IR 05000440/2022003

Integrated Inspection Report 05000440/2022003

ML22311A540
Person / Time
Site:	Perry
Issue date:	11/08/2022
From:	Billy Dickson NRC/RGN-III/DORS/RPB2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2022003
Download: ML22311A540 (1)

Text

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2022003

Dear Mr. Penfield:

On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On October 26, 2022, 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.

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 Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440

License Number: NPF-58

Report Number: 05000440/2022003

Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Inspection Dates: July 01, 2022 to September 30, 2022

Inspectors: V. Myers, Senior Health Physicist T. Ospino, Resident Inspector J. Steffes, Senior Resident Inspector

Approved By: Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety

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 at full power. On August 8, 2022, reactor power was lowered to 46 percent to facilitate work on the "C" hotwell pump suction strainer due to indications of degrading performance. The Unit was returned to full power on August 9, 2022.

On August 20, 2022, reactor power was lowered to 47 percent to facilitate work on the "A" hotwell pump suction strainer due to similar indications of degrading performance. The Unit was returned to full power on August 22, 2022. On September 17, 2022, reactor power was lowered to 63 percent to perform rod sequence exchange. The Unit was restored to full power on September 23, 2022. On September 24, 2022, reactor power was lowered to 76 percent to perform rod pattern adjustment. The Unit was returned to full power operations on September 25, 2022. The Unit remained at or near full power for the remainder of the inspection period with several exceptions. Specifically, on several occasions, power was reduced between 1 and 16 percent ranging from a few hours to several days due to environmental conditions.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated summer readiness for seasonal extreme weather conditions prior to the onset of hot weather on July 5, 2022

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1) Division 2 diesel generator on August 18, 2022

(2) Division 1 diesel generator on August 23, 2022

(3) Residual heat removal C system on August 31, 2022

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

(1) The inspectors evaluated system configurations during a complete walkdown of the reactor core isolation system on August 12 to September 23, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) Unit 1 Division 2 cable spreading, 125-volt direct current distribution and battery rooms, 638' elevation on July 6, 2022

(2) Unit 1 Division 1 cable spreading room, 638' elevation on July 29, 2022

(3) Auxiliary building, 599' elevation on August 11, 2022

(4) Emergency diesel generator-1 room on September 6, 2022

(5) Unit 2 switchgear, 620 elevation on September 7, 2022

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 power reduction for work on the "C" hotwell pump suction strainer on August 8, 2022

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

(1) The inspectors observed and evaluated licensed crew performance in the simulator on August 1, 2022

(2) The inspectors observed and evaluated licensed crew performance in the simulator on August 8, 2022

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

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

(1) "A" reactor water cleanup pump leak into the nuclear closed cooling system on August 3, 2022

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) Emergent work related to fire protection jockey pump continuous running, as documented in Condition Report (CR) 2022-05084 on July 7, 2022

(2) Emergent work related to the Division 1 diesel generator fuel oil leak, as documented in CR 2022-05733 on July 23, 2022

(3) Emergent work on "B" residual heat removal system on July 29, 2022

(4) Plant risk assessment while unit 2 startup transformer disconnected from Division 2 emergency bus for maintenance on August 11, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

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

(1) Division 1 diesel generator fuel oil leak on July 23, 2022

(2) Drywell unidentified leakage increase due to shift in drywell cooling trains, as documented in CR 2022-06077

(3) Hydraulic oil spill into the suppression pool, as documented in CR 2022-07165

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 configuration change to the facility:

(1) Review of the disconnect linear velocity transducer on B33 flow control valve A ECP on September 13-26, 2022

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

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

(1) Direct current bus supply breaker D1A05 replacement from July 15 to August 2, 2022

(2) Rod control and information system amplifier card BJM-32 replacement on September 12, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (4 Samples)

(1) Rod control system on June 25, 2022

(2) Automatic depressurization system A air storage tank pressure calibration on July 12, 2022

(3) Residual heat removal heat exchangers B testing review on August 30, 2022

(4) Instrument air valve operability test in accordance with work order 200814641 on August 15, 2022

Inservice Testing (IP Section 03.01) (1 Sample)

(1) "A" emergency service water system on August 15, 2022

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) Hostile Action Base drill on September 27,

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,

& Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling and securing radioactive materials in the following areas:

(1) Waste abatement and reclamation facility

(2) On-site storage area

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:

(1) Avantech processing equipment

(2) Resin liner filling and dewatering equipment

Waste Characterization and Classification (IP Section 03.03) (2 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1) Condensate backwash

(2) Spent resin

Shipping Records (IP Section 03.05) (3 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) 22-1024; Condensate backwash as LSA-II

(2) 22-1023; Spent resin as LSA-II

(3) 21-1011; Dry active waste as LSA-II

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===

(1) Unit 1 (April 1, 2022 through March 31, 2022)

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) Unit 1 (April 1, 2022 through March 31, 2022)

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) Unit 1 (April 1, 2022 through March 31, 2022)

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) Unit 1 (October 1, 2021 through June 30, 2022)

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

(1) October 1, 2021 through June 30, 2022

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) October 1, 2021 through June 30, 2022

71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)

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

(1) Reactor recirculation bi-stable events between September 12, 2021 to September 12, 2022

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) Jockey fire pump challenges on July 8,

INSPECTION RESULTS

Observation: Reactor Recirculation Bi-Stable Events 71152A During the corrective action program review, the inspectors noted nine bi-stable events recorded from May 18, 2022, to August 31, 2022. A bi-stable event results from oscillations in reactor core flow which cause power changes absent operator demand. The inspectors' review identified three primary power monitors affected by the bi-stable events; average power range monitors "A," "D," and "E." The inspectors reviewed licensee actions, procedural requirements, and decisions to ensure operational bias did not translate into misdiagnosed unplanned power changes. The inspectors discussed with licensee management the conditions surrounding each instance to gain a better understanding of the events, the licensees implementation of IOI-3, "Power Changes," Attachment 2, which was used to process bi-stable events and challenged licensee conclusions not to enter ONI-C51, "Unplanned Change in Reactor Power or Reactivity," which directs licensee action during associated events.

Following review, the inspectors concluded that the power changes were localized to singular average power range monitors and because changes in flow due to recirculation pump changes or flow control valves were not observed, the changes in power were likely the result of bi-stable events. The inspectors reviewed the licensee's event analysis and engaged staff to understand better the drivers behind bi-stable events and licensee actions to address the issue. The inspectors determined that two likely contributors existed associated with the bi-stable events. Firstly, complex and complicated thermo-hydraulic interactions in the core late in core life due to fuel burnup and the position of jet pumps that create vortex flow anomalies could reasonably account for the observed phenomenon. At the end of the inspection period, the inspectors continued to follow the issue disposition and committed to monitoring for any further changes. The inspectors did not identify any findings or violations associated with this review.

Observation: Fire Protection System 71152S The inspectors performed a semiannual trend review of the licensee's corrective action program for the first and second quarters of 2022. The inspectors noted an increasing trend in issues associated with the fire protection systems, specifically the jockey fire pump. Based upon their initial review and to better inform their inspection results, the inspectors expanded their scope to include issues noted in late 2021. The inspectors focused on equipment performance, maintenance practices, and issue resolution. The inspectors reviewed multiple conditions reports (CRs) associated with the jockey fire pump, including, but not limited to, CR 2021-05505, "Jockey Fire Pump Degraded Cycle Times," CR 2021-09579, "Jockey Fire Pump Has Increased Run Time Indication Possible of Reduced Capability," CR 2022-01447, "Jockey Fire Pump Tripped," CR 2022-05084, and "Jockey Fire Pump Continuously Running."

The inspectors concluded that the licensee had addressed each corrective action program instance of degraded performance associated with the jockey fire pump. The inspectors further noted challenges to overall fire protection system performance associated with the diesel fire pump, the motor-driven fire pump, the system's discharge check valve performance, and system leaks. The inspectors were concerned that challenges to overall system health and degraded components could present unidentified challenges to jockey fire pump functionality and performance. The inspectors raised their concerns with licensee management, who agreed that unidentified trends in system performance and system integrated response could contribute to degrading system health and challenge response to on-site fires. The inspectors noted that the licensee took action to holistically review system health and created an action plan to address system and component performance. The inspectors continued to follow licensee action to address the issues through the end of the quarter. The inspectors did not identify any findings or violations associated with this review.

EXIT MEETINGS AND DEBRIEFS

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

On October 26, 2022, the inspectors presented the integrated inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

On September 15, 2022, the inspectors presented the radiation protection inspection results to Mr. C. Elliott, General Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Miscellaneous Summer list Summer Work List 01/01/2022 - 07/01/2022 7/5/2022

71111.04 Procedures SOI-E12 Residual Heat Removal System 8/31/2022

VLI-E12 Valve Lineup Instruction - Residual Heat Removal System 8/31/2022

VLI-R44 Division 1 and 2 Diesel Generator Starting Air System 6

VLI-R44/E22B Division 3 Diesel Generator Starting Air System 10

VLI-R45 Division 1 and 2 Diesel Generator Fuel Oil System 5

VLI-R45/E22B Division 3 Diesel Generator Fuel Oil System 3

VLI-R46 Division 1 and 2 Diesel Generator Jacket Water Systems 4

VLI-R46/E22B Division 3 Diesel Generator Jacket Water System 6

VLI-R47 Division 1 and 2 Diesel Generator Lube Oil 7

VLI-R47/E22B Division 3 Diesel Generator Lube Oil System 4

VLI-R48 Division 1 and 2 Diesel Generator Exhaust, Intake and 6

Crankcase Systems

71111.05 Corrective Action ATA-2022-15646 DCR FPI-OCC 9/13/2022

Documents

Corrective Action ATA-2022-12557 Recommending Enhancement to FPI-0CC for Unit 2 7/14/2022

Documents Division2 Cable Spreading Room, 125 Volt DC Distribution

Resulting from Room and Battery Room 638'-6" (See Marked Up

Inspection Attachment) During Next Revision

CR 2022-05380 NRC Identified Housekeeping Concerns in Control Complex 7/7/2022

Unit 2 Div1 & Div2 Cable Spreading Areas

Fire Plans 1DG-1C Unit 1 - Division 1 Diesel Generator Building 6206 and 9/6/2022

646 6

2CC-3a, 3b, 3c, Unit 2 - Division 1,2,3 4160 V & 480 V Switchgear, 9/7/2022

3d Communications Room, Radiation Protection Offices and

RRA Access Facility 620 6 Elev

FPI-0CC Control Complex 12

Procedures FPI-1AB Auxiliary Building Unit 1 4

71111.11Q Miscellaneous Cycle 202209 Cycle 202209 Evaluation Scenario Guide Lesson Plan 8/1/2022

Evaluation Number OTLC 3058202209-PY-SGC1

Scenario Guide

Evolution Specific Perry Nuclear Power Plant August 2022 Hotwell Pump 0

Inspection Type Designation Description or Title Revision or

Procedure Date

Reactivity Plan Maintenance

OTLC-Cycle 202209 Evaluation Scenario Guide 0

3058202209_PY-

SGC1

71111.12 Corrective Action 2022-05992 Nuclear Closed Cooling Liquid Process Radiation Monitor 8/3/2022

Documents Steady Rise in Indication

22-06020 Reactor Water Cleanup A Pump Identified as the Source of 8/4/2022

Reactor Water In-Leakage into Nuclear Closed Cooling

71111.13 Corrective Action CR 2022-02534 Div 1 Diesel Generator Injector Pump Leak 3/22/2022

Documents 2022-05084 Jockey Fire Pump Continuously Running 6/23/2022

ATL-2022-0580- NRC Requested the PORC Meeting Minutes that Discussed 7/27/2022

ATA-17 Use of a Jumper for SJAE Work

CR 2022-05733 Division 1 Diesel Generator Left Bank #6 Injector Fuel Oil 7/23/2022

Leak

CR-2022-05473 Steam Leak around SJAE Flow Element Clamp Degraded 7/11/2022

Procedures NOP-OP-1007 Risk Management 37

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

PYBP-POS-2-2 Protected Equipment Postings 13

Work Orders 200850132 Residual Heat Removal "B" to Feedwater Line Flush Check 7/29/2022

Valve

71111.15 Corrective Action 2022-06139 Documentation of Drywell Leakage Rise Search Results 8/9/2022

Documents ATL-2022-0580- NRC Residents Requests a Completed Copy of Div 1 DG 7/25/2022

ATA-07 Fuel Oil Leak Order 200878600

CR 2022-05733 Division 1 Diesel Generator Left Bank #6 Injector Fuel Oil 7/23/2022

Leak

71111.18 Corrective Action CR 2022-02694 Flow Control Valve A Position Fluctuation 3/27/2022

Documents

Engineering ECP-22-0052-Disconnect Linear Velocity Transducer on B33 Flow Control 4/2/2022

Changes 001 Valve A

71111.19 Corrective Action CR 2022-06652 As-Found Breaker Setup Not Correct per 208 Drawing 8/29/2022

Documents

Resulting from

Inspection

Work Orders 200326195 BJM-32 Replace Card or Electrolytic 9/12/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

200461333 Replace Amplifier Card - BLM-32 9/12/2022

200677382 Breaker D1A05 Overhaul 8/3/2022

200813976 Shadow to 200677382 BRK D1A05 Exercise A 8/3/2022

71111.22 Corrective Action 2022-05807 Inadequate Detail and Signatures Found on Work Order 7/26/2022

Documents Walkdown Sheets

ATA-2022-12374 Remove Over Pressurization Step from SVI-P57-T0392A on 7/12/2022

Page 12 of REV 5. (Steps 27,28,29)

CR 2022-04802 Slow Control Rod Movement for Control Rod 34-39 6/11/2022

Procedures PTI-C11-P0010 Control Rod Speed Adjustment 6/25/2022

SVI-C11-T1022 Rod Pattern Control System - Rod Withdrawal Limiter 6/25/2022

SVI-P57-T0392-A ADS A - Safety Related Instrument Air Storage Tank 7/12/2022

Pressure Channel Calibration for 1P57-N024A

Work Orders 200767208 (4Y) RHR Heat Exchangers B and D Performance Testing 8/10/2022

200805602 Emergency Service Water Pump A and Valve Operability 8/16/2022

Test

71114.06 Miscellaneous PNPP ERO Perry 9-27-2022 Evaluated Exercise 9/27/2022

Evaluated

Exercise

Slides Energy Harbor Scenario Slides 8/4/2022

71124.08 Corrective Action CR-2022-01816 Three Radwaste Tanks with the Recycle Line Clogged with 3/7/2022

Documents Resin

CR-2022-03862 Fill Head Stuck on Liner 5/5/2022

Miscellaneous GEL Laboratories Analysis Report for Sample ID 510237001 5/13/2020

GEL Laboratories Analysis Report for Sample ID 526714001 11/25/2020

Procedures HPI-H0005 10 CFR 61 Compliance Sampling Program 5

NOP-OP-5201 Shipment of Radioactive Material-Waste 11

RPI-1301 Movement of Radioactive Material/Waste Outside of 13

Radiologically Controlled Areas

RWI-G51 Solid Radwaste Solidification System 24

Shipping Records 21-1011 Dry Active Waste Shipment 3/21/2021

21-1023 Resin Shipment 6/28/2021

2-1024 Resin Shipment 8/31/2022

71152A Corrective Action CR 2022-04205 Bistable Flow Event 5/18/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents CR 2022-05192 Suspected Bistable Flow Event 6/29/2022

CR 2022-05228 Suspected Bistable Flow Event 6/30/2022

CR 2022-06186 Reactor Recirc Bistable Flow Observed 8/11/2022

CR 2022-06190 Reactor Recirc Bistable Flow Observed 8/11/2022

CR 2022-06247 Reactor Recirc Bistable Flow Observed 8/14/2022

CR 2022-06432 Reactor Recirc Bistable Flow Observed 8/21/2022

CR 2022-06438 Reactor Recirc Bistable Flow Observed 8/21/2022

CR 2022-06715 Reactor Recirc Bistable Flow Observed 8/31/2022

71152S Corrective Action 2022-03205 Fire Protection Jockey Pump Cycle Time Monitoring - 4/12/2022

Documents System Leakage Exceeds 10 Gallons per Minute Workorder

Criteria

22-05084 Jockey Pump Continuously Running 6/23/2022

22-05113 Abnormal Indications for Fire Protection Pressure 6/25/2022

Maintenance Tank

Miscellaneous Plan of action Plan of Action for Operational Challenge 6/24/2022

Work Orders 200813807 Monitor Jockey Pump Cycle Time 4/11/2022

13