RPS Neutron Mon Trip

71111.22 Procedures PTI-C11-P0010 Control Rod Speed Adjustment 04/05/2021

SVI-B21-T0137A ECCS Drywell Pressure High Channel 'A' Functional for 04/22/2021

1B21-N694A

SVI-B21-T0369-B SRV and Low-Low Set Pressure Actuation Channel 05/25/2021

Functional for 1B21-N668B

SVI-C51-T0030A APRM 'A' Channel Calibration for 1C51-K605A 13

SVI-F42-T8205 Type C Local Leak Rate Test of 1F42 Penetration P205 6

Penetration Piping and Drain Valve

SVI-P11-T9111 Type C LLRT of Condensate Return 1P11 Penetration P111 17

Inspection Type Designation Description or Title Revision or

Procedure Date

SVI-P53-T7305 Lower Containment Airlock Pneumatic System Leak Test, 17

Pen 305

SVI-P53-T7305 Lower Containment Airlock Pneumatic System Leak Test, 05/15/2021

Pen 305

SVI-R43-T1318 Diesel Generator Start and Load Division 2 26

Work Orders WO 200754001 Accident Monitoring and Remote Shutdown Channel Checks 04/23/2021

WO 200773730 Bkr EH1206 Exercise and Service (CCCW B) 06/28/2021

71151 Miscellaneous Narrative Logs 06/24/2021

2