IR 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
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, 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:
Report Number:
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
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.
REACTOR SAFETY
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
Procedure
Type
Designation
Description or Title
Revision or
Date
2-0631-00000
Reactor Core Isolation Cooling System
HH
Drawings
2-0632-00000
Reactor Core Isolation Cooling System
ELI-R24
480 Volt MCC
Procedures
VLI-E51
Reactor Core Isolation Cooling System
Corrective Action
Documents
Resulting from
Inspection
CR 2021-04450
NRC ID: NRC Identified Concerns During Walkdown on
Fuel Handling Building 620
06/04/2021
Fuel Handling Building 620-6 Elevation
06/02/2021
FPI-0CC
Control Complex
FPI-0IB
Intermediate Building
FPI-1DG
Diesel Generator Building
OEW-1a
Fire Zone OEW-1a Emergency Service Water Pump House
06/14/2021
OEW-1b
Fire Zone OEW-1b Diagram
06/14/2021
Fire Plans
TP-568 and TP-
26
06/15/2021
Procedures
FPI-A-C01
Fire Protection Program Control Processes (Hot Work
Permits, Transient Combustible Permits, Impairment
Permits, and Fire Watches)
Calculations
JL-61
Auxiliary Building Flooding Analysis
OIO-001
Cold Startup
Miscellaneous
OTLC-
3058202102_PY-
SGC1
Simulator Evaluation Scenario Cycle 2
05/10/2021
Miscellaneous
NOP-ER-3004-03
Maintenance Rule Failure Review Form
FORM-2021-
03477-1
Maintenance Rule Failure Review Form
04/29/2021
NOP-ER-3004-03
Maintenance Rule Failure Review Form
04/15/2021
Procedures
NOP-ER-304-03
Maintenance Rule Failure Review Form
05/26/2021
Miscellaneous
Notification
601316886
Cooler No. 4 Trbl Locked in on 'B' Main/CR
05/19/2021
Procedures
NOP-OP-1007
Risk Management
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PAP-1924
Risk-Informed Safety Assessment and Risk Management
CR 2020-07313
LPRM 2B-48-49 Found Upscale on APRM E
09/19/2020
CR 2021-01359
LPRM 2B-48-49 Showing Signs of Failing
2/28/2021
CR 2021-01789
Two Main Steam Isolation Valves Failed Stroke Time
Testing
03/13/2021
CR 2021-02560
Control Rod 30-39 had no SCRAM Time Test Report
Following SCRAM
04/05/2021
CR 2021-02974
LPRM 2B-48-49 Showing Signs of Failing 02/28/2021
2/28/2021
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
1X11C0001
06/09/2021
CR 2021-04577
Flex Lake Water Pump Transformer High Side Meggar
Readings Below Acceptance Criteria
06/09/2021
CR-2021-00128
Multiple Alarms Received Coincident with Annunciator
System Ground
01/07/2021
Corrective Action
Documents
CR-2021-02562
HCU 10-51 Cannot be Speed Adjusted into Required Band
(OPE)
04/05/2021
SVI-C71-T1034-A
RPS Channel A Logic System Functional Test
Procedures
SVI-C71-T1034-C
RPS Channel C Logic System Functional Test
Work Orders
Received One Half SCRAM A/C (1H13-P680-5A-A9) and
RPS Neutron Mon Trip
04/20/2021
Engineering
Changes
ECP 16-0039-010
Elimination of the Drain Appendage Attached to
1B33F0067B in the B33 Reactor Recirculation System
DIV1 Diesel Hx ESW Relief
03/25/2021
Replace Relays 1E22K0900/K0901
04/14/2021
03/01/2021
Received 1/2 SCRAM A/C (1H13-P680-5A-A9) and RPS
Neutron Mon Trip
04/16/2021
Replace Both SRI Switches and Fuses On 1CD3029
04/01/2021
Rev 1 EP-123/EP-121 & Pencil Filters
04/07/2021
Work Orders
TB/HB Post-Accident Radiation Monitor No Sample Flow CR 05/07/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-03618
CR 2019-02848
Damaged Spring Cans on 1B33F0060A HPU Supply and
Return Lines
03/27/2019
CR 2021-01597
Leak from Seal Area of RHR Pump 'B'
03/07/2021
Corrective Action
Documents
CR 2021-02217
Drywell Floor Drain Sump Pump 'A' has Low Flow
03/25/2021
Engineering
Changes
EC 21-0070-001
Coupling Hub Check Nut Modification for RFPT 'A' Pump
Shaft
Engineering
Evaluations
GAI Report 2329
Control of Heavy Loads Study
Miscellaneous
20 VMT 1F-
7830 (238 RHR)
Technical Manual for Vertical RHR Pump
2/27/1979
GMI-0185B
Reactor Vessel Assembly
ISI-B21-T1300-1
Reactor Coolant System Leakage Pressure Test
04/03/2021
Procedures
PTI-GEN-P0012
Total Water Leakage Rate of Primary Coolant from Systems
Outside Containment
Radiation
Surveys
200848382
CR 58-35 Insert Speed Too Slow, Replace EP-123
04/07/2021
Replace Relays 1E22K0900/K0901
04/14/2021
Remove and Install Blind Flange of the Incline Fuel Transfer
Tube
04/05/2021
Received Multiple Alarms Coincident with Annunciator
System Ground
01/07/2021
03/01/2021
Work Orders
Received One Half SCRAM A/C (1H13-P680-5A-A9) and
RPS Neutron Mon Trip
04/16/2021
PTI-C11-P0010
Control Rod Speed Adjustment
04/05/2021
SVI-B21-T0137A
ECCS Drywell Pressure High Channel 'A' Functional for
04/22/2021
SVI-B21-T0369-B
SRV and Low-Low Set Pressure Actuation Channel
Functional for 1B21-N668B
05/25/2021
SVI-C51-T0030A
APRM 'A' Channel Calibration for 1C51-K605A
SVI-F42-T8205
Type C Local Leak Rate Test of 1F42 Penetration P205
Penetration Piping and Drain Valve
Procedures
SVI-P11-T9111
Type C LLRT of Condensate Return 1P11 Penetration P111
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SVI-P53-T7305
Lower Containment Airlock Pneumatic System Leak Test,
Pen 305
SVI-P53-T7305
Lower Containment Airlock Pneumatic System Leak Test,
Pen 305
05/15/2021
SVI-R43-T1318
Diesel Generator Start and Load Division 2
Accident Monitoring and Remote Shutdown Channel Checks 04/23/2021
Work Orders
Bkr EH1206 Exercise and Service (CCCW B)
06/28/2021
71151
Miscellaneous
Narrative Logs
06/24/2021