IR 05000440/2021013
| ML22005A330 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/10/2022 |
| From: | Billy Dickson NRC/RGN-III/DRP/B2 |
| To: | Penfield R Energy Harbor Nuclear Corp |
| References | |
| IR 2021013 | |
| Download: ML22005A330 (13) | |
Text
SUBJECT:
PERRY NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2021013
Dear Mr. Penfield:
On December 14, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Perry Nuclear Power Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
January 10, 2022 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-2021-013-0018
Licensee:
Energy Harbor Nuclear Corp.
Facility:
Perry Nuclear Power Plant
Location:
Perry, OH
Inspection Dates:
November 15, 2021 to December 14, 2021
Inspectors:
V. Meghani, Reactor Inspector
G. O'Dwyer, Reactor Engineer
T. Ospino, Resident Inspector
R. Ruiz, Project Engineer
J. Steffes, Senior 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 a biennial problem identification and resolution 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.
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.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Division I and II emergency diesel generators.
Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness:
The inspectors assessed the licensees corrective action program (CAP) and its effectiveness in identifying, prioritizing, evaluating, and correcting problems. Based on the samples reviewed, the team determined that the licensees performance in these areas adequately supported nuclear safety.
Problem Identification:
Overall, the licensee effectively identified issues at a low threshold and correctly entered them into the CAP as required by Fleet procedures. The inspectors determined that the station was generally effective at identifying trends that could potentially impact nuclear safety. The inspectors also performed plant walkdowns of various areas/systems important-to-safety, including the division 1 and division 2 emergency diesel generators (EDGs) and the service water pump house. For the samples reviewed, the inspectors did not identify any regulatory issues of concern in the area of problem identification.
Regarding problem identification, the team identified three examples of the inconsistent use of the repair tag process outlined in procedure NOP-WM-1003, Nuclear Maintenance Notification Initiation and Screening, which could adversely affect the staffs ability to enter issues into the CAP appropriately. These examples included: a known minor leak on a safety-related valve which had a catch-container installed but no repair tag present; a repair tag hanging in the division 2 EDG room for a condition that maintenance staff had already fixed; and a known oil leak on the division 2 EDG starting air compressor that had no repair tag, whereas a nearly identical leak on the division 1 EDG stating air compressor had a repair tag. Although such inconsistencies are not prohibited by procedure under specific circumstances (such as a prevailing desire to preclude the tags from becoming foreign material), if prevalent, such inconsistent use of the repair tag process could result in a situation where staff may fail to enter conditions into the CAP based on assumptions made in the field that an issue may already be known and entered into the CAP when its not.
Problem Prioritization and Evaluation:
In-depth reviews of a risk-informed sampling of condition reports (CRs), work orders (WOs),and causal evaluations were completed, including a 5-year review of CAP issues and trends associated with the division 1 and division 2 EDGs. The inspectors concluded that the licensee generally prioritized and evaluated issues for resolution appropriately commensurate with their safety significance.
Corrective Actions:
The team concluded that the licensee was generally effective in developing corrective actions (CAs) that were appropriately focused on correcting the identified problem and correcting conditions adverse to quality. The team reviewed a sample of CA assignments developed for selected NRC documented violations, selected licensee event reports, licensee self-assessments, and licensee-identified issues. Based on the samples reviewed, the team determined that the licensee adequately implemented corrective actions.
Operating Experience, Self-Assessments and Audits:
The inspectors assessed the effectiveness of the stations processes for the use of operating experience, audits, and self-assessments. Based on the samples reviewed, the team determined that the licensee's performance in these areas adequately supported nuclear safety.
Safety Conscious Work Environment:
The team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed a representative cross-section of station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, workers at the Perry plant expressed freedom to raise and enter safety concerns through any of the various avenues available. The team encountered no indications of chilling or retaliation. Finally, all plant personnel interviewed were aware of the Employee Concerns Program (ECP) and expressed a willingness to use it as an avenue to raise concerns, if desired.
The team communicated two observations based on comments received during interviews.
The first observation was regarding a supervisor who expressed a lack of clear understanding concerning the initial categorization of issues as adverse to quality versus Non-adverse to quality. Although this was only one individual, given their position as a supervisor, this lack of clarity may extend to their workgroup. Additionally, a lack of clarity in this area could lead to instances where the Management Review Board is challenged as the barrier to catch potential categorization errors in condition reports. The team did not identify any such instances through its reviews. During its follow-up, the team also learned that plant leadership already knew of this topic, and actions were underway to address the categorization clarification area.
The second observation is related to a theme of comments that the team received throughout many of the interviews regarding workforce staffing levels. Specifically, the team encountered a high percentage of comments regarding workforce staffing levels being notably lower than in the past with the same amount of work existing, resulting in longer hours, more overtime, and lowering morale. Industry operating experience has shown that sustained low workforce morale and resource pressures can reduce the quality of work, which can lead to future events or challenges to regulatory limits. Additionally, such sustained pressures can exacerbate the effect of driving staff out of an organization. During its follow-up, the team recognized that this topic was already known by plant leadership and is a focus area with actions being taken. Although the inspection team did not identify any such instances of regulatory challenges, the Resident Inspectors will continue to track and monitor station performance for any potential impacts on safety margin or regulatory limits.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On December 14, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Rod Penfield, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ATA-2021-4992
Pre-NRC Inspection on Problem Identification & Resolution
04/01/2021
ATL-2018-0166-
ATA-150
CR 2020-08686 will be Included in the Electrical Training
Program for Electrical Safety
2/17/2021
CA-2020-08383-
001
Label the Sewage Pump House Quincy 400 AMP Disconnect
Switch with a Warning Sign
2/16/2020
CA-2020-08383-
2
Replace the Quincy Feed Cable from Pole 9525
2/05/2021
CR-2019-01671
Main Generator/Main Turbine Trip Resulting in a Reactor
2/25/2019
CR-2019-02529
Request to Use Longer Bolt or Heli Coil to Repair
1B21F0022A Control Air Pack Mounting
03/19/2019
CR-2019-02533
B21-029B Failed Leak Rate Test
03/19/2019
CR-2019-02796
Threads Damaged During Air Blow of "C" inboard MSIV
03/25/2019
CR-2019-02861
Oil Leaking from Outboard MSIV D
03/27/2019
CR-2019-02939
Inboard MSIV 'D' 1B21F0022D Slow Speed Adjustment
Found Damaged
03/29/2019
CR-2019-03273
High Main Generator Casing Liquid Level Requires Manual Trip of Main Turbine
04/07/2019
CR-2019-05852
General Causal Evaluation for Proper Categorization of
Previous CRs and Associated Maintenance Rule Applicability
07/11/2019
CR-2020-00032
Error Identified in USAR Section 9A.4.23.5 (Unit 2 Turbine
Building Fire Hazards Analysis)
01/03/2020
CR-2020-00284
PY-PTI-R50-P0001 Portion Failure Due to E-plan 5-way
Notification Line Not Connecting to All Parties
01/15/2020
CR-2020-00611
Cause Evaluation: Issue identified with the RCIC Turbine
Mechanical Overspeed Trip While Performing Overspeed
Trip Testing
01/26/2020
CR-2020-00622
RCIC Waterleg Pump Vertical Velocity Vibration Reading is
in the Alert Range
01/26/2020
CR-2020-00623
Alarm Wouldn't Clear Div 2 DG
01/26/2020
Corrective Action
Documents
CR-2020-00843
Combustible Gas Mixing Compressor Tripped on Degraded
Thermal Overloads.
2/04/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2020-01878
Potential Past Operability Concerns with Combustible Gas
Mixing Compressor B
11/01/2019
CR-2020-02630
Drawing 302-730 has an Incorrect "Fails Open" Annotation
for Solenoid Control Valve 0G50F057 (Seal Water to Floor
Drain Filtrate Pump)
03/25/2020
CR-2020-02939
Perry 3 Minute Audible Test Not Performed Per County
Request
04/06/2020
CR-2020-03062
Emergency Notification System Phone (Red Phone) is not
Working
04/10/2020
CR-2020-03770
Div 2 DG Fuel Oil Press Low Alarm
04/28/2020
CR-2020-04340
MS-C-20-05-07: Record Copy of Work Order Missing
Signature for Submitting As-Built Drawings
05/18/2020
CR-2020-04341
MS-C-20-05-07: Record Copy of Work Order Missing
Signature for Document Verification
05/18/2020
CR-2020-04439
MS-C-20-05-07: Procedure Approval Form Administrative
Discrepancies - Maintenance
05/21/2020
CR-2020-04440
Review of 21 completed Procedure Approval Form Record
Packages (Quality Records) Identified Discrepancies
05/18/2020
CR-2020-04686
Received Aux. Building and Steam Tunnel Cooling HVAC
Trouble
05/30/2020
CR-2020-04955
Concrete Spalling and Leakage in Emergency Service Water
Pump House, 586' Elevation
06/09/2020
CR-2020-06467
ERO Drill - Unplanned Controller Injects Performed During
the 8/12/2020 Dry Run Drill
08/12/2020
CR-2020-06471
ERO-Drill: Timeliness of General Emergency Classification
During 8/12/2020 Dry Run Drill
08/12/2020
CR-2020-07230
NRC EPlan Drill - Objective F.18 Met with Comments due to
Shortfalls in Rigor Regarding Communication Standards.
09/15/2020
CR-2020-07231
Cause Evaluation: NRC EPlan Drill Objective F6 for Dose
Assessment, Not Met
09/16/2020
CR-2020-08383
General Causal Evaluation for Live Electrical Cable Identified
During Work being Performed
10/28/2020
CR-2020-08383-
ATA-01
Threat Assessment of Outbuildings for Safety Issues
03/19/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2020-09635
(MPFF) - Combustible Gas Mixing Compressor Suction
Valve Would Not Reopen Following Compressor Start
2/22/2020
CR-2021-01124
Inconsequential Latent Error Identified in Control Blade
Lifetime Monitoring Software
2/19/2021
CR-2021-01197
Weekly E-Plan Pager Test Did Not Call the Control Room
Shift Manager Notification Device
2/22/2021
CR-2021-01650
(MPFF) - RWCU Pump A and B Failed During 1R18
03/09/2021
CR-2021-01724
Monthly 5 Way Communication Test - Lake County
Equipment Deficiency Identified
03/10/2021
CR-2021-01759
Leakage Rate of 1B21F0028B Outboard MSIV Steam Line B
Exceeds Acceptance Criteria in SVI-B21-T9000
03/12/2021
CR-2021-01759
Leakage Rate Of 1B21F0028B Outboard MSIV Steam Line B
Exceeds Acceptance Criteria In SVI-B21-T9000
03/12/2021
CR-2021-02036
Chain Fall with Incorrect (Short) Pull Chain Rigged to the
Reactor Dry Tube Strong Back
03/20/2021
CR-2021-02292
Second MSIV Accumulator Supply Leaking During ISLT
03/27/2021
CR-2021-02297
SVI-B21-T9000 Step 5.3.5 Acceptance Criteria Not Met
03/27/2021
CR-2021-02894
Cause Evaluation: Reactor Water Cleanup System (RWCU)
Containment Isolation Valves (Penetration (P132)) Issues
04/14/2021
CR-2021-04817
REMP Fish Samples Lost During Transit to Offsite Vendor
06/21/2021
CR-2021-05006
Document ANS Siren L17 Out of Service
06/29/2021
CR-2021-05033
Service Water Building Intake REMP Location # 34 Water
Sampling Pump is Malfunctioning
06/30/2021
CR-2021-05353
General Cause Evaluation for CR-2021-05353, Cycle 18
Maintenance Rule Periodic Assessment Report Identifies
Potential Adverse Trend
07/13/2021
CR-2021-
054082021
DBAI POV Inspection: RCIC Steam Supply Isolation Valves
Questionable Calculation Justification
09/17/2021
CR-2021-05435
Addition - 2021 DBAI POV Inspection: JOG Classification of
RCIC Steam Supply Isolation Valves
07/16/2021
CR-2021-05580
Site Projects Exceeded Annual Dose Budget
07/22/2021
CR-2021-06362
Rad-Cal Standard for Calibrator Verification is Broken
08/23/2021
CR-2021-06976
EPLAN Drill, Near Miss with Incorrect Pager Message for
Unusual Event
09/15/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2021-07221
Hi Fuel Oil Filter Differential Pressure for Division 2 Diesel
Generator
09/26/2021
CR-2021-07223
Div 2 DG Lube Oil Strainer High DP Alarm Coming in During
DG Run
09/26/2021
Corrective Action
Documents
Resulting from
Inspection
CR-2021-09144
NRC Identified: Div 1 DG High Crankcase Pressure Trip
Valve, 1R43N0711A, Leaking from Sensing Line
2/02/2021
Commitment
Change notice
21-023
Closed Commitment L02393 and Changed TS Bases to
Remove Requirement to Restore Leakage Within 25 SCFH
When MSL Leakage Rate Exceeds 100 SCFH
Commitment
L02393
If the Leakage Rate on Any Main Steam Line Exceeds 100
SCFH, the Leakage Rate Will Be Restored to Within 25
SCFH When Tested at > = PA
OE-2020-0072-1
OE468879R20200310 Auxiliary Feedwater System Declared
Inoperable Due to Check Valve Leakage
OE-2020-0255-1
OE485135R20200918 Error in Basis for Emergency Action
Levels for Fission Product Barrier Containment
Radiation/Reactor Coolant System Activity Thresholds
Miscellaneous
OE-2020-0272-1
NRC IN 20-02, Flex Diesel Generator Operational
Challenges
NOBP-LP-2003
Employee Concerns Program
NOBP-LP-2013
Safety Conscious Work Environment Review Team
NOP-LP-2001
Corrective Action Program
NOP-WM-0001
Work Management Process
Procedures
NOP-WM-1003
Nuclear Maintenance Notification Initiation and Screening
ATA-2020-10929
Attached is the Self-Assessment for the 2020 Drill from
8/12/2020
08/12/2020
ATL-2021-0467-
ATA-01
Assessment of Current Primary Strategic Chemistry Plan
07/29/2021
ATL-2021-0521-
ATA-02
Assessment of Emergent Scope of Last Three Refueling
Outages R16, R17 and R18
08/26/2021
Self-Assessments
CR-2020-06562-
ATA-01
Engineering Change Package (ECP) Product Quality
10/22/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
MS-C-20-01-13
Audit: Design Control/Engineering Programs/ASME
03/05/2020
MS-C-20-03-01
Fleet Oversight Audit Report: Audit Area: Operations Audit
03/01/2020
MS-C-20-05-07
Maintenance/Work Management Quality Assurance Audit
6/30/2020
MS-C-20-11-24
Audit: Emergency Preparedness
2/04/2020
MS-C-21-08-03
Quality Assurance Audit Report for Radiation
Protection/Radwaste
09/23/2021
MS-C-21-09-22
21
Quality Assurance Audit Report; Corrective Action Program
10/11/2021
Repair Oil Leak from Shaft Seal on Engine Driven Jacket
Water Coolant Pump
11/22/2016
In 1R18, 1B21-F028B was Found to be Leaking 52.2 SLM
(110.6 SCFH)
04/01/2021
1B21-F0028B Passed on April 1, 2021
04/01/2021
Repair Oil Leak on Air Dryer Tower Pressure Gauge
07/09/2021
Work Orders
Repair Fuel Oil Leak on Diesel Generator Engine Fuel Oil
Pump Mechanical Seal
11/21/2021