IR 05000440/2022004

Integrated Inspection Report 05000440/2022004; and 07200069/2022001 and Exercise of Enforcement Discretion

ML23040A016
Person / Time
Site:	Perry, 07200069   (NPF-058)
Issue date:	02/10/2023
From:	Billy Dickson NRC/RGN-III/DORS/RPB2
To:	Penfield R Energy Harbor Nuclear Corp
References
EA-22-133 IR 2022001, IR 2022004
Download: ML23040A016 (1)

Text

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2022004; AND 07200069/2022001 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Rod Penfield:

On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On January 26, 2023, 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. One Severity Level IV violation without an associated finding is documented in this report. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

A licensee-identified violation which was determined to be Severity Level IV is documented in this report. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

The NRC identified a violation of Title 10 of the Code of Federal Regulations (10 CFR)

72.212 (b)(6) associated with tornado hazard protection. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 22-001, Enforcement Discretion for Noncompliance of Tornado Hazard Protection requirements at Independent Spent Fuel Storage Installations, and because the licensee was implementing compensatory measures and plans to take the necessary actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and is allowing continued ISFSI handling operations.

If you contest the violations or the significance or severity of the violations 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.

February 10, 2023 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, Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000440 and 07200069 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000440 and 07200069

License Number:

NPF-58

Report Numbers:

05000440/2022004 and 07200069/2022001

Enterprise Identifiers: I-2022-004-0051 and I-2022-001-0110

Licensee:

Energy Harbor Nuclear Corp.

Facility:

Perry Nuclear Power Plant

Location:

Perry, OH

Inspection Dates:

October 01, 2022 to December 31, 2022

Inspectors:

J. Bozga, Senior Reactor Inspector

R. Cassara, Resident Inspector, Davis-Besse Nuclear Power Station

R. Edwards, Chief Materials Inspection Branch

N. Egan, Senior Physical Security Inspector

G. Hansen, Senior Emergency Preparedness Inspector

J. Kutlesa, Emergency Preparedness Inspector

J. Nance, Senior Operations Engineer

R. Ng, Senior Project Engineer

T. Ospino, Acting Senior Resident Inspector

D. Sargis, Senior Reactor Inspector

J. Steffes, Senior Resident Inspector

T. Taylor, Senior Resident Inspector, Fermi 2

T. Wingfield, Senior Operations Engineer

Approved By:

Billy C. Dickson, Jr., Chief

Reactor Projects Branch 2

Division of Operating Reactor Safety

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

Zero Profile Transporter Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000440/2022004-01 Open/Closed Not Applicable 60856 The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 72.48(d)(1),

Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to the design of the Holtec HI-STORM FW system did not require a license amendment. Specifically, while implementing the HI-STORM FW system, the licensees calculational verification of the zero profile transporter (ZPT) did not adhere to the design requirements resulting in two changes that could result in uncontrolled movements of the HI-STORM FW overpack during transport potentially impacting the shielding function of the overpack.

LER 2022-002-00, Steam Bypass Valve Demand Limited on the 'B' Train due to a Degraded Signal in the Maximum Combined Flow Limit (MCFL) Circuit Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000440/2022004-02 Open/Closed

[H.4] -

Teamwork 71153 The inspectors identified a Green finding and associated non-cited violation (NCV) for the licensees failure to enter Technical Specification (TS) 3.7.6 in a timely manner when the maximum combined flow limiter (MCFL) In Control light was lit in the Main Control Room on October 7, 2022. Specifically, when the MCFL light was lit in the controlling channel, the main turbine bypass system was inoperable and the licensee did not enter the appropriate TS condition.

LER 2021-002-00, Core Monitoring System Software Modeling Error Results in Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000440/2022004-03 Open/Closed Not Applicable 71153 Licensee Event Report (LER) 2021-002-00, Core Monitoring System Software Modeling Error Results in Condition Prohibited by Technical Specifications (ADAMS Accession No.

ML21216A344). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. This condition, a Severity Level IV NCV of TS 3.2.2, Minimum Critical Power Ratio (MCPR), was self-revealed upon review of operational history and General Electric - Hitachi (GEH) Safety Communication SC 21-04, Revision 1, Fuel Support Side Entry Orifice Meta-Stable for two Beam Locations in the BWR/6 Reactors. Specifically, during periods on Cycles 17, 18, and 19, Technical Specifications Limiting Condition for Operation 3.2.2, Minimum Critical Power Ratio, was not met, the required action A.1 to restore MCPR to within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was not completed, and the subsequent required action B.1 to reduce thermal power to less than 23.8 percent RTP in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> also was not completed.

Additional Tracking Items

Type Issue Number Title Report Section Status EDG EA-22-133 Tornado Hazards Protection Requirements at Independent Spent Fuel Storage Installations 60855 Closed LER 05000440/22-002-00 LER 22-002-00 for Perry Nuclear Power Plant, Steam Bypass Valve Demand Limited on the 'B' Train due to a Degraded Signal in the Max Combined Flow Limit Circuit 71153 Closed LER 05000440/2021-002-00 LER 2021-002-00 for Perry Nuclear Power re Core Monitoring System Software Modeling Error Results in Conditions Prohibited by Technical Specifications 71153 Closed

PLANT STATUS

The plant began the inspection period at full power. On October 31, 2022, plant operators shut down the reactor to facilitate work on the reactor coolant system (RCS) unidentified leakage, due to indications of degrading performance on one of the A recirculation pump seals. Plant operators returned the reactor to full power operations on November 11, 2022. On December 2, 2022, plant operators lowered reactor power to 76 percent to facilitate work for the load line adjustment. Plant operators returned to full power operation by December 3, 2022. On December 18, 2022, plant operators lowered reactor power to 68 percent to perform rod sequence exchange. Plant operators returned the reactor to full power operations on December 19, 2022. The Unit remained at or near full power for the remainder of the inspection period.

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 onsite 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 readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures on December 14, 2022.

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

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding during the week ending December 17, 2022.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (8 Samples)

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

(1)

"A" control room HVAC and emergency recirculation system on October 7, 2022 (2)

"A" control complex chilled water system on October 8, 2022

(3) Division 1 direct current electrical bus system on October 15, 2022 (4)

"B" train residual heat removal (RHR) system on November 1, 2022 (5)high pressure core spray system while two low-pressure emergency core cooling systems were inoperable for maintenance on November 18, 2022 (6)emergency service water (ESW) A system on November 22, 2022

(7) Division 2 emergency diesel generator (EDG) between November 26 and 28, 2022

(8) RHR "A" alignment on rooms 620 east and aux 574 on November 30, 2022

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

(1) The inspectors evaluated system configurations during a complete walkdown of the low-pressure core spray (LPCS) system on November 29, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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, 679' -6" elevation on November 8, 2022 (2)intermediate building, 682' elevation on November 14, 2022 (3)intermediate building, 665' elevation on November 14, 2022 (4)auxiliary building, 620 -8 elevation on December 20, 2022

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)watertight doors located in the emergency core cooling corridor as flooding barriers on November 29, 2022

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) residual heat exchanger "B" and "D" performance testing

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 annual operating exam and biennial written exam administered from October 10, 2022, through December 2, 2022.

71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance

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

(1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on October 20, 2022.

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

Administration of an Annual Requalification Operating Test The inspectors evaluated 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.

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) (2 Samples)

(1) The inspectors observed and evaluated licensed operator performance in the Control Room during plant startup following a forced outage to correct drywell leakage on November 6, 2022.

(2) The inspectors observed licensed operator performance in the Main Control Room during periods of heightened activity on November 19, 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 October 19, 2022.

(2) The inspectors observed and evaluated licensed crew performance in the simulator on November 9, 2022.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (5 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)review of the identification and addressing of common-cause failures associated with the maximum combined flow limiter (MCFL) challenge on November 18, 2022 (2)review of trending key parameters and conditioning monitoring of the reactor coolant system (RCS) unidentified leakage on November 30, 2022 (3)review of the appropriate working practices for repetitive issues with the alarms in the Division 2 diesel generator on December 6, 2022 (4)review of the EDG starting air compressor foreign material issues, completed the week ending December 17, 2022 (5)review of the periodic assessment of the maintenance rule program for Cycle 18, completed the week ending December 1, 2022

Quality Control (IP Section 03.02) (1 Sample)

The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:

(1)review of the control of quality parts during the maintenance process on the replacement of the control rod drive (CRD) B pump motor on November 21, 2022

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 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)issues related to the Traverse In-Core Probe system (TIP) operations captured in Condition Report (CR) 2022-05976 October 12, 2022 (2)emergent work related to the drywell unidentified leakage increase on October 17, 2022 (3)emergent work and risk associated with the forced shutdown between October 30 and November 11, 2022 (4)emergent work and risk associated with the main turbine manual trip on November 7 and 8, 2022 (5)emergent work and risk associated with reactor control information system challenges during the week of December 18, 2022

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) MCFL system issue on October 7, 2022 (2)drywell atmospheric monitor equipment issue on October 14, 2022 (3)control complex chiller B time delay relay issue on October 17, 2022

(4) Division 1 vital direct current bus tie breaker issue from October 26 to 28, 2022 (5)review of the challenges related to the shutdown switch contacts 11 and 12 found faulty on bucket ED1D07 associated with the remote shutdown control test issue reported in CR 2022-08160 October 27, 2022 (6)reactor core Isolation cooling watertight door functionality review due to the adjustments based on CR 2022-07534 on November 22, 2022 (7)operability review after challenges related to the MCFL and the impact on the bypass valves system on November 29, 2022

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)lower containment airlock 3-way ball valves on November 17, 2022

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site Severe Accident Management Guidelines were updated in accordance with the BWR generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1.

Changes to the Perry Nuclear Power Plant SAMGs were reviewed during the week of November 13, 2022.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (13 Samples)

(1)replacement of the Tefzel seat on the equalizing valves in the lower airlock inner door on June 16, 2022 (2)main generator transformer A maintenance and restoration activities on July 12, 2022 (3)replacement of alarm card number 100120361 as part of the EDG alarm system on August 31, 2022 (4)replacement of control complex CO2 hoses with hydro test on September 7, 2022 (5)

"B" RHR system sump alarm level switch replacement on September 8, 2022 (6)control complex chiller B relay replacement on October 5, 2022 (7)replacement and testing of oil on the CRD B pump during the planned outage on November 11, 2022 (8)replacement of LPCS and RHR "A" Waterleg Pump 1E21C002 on November 17, 2022 (9)review of the drywell (DW) airlock door seal testing and restoration after the forced outage on November 17, 2022 (10)replacement of the relay 1N710330A-1 associated with the circulation water "A" loop on November 22, 2022 (11)replacement of the transformer T8 (part # 100128136) on December 2, 2022 (12)replacement of the logic OR 1R43F0504B (part # 100063407) associated with the Division 2 diesel generator pneumatic logic board functional check system on December 13, 2022 (13)replacement of the Division 2 EDG governor drive coupling insert, completed the week ending December 17, 2022

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated forced outage activities to address drywell unidentified leakage increase activities from October 30 to November 11, 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) (8 Samples)

(1)main turbine bypass valve testing on September 23, 2022

(2) Division 1 EDG on October 4, 2022 (3)traversing in-core probes system on October 11, 2022

(4) Control Room Ventilation Removal test (SVI-M25-T1270B) on October 18, 2022

(5) DW Lower Airlock Leakage test after finishing outage activities on November 7, 2022 (6)review of an instrument air valve operability test on December 13, 2022 (7)

"L" Channel High Pressure Core Spray DW Pressure High Channel Functional test in accordance with Work Order 200818694 on November 8, 2022 (8)quarterly fire alarm testing in accordance with Work Order 200814635 completed on October 24, 2022

Inservice Testing (IP Section 03.01) (2 Samples)

(1) Reactor Core Isolation Cooling Pump and Valve Operability test review, completed on December 13, 2022

(2) RHR Pump C Pump and Valve Operability test review, completed on December 13, 2022

RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Increase in RCS leakage from November 7 to 8, 2022

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Annual test of the 6KW FLEX generators on September 8, 2022

71114.04 - Emergency Action Level and Emergency Plan Changes

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

(1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes:

PY-2020-017-00, Emergency Plan Revision 59, July 13, 2021

PY-2022-001-00, Emergency Plan Revision 60, March 3, 2022 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)licensed operator requalification training evolution on October 19, 2022 (2)emergency response organization tabletop on October 20,

OTHER ACTIVITIES - BASELINE

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

MS08: Heat Removal Systems (IP Section 02.07)===

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

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

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

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

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

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

(1) Unit 1 (October 1, 2021 through September 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)the RCS unidentified leakage from November 21, 2021, to November 21, 2022 (2)annual review of the divisional diesel generator alarms from December 2021 to December 1, 2022

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

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in rework activities since January 1, 2022, that might be indicative of a more significant safety issue.

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 2021-001, Core Monitoring System Software Modeling Error Results in Condition Prohibited by Technical Specifications, (ML21216A344). The inspection conclusions associated with the LER are documented in this report under Inspection Results, Section 71153.

(2) LER 2022-002-00, Steam Bypass Valve Demand Limited on the 'B' Train due to a Degraded Signal in the Max Combined Flow Limit Circuit (ML22339A029). The inspection conclusions associated with the LER are documented in this report under Inspection Results, Section

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===60854 - Preoperational Testing of an ISFSI The inspectors reviewed documents, interviewed plant personnel, and performed in-field observations to assess the licensees preoperational testing of an ISFSI. The inspectors performed an independent assessment to determine whether the licensee had adequately demonstrated its readiness to safely perform ISFSI loading and unloading operations.

Specifically, the inspectors evaluated the following:

(1) Preoperational dry run activities:

The licensee performed preoperational dry run activities, including demonstrating stack-up, movement of a HI-STORM FW to the ISFSI pad, and spent fuel pool operations. The inspectors observed dry run pool operations involving the HI-STORM FW system, and movement of dummy fuel assemblies into an MPC, during the week of October 31, 2022.

(2) Fuel Selection:

The inspectors reviewed cask fuel selection packages to verify that the licensee was loading fuel in accordance with TS 2.1, Fuel to be Stored in the HI-STORM FW MPC Storage System.

60855 - Operation of an ISFSI Operation of an ISFSI===

(1) The inspectors evaluated the licensees independent spent fuel storage installation (ISFSI) cask loading activities from November 8 through November 18, 2022. Specifically, the inspectors observed the following activities:

heavy load movement of transfer cask and multi-purpose canister

closure welding and non-destructive weld evaluations

transfer and transport evolutions

radiological field surveys The inspectors performed walkdowns of the ISFSI pad, including walkdowns of the ISFSI haul path.

The inspectors evaluated the following:

spent fuel selected for loading into dry cask storage during this loading campaign

selected corrective action program documents

selected 72.48 screenings and evaluations 60856 - Review of 10 CFR 72.212(b) Evaluations The inspectors evaluated the licensees compliance with the requirements of 10 CFR 72.212 and 10 CFR 72.48, as well the licensees revised engineering documentation and calculations associated with the HI-STORM FW CoC 072-1032, Amendment 5. Prior to use of a dry cask storage system, the licensee is required to perform written evaluations in accordance with 10 CFR 72.212(b)(5)(i) to establish that the terms, conditions, and specifications of a CoC or an amended CoC have been met. Specifically, from July 14 - November 23, 2022, the inspectors reviewed the 10 CFR 72.212 Evaluations Report for Certificate of Compliance (CoC) 1032, and ECP 21-0001-001, "ISFSI Dry Fuel Storage HI-STORM Transition," including engineering changes and referenced calculations related to:

structural analysis of the zero profile transporter (ZPT)

structural evaluation of the lift yoke, mini lift yoke, and lift yoke extensions

stack-up and MPC transfer seismic analysis

ISFSI pad structural analysis including non-mechanistic tip over analysis

compliance with dose rate limits established in 10 CFR 72.104

tornado missile and fire protection requirements

INSPECTION RESULTS

Enforcement Discretion Enforcement Action EA-22-133: Tornado Hazards Protection Requirements at Independent Spent Fuel Storage Installations 60855

Description:

Upon issuance of U.S. NRC Enforcement Guidance Memorandum (EGM) 22-001 (ML22087A496), dated April 15, 2022, the licensee performed an assessment of all outdoor dry cask storage activities that are not explicitly analyzed for tornado hazards in the cask licensing basis. One configuration was identified by the licensee when a loaded Holtec HI-STORM FW storage overpack was brought out of the fuel building without a lid installed. This configuration is not explicitly analyzed in the HI-STORM FW Final Safety Analysis Report (FSAR). Title 10 of the Code of Federal Regulations (CFR) 72.212 (b)(6),states, in part, that:

the general licensee must:...review the Safety Analysis Report referenced in the CoC [Certificate of Compliance] or amended CoC and the related NRC Safety Evaluation Report prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of earthquake intensity and tornado missiles, are enveloped by the cask design bases considered in these reports. The results of this review must be documented in the evaluation made in paragraph (b)(5) of this section.

Tornado hazards are evaluated in the Holtec HI-STORM FW FSAR Section 2.2.3.e, "Environmental Phenomena and Accident Condition Design Criteria," and Section 12.2.6.2, "Tornado

Analysis.

" These sections of the FSAR do not include an analysis for tornado hazards with the storage overpack lid removed.

Corrective Actions: The licensee entered the issue into its corrective action program to address the actions specified in EGM 22-001. Specifically, the licensee established additional measures that:

1) mitigate tornado hazards, through procedures, during periods of ISFSI handling operations which include:

a.

precluding starting ISFSI handling operations during periods of predicted adverse weather; b.

establishing meteorological monitoring criteria and assigning staff to monitor weather during ISFSI handling operations; c.

describing actions to take if a severe weather hazard is predicted to cease ISFSI handling operations and to place the cask in an analyzed condition; and d.

minimizing the duration of ISFSI handling operations during which ISFSI important to safety structures, systems, and components are in an unanalyzed condition.

2) document that required weather checks are complete prior to the start of ISFSI handling operations 3) document in the CAP a request for the CoC holder to request an amendment within 6 months of the date of the EGM Because the licensee implemented compensatory measures and plans to take necessary actions to restore compliance in accordance with the EGM, the NRC is allowing continued ISFSI handling operations.

Corrective Action References: CR-2022-03637; Evaluation and Implementation of EGM-22-001 at Energy Harbor Sites; April 27, 2022 CR-2022-08592; DCS-NRC Identified Issue: Perry Dry Cask Procedures did not Fully Satisfy the Requirements of EGM 22-001, Enforcement Discretion for Noncompliance of Tornado Hazards Protection Requirements at ISFSIs; November 9, 2022

Enforcement:

Significance/Severity: The inspectors assessed the issue as being of more than minor significance, but not more than Severity Level IV. Consistent with the guidance in EGM 22-001, the NRC is exercising enforcement discretion.

Violation: Title 10 of the Code of Federal Regulations (CFR) 72.212 (b)(6), states, in part, that:

the general licensee must review the Safety Analysis Report referenced in the CoC and the related NRC Safety Evaluation Report, prior to use of the general license, to determine whether or not the reactor site parameters, including analyses of tornado missiles, are enveloped by the cask design bases considered in these reports. The results of this review must be documented in the evaluation made in paragraph (b)(5) of this section.

On April 15, 2022, the licensee did not have a documented evaluation determining whether the reactor site parameters, including analyses of tornado missiles, were enveloped by the cask design bases considered in the safety analysis report. Specifically, the licensee failed to have an analysis for tornado hazards when the loaded storage overpack is outside the fuel building without a lid installed.

Basis for Discretion: Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 22-001, "Enforcement Discretion for Noncompliance of Tornado Hazard Protection requirements at Independent Spent Fuel Storage Installations,"

and because the licensee was implementing compensatory measures and plans to take the necessary actions to restore compliance, the NRC is exercising enforcement discretion by not issuing an enforcement action for the violation and is allowing continued ISFSI handling operations.

Zero Profile Transporter Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000440/2022004-01 Open/Closed Not Applicable 60856 The inspectors identified a Severity Level IV non-cited violation (NCV) of 10 CFR 72.48(d)(1),

Changes, Tests, and Experiments, for the licensees failure to provide a written evaluation describing the basis for determining that the change to the design of the Holtec HI-STORM FW system did not require a license amendment. Specifically, while implementing the HI-STORM FW system, the licensees calculational verification of the zero profile transporter (ZPT) did not adhere to the design requirements resulting in two changes that could result in uncontrolled movements of the HI-STORM FW overpack during transport, potentially impacting the shielding function of the overpack.

Description:

Holtec Report No. HI-2114830, titled, HI-STORM FW Multi-Purpose Canister Storage System Final Safety Analysis Report, Revision 9, is the safety analysis report for the HI-STORM FW. Section 2.0.2 of Holtec Report No. HI-2114830, titled HI-STORM FW Overpack Design Criteria, states, in part, The HI-STORM FW overpack includes both concrete and structural steel parts that are classified as important-to-safety. The concrete material is defined as important-to-safety because of its shielding function. At Perry, the ZPT is used to move a HI-STORM FW overpack loaded with spent fuel from the Fuel Handling Building to the ISFSI pad. The ZPT is classified as not important to safety by the licensee and was not certified with an ASME N-stamp to meet all quality assurance standards of ASME Section III.

The inspectors reviewed Drawing No. 5401, Zero Profile Transporter, Revision 10 which is the design drawing for the ZPT, and Document No. PS-1129, Purchase Specification for the HI-STORM Zero Profile Transporter, Revision 5 which is the purchase specification for the ZPT. Section 4.1 of Document No. PS-1129 states, in part, Structural integrity will be evaluated using ASME Section III, Subsection NF, Class 3, 2001 Edition (for linear structure stress limits) and Appendix F. Section 4.2 of Document No. PS-1129, states, in part, Welds will be evaluated using ASME Section III, Subsection NF, Class 3, 2001 Edition.

The ZPT and its associated connections were evaluated for Level D loading condition. The Level D loading condition addressed the dead load of the ZPT in combination with the safe shutdown earthquake loads of the ZPT. Structural integrity of the not-important-to-safety ZPT is maintained when subjected to the Level D loading by ensuring the ZPT meets ASME Section III, Subsection NF, and Appendix F. However, if ASME Section III, Subsection NF, and Appendix F are not met, then structural integrity of the ZPT is not ensured when subjected to the Level D loading. If the structural integrity of the ZPT is not maintained during the transport of the spent fuel cask, this could result in the uncontrolled movement of the spent fuel cask, potentially impacting the shielding function of the overpack.

As stated above, the licensees calculational verification of the zero profile transporter (ZPT)did not adhere to the design requirements, resulting in two changes that introduced the potential for uncontrolled movements of the HI-STORM FW overpack. The changes were to the fillet weld connection between the ZPT top and bottom plate and the ZPT side shell, and were specific to the

(1) connection acceptance limit, and

(2) limit based on the ultimate tensile strength:

(1) Fillet Weld Connection Acceptance Limit:

Based on PS-1129, Revision 5, the ZPT was evaluated as an ASME Class 3 linear support.

ASME Section III, Subsection NF-3360 (2001 Edition), requires that the design by analysis of Class 3 linear-type supports shall be performed in accordance with ASME Section III, Subsection NF-3320, and NF-3340. ASME Section III, Subsection NF-3324.5 (2001 Edition),requires that the allowable stress limits for fillet welds shall be as specified in Table NF-3324.5(a)-1, titled Allowable Stress Limits for Class 1 Linear-Type Support Welds. ASME Section III, Subsection NF, Table NF-3324.5(a)-1 (2001), provides the stress limits for fillet welds which are based on 0.30 times the minimum tensile strength of weld metal, except shear stress on base metal shall not exceed 0.40 times the yield stress of base metal. The inspectors reviewed ASME Section III, Subsection NF (2001 edition), and Section NF-3324.5, titled, Design of Welded Joints. Section NF-3324.5 states, in part, The rules and stress limits which must be satisfied for welds for any Level A through D Service and Test Loading stated in the Design Specification are those given in NF-3324.5(b) multiplied by the appropriate base material stress limit factor given in Table NF-3523(b)-1 for component supports ASME Section III, Subsection NF, titled Table NF-3523(b)-1 Elastic Analysis Stress Categories and Stress Limit Factors for Class 1, 2, 3, AND MC Linear Type Supports Designed by Analysis Component Supports delineates for Service Level D loading condition to use ASME Section IIII Appendix F.

The inspectors reviewed ASME Section III, Appendix F (2001 Edition), and identified an acceptance limit that was associated with the failure mode based on the shear of the base metal for the fillet welded connection. ASME Section III, Subsection F-1334.2, titled Stresses in Shear (2001 edition), states, in part, The shear stress on the gross section shall not exceed the lesser of 0.72 multiplied times Sy and 0.42 multiplied times Su. In this application Sy is considered the yield strength of the material (structural member) and Su is considered the ultimate tensile strength of the material (structural member). In their review of Calculation No. G58-H-HI-2084138, Structural Analysis of Zero Profile Transporter for Perry, Revision 2, the inspectors noted that the licensee used a Level D acceptance limit of 0.54 multiplied times the ultimate strength of the weld metal/base metal for the fillet welded connection between the ZPT top and bottom plate and the ZPT side shell, in lieu of 0.42 multiplied times the ultimate strength of the base metal.

(2) Limit Based on the Ultimate Tensile Strength:

ASME Section III, Subsection NF, Table NF-3324.5(a)-1, provides an acceptance limit of 0.30 times the minimum tensile strength of weld metal for Level A. Calculation No. G58-H-HI-2084138, Revision 2 used acceptance limits for the Level A (dead load of ZPT)loading condition based on 0.3 multiplied times the minimum tensile strength of the base metal for Level A. The licensee also used the strength of the base metal in lieu of the weld metal for Level D limits which was a change to the design requirements of the ZPT.

The inspectors were particularly concerned with whether the two changes would result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety, specifically the HI-STORM FW overpack, and hence require a license amendment per 10 CFR 72.48(c)(2). NEI 96-07, Guidelines for 10 CFR 72.48 Implementation, Appendix B, dated March 5, 2001, endorsed by the NRC in Regulatory Guide 3.72, Guidance for Implementation of 10 CFR 72.48, Changes, Tests, and Experiments, March 2001, provides industry guidance on complying with the provisions of 10 CFR 72.48. The two issues described above are consistent with the definition of a change; in 10 CFR 72.48 and the NEI 96-07, Appendix B, guidance states, the definition of change includes modifications of an existing provision (e.g., SSC design requirement, analysis method, or parameter)to the ISFSI facility or spent fuel storage cask design or procedures. Pertinent guidance when evaluating the impact a not-important-to-safety component has on the design function of an important to safety component includes the following:

a.

Section B4.3.2 of NEI 96-07 states, in part, the term malfunction of an SSC important to safety refers to the failure of structures, systems, and components (SSCs) to perform their intended design functions - including both important to safety (ITS) SSCs and not-important to safety (NITS) SSCs when the failure of the NITS SSCs to perform their design functions could affect the ability of the ITS SSCs to perform their design function.

b.

Section B4.3.2 of NEI 96-07 states, changes in design requirements for earthquakes, tornados, and other natural phenomena should be treated as potentially affecting the likelihood of malfunction. Although this criterion allows minimal increases, licensee must still meet applicable regulatory requirements and other acceptance criteria to which they are committed (such as contained in Regulatory Guides and nationally recognized industry consensus standards, e.g., the ASME BPV Code and IEEE standards). Further, departures from the design, fabrication, construction, testing, and performance standards as outlined in the General Design Criteria ([Subpart] F to Part 72) are not compatible with a no more than minimal increase standard.

The licensee screened the engineering changes to implement the Holtec HI-STORM FW system at Perry in 10 CFR 72.48 Screen No. 22-00572, ISFSI Dry Fuel Storage HI-STORM FW Transition, dated November 1, 2022. In the screening, the licensee concluded that Calculation No. G58-H-HI-2084138, Revision 2, demonstrate structural integrity of the ZPT per the ASME Boiler and Pressure Vessel Code (BPVC),Section III, Division 1, Subsection NF criteria. Furthermore, the licensee concluded the results/conclusions of these calculations confirm that using the existing ZPT does not represent an adverse change to the design functions of the FW system. As such, use of the ZPT ancillaries for the HI-STORM FW system screens out from further review under the provisions of 10 CFR 72.48. However, since the licensee did not perform an actual written evaluation pursuant to 10 CFR 72.48 for the two changes, the impacts of the changes to the fillet weld connection between the ZPT top and bottom plate and the ZPT side shell were not appropriately considered. Based upon the above, the inspectors concluded the licensee failed to provide a written evaluation describing the basis for determining that the change to the design of the Holtec HI-STORM FW system did not require a license amendment. Specifically, while implementing the HI-STORM FW system, the licensees calculational verification of the zero profile transporter (ZPT) did not adhere to the design requirements, resulting in two changes that could result in uncontrolled movements of the HI-STORM FW overpack during transport, potentially impacting the shielding function of the overpack described in the safety analysis report. By the licensee failing to provide a written evaluation, the inspectors could not conclude that the changes would not meet any of the 10 CFR 72.48(c)(2) criteria, and in particular, not result in a more than minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety used in establishing the cask design bases without further evaluation.

Corrective Actions: The licensee documented the two issues in Condition Report (CR) 2022-08533 and CR 2022-08952. In response to this issue, the licensee performed a functionality determination. The inspectors reviewed the functionality determination, and no performance deficiencies were identified in this determination.

Corrective Action References:

CR 2022-08533; NRC Identified: Potential Non-Conformance Identified with the Design Calculation for the Dry Cask Storage Zero Profile Transporter; November 8, 2022 CR 2022-08952; NRC Identified: Potential Non-Conformance Identified with the Design Calculation for the Dry Cask Storage Zero Profile Transporter; November 22, 2022

Performance Assessment:

None. In accordance with Section 2.2 of the Enforcement Policy and Inspection Manual, Chapter 0612, Appendix B, Issue Screening, ISFSIs are not subject to the Significance Determination Process and are not subject to the Reactor Oversight Process; therefore, violations identified at ISFSIs are assessed using traditional enforcement.

Traditional enforcement violations are not assessed for cross-cutting aspects.

The inspectors assessed the significance of the violation using the NRC Enforcement Policy and Enforcement Manual. The inspectors determined that the violation was more than minor because the licensees design did not meet the acceptance limits of ASME Section III, Subsection NF, and Appendix F; and the inspectors could not conclude that the changes would not result in a more than minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety used in establishing the cask design bases without further evaluation.

Enforcement:

Severity: The inspectors characterized the violation as a Severity Level IV violation because the licensee was able to determine the ZPT was functional but nonconforming.

Violation: 10 CFR 72.48(d)(1) requires, in part, that the licensee shall maintain records of changes in the facility or spent fuel storage cask design, of changes in procedures, and tests and experiments made pursuant to paragraph

(c) of this section. These records must include a written evaluation which provides the bases for the determination that the change does not require a Certificate of Compliance (CoC) amendment pursuant to paragraph (c)(2) of this section.

10 CFR 72.48(c)(2) requires, in part, that a general licensee shall request that the certificate holder obtain a CoC amendment pursuant to 10 CFR 72.244, prior to implementing a proposed change if the change would meet any of several specific criteria, including creating more than a minimal increase in the likelihood of occurrence of a malfunction of a system, structure, or component (SSC) important to safety previously evaluated in the FSAR.

Contrary to the above, as of November 1, 2022, the licensee did not include a written evaluation providing the bases for determining that changes did not require a CoC amendment pursuant to the criteria in 10 CFR 72.48(c)(2). Specifically, the licensee introduced the potential for uncontrolled movements of the HI-STORM FW overpack, potentially impacting the shielding function of the overpack described in the safety analysis report, due to the changes in the ZPT design of the fillet weld connection between the ZPT top and bottom plate, and the ZPT side shell and were specific to the

(1) connection acceptance limit, and

(2) limit based on the ultimate tensile strength. Because this violation was of low safety significance and was entered into the corrective actions programs as CR-2022-08533 and CR 2022-08952, and the issue was not repetitive or willful, this is being treated as a Severity Level IV, non-cited violation (NCV), consistent with Section 2.3.2.a of the Enforcement Policy.

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

Observation: Reactor Coolant System Unidentified Leakage from November 21, 2021, to November 21, 2022 71152A During this period, the inspectors reviewed the reactor coolant system (RCS) leakage, tracking, and actions, by the licensee from April 2022, with a leak rate of 0.12 gallons per minute (gpm), through October 2022, with a final leak rate of 2.5 gpm and that lead to a reactor shutdown to identify and repair the leak source.

The inspectors reviewed the licensees procedure for tracking degrading RCS leakage and their adherence to the implementation of response actions at the various levels outlined within this procedure. Yellow level 2, greater than 0.5 gpm, was reached on April 2022, and red level 3, greater than 1.0 gpm, was reached on October 2022. The licensee promptly demonstrated the required increased sampling, chemistry analysis, and assessments at each level. By October 20, 2022, the leak rate had reached 2.0 gpm, and there were indications of A reactor recirculating pump seal degradation. On October 31, 2022, plant operators shut down the reactor and completed a drywell entry to identify and resolve the unidentified RCS leakage. During drywell entries, the licensee, verified by the inspectors, identified the A reactor recirculating pump seal as the primary source of RCS leakage. Additional efforts, such as using a drone to assess potential leakage sources above the 620 level in the drywell, were unsuccessful. After completing the repairs and maintenance outage, the RCSs unidentified leakage lowered to 0.15 gpm, which is in line with the baseline leakage coming out of the last refueling outage.

The inspectors assessment found the licensees problem identification and resolution program effective in identifying, prioritizing, evaluating, and correcting problems related to this sample. The inspectors identified no performance deficiencies or violations.

Observation: Annual Review of the Divisional Diesel Generators Alarms between December 2021, and December 1, 2022 71152A The inspectors reviewed and assessed the licensees corrective action documents associated with emergency diesel generator annunciator alarms over the past year. The inspectors review included 35 corrective action documents.

During this period, the inspectors noted the documentation of several similar issues associated with the diesel generator jacket water, lube oil, and fuel oil subsystems. None of these issues directly impacted operability or functionality, but the number of issues during this period warranted this detailed review.

The inspectors reviewed several electrical protective relays and contactor issues showing age-related wear identified during the licensees routine electrical bucket inspections. The inspectors reviewed instances that indicated several components were near the end of useful life with no ultimate failures. Additionally, the inspectors reviewed the circumstances related to multiple alarms of the open-phase detection instrumentation that occurred during electric distribution bus maintenance. The inspectors did not identify operability issues, and the setpoints of these alarms are under review by the licensee for adjustment to more accurately represent alarm and safe conditions for operation.

The inspectors assessment found the licensees problem identification and resolution program effective in identifying, prioritizing, evaluating, and correcting problems related to this sample. The inspectors identified no performance deficiencies or violations.

Observation: Semiannual Sample for Potential Adverse Trend in Maintenance Rework 71152S The inspectors performed a semiannual review of the licensee's potential adverse trend in maintenance rework for the third and fourth quarters of 2022. During this period, there were 11 rework issues reviewed for this sample by the inspectors. These issues had minimal risk impacts on the initiating events and Mitigating Systems Safety cornerstones, but the number of rework issues and their impact on the work management process remains an issue worth tracking. Common problems include:

wrong replacement parts,

failure to eliminate identified leakage, and

timeliness of repairs, as the timeliness impacted the necessary final repair work as degradation was more exponential than linear.

The inspectors found no major safety concerns or loss of function but identified a negative trend with the licensee's work management program's process of planning, controlling, and executing work activities; that is, the necessary rework has an impact on long term scheduled planned maintenance efficiency and scope of work.

The inspectors' assessment found the licensee's problem identification and resolution program effective in identifying, prioritizing, evaluating, and correcting problems related to this sample. The inspectors identified no performance deficiencies or violations.

LER 2022-002-00, Steam Bypass Valve Demand Limited on the 'B' Train due to a Degraded Signal in the Maximum Combined Flow Limit (MCFL) Circuit Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000440/2022004-02 Open/Closed

[H.4] -

Teamwork 71153 The inspectors identified a Green finding and associated non-cited violation (NCV) for the licensees failure to enter Technical Specification (TS) 3.7.6 in a timely manner when the maximum combined flow limiter (MCFL) In Control light was lit in the Main Control Room on October 7, 2022. Specifically, when the MCFL light was lit in the controlling channel, the main turbine bypass system was inoperable, and the licensee did not enter the appropriate TS condition.

Description:

On October 7, 2022, at 17:40, plant operators identified that the maximum combined flow limiter (MCFL) "In Control" light was lit, with the steam bypass and pressure regulating system on the "B" channel. This light being lit indicates that the MCFL is in control, limiting steam flow to the main turbine and condenser through the control and bypass valves. This indication appeared to be erroneous, as reactor power and pressure remained stable. The system contains two channels of pressure regulation, an "A" and a "B" channel, and a failure in either channel could cause the light to illuminate. The licensee developed a troubleshooting team to determine the potential failure modes.

On October 13, 2022, during problem solving for the MCFL "In Control" light, the problem-solving team determined that the "A" channel was operating normally and that the "B" channel would prevent the bypass valves from responding to a pressure perturbation with the steam bypass and regulating system operating on the "B" channel. The control room shifted off the "B" channel to the "A" channel and declared the "B" channel inoperable.

Technical Specification (TS) 3.7.6 requires the main turbine bypass system to be operable with rated power greater than 23.8 percent. When the main turbine bypass system was inoperable, TS 3.7.6, Required Actions A.1 requires that bypass valve operability be restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and Required Action B.1, requires thermal power to be reduced to less than 23.8 percent power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> If Required Action A.1 is not met. When the "B" channel was in control, the licensee determined that the main turbine bypass system was not operable. Therefore, the licensee violated this TS between October 7 and October 13, 2022, when the required actions were not taken.

Corrective Actions: Immediate corrective actions, troubleshooting, and investigation(s) started after the licensee found the light lit. A multidisciplinary group was established, and the licensee worked multiple courses of actions based on a main failure mode analysis (FMA).

The event was closed when the B flow demand circuit card was replaced on October 30, 2022. After the proper testing and evaluation, the channel B was verified to be working properly.

Corrective Action References:

CR 2022-00843, Maximum Combined Flow Limiter in Control Light on H13-P680 CR 2022-07745 Steam Bypass Valve Demand Limited on the 'B' Train Due to a Degraded Signal in the Max Combined Flow Limit Circuit CR 2022-08771 New GE Hitachi Circuit Card Failed Calibration Testing CR 2022-07531 Maximum Combined Flow Limiter in Control Light Lit on H13-P680

Performance Assessment:

Performance Deficiency: The inspectors determined that the licensee failed to enter Technical Specification (TS) 3.7.6 in a timely manner when the maximum combined flow limiter (MCFL) In Control light was lit in the Main Control Room on October 7, 2022.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors screened the finding against the initiating events screening questions in IMC 0609, Exhibit 1 and answered NO in the transient initiators subsection. Therefore, the finding screened to very low safety significance (Green).

Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the operators in the control room did not communicate the potential issue to the relief crew when it was first identified on October 6, 2022, resulting in a delayed response and a failure to comply with TS 3.7.6 in a timely manner.

Enforcement:

Violation: Technical Specification (TS) 3.7.6 requires the main turbine bypass system to be operable with rated power greater than 23.8 percent. When the main turbine bypass system was inoperable, TS 3.7.6, Required Actions A.1 requires that bypass valve operability be restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and Required Action B.1, requires thermal power to be reduced to less than 23.8 percent power within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> If Required Action A.1 is not met.

Contrary to the above, on October 7, 2022, the licensee did not comply with TS 3.7.6.

Specifically, the licensee determined that when the "B" channel was in control, the main turbine bypass system was not operable, but the licensee failed to restore the system to an operable status, nor reduce power to less than 23.8 percent, within the allowed completion time. The system was inoperable for 7 days.

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

LER 2021-002-00, Core Monitoring System Software Modeling Error Results in Condition Prohibited by Technical Specifications Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000440/2022004-03 Open/Closed Not Applicable 71153 Licensee Event Report (LER) 2021-002-00, Core Monitoring System Software Modeling Error Results in Condition Prohibited by Technical Specifications (ML21216A344). The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER; therefore, no performance deficiency was identified. This condition, a Severity Level IV NCV of TS 3.2.2, Minimum Critical Power Ratio (MCPR), was self-revealed upon review of operational history and General Electric - Hitachi (GEH) Safety Communication SC 21-04, Revision 1, Fuel Support Side Entry Orifice Meta-Stable for 2 Beam Locations in the BWR/6 Reactors. Specifically, during periods on Cycles 17, 18, and 19, Technical Specifications Limiting Condition for Operation 3.2.2, Minimum Critical Power Ratio, was not met, the required action A.1 to restore MCPR to within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was not completed, and the subsequent required action B.1 to reduce thermal power to less than 23.8 percent RTP in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> also was not completed.

Description:

On June 2021, the licensee was informed by GEH of a potential software error and determined later that they had operated in conditions prohibited by TS. The licensee based this determination on a review of operational history and General Electric - Hitachi (GEH)

Safety Communication SC 21-04, Revision 1, issued on June 17, 2021. Perrys review concluded that there were periods between Cycles 17, 18, and 19, when TS 3.2.2, Power Distribution Limits - Minimum Critical Power Ration (MCPR), was not met due to a core monitoring system software modeling error. The error was identified by GEH, and was caused by an underprediction of side entry orifice (SEO) loss coefficient for some fuel bundle locations, which impacted the maximum fraction of the limiting critical power ratio (MFLCPR).

SC 21-04, Revision 0, issued in April 2021, identified a flow pattern that may periodically form under certain core conditions, in which fuel bundle bypass flow is not accurately modeled by the core monitoring software (3DMONICORE). This potential problem would cause 3DMONICORE to underestimate bundle fraction limiting critical power ratio (FLCPR).

GEH has completed the evaluation of the condition to determine reportability under 10 CFR Part 21, and determined it is a reportable condition under 10 CFR 21.21(a)(2), and a transfer of information under 10 CFR 21.21(b). This evaluation established a 0.950 MFLCPR limit for only the two beam locations in the core. This limit, however, can be conservatively applied to the entire core.

On June 17, 2021, GEH revised SC 21-04. Revision 1 provided additional guidance and clarification on the application of the MFLCPR penalty recommended in Revision 0.

Previously, GEH recommended a 0.05 penalty be placed on core wide MFLCPR. Upon further investigation, SC 21-04, Revision 1, recommended that the MFLCPR penalty be calculated via a plant-specific formula, which results in differing penalty values for different core power, flow, and equipment out-of-service conditions.

The inspectors determined that the condition, the level of details used in the vendor calculations, and the basis of the data used in the applied application were beyond the licensees control to identify, predict, or prevent, because it is a legacy vendor design calculation error. The licensee does not have the capability to check these calculations nor the resources to perform an independent review of GEH calculations.

The operating limit MCPR (OLMCPR) is set such that if the plant is operating at the OLMCPR, the most limiting operational transient for the cycle will not result in violation of the safety limit MCPR (SLMCPR). The licensee reviewed the unit operating history and concluded that no limiting or near limiting transients occurred, and therefore, the margin between SLMCPR and OLMCPR was adequate for continued SLMCPR protection.

This instance is reportable under 10 CFR 50.73(a)(2)(i)(B), any operation or condition which was prohibited by the plants TS.

Corrective Actions: As recommended in SC 21-04 (Revision 0 Draft) issued in April 2021, Perry Nuclear Power Plant (PNPP) implemented an administrative limit of maintaining MFLCPR less than or equal to 0.950. PNPP Cycle 19 startup (April 2021), and subsequent operations has maintained MFLCPR less than or equal to 0.950. Also, the licensee generated the Condition Report 2022-08197 on September 28, 2022.

Corrective Action References:

CR 2022-08197, "Fuel Vendor Identified Thermal Limit Non-Conservatism in Analysis,"

September 28, 2022

Performance Assessment:

The NRC determined this violation was not reasonably foreseeable and preventable by the licensee, and therefore, is not a performance deficiency.

Enforcement:

Enforcement Policy Section 2.2.4 states that violations with no associated performance deficiency will be dispositioned using traditional enforcement. Therefore, operating reactor violations with no associated performance deficiencies should be assigned a severity level, as long as the violation meets the criteria described in Section 2.3.2 of the policy for disposition as an NCV.

Severity: Traditional enforcement is being used to disposition this violation with no associated Reactor Oversight Process performance deficiency, per the NRC Enforcement Manual, revision dated January 14, 2022, Section 3.10. The inspectors determined the severity of the violation using Section 6 of the NRC Enforcement Policy, and determined this issue was a SL IV because it most represented the examples in Section 6.1.d. The failure to meet the TS LCO and Action Statement was unknown to the licensee until Safety Communication SC 21-04 was received from GEH, and a review of operational history was performed.

Violation: Technical Specification LCO 3.2.2 requires that all MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR. LCO 3.2.2, Condition A for any MCPR not within limits requires MCPR(s) to be restored within limits in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. LCO 3.2.2, Condition B, states the required action associated completion time for Condition A was not met; the licensee is required to reduce thermal power to less than 23.8 percent RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Contrary to the above, during periods on Cycles 17, 18, and 19, Perry found in some instances that MCPR was not within limits for greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the licensee did not reduce thermal power to less than 23.8 percent RTP within the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> stipulated by TSs; specifically during the Cycle 18 as explained in the LER, when there were seven instances where MFLCPR (SC 21-04) was greater than 1.0 for longer than six hours. During these instances, the requirements of TS 3.2.2 were not met, and during this time period there were no limiting transients that would be a challenge to the Safety Limit...

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

EXIT MEETINGS AND DEBRIEFS

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

On January 26, 2023, the inspectors presented the integrated inspection results to R. Penfield, Site Vice President, and other members of the licensee staff.

On October 20, 2022, the inspectors presented the biennial licensed operator requalification program inspection results to C. Elliott, Plant General Manager, and other members of the licensee staff.

On December 13, 2022, the inspectors presented the emergency action level and emergency plan changes inspection results to G. Burnham, Manager, Site Regulatory Compliance, and other members of the licensee staff.

On January 5, 2023, the inspectors presented the licensed operator requalification program annual testing summary results inspection results to B. Udell, Exam Writer, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

FM-100

22 Perry Dry Fuel Storage Campaign Fuel Selection

60854

Calculations

G58-H-HI-

210746

Fuel Compatibility Report for Perry for Hi-Storm FW System

CR-2022-0367

Evaluation and Implementation of EGM 22-001 at Energy

Harbor Sites

04/27/2022

CR-2022-04846

FME: Foreign Material Identified During Dry Cask Top of

Bundle Inspections

06/14/2022

CR-2022-06334

SFDS HI-TRAN Qualification Limits HI-STORM Travel

Height

08/17/2022

Corrective Action

Documents

CR-2022-08592

DCS - NRC Identified Issue: Perry Dry Cask Procedures did

not Fully Satisfy the Requirements of EGM 22-001,

Enforcement Discretion for Noncompliance of Tornado

Hazards Protection Requirements at ISFSIs

11/09/2022

2.212 Report

10CFR72.212 Report for CoC-1032 (HI-STORM FW and

MPC 89)

Miscellaneous

MPC-0281-0369

Special Nuclear Material Physical Inventory - MPC 281

11/09/2022

NDE Reports

918866-282-07

Shell to Closure Ring, Closure Ring to Lid, Closure Ring to

Closure Ring, SN 282

11/21/2022

HPP-3119-0200

MPC Loading at Perry

HPP-3119-0300

MPC Processing at Perry

HPP-3119-0400

MPC Transfer at Perry

Procedures

HPP-3119-0500

HI-STORM Movements at Perry

PY-M-20220614-

Quarterly Taskcal ISFSI Pad

06/14/2022

Radiation

Surveys

PY-M-20220909-

Quarterly Taskcal ISFSI Pad

09/09/2022

200813859

ISFSI Concrete Pad Inspections

06/15/2022

200834471

Perform Foreign Material Inspection of the Tops of Fuel

Assemblies

03/22/2022

60855

Work Orders

200852469

Repair/Rework Oil/Grease Leaking from FHB Crane

05/23/2022

60856

Calculations

G58-H-HI-

2084111

Structural Analysis Details for Perry Lift Yoke Extension

(Ancillary No. 117)

3/Addendum

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

G58-H-HI-

2084138

Structural Analysis of Zero Profile Transporter for Perry

G58-H-HI-

2094487

Eval of Wind and Neighboring HI-STORM Casks at the Perry

ISFSI on Peak Clad Temp for Stored Fuel

G58-H-HI-

2115012

Stability and Rail/Floor Loading Analysis for HI-STORM on

ZPT

G58-H-HI-

25129

Mini Lift Yoke Extension (Ancillary No. 117A)

G58-H-HI-

25154

Structural Evaluation of HI-STORM Lifting Bracket

G58-H-HI-

2135769

Structural Analysis of the MPC Lift Lock for FW

G58-H-HI-

2135834

Dynamic Analysis of HI-STORM/HI-Trac Stack-Up for PNPP

Using ANSYS

G58-H-HI-

210371

HI-STORM FW Cask Handling Weights at Perry Nuclear

Power Plant

G58-H-HI-

210750

Evaluation of HI-STORM FW Version F Burial Under Debris

Accident at Perry Nuclear Power Plant

G58-H-HI-

210751

Structural Evaluation of the Lift Yoke

G58-H-HI-

210899

Postulated Fuel Drop Accident Evaluation at Perry Nuclear

Power Plant (PNPP)

G58-H-HI-

210902

HI-STORM FW Version F and HI-STORM 100S Version B

Dose Versus Distance from a Single Cask and Cask Array at

the Perry ISFSI

G58-H-HI-

210976

HI-STORM FW Version F and HI-TRAC VW CoC Radiation

Protection Program Dose Rate Limits for Perry

G58-H-HI-

20206

ISFSI, Operating Area, Haul Path Underground Utilities

Evaluation at Perry NPP

G58-H-PS-3200

Multi-Purpose Rigging System for FW System Dry Storage

G58-H-PS-3208

MPC 37/89 Lid Lift Slings for FW Storage System

G58-H-RRTI-

3119-0012

Non-Mechanistic Tip Over Analysis for the HI-STORM FW

G58-P-006

Fire Hazards Analysis for the Dry Cask Storage System

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Inside the Fuel Handling Building

G58-S-G-004

ISFSI Pad Overturning, Sliding, and Bearing Capacity

Analysis

G58-S-G-005

Static Settlements at Independent Spent Fuel Installation

(ISFSI Site)

22-05939

NRC ID Review of 72.212(b) Inspection: Error Identified in

Calculation for Dry Cask FW Upgrade

08/01/2022

22-08533

NRC Identified: Potential Non-Conformance Identified with

the Design Calculation for the Dry Cask Storage Zero Profile

Transporter

11/08/2022

22-08952

NRC Identified: Potential Non-Conformance Identified with

the Design Calculation for the Dry Cask Storage Zero Profile

Transporter

11/22/2022

Corrective Action

Documents

Resulting from

Inspection

CR-2022-08592

DCS-NRC Identified Issue: Perry Dry Cask Procedures did

not Fully Satisfy the Requirements of EGM 22-001

11/08/2022

Drawings

5401

Zero Profile Transporter Main Frame Weldment

Engineering

Changes

21-0001-001

ECP 21-0001-001 ISFSI Dry Fuel Storage HI-STORM FW

Transition

CFR 72.48

Screening 22-

00572

ISFSI Dry Fuel Storage HI-STORM FW Transition

11/01/2022

Holtec Report No.

HI-2114830

HI-STORM FW Multi Purpose Canister Storage System

Final Safety Analysis Report

NEI 96-07

Appendix B

Guidelines for 10 CFR 72.48 Implementation

03/05/2001

Miscellaneous

Purchase

Specification PS-

29

Purchase Specification for the HI STORM Zero Profile

Transporter

Corrective Action

Documents

Resulting from

Inspection

22-09467

NRC Identified Items

2/13/2022

Miscellaneous

Winter work list

Winter Work List 08/01/2022 to 11/01/2022

2/14/2022

71111.01

Procedures

PTI-GEN-P0026

Preparations for Winter Operations

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

Resulting from

Inspection

ATA-2022-19287

Create Label for 1P45F0533A per Attached Request

11/22/2022

206-0051-00000

Electrical One Line Diagram Class 1E DC System

DDD

2-0610-00000

Control Room HVAC and Emergency Recirculation System

GG

Drawings

913-0001-00000

Control Complex Chilled Water

FF

ELI-R22

Electrical Lineup Instruction 15KV Metal Clad Switchgear

11/26/2022

ELI-R23

Electrical Lineup Instruction 480 Volt Load Centers

11/26/2022

ELI-R24

Electrical Lineup Instruction 480 Volt MCC

11/28/2022

ELI-R25

Electrical Lineup Instruction 120. 240 and 480V AC

Distribution System

11/26/2022

ELI-R42

DC Systems: Batteries, Chargers and Switchboards

SOI-E12

Residual Heat Removal System

Rev 78

SOI-E12

Residual Heat Removal System

11/30/2022

SOI-E21

Low Pressure Core Spray System

11/28/2022

SOI-R43

Division 1 and 2 Diesel Generator System

11/26/2022

VLI-E12

Valve Lineup Instruction Residual Heat Removal System

11/30/2022

VLI-E21

Valve Lineup Instruction Low Pressure Core Spray System

11/28/2022

VLI-E22A

High Pressure Core Spray

VLI-M25/26

Control Room HVAC and Emergency Recirculation System

VLI-P45

Valve Lineup Instruction - Emergency Service Water System

11/22/2022

VLI-P47

Control Complex Chilled Water System

VLI-R44

Valve Lineup Instruction Division 1 and 2 Diesel Generator

Starting Air system

11/26/2022

VLI-R45

Valve Lineup Instruction Division 1 and 2 Diesel Generator

Starting Air system

11/26/2022

VLI-R46

Valve Lineup Instruction Division 1 and 2 Diesel Generator

Jacket Water Systems (Unit 1)

11/26/2022

71111.04

Procedures

VLI-R47

Valve Lineup Instruction Division 1 and 2 Diesel Generator

Lube Oil

11/26/2022

1AB-3B

20 8 Elevation

2/20/2022

71111.05

Fire Plans

FPI-0CC

Control Complex

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

FZ OIB-4

Intermediate Building 665-0 Elev

11/14/2022

FZ OIB-5

Intermediate Building 682 Elevation

11/14/2022

71111.11A

Miscellaneous

22 LORT

Annual Licensed

Operator Requal

Test Results

Perry 2022 Annual LORT Exam Summary Results

2/06/2022

CR 2021-03498

Potential Station Identified Finding for INLO Missed Initial

FLEX Training

08/19/2021

CR-2021-01208

Simulator Issues Identified during NRC On-Site Validation of

1-LOT-21 NRC Operating Exam

2/23/2021

CR-2021-01210

Simulator Experienced a THOR Abort during Administration

of 1-LOT-21 NRC Operating Exam

2/23/2021

CR-2021-02588

Reactivity Plan Contingency Actions Implemented during

Startup from 1R18

11/05/2021

CR-2021-02588

Reactivity Plan Contingency Actions Implemented during

Startup from 1R18

11/05/2021

CR-2021-03668

SE Simulator Exam Failure

05/05/2021

CR-2021-04032

Simulator Panel Issues

05/18/2021

CR-2021-04935

Simulator Recorder C34R607 is Failing and Display Blue

Screen with Errors

06/25/2021

CR-2021-05398

Simulator Controller N21-R042 Green Light Burned Out

07/15/2021

CR-2021-05692

One Individual Failed the Generic

Fundamentals - Components Exam in PY_1LOT22

07/27/2021

CR-2021-06980

ERO Drill - Unexpected Simulator Response

09/16/2021

CR-2021-06999

ERO Drill - Simulator Accountability Message Not Heard in

Multiple Plant Facilities During 9/25/2021 Drill

09/16/2021

CR-2021-07719

Simulator Anomalies May Potentially Affect Licensed

Operator Annual Requalification Exams

10/14/2021

CR-2021-08238

Simulator Setup for JPM Exams did not Work as Previously

Validated

10/29/2021

CR-2021-09305

Simulator Relays Showing Degradation

2/08/2021

CR-2022-00279

Simulator Lock Out Relay Failures Found during Training

01/13/2022

CR-2022-01984

ERO Drill - Simulator Emergency Response Facility Phones

03/10/2022

71111.11B

Corrective Action

Documents

CR-2022-02797

Simulator Transient Data for Operations with the Recirc A

03/30/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Flow Control Valve Hydraulics Shutdown

CR-2022-04675

Potential Vulnerability for Exam Security in the Simulator

06/08/2022

CR-2022-07275

ERO Drill - Multiple Simulator Crashes During ERO Drill

09/27/2022

CR-2022-07765

One Senior Reactor Operator Failed the Licensed Operator

Requalification Biennial Written Exam

10/14/2022

CR-2022-07885

A Ty-Wrap was Maintaining the CLOSE Pushbutton for the

ESW A Sluice Gate Control in the Depressed Position

10/18/2022

Corrective Action

Documents

Resulting from

Inspection

CR-2022-07886

Multiple THOR Abort Failures while Performing JPMs in the

Simulator

10/18/2022

ADM-003SRO;

ADM-312SRO;

IP C61-003;

IP C61-110;

IP C71-002;

RRA R10-014;

Sim B21-507;

Sim C11-504;

Sim C85-501;

and Sim N41-502

Operating Test JPMs: 2 - SRO Admin; 4 - In-plant;

and 4 - Simulator

10/17/2022

Attendance

Sheets

Licensed Operator Requalification Cycle 2021, Inclusive

10/17/2022

BOL Core Simulator Installation Test

03/16/2021

BOL Core Simulator Transient Test Data

(ANSI/ANS-3.5-1998, App. B, B2.2.1(1) through (10))

03/25/2021

Credit for

Standing Watch

Logs

By Individual's Names

10/17/2022

EOL Core Simulator Installation Test

09/19/2022

EOL Core Simulator Transient Test Data

(ANSI/ANS-3.5-1998, App. B, B2.2.1(1) through (5) and (8)

through (10))

01/10/2022

Miscellaneous

Mantis Simulator

Program Change

Request 0019952

HPCS and LPCS Injection Valve Indicate Open with Pump

Tripped and Zero Flow Indicated

03/16/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Mantis Simulator

Program Change

Request 0020106

Convert or Print Perry Radnet Nodal Drawings from Visio to

PDF

05/04/2021

Mantis Simulator

Program Change

Request 0020480

THORECCSOUT Update

08/19/2021

Mantis Simulator

Program Change

Request 0020675

New Perry Load Uploaded to FTP Site (Dated 10/05/2021)

10/07/2021

Mantis Simulator

Program Change

Request 0020892

CANIO has been Locking Up - All CANIO Recorders

01/24/2022

Mantis Simulator

Program Change

Request 0020893

THOR Aborts No Longer Flagged in Critical Alarms or

Indicate with Pop-Up

01/25/2022

Mantis Simulator

Program Change

Request 0020895

Request IRM H Gain Adjustment Capability

01/26/2022

Mantis Simulator

Program Change

Request 0021099

Recorder No Longer Clear on IC Reset

03/18/2022

Mantis Simulator

Program Change

Request 0021299

Running DORT Kills Executive

05/12/2022

Mantis Simulator

Program Change

Request 0021301

Warning Popups If Not Acknowledged Right Away the IC

Doesnt Load Right

05/12/2022

Mantis Simulator

Program Change

Request 0021753

Simulator Executive Aborted Multiple Times during NRC

Evaluated E-Plan Exercise

09/28/2022

Mantis Simulator

Program Change

Request 0021765

Steam Tunnel Temp Continues to Rise to Unrealistic Value

with No Steam Leak and MSIVs Closed

10/04/2022

MOL Core Simulator Installation Test

2/23/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

MOL Core Simulator Transient Test Data

(ANSI/ANS-3.5-1998, App. B, B2.2.1(1) through (10))

2/07/2022

NOBP-TR-1112

Conduct of Simulator Training and Evaluation: Attachment D

Crew Evaluation Annual Exam Form 2021 LOR

PC1C Rev 0;

RP1A Rev 6;

RP2A Rev 5; and

RP6C Rev0

Operating Test Simulator Scenarios

10/17/2022

Remediation

By Individual's Names

10/17/2022

SWO/SWR 20-

0053 and 20-

0057

Simulator Work Orders/Requests December, 2020

2/02/2020

SWO/SWR 21-

0001 through 21-

0042

Simulator Work Orders/Requests in 2021

01/13/2021

SWO/SWR 22-

0001 through 22-

0035

Simulator Work Orders/Requests in 2022 (Jan-Sep)

04/06/2022

NOBP-TR-1112

Conduct of Simulator Training and Evaluation

NOBP-TR-1271

Operator License Administration

NOP-OP-1013

Control of Time Critical Operator Actions

NOP-TR-1010

Licensed Operator Requalification Exam Development and

Administration

PYBP-PTS-0005

Operator Continuing Training Program Administration

PYBP-PTS-0015

JPM Preparation, Review, Revision, Approval and

Administration

Procedures

PYBP-PTS-0033

Simulator Configuration Control

Self-Assessments Snapshot

Assessment ATA-

22-9559

NRC 71111.11b Licensed Operator Requalification Program

and Licensed Operator Performance Assessment

10/17/2022

OT-3070-005-

RP2A

Simulator Scenario Guide

OT-3070-PC1B

Simulator Scenario Guide

71111.11Q

Miscellaneous

OT-3070-RP5A

Simulator Scenario Guide

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Reactivity Plan -

Perry Nuclear

Power Plant

Evolution Specific - Startup 133 - Part 1

Reactivity Plan -

Perry Nuclear

Power Plant

Evolution Specific - Startup 133 - Part 2

71111.11

Licensed Operator Requalification Program and Licensed

Operator Performance

11/21/2022

Procedures

FTI-A0009

Estimated Range for Critical

11/06/2022

Self-Assessments Scenario guide

Working Copy Cover Sheet OT-3070-PC1C Copy 5 of 6

10/09/2022

21-05353

Cycle 18 Maintenance Rule Periodic Assessment Report

Identifies Potential Adverse Trend

07/23/2021

22-09017

Oil Leak and Fibrous Material Found in Oil Sump

11/25/2022

CR 2021-06860

Multiple Unexpected Alarms Received Locally and in the

Control Room for the Division 2 Diesel Generator

09/11/2021

CR 2022-06690

Multiple Spurious Alarms Received for Div 2 DG

08/31/2022

Corrective Action

Documents

CR 2022-06774

Multiple Alarms Received for the DIV 2 DG

09/03/2022

Corrective Action

Documents

Resulting from

Inspection

CR 2022-09493

NRC Identified: Wrong Procedure Revision Submission

2/14/2022

ATL-2020-0760-

ATA-03

The Perry Nuclear Power Plant Cycle 18 Maintenance Rule

(a)(3) Periodic Assessment

07/26/2021

NOP-ER-3001

Problem Solving Plan

Miscellaneous

NOP-ER-3001-2

Failure Mode Analysis

N/A

Type 40 Maintenance Instructions Models 25 thru 100

Air-Cooled Stationary Air Compressors

10/1976

NOP-ER-3001-2

Failure Mode Analysis

11/30/2022

PMI-0050

Preventive Maintenance Lubricating Guidelines

11/21/2022

Procedures

SOI-R44

Division 1 and 2 Diesel Generator Starting Air System

200813459

Sample/Change Motor Bearing Oil

11/21/2022

200862895

Troubleshooting the Cause Associated with Div 2 Diesel

09/11/2021

71111.12

Work Orders

200891540

Determine the Cause of The Alarms and Repair/Replace

Parts as Required

09/07/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

22-05976

Issues Encountered during Tip Operation with Common

Channels

08/02/2022

22-07110

Rise in Drywell Unidentified Leakage

09/19/2022

22-07407

Rise in Drywell Unidentified Leakage

10/03/2022

22-07485

Drywell Unidentified Leakage Classified as RED

(>= 1.0 GPM) per PYBP-SITE-0029

10/05/2022

22-07646

Rise in Drywell Unidentified Leakage

10/11/2022

22-07710

Rise in Drywell Unidentified Leakage

10/15/2022

22-07784

Rise in Drywell Unidentified Leakage

10/15/2022

22-07802

Rise in Drywell Unidentified Leakage

10/16/2022

22-08498

During the Disassembly of Reactor Recirculation Pump

Shaft Seal Cartridge, Several Erosion Grooves were

Identified on the First and Second Stage Stationary Face

11/07/2022

22-08509

Manual Trip of Main Turbine during Startup

11/07/2022

22/07537

Rise in Drywell Unidentified Leakage

10/08/2022

Corrective Action

Documents

CR 2022-09448

Received Inhibit Rod Motion RCIS OOS Alarm

2/13/2022

Miscellaneous

NOP-ER-3001-03

Simple Troubleshooting Plan Revision (Various Versions)

11/08/2022

IOI-3

Power Changes

Procedures

SOI-

N32/39/41/51

Main Turbine Generator and Turning Gear System

71111.13

Self-Assessments NOP-ER-3001-2

Failure Mode Analysis Issues Encountered During Tip

Operation with Common Channels

22-07466

Control Complex Chiller B Nonrepeatable Time Delay Relay

10/05/2022

22-07531

Maximum Combined Flow Limiter in Control Lit on

H13-P680-07C. No Other Abnormal Indications Observed

10/07/2022

22-07534

RCIC Watertight Door Need an Adjustment

10/23/2022

22-07745

Steam Bypass Valve Demand Limited on the B Train Due

to a Degraded Signal in the Max Combined Flow Limit

Circuit

10/13/2022

22-07752

Drywell D17 Moving Filter Paper Alignment Issues

10/14/2022

22-07961

Incorrect Breaker Installed in ED1A03

10/20/2022

71111.15

Corrective Action

Documents

22-08160

Remote Shutdown Switch Contacts 11 and 12 Found Faulty

on EF1D07

10/27/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Miscellaneous

NOP-ER-3001-01

Problem Solving Plan Rev 0 and 3

200591836

Replace AGASTAT E7000 TD Relay

10/13/2022

Work Orders

200806338

Remote Shutdown Switch Contact Faulty

11/04/2022

22-00066

Failed Seal Test Lower Inner Airlock Door

01/05/2022

Corrective Action

Documents

22-01293

Upper Containment Airlock Outer Door Failed Testing

2/19/2022

Engineering

Changes

19-0148-000

Containment Airlock 3-Way Ball Valve Return to Original

Design Configuration, PY-1P530577B, PY-1P53F0578B

(Lower Containment Airlock Inner Door) 9/7/2021

71111.18

Work Orders

200790603

Add Washers to Ball Valves

1P53F0577B/1P53F0578/ECP 19-0148-001

01/12/2022

22-04833

Lower Containment Airlock Inner Door Failed Surveillance

Testing

06/14/2022

22-06820

RHR B Room Sump Level Switch 1G61N0720B Failed

Functional Check

09/06/2022

22-06829

RHR B Room Sump Level High Alarm Received with No

High Level in The Sump 9/7/2022

09/07/2022

Corrective Action

Documents

CR 2022-08938

Circ Water Pump A 1N71C001A Would Not Start

11/21/2022

8000748-IP-1

Installation Procedure for New Components of Governor

Drive Assembly

GEI-0007A

Instructions For Cable and Wire Terminations

2/07/2022

GMI-0176

Containment Airlock Door Maintenance

PMI-0011B

Division 2 Diesel Generator Woodward Governor

Maintenance

PMI-0050

Preventive Maintenance Lubricating Guidelines

11/21/2022

PTI-R43-P0006-B Division 2 Diesel Generator Pneumatic Logic Board

Functional Check

2/12/2022

Procedures

SVI-R43-T1318

Diesel Generator Start and Load Division 2

200471341

Rev 1 Replace Transformer T8

2/7/2022

200807120

Replace Governor Drive Coupling Insert

2/06/2022

200807196

Replace 1R43F0504B OR Gate

2/13/2022

200813355

Replace CC CO2 W/ Hydro Tested

09/07/2022

200813459

Sample/Change Motor Bearing Oil

11/21/2022

71111.19

Work Orders

200813499

General Cleaning of the Cooling Coils & Megger Motors

07/12/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

200813923

Calibration Check 0P47Q7028

10/05/2022

200878642

LPCS and RHR A Waterleg Pump and Associated Valves

Cold Shutdown Operability Test

11/17/2022

200885412

Lower Containment Airlock Reactor Door

06/16/2022

200891540

Determine the Cause of The Alarms and Repair/Replace

Parts as Required

08/31/2022

200891944

Determine the Cause of The Level Switch Failing and

Repair/Replace

09/07/2022

200896253

SVI-P53T9024 DW Airlock Between Seals

11/07/2022

200897242

Circ Water Pump A Will Not Start Perform Troubleshooting

to Determine

11/21/2022

Miscellaneous

Reactivity plan

Evolution Specific - Startup 133 - Part 1

71111.20

Procedures

IOI-3

Power Changes

Calculations

E12-48

E12/LPCI System Adequacy in Accident Injection Mode

22-06043

Increasing Friction in TIP Common Channel 10

08/05/2022

22-07326

Heater (0M25-B005A) Found Not Operating Property

09/29/2022

Corrective Action

Documents

22-07358

Control Room Ventilation Disconnect Would Not CLOSE

09/29/2022

Miscellaneous

USAR

Updated Safety Analysis Report Section 6.2, Containment

Systems

SOI-R45/E22B

Division 3 Diesel Generator Fuel Oil System

10/20/2022

SVI-E12-T2003

RHR C Pump and Valve Operability Test

SVI-E51-T2001

RCIC Pump and Valve Operability Test

Procedures

SVI-P53-T9024

Drywell Airlock In Between Seal Tests

11/07/2022

200640132

FTI-A0001 - (TIP operation)

08/05/2022

200807704

SVI-E22T1310 HPCS D/G Start and Load

10/04/2022

200813329

Control Room Ventilation Heat Removal Test - B Train

10/07/2022

200813881

Annual Operational Test 120V/ 6KW

09/08/2022

200813883

Annual Operational Test 120V/ 6KW

09/08/2022

200813886

Annual Operational Test 120V/ 6KW

09/08/2022

200813887

Annual Operational Test 120V/ 6KW

09/08/2022

200814635

Quarterly Fire Alarm Test

10/24/2022

200814641

Instrument Air Valve Operability Test

08/15/2022

71111.22

Work Orders

200824159

SVI-N31-T1151 Mn Turbine Valve Exercise

09/24/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

200851621

Determine and Correct the Cause of Annunciator RPS Turb

Stop Valve Closure (P680-05A-4A), and Computer Point

C71NC014 Not Responding as Desired During

SVI-C71-T0047 and SVI-N31-T1151 CR 2021-02376,

CR 2021-02480

09/24/2022

200851628

C71NC014 Computer Pnt Failure /CR

09/24/2022

PY-2020-017-00

Emergency Plan Revision 59

07/13/2021

Miscellaneous

PY-2022-001-00

Emergency Plan Revision 60

03/30/2022

EP-0000

Perry Nuclear Power Plant Emergency Plan

EP-0000

Perry Nuclear Power Plant Emergency Plan

71114.04

Procedures

EP-0000

Perry Nuclear Power Plant Emergency Plan

71114.06

Miscellaneous

Fourth Quarter 2022 Emergency Response Organization

Table-Top Drill TSC-EOF

MSPI Derivation Report - Cooling Water System

Unavailability Index

09/30/2022

MSPI Derivation Report - Cooling Water System Unreliability

Index

09/30/2022

MSPI Derivation Report - Residual Heat Removal System

Unavailability Index

09/30/2022

MSPI Derivation Report - Residual Heat Removal System

Unreliability Index

09/30/2022

MSPI Derivation Report - Heat Removal System

Unavailability Index

09/30/2022

MSPI Derivation Report - Heat Removal System Unreliability

Index

09/30/2022

71151

Miscellaneous

eSOMS Operators' Narrative Logs

Various

22-04716

Increasing Unidentified RCS Leakage

06/08/2022

22-05522

Rise in Unidentified RCS Leakage

07/13/2022

22-06139

Documentation of Drywell Leakage Rise Search Results

08/09/2022

22-07110

Rise in Drywell Unidentified Leakage

09/19/2022

22-07407

Rise in Drywell Unidentified Leakage

10/03/2022

22-07485

Drywell Unidentified Leakage Classified as RED

(>= 1.0 GPM) per PYBP-SITE-0029

10/06/2022

71152A

Corrective Action

Documents

22-07485

Drywell Unidentified Leakage Classified as RED

10/05/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

(>= 1.0 GPM) per PYBP-SITE-0029

22-07537

Rise in Drywell Unidentified Leakage

10/08/2022

22-07646

Rise in Drywell Unidentified Leakage

10/11/2022

22-07710

Rise in Drywell Unidentified Leakage

10/15/2022

22-07881

Rise in Drywell Unidentified Leakage

10/18/2022

CR 2020-04607

EF1E-1-M Blown Mainline Fuse

05/28/2020

CR 2020-06027

Division 2 DG Jacket Water Heater Disconnect Contacts

Found Degraded

07/29/2022

CR 2020-06027

Division 2 DG Jacket Water Heater Disconnect Contacts

Found Degraded

07/29/2022

CR 2021-06860

Multiple Unexpected Alarms Received Locally and in the

Control Room for the Division 2 Diesel Generator

09/11/2021

CR 2021-09640

Division 1 DG Fuel Oil Pressure Low Alarm Received During

DG Run

2/22/2022

CR 2022-01187

Evaluate Availability of Alternate Contactors

08/23/2022

CR 2022-01385

Div 2 DG Fuel Filter DP Indicates High

2/22/2022

CR 2022-03670

1A and 2A Open Phase Injection Voltage Causing Alarms

During 4-6 345kV Bus Outage

04/28/2022

CR 2022-03986

Div 2 Diesel - Fuel Filter High d/p Alarm

05/10/2022

CR 2022-05869

Tracking and Trending Degraded Relay and Contactor in

Diesel Water Jacket MCC Bucket EF1C08-T

07/28/2022

CR 2022-06690

Multiple Spurious Alarms Received for Div 2 DG

08/31/2022

CR 2022-06774

Multiple Alarms Received for the DIV 2 DG

09/03/2022

CR 2022-08799

Div 1 DG Lube Oil Low Level Alarm In

11/16/2022

Procedures

PYBP-SITE-0029

Reactor Coolant System (RCS) Leakage Monitoring

22-00066

Failed Seal Test Lower Inner Airlock Door

01/05/2022

22-00587

Nitrogen Leak on HCU 22-55

01/26/2022

22-01836

HCU 22-55 Pressure Gauge has a Nitrogen Leak

03/08/2022

22-0266

Differential Ground Relay (87 Device) 1R22Q0208 could not

be Calibrated (for CW Pump B)

03/12/2022

22-03391

Site Glass on Main Turbine Lube Oil Purifier Filter Sight

Glass and Isolation Valve Broken During Screen Cleaning

04/18/2022

71152S

Corrective Action

Documents

22-03823

Turbine Building Chilled Water Chiller A Tripped During Post

05/04/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Maintenance Testing Run

22-03961

Division 3 Diesel Fuel Line Sheared During Maintenance

Run on Number 8 Cylinder

05/10/2022

22-04066

Lube Oil Clamp Plate Leakage Identified during Division 3

D/G Operation

05/13/2022

22-04259

C85 Backup Filter Leaking

05/20/2022

22-05861

Issue Identified During Pre-Outage Work for the RHR B to

Feedwater Line Flush Check Valve

07/28/2022