Text

IR 05000440-13-007; 11/04/2013 - 11/22/2013; Perry Nuclear Power Plant; Biennial PI&R Inspection
	ML14003A186
Person / Time
Site:	Perry
Issue date:	01/03/2014
From:	Michael Kunowski; NRC/RGN-III/DRP/B5
To:	Harkness E; FirstEnergy Nuclear Operating Co
References
	IR-13-007
	Download: ML14003A186 (27)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210

LISLE, IL 60532-4352

January 3, 2014

Mr. Ernest Harkness

Site Vice President

FirstEnergy Nuclear Operating Company

Perry Nuclear Power Plant

P. O. Box 97, 10 Center Road, A-PY-A290

Perry, OH 44081-0097

SUBJECT: PERRY NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION

AND RESOLUTION INSPECTION REPORT 05000440/2013007

Dear Mr. Harkness:

On November 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a

Problem Identification and Resolution biennial inspection at your Perry Nuclear Power Plant.

The enclosed inspection report documents the inspection results, which were discussed on

November 22, 2013, with you and other members of your staff.

Based on the inspection sample, the inspection team determined that your staffs

implementation of the corrective action program supported nuclear safety. In reviewing your

corrective action program, the team assessed how well your staff identified problems at a low

threshold, your staffs implementation of the stations process for prioritizing and evaluating

these problems, and the effectiveness of corrective actions taken by the station to resolve these

problems. In each of these areas, the team determined that your staffs performance was

adequate to support nuclear safety.

The team also evaluated other processes your staff used to identify issues for resolution.

These included your use of audits and self-assessments to identify latent problems and your

incorporation of lessons learned from industry operating experience into station programs,

processes, and procedures. The team determined that your stations performance in each of

these areas supported nuclear safety

Finally, the team determined that your stations management maintains a safety-conscious work

environment adequate to support nuclear safety. Based on the teams observations, your

employees are willing to raise concerns related to nuclear safety using at least one of the

several means available.

Two NRC-identified findings of very low safety significance (Green) were identified, both of

which involved violations of NRC requirements. However, because of their very low safety

significance, and because the issues were entered into your Corrective Action Program, the

NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of

the NRC Enforcement Policy.

E. Harkness -2-

If you contest a violation or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with

copies to the Regional Administrator, Region III; the Director, Office of Enforcement,

U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Perry Nuclear Power Plant.

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 Regional Administrator, Region III, and the NRC Resident Inspector at the

Perry Nuclear Power Plant.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections,

Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and your response (if any) will be available electronically for public inspection in

the NRCs Public Document Room or from the Publicly Available Records System (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

/RA/

Michael A. Kunowski, Chief

Branch 5

Division of Reactor Projects

Docket No. 50-440

License No. NPF-58

Enclosure: Inspection Report 05000440/2013007

w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServTM

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-440

License No: NPF-58

Report No: 05000440/2013007

Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Dates: November 4 through November 22, 2013

Inspectors: J. Jandovitz, Project Engineer, Team Lead

C. Brown, Senior Reactor Inspector

J. Gilliam, Reactor Engineer

J. Nance, Resident Inspector

Approved by: Michael Kunowski, Chief

Branch 5

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000440/2013007; 11/04/2013 - 11/22/2013; Perry Nuclear Power

Plant; Biennial Problem Identification and Resolution (PI&R) Inspection.

This inspection was performed by three regional-based inspectors and the Perry Nuclear Power

Plant resident inspector. Two (Green) findings were identified by the inspectors, both with

associated Non-Cited Violations (NCVs) of NRC regulations. The significance of inspection

findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and

determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process,

dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within

the Cross Cutting Areas, dated October 28, 2011. All violations of NRC requirements are

dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The

NRCs program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, Reactor Oversight Process, Revision 4.

Problem Identification and Resolution

Based on the samples selected for review, the team concluded that implementation of the

corrective action program (CAP) at the Perry Nuclear Power Plant was effective. The licensee

had a low stated threshold for identifying problems and entering them in the CAP. Items

entered into the CAP were generally screened and prioritized in a timely manner using

established criteria, although the team identified timeliness issues for a small percentage of

issues. With a few exceptions documented by the team, issues in the CAP were evaluated and

corrective actions were generally implemented in a timely manner. The team noted that the

licensee reviewed operating experience (OE) for applicability to station activities. Audits and

self-assessments were performed at an appropriate level to identify deficiencies. Based on

interviews conducted during the inspection, licensee staff expressed freedom to raise nuclear

safety concerns and to enter nuclear safety concerns into the CAP.

NRC-Identified and Self-Revealed Findings

Cornerstone: Barrier Integrity

Green. The inspectors identified a finding of very low safety significance (Green) and

associated Non-Cited Violation of Technical Specification 3.4.11, RCS Pressure and

Temperature (P/T) Limits, for failure to comply with reactor pressure vessel

pressure/temperature limits. Specifically, in 2011 the inspectors identified the

pressure/temperature limits in Technical Specification 3.4.11 only contained values for reactor

pressure vessel pressures greater than 0 pounds per square inch gauge. However, between

June 2011 and July 2013, the licensee operated the plant with a vacuum in the reactor pressure

vessel during 5 cold startups and 1 cooldown. The licensee entered the finding into its

corrective action program as Condition Report CR 2013-18689.

The performance deficiency was determined to be more than minor because the finding was

associated with the area of Routine Operations Performance within the Human Performance

attribute of the Barrier Integrity Cornerstone and had the potential to adversely affect the

associated cornerstone objective of providing reasonable assurance that a physical design

barrier (reactor coolant system) protects the public from radionuclide releases caused by

accidents or events. The finding screened as very low safety significance because it was

determined that there was no change in risk due to the performance deficiency. This finding

1 Enclosure

has a cross-cutting aspect in the area of human performance, resources. Specifically,

complete, accurate, and up-to-date procedures were not available to operators to ensure

operations within the requirements of Technical Specification 3.4.11, (H.2(c)).

(Section 4OA2.1b.(2).1)

Green. The inspectors identified a finding of very low safety significance (Green) and

associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective

Action, for failure to promptly correct a non-conservative Technical Specification. Specifically,

the inspectors identified on November 14, 2013, that the licensee failed to promptly correct the

non-conservative Technical Specification 3.4.11 by not submitting a license amendment request

in accordance with NRC Administrative Letter 98-10, which required submittal within 1 year

or 1 operating cycle. The licensee had determined Technical Specification 3.4.11, RCS

Pressure and Temperature (P/T) Limits, to be non-conservative on October 16, 2009, and

implemented administrative controls as allowed by the Administrative Letter. As of

November 14, 2013, the licensee had not submitted the license amendment request, over

4 years and 2 operating cycles after determining the Technical Specification was non-

conservative. The licensee entered the finding into the corrective action program as Condition

Report CR 2013-18983.

The performance deficiency was determined to be more than minor because the finding was

associated with the area of Routine Operations Procedures within the Procedure Quality

attribute of the Barrier Integrity Cornerstone and had the potential to adversely affect the

associated cornerstone objective of providing reasonable assurance that physical design

barriers (fuel cladding, reactor coolant system, and containment) protect the public from

radionuclide releases caused by accidents or events. The finding was screened as very low

safety significance because it was determined that operators followed the appropriate reactor

coolant system P/T curves even though the Technical Specification was non-conservative.

The finding has a cross-cutting aspect in the area of human performance, decision-making,

where licensee decisions demonstrate that nuclear safety is an overriding priority. Specifically,

from the time of discovery of the non-conservative technical specification until now, various

decisions had been made by the licensee that have delayed the timely submittal of the license

amendment request (H.1(c)). (Section 4OA2.1b.(3).1)

2 Enclosure

REPORT DETAILS

4. OTHER ACTIVITIES

4OA2 Problem Identification and Resolution (71152B)

This inspection constituted one biennial sample of Problem Identification and Resolution

(PI&R) as defined in Inspection Procedure (IP) 71152, Problem Identification and

Resolution. Documents reviewed are listed in the Attachment to this report.

.1 Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees Corrective Action Program (CAP) implementing

procedures and attended CAP meetings to assess the implementation of the CAP by

licensee staff. The inspectors also interviewed licensee staff about their use of the CAP.

The inspectors reviewed risk and safety significant issues in the licensees CAP since

the last NRC PI&R inspection in January 2012. The selection of issues ensured an

adequate review of issues across NRC cornerstones. The inspectors used issues

identified through NRC generic communications, department self-assessments, licensee

audits, OE reports, and NRC documented findings. The inspectors reviewed Condition

Reports (CRs) that were generated and a selection of completed investigations from the

licensees various investigation methods, including root cause evaluations (RCEs), full

apparent cause evaluations (ACEs), limited apparent cause evaluations (LACEs), and

common cause analyses (CCAs).

The inspectors selected the station large transformers to review in detail because the

system had numerous operational problems, including replacements, in recent years.

The intent of the review was to determine whether the licensee staff were properly

monitoring and evaluating the performance of this system through effective

implementation of station monitoring programs. A five-year review of the Unit 1 main

transformer, 1-PY-T, the Unit 1 auxiliary transformer, 110-PY-B, and the Unit 2 start-up

transformer, 200-PY-B, was performed. A review of the use of the station maintenance

rule program to help identify equipment issues was also conducted.

On September 3, 2013, the NRC issued the Mid-Cycle Assessment Letter for the Perry

Nuclear Plant (ADAMS Accession Number ML13246A237). That assessment discussed

that continued management attention and focus was needed to address lower level, less

risk significant issues involving procedure use and adherence and procedure quality.

To further evaluate these issues, this inspection implemented the NRC plan to

specifically review the licensees corrective actions for the extent of cause evaluations

completed in response to the 2011 and 2012 White findings in the radiation protection

area.

During the reviews, the inspectors determined whether the licensees actions were in

compliance with the licensees CAP and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors determined whether licensee personnel were identifying plant

issues at the proper threshold, entering the plant issues into the stations CAP in a timely

manner, and assigning the appropriate prioritization for resolution of the issues. The

inspectors also determined whether the licensee staff assigned the appropriate

3 Enclosure

investigational method to ensure the correct determination of root, apparent, and

contributing causes. The inspectors also evaluated the timeliness and effectiveness of

corrective actions for selected issue reports, completed investigations, and NRC

previously identified findings that included principally non-cited violations.

b. Assessment

(1) Effectiveness of Problem Identification

Based on the information reviewed, including initiation rates of CRs and interviews, the

inspectors concluded that the licensee has an appropriate low threshold for initiating

CRs. The number of CAP items generated were distributed across the various

departments. The inspectors did not identify any safety significant items that were not

entered into the CAP, but noted that various licensee assessments found instances that

did not meet licensee expectations for entering issues into the CAP. The inspectors

assessed the effectiveness of problem identification as adequate, partially due to the

continued expectation that the licensee will continue to perform assessments of the

same quality and resulting corrective actions improving the CAP process.

Observations

Since 2012, the inspectors noted that licensee assessments of the CAP, including fleet

and oversight assessments, have been self-critical and rated the CAP as marginally

effective but with an improving trend. Corrective actions have been developed to

improve CAP implementation, but the assessments continue to reveal areas for

improvement as late as the 2013 second trimester assessment.

The 2012 NRC Problem Identification and Resolution (PI&R) Inspection Report,

05000440/2012007 (ADAMS Accession Number ML12066A195), noted that issues with

the use of work order Work-In-Progress (WIP) logs where the logs included information

that should have been included in the CAP, provided technical direction, and that either

initiated or stopped work. The inspectors noted improvement during this inspection with

one similar WIP log issue that was identified by the licensee.

Review of the CAP performance indicators showed that the number of CRs generated

has increased over the last year. Reviewing the six-month averages, the site had a low

of 566 in March 2013, and a high of 709 in September of 2013. As expected, the

number increased significantly during the spring outage period, a high of 952 CRs

initiated in May 2013.

Findings

No findings were identified.

(2) Prioritization and Evaluation of Issues

The inspectors reviewed the classification of CRs and attended licensee meetings that

categorized and prioritized CRs and determined that, in general, CRs were assigned

appropriate prioritization and evaluation levels. Evaluations in RCEs and ACEs

reviewed by the inspectors were adequate. The licensee completed about 12 RCEs

since November 2012. The inspectors considered the quality of the selected RCEs to

have improved since the last inspection. A contributing factor may be that licensee

4 Enclosure

review groups had previously identified issues with the quality of the evaluations

resulting in corrective actions. The inspectors determined that the licensees

prioritization and evaluation of issues were sufficient to ensure that established

corrective actions would be effective and that there was appropriate consideration of risk

in prioritizing issues.

Several CR evaluations were found to lack sufficient depth to fully evaluate and correct

the issue. In most of these cases, the CRs were processed to trend and when a trend or

more CRs with the same issue were identified, it was more fully evaluated by the

licensee. None of these evaluations were considered by the inspectors to be of more-

than-minor significance.

Observations

CR 2013-09086 was reviewed. It discussed material near the transformers that could

become missiles in high winds, impacting the transformers. The CR stated previous

communications had been unsuccessful in addressing this issue. The CR provided

minimal evaluation and was closed to the action to remove the material. There was no

consideration of procedure and process deficiencies that should have prevented the

condition. After questions by the inspectors, the licensee staff conducted a walkdown

of the area identified in the CR. Additional material was found in the area and

CR 2013-17984 was generated. That CR evaluation identified existing procedures

which controlled material in these areas to protect the transformers and found the

licensee personnel were not familiar with those procedures. Specifically, the procedures

were PAP-0204, Housekeeping/Cleanliness Control Program, and NOP-O-1012,

Material Readiness and Housekeeping Inspection Program. These procedures

contained directions for inspections in or around the switchyard and for the removal or

restraint of material or debris that had the potential to become airborne with high winds

and cause the loss of offsite power. This was determined to be a performance

deficiency but not considered more-than-minor and it was entered into the CAP.

A notice was issued to all site personnel by the licensee to highlight these procedures

and requirements.

CR 2011-03864 was reviewed. It identified an NRC question on operating with a

vacuum in the reactor pressure vessel when it appeared that Technical Specifications

(TSs) only contained criteria that allowed operation with reactor vessel pressure greater

than 0 pounds per square inch gauge (psig). The inspectors found the evaluation of the

condition to address only the technical aspects of the question and not compliance with

the TSs. No further action was taken or planned by the licensee. As a result, the NRC

determined operating with a vacuum in the reactor pressure vessel was not in

compliance with the TSs and documented a finding.

Findings

.1 Failure To Comply With TS 3.4.11

Introduction: The inspectors identified a finding of very low safety significance (Green)

and associated NCV of TS 3.4.11 for failure to comply with the reactor coolant system

(RCS) pressure and temperature (P/T) limits, a condition adverse to quality. Specifically,

although the TS P/T limits only contain values for operating with pressures greater than

0 psig in the reactor pressure vessel (RPV), between May 2011 and July 2013, the

5 Enclosure

licensee operated the plant with a vacuum in the RPV during 5 cold startups and 1

cooldown.

Description: In October 2011, the inspectors identified a concern with the P/T limits for

TS 3.4.11, RCS Pressure and Temperature (P/T) Limits. The pressure limits for non-

nuclear heatup only existed for values greater than or equal to 0 psig and the licensee

was actually operating with a vacuum (below 0 psig) in the RPV. The licensee initiated

CR 2011-03864, NRC Question on Tech Spec 3.4.11 RCS Pressure and Temperature

Curves/Drawing a Vacuum during Non-Nuclear Heatup, and evaluated the concern to

determine if any potential deficiency existed for not operating within the curve limits.

The resulting engineering evaluation stated that The Reactor Vessel is designed

following the rules of ASME Section III Subsection NB Class 1 components. From the

Chicago Bridge and Iron, ASME Code Design Report, D-1, page 35, the vessel head

is 4 19/32 inch thick with an inner radius of 119 inches and the vessel wall below the

flange is 6 inches thick with an inner radius of 120 inches. The dimensions of these

components are identified to provide indication of the robustness of the design. Due to

the size and thicknesses of these components the stresses produced by vacuum are

judged to be relatively insignificant. The licensee, however, did not evaluate implication

for TS compliance.

In January 2013, during a cold startup following an automatic scram, the inspectors

again questioned operating with the RPV in a vacuum during the startup. The licensee

referred to the 2011 CR. The licensee had not committed to update the curves and

submit a license amendment request (LAR) for approval of new P/T limits to reflect

operation with a vacuum in the RPV during cold startups and during cooldowns. On

November 5, 2013, during a phone call with various branches in the Office of Nuclear

Reactor Regulation, including the Technical Specification branch, it was decided that

the current TS does not address operating the RPV in a vacuum and doing so violated

TS 3.4.11.

Analysis: The inspectors determined that the failure to comply with the RCS P/T limits of

TS 3.4.11 was a performance deficiency. The performance deficiency was determined

to be more than minor, and thus a finding, using Inspection Manual Chapter (IMC) 0612,

Appendix B, Issue Screening, dated September 7, 2012, because it was associated

with the Human Performance attribute area of Routine Operations Performance of the

Barrier Integrity Cornerstone and had the potential to adversely affect the associated

cornerstone objective of providing reasonable assurance that a physical design barrier

(reactor coolant system) protects the public from radionuclide releases caused by

accidents or events. Specifically, without NRC evaluation and approval of revised P/T

limits that include operating the RPV in a vacuum, the inspectors did not have

reasonable assurance the RPV was not adversely affected. The finding was evaluated

using Inspection Manual Chapter (IMC) 0609, Significance Determination Process

(SDP), Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012,

and IMC 0609, Appendix A, Exhibit 3 - Barrier Integrity Screening Questions, dated

June 19, 2012. Because the finding involved the RCS boundary (e.g., pressurized

thermal shock issues), the SDP directs the inspectors to stop and go to the detailed risk

evaluation section. The regional Senior Reactor Analyst (SRA) reviewed the finding and

determined that a detailed risk evaluation was not required based on the licensee

engineering evaluation. As a result, the SRA concluded that there was no change in risk

due to the performance deficiency. This finding has a cross-cutting aspect in the area of

human performance, resources. Specifically, complete, accurate and up-to-date

6 Enclosure

procedures were not available to operators to ensure operations within the requirements

of TS 3.4.11, (H.2(c)).

Enforcement: Technical Specification 3.4.11 requires that RPV pressures and

temperatures be maintained within limits at all times. Contrary to this requirement,

between June 2011 and July 2013, the licensee operated the plant with a pressure in the

RPV less than the TS 3.4.11 limit of greater than or equal to 0 psig. Specifically, the

licensee operated the RPV in a vacuum during cold startups on June 4, 2011, for more

than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months ; on October 18, 2011, for more than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ; on March 3, 2012, for more

than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ; on June 17, 2012, for more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; and on May 11, 2013, for more

than 30 minutes; and twice during a cooldown on June 16, 2013, for 15 and 30 minutes.

Because the violation was of a very low safety significance and was documented in the

licensees corrective action program (as Condition Report CR 2013-18689), it is being

treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy

(NCV 05000440/2013007-01, Failure To Comply With Technical Specification 3.4.11).

(3) Corrective Actions

In general, the inspectors concluded that the corrective actions were appropriate for the

identified issues. The corrective actions in 2011 and 2012 in response to the NRC White

radiation protection issues were found to be ineffective to improve procedure use and

adherence. For other selected NRC documented violations, corrective actions were

determined to be effective and timely. The inspectors review of the previous 5 years of

the licensees efforts to address issues with the station large transformers did not identify

any negative trends or inability by the licensee to address long-term issues.

Observations

The inspectors reviewed various corrective actions from the RCEs for the 2011 and

2012 NRC White issues. The inspector noted that licensee assessments and plant

events have continued to demonstrate weakness in procedure compliance indicating the

corrective actions developed from the RCEs were not effective. The inspectors also

noted that on August 8, 2013, licensee senior managers conducted site standdowns to

provide clear site expectations and standards, including procedure use and adherence.

Also in August 2013, the licensee rolled out a new site action plan, the Perry Strategic

Improvement Plan, to improve procedure use and adherence as well as the use of

performance improvement tools, teamwork, and accountability. The inspectors reviewed

portions of the Strategic Improvement Plan and noted it included required field

observations by supervisors and management specifically observing and documenting

procedure use behaviors. A review by the inspectors of the documented observations

indicated procedure use and adherence was improving but the plan and actions have

not been implemented long enough for the inspectors to conclude that notable and

sustained improvement in this area had yet occurred.

In CR 2013-09637, the licensee identified that Plant Data Book I0004, Instrumentation

Channels, was approved and made effective before the NRC approved the associated

LAR. After discussions with the licensee and review of the CR, the inspectors

determined that the premature change was made because of a failure to follow

procedure NOP-SS-3001, Procedure Review and Approval. The corrective action

assigned by the licensee was to send out a lessons-learned notice to all of the

7 Enclosure

procedure writers. However, the notice did not address the failure to follow procedure.

In addition, there was no verification that all of the procedure writers reviewed the

information. The licensee initiated CR 2013-18661, NRC Questions the Thoroughness

of CR 213-09637, License Amendment Implementation Completed Prior to Amendment

Approval, to address this concern.

Findings

.1 Failure to Promptly Correct a Non-Conservative TS

Introduction: The inspectors identified a finding of very low safety significance (Green)

and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

for failure to promptly correct a condition adverse to quality, a non-conservative TS.

Specifically, in November 2013, the inspectors identified that the licensee implemented

an administrative TS change when the licensee identified in October 2009 that

TS 3.4.11, RCS Pressure and Temperature (P/T) Limits, was non-conservative, but

did not promptly submit the required LAR.

Description: In October 2009, the licensee documented in Condition Report CR 2009-

64465 that TS 3.4.11, RCS Pressure and Temperature (P/T) Limits, was non-

conservative. These limits protect the reactor vessel material from pressurized thermal

shock. The corrective action by the licensee was an administrative TS change in

accordance with NRC Administrative Letter 98-10, Dispositioning of Technical

Specifications That Are Insufficient To Ensure Plant Safety. The change shifted a

portion of the reactor pressure vessel P/T limits so that it required operation at a higher

RPV temperature than previously specified at certain pressures. The licensee correctly

invoked Administrative Letter 98-10 and took an action to issue a non-conservative TS

tracking form, prepared in accordance with procedure NOP-LP-4009, for the purpose of

alerting all TS holders of the changes to the P/T limit curves. The licensee also initiated

a corrective action to formally update the calculations from which the curves were

developed and, when the calculations were approved, to initiate the appropriate change

mechanism, a license amendment request, to formally update the TS P/T curves.

However, as of the November 2013 start of the current inspection, that calculation had

not been performed. The inspectors also noted that the procedure did not specify a time

requirement for the LAR submittal and did not clearly identify the organization

responsible to initiate a LAR for non-conservative TSs. A timeline of this issue is

presented below.

Timeline of Licensee Actions

09/11/2009 GE Hitachi (GEH) Nuclear Energy letter to FirstEnergy identified non-

conservative TS values through an Impact Assessment for Water Level

Instrumentation Nozzle Penetration on P/T curves provided to BWR

Owners Group (BWROG) members.

09/15/2009 CR 2009-64465 was initiated based on GEH letter; corrective action

CA-001 was initiated to seek revision to calculation EA-0246 to include

level instrument analyses.

10/02/2009 GEH letter File 0000-0106-1616 Rev. 1 to FirstEnergy identified level

instrument nozzle impact on P/T curves.

10/16/2009 Non-conservative TS tracking forms issued and placed into all

controlled copies of licensees TS manuals per NOP-LP-4009-04.

8 Enclosure

02/09/2010 CA-001, due February 10, 2010, extended to June 11, 2010, and

provided estimated schedule with GEH as primary contractor.

05/06/2010 CA-001, due June 11, 2010, was extended to February 28, 2011,

based on unacceptable proposal costs. The alternate BWROG revision

to the P/T limits topical report was chosen. No definitive schedule was

identified other than financial approval by the FENOC BWROG

representative in April 2010. Justification was based on low safety

significance.

02/14/2011 CA-001 due on February 28, 2011, was extended to August 12, 2011,

based on receipt of draft calculation from the BWROG contractor.

08/10/2011 Calculation EA 0272 was initiated on August 10, 2011, and was

approved on September 2. It used preliminary BWROG results to

incorporate the level instrument curve.

09/16/2011 CA-001, due August 12, 2011, was closed to CA-004 which added the

tracking of this item to the Design Basis Assessment Report which is

output quarterly.

03/15/2013 A proposal was received to update P/T curves for License Renewal by

incorporating the results of the capsule pulled in the recent refueling

outage, with inclusion of instrument line impact, and an additional note

to the curves for startup under a vacuum.

11/26/2013 CR 2013-18983, 2013 NRC PI&R: Timeliness Concern with Non-

Conservative Technical Specification 3.4.11, was initiated to address

the timeliness issue raised by the NRC.

Administrative Letter 98-10 contained two examples of untimely corrective action to

correct a non-conservative TS. The first example was a licensee that waited until after a

refueling outage to submit a license amendment. The second example a licensee that

waited over one year to submit an LAR. As of November 14, 2013, Perry had not

submitted an LAR license amendment after implementing administrative controls, over

four years and two operating cycles. Based on the two examples in 98-10, the

inspectors determined that Perrys corrective action to submit the LAR was not timely

and a violation of 10 CFR Part 50, Appendix B, Criterion XVI.

Analysis: The licensees failure to promptly correct a condition adverse to quality was a

performance deficiency and was more than minor in accordance with IMC 0612, Power

Reactor Inspection Reports, Appendix B, Issue Screening, dated September 12, 2012,

because the finding was associated with the area of Routine Operations Procedures

within the Procedure Quality attribute of the Barrier Integrity Cornerstone, and had the

potential to adversely affect the associated cornerstone objective of providing

reasonable assurance that physical design barriers (fuel cladding, reactor coolant

system, and containment) protect the public from radionuclide releases caused by

accidents or events. Specifically, without NRC approval of the revised P/T limits, the

inspectors did not have reasonable assurance the reactor vessel was not adversely

affected. The finding was evaluated using IMC 0609, Significance Determination

Process (SDP), Attachment 0609.04, Initial Characterization of Findings, dated

June 19, 2012, and IMC 0609, Appendix A, Exhibit 3 - Barrier Integrity Screening

Questions, dated June 19, 2012. Because the finding involved the RCS boundary

(e.g., pressurized thermal shock issues), the SDP directs the inspectors to stop and go

to the detailed risk evaluation section. The regional SRA determined that a detailed risk

evaluation was not required because operators followed the appropriate TS P/T curves

9 Enclosure

which were supported with approved licensee calculations. Therefore, there was no

impact to the RCS boundary as a result of this finding and the analyst concluded that

this issue was of very low safety significance. The finding has a cross-cutting aspect in

the area of human performance, decision-making, where licensee decisions

demonstrate that nuclear safety is an overriding priority. Specifically, from the time of

discovery of the non-conservative technical specification until now, various decisions

had been made by the licensee that have delayed the timely submittal of the license

amendment request (H.1(c)).

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,

requires, in part, that conditions adverse to quality be promptly identified and corrected.

Contrary to the above, the licensee failed to promptly correct a non-conservative

Technical Specification, a condition adverse to quality. Specifically, the inspectors

identified on November 14, 2013, that the licensee failed to promptly correct the non-

conservative TS 3.4.11 by not submitting the LAR in accordance with NRC

Administrative Letter 98-10, which specified submittal within one year or one operating

cycle. The licensee had determined TS 3.4.11, RCS Pressure and Temperature (P/T)

Limits, to be non-conservative on October 16, 2009, and implemented administrative

controls as allowed by the Administrative Letter. However, as of November 14, 2013,

the licensee had not submitted the LAR, over four years and two operating cycles after

determining TS 3.4.11 was non-conservative. Because the violation was of very low

safety significance and was documented in the licensees corrective action program

(as Condition Report CR 2013-18983), it is being treated as a Non-Cited Violation,

consistent with Section 2.3.2 of the Enforcement Policy (NCV 05000440/2013007-02,

Failure To Promptly Correct a Non-Conservative Technical Specification).

.2 Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating

Experience (OE) program. Specifically, the inspectors reviewed implementing OE

program procedures, attended CAP meetings to observe the use of OE information,

reviewed completed evaluations of OE issues and events, interviewed the OE

coordinator, and attended a weekly OE meeting which included representatives from

various departments. The intent of the review was to: (1) determine whether the

licensee was effectively integrating OE experience into the performance of daily

activities; (2) determine whether evaluations of issues were appropriate and conducted

by qualified individuals; (3) determine whether the licensees program was sufficient to

prevent future occurrences of previous industry events; and (4) determine whether the

licensee effectively used the information in developing departmental assessments and

facility audits. The inspectors also assessed if corrective actions, as a result of OE

experience, were identified and implemented effectively and timely.

b. Assessment

Overall, the inspectors determined that the licensee was adequately evaluating industry

OE for relevance to the facility. The licensee had entered all applicable items in the CAP

in accordance with the licensees procedures. Both internal and external OE was being

incorporated into lessons learned for training and pre-job briefs. The inspectors

10 Enclosure

concluded that the licensee was evaluating industry OE when performing root cause and

apparent cause evaluations.

Observations

The inspectors identified a potential weakness in the licensees documenting of the basis

for OE not requiring an evaluation. Specifically, once an OE was sent to the responsible

department as Information Only, the expectation was that if it were determined to need

an evaluation, then Corrective Action (CA) would be documented. Currently, however,

there was no documentation of the justification of why an evaluation was not required,

even if the OE were discussed in the weekly OE meeting. The licensee initiated

CR 2012-17901, Potential Improvement Item was Identified Regarding Information

Only OE Justification. The inspectors did not identify any OE for which an evaluation

had not been performed if required.

Findings

No findings were identified.

.3 Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the

CAP, prioritize and evaluate issues, and implement effective corrective actions, through

efforts from departmental assessments and audits. The inspectors reviewed audit

reports and completed assessments. The inspectors reviewed fleet assessments, site

Quality Assurance audits, and departmental self-assessments.

b. Assessment

Based on the self-assessments and audits reviewed, the inspectors concluded that

self-assessments and audits were typically accurate, thorough, and effective at

identifying issues and enhancement opportunities at an appropriate threshold. The

audits and self-assessments were completed by personnel knowledgeable in the subject

area, and the audits were thorough and critical. The inspectors observed that CAP

items had been initiated for issues identified through audits and self-assessments. The

inspectors reviewed the self-assessment performed on the CAP and found no issues

and generally agreed with the overall results and conclusions drawn.

Observations

The inspectors reviewed fleet oversight assessment reports since the third trimester of

2012. The assessments were found to be critical of site performance. For instance, the

2013 second trimester report concluded two of the site organizations ineffective and four

marginally effective (of 9 total organizations). Repeat comments and deficiencies noted

in these assessments included:

Workmanship issues due to procedure use,

Procedure compliance issues,

Lapses in accountability,

Issues with management intrusiveness, and

11 Enclosure

Concerns and issues over CAP implementation.

The relatively longstanding and repetitive nature of the issues identified support the

inspector conclusions that corrective actions to improve procedure use and adherence

were ineffective. The licensee was relying on the recently issued Strategic Improvement

Plant to improve and sustain a higher standard of human performance.

Findings

No findings were identified.

.4 Safety Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors assessed the licensees SCWE through the review of the licensees

employee concerns program (ECP), implementing procedures, discussions with the

coordinator of the ECP, interviews with personnel from various departments, and

reviews of issue reports.

An extensive SCWE review was conducted with multiple focus groups during the 2013

Inspection Procedure 95002 inspection that the NRC conducted in June. The results of

that review are contained in NRC Inspection Report 05000440/2013009 (ADAMS

Accession Number ML13224A382) and concluded the SCWE environment at Perry was

adequate. Therefore, for the current inspection, the inspectors conducted impromptu

interviews with plant personnel to verify the results of the 95002 inspection.

Approximately 20 people were involved in questions and discussions involving SCWE.

In addition to assessing individuals willingness to raise nuclear safety issues, the

interviews also addressed changes in the CAP and plant environment and management

over the past 2 years. Other items discussed included:

knowledge and understanding of the CAP,

effectiveness and efficiency of the CAP, and

willingness to use the CAP.

b. Assessment

The interviews and discussions reinforced the conclusion from the 95002 inspection that

the licensee has an environment where people are free to raise nuclear safety issues

without fear of retaliation. All of the individuals interviewed knew that in addition to the

CAP, they could raise issues to their immediate supervisor, the ECP, or the NRC. The

number of issues raised to the ECP and the subsequent investigations conducted by the

ECP personnel support the responses that personnel are knowledgeable and willing to

use this program.

Observations

A number of the people interviewed identified that one of the organizational issues was

staffing. This had also been identified as one of the major concerns during the 95002

inspection and continued to be an issue for employees although no nexus was drawn to

a SCWE issue. The licensee was aware of the staffs beliefs related to staffing.

12 Enclosure

Several comments indicated that there was an improvement with the communication of

the leadership at Perry. Both the Site Vice-President and the Plant Manager were newly

assigned to Perry since the 95002 inspection. Personnel commented that both

individuals appear to spend more time in the field communicating directly with them, and

appear to listen to their concerns. Continuing this behavior by the senior leadership

would likely result in an improvement to the SCWE.

Findings

No findings were identified.

4OA6 Management Meeting

.1 Exit Meeting Summary

On November 22, 2013, the inspectors presented the inspection results to

Mr. Harkness, the Site Vice-President, and members of his staff. The licensee

acknowledged the issues presented. The inspectors confirmed that proprietary

documents were appropriately returned or will be destroyed.

ATTACHMENT: SUPPLEMENTAL INFORMATION

13 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

E. Gordon, Supervisor, Performance Improvement

B. Blair, Manager - Maintenance

E. Harkness, Site Vice President

D. Hamilton, Director - Site Operations

N. Conicella, Manager - Regulatory Compliance

L. Zerr, Supervisor - Regulatory Compliance

J. Ellis, Director - Recovery

V. Veglia, Director - Maintenance

T. Veitch, Manager - Regulatory Compliance

R. Coad, Supervisor, Design Engineering

K. Coggins, Maintenance

NRC Personnel

M. Kunowski, Chief, Branch 5, Division of Reactor Projects

M. Marshfield, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000440/2013007-01 NCV Failure To Comply With Technical Specification 3.4.11

(Section 4OA2.1b.(2).1)05000440/2013007-02 NCV Failure To Promptly Correct a Non-conservative

Technical Specification (Section 4OA2.1b.(3).1)

Discussed

None

1 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does not

imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected

sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any part

of it, unless this is stated in the body of the inspection report.

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED

OPERABILITY EVALUATIONS

Number Description or Title Date or Revision

2012-03521 DG Ventilation Fans Cracking May 10, 2012

2013-07483-01 Condensate Transfer System Elevated Temperatures May 13, 2013

2013-13136 Turbine Stop Valve Testing August 25, 2013

PLANT PROCEDURES

Number Description or Title Date or Revision

GEI-0007-A Instructions For Cable And Wire Terminations 11

IOI-1 Cold Startup 37

IOI-4 Shutdown 19

NOBP-LP-2001 FENOC Self-Assessment And Benchmarking 19

NOBP-LP-2008 FENOC Corrective Action Review Board 14

NOBP-LP-2011 FENOC Cause Analysis 16

NOBP-WM-4003 FENOC Refurbishment Process 00

NOBP-WM-4300 Order Execute Process 12

NOPB-LP-2022 Compliance Auditing 11

NOPB-LP-2023 Conduct Of Fleet Oversight 12

NOP-ER-3004 FENOC Maintenance Rule Program 2

NOP-LP-2020 Quality Control Receipt Inspection 14

NOP-LP-4009 Requests For NRC Licensing Action 2

NOP-LP-4009-04 TS Tracking Form; RCS P/T Limits 3.4.11 October 16, 2009

NOP-OP-1009 Operability Determinations And Functionality 3

Assessments

NOP-OP-1012 Material Readiness And Housekeeping Inspection 7

Procedure

NOP-SS-3001 Procedure Review And Approval 19

NORM-LP-2003 Analytical Methods Guidebook 4

PAP-0204 Housekeeping/Cleanliness Control Program 26

PYBP-PNMD-005 Maintenance Mentoring Process 00

PYBP-POS-5-11 Operations Work Control Unit (WCU) Guide 11

SOI-G33 Reactor Water Cleanup System 38

SVI-B21-T1176 RCS Heatup Data, Table 1 June 4, 2011

SVI-B21-T1176 RCS Heatup Data, Table 1 October 18, 2011

SVI-B21-T1176 RCS Heatup Data, Table 1 March 3, 2012

SVI-B21-T1176 RCS Heatup Data, Table 1 June 17, 2012

SVI-B21-T1176 RCS Heatup Data, Table 1 May 11, 2013

SVI-B21-T1176 RCS Cooldown Data, Table 1 June 16, 2013

2 Attachment

Number Description or Title

2008-48338 High Water Content In U2 Startup XFMR Oil

2010-82586 Unit 2 Startup XFMR Oil Sample Results Indicate High Moisture

Content

2011-06031 2011 AFI MA. 1-1 Maintenance Consistent Use Of Procedures And

Work Orders As Written

2011-06137 Declining Ownership With CAP And OE Due Dates

2011-06714 Focused Self-Assessment Recommendation Four Actions From

Industry Peers To Be Tracked In CAP

2011-07124 Lack Of Work Preparation/Execution Not Limited To, But Including

Div-1 AOT

2012-00212 Historical Review Of Oil Analysis On Aux Transformer Reviewed

IEEE Condition 1 Limits Exceeded

2012-00386 Work Could Not Be Performed As Scheduled During Div 2 EDG

Outage

2012-00400 SLC Pump A Unavailable In Narrative Log But Not In A Timely

Manner

2012-00406 Voltage Found During Live Dead Live Check

2012-00615 SN-SA-2012-006: Deficiencies Found With OE Reviews During FP

Self-Assessment

2012-00658 Activity To Perform Line Kill Of RFPT B Casing Drain Line Was

Unsuccessful

2012-00798 Adverse Trend - Declining Performance In Maintenance Training

Programs (IP-SA-2012-0001)

2012-01073 TSC UPS B Abnormal DC Voltage Alarm

2012-02767 Unexpected Trip Of S-621 And S-620

2012-03809 Rigging Issue During Removal Of A Beam In Dry Cask Storage

Project

2012-06153 Loss Of Control For The Seismic Restraint For The Dry Cask

Storage Project

2012-11886 RWCU Isolation Pump Trip During SVI Restoration

2012-01516 PY-PA-12-01 The CAP Performance Was Rated Marginally Effective

For The 3rd Trimester Of 2011

2012-01908 Review Of All Site Condition Reports From January Identified A

Trend Of Repeat Issues

2012-02678 MS-C-12-01-13, Issues Identified Pertaining To GL-89-13 Program

2012-02794 MS-C-12-01-13, Test Equipment Uncertainties Not Accounted In

Valve Testing

2012-02911 CNRB Recommendation: Capture Feedback From NRC PI&R

Inspection Debrief

2012-03231 Manual Reactor SCRAM 1-12-01 Occurred at 02:24 March 1, 2012

2012-03720 Unexpected Breaker Trip During Uncoupled Run

2012-03840 Miscommunication Of Emergency Diesel Generator Ventilation Fan

Air Flow Compensation Requirements

2012-06167 Actions Taken In Response To CR11-89188 Are Outside The

Corrective Action Program

2012-06485 Procedure Adherence Issues During Unit 1 Division 2 Battery

Charge

2012-06660 Feedwater Heater 5A Leak As Reported Is Above An ODMI Trigger

Point

3 Attachment

2012-06973 NRC NCV, Inadequate Risk Evaluation For Main Generator Stator

Water Cooling System Maintenance Resulted In A Manual Reactor Scram

2012-07882 NRC NCV, Inadequate Procedure Resulted In Loss Of High-

Pressure Core Spray Function

2012-09931 Supplemental Personnel Injured During Scaffold Modification

2012-10293 PA-PY-2012-02, Maintenance CAP Implementation Issues

2012-11148 PYSP IPAT 1st Half of 2012- Emerging Trend Identified Related To

An Increase In Human Performance Events Within the Section

(IP-SA-2012-0119)

2012-11369 Belt Installed On TB Supply Fan B, Unsafe Act

2012-12152 Declining CAP Health Indicators

2012-12349 July CAP Performance Indicator Shows A Declining Trend In Cause

Evaluation Quality

2012-12674 Missed SVI Unit 1 Division 1 Battery

2012-13408 FO-SA-2012-0013: Activities Are Being Inappropriately Designated

A Different Color Of Risk Than What Is Assessed Per NOP-OP-1007

2012-13758 Ineffective Communications During Pre-Job Brief Resulted In Drilling

Through Rebar Without Prior Engineering Approval

2012-15950 SN-SA-0220 Perry Nuclear Safety Culture Review Self-Assessment-

Principle 7

2012-16671 The 3rd Quarter Safety Culture Monitoring Meeting Held On

October 19, 2012 Determined That Safety Culture Attribute If Needs

Further Review And Attention

2012-16828 Work Group Unprepared to Start Task For Hot Short Modification

Causes Un-necessary Unavailability Time For Division 1 Diesel

2012-18618 Chemistry Section Was Rated RED For The 2012 SCWE Survey

Pillar

2012-19535 XCAP Precursor Issues In Cross-Cutting Aspect H.4(a)

2013-00013 Data Suggests That The Importance Placed On The Corrective

Action Program Is Not Where It Needs To Be For The Station

2013-00511 TB West Crane Deficiencies Not Entered Into CAP And Resolution

Not Documented In WO 200493418

2013-00826 FO-SA-2011-0017, Based On The Number Of Issues Of Issues

Identified Similar In Nature To Previously Identified Issues. The

Corrective Actions Taken Have Been Less Than Fully Effective

2013-00753 Clearance Not Adequate For Work To Be Performed

2013-01011 Inverter 1R14S0004 Found On Alternate Source With The Fila Light

On Following Reactor Scram

2013-01476 PY-C--13-01-01, Clearance Revision Process Described In NOP-

OP-1001 Is Not Being Followed

2013-01965 CARB Identified Line Ownership Of The CAP Is Inconsistent And Is

Delaying Improvement Of The Implementation Of CAP At Perry

2013-03005 Snapshot Self-Assessment SN-SA-2012-0079, Found Project

Section That Had One LACE CR That Required Cause Code(s)

2013-03016 MS-C-13-02-22, CR 2012-13758 Interim Effectiveness Review Not

Adequately Reviewed Or Issues Identified In CAP

2013-03223 Corrective Actions Assigned In CR 2013-00478 Do Not Address

Apparent Cause Identified

2013-04435 Valve Found Out-of-Position

4 Attachment

2013-05236 Resolution Of A Condition Adverse To Quality (Non-Conservative

Technical Specification) Is Not Being Tracked In The Corrective

Action Program

2013-05741 NRC Cross-Cutting Theme In Human Performance Aspect H.4(a)

2013-05809 Potential Trend: There Have Been Nine Overdue CAP Products

Between March 31, 2013 And April 14, 2013

2013-05993 MS-C-13-02-22: Perry Corrective Action Program Implementation

Rated Marginally Effective

2013-06207 Auto Start Of 1M15C0001A During SVI-R43-T7000A. On April 15,

2013, Was Not Documented In CAP

2013-06479 P-1925 Could Inappropriately Credit RHR Availability For Decay

Heat Removal In Defense-In-Depth When ADHR Is In Service

2013-07473 Level Transient During Performance Of PTI-N27-P0012

2013-07582 Conditional Release Of 1P11-F0545

2013-07585 Valve Refurbishment Did Not Follow NOBP-WM-4003

2013-07665 Field Wiring Did Not Match Drawing 209-0158-00003 For The AT

Junction Box In The Generator Alterex Cabinet

2013-07881 NRC FIN, Failure To Perform Vendor Recommended Preventative

Maintenance

2013-07883 NRC NCV, Valve Mis-Position Causes SDV Level Detector

Inoperability

2013-07884 NRC NCV, Failure To Follow Procedures For Conducting A Standby

Liquid Control System Surveillance

2013-08962 PA-PY-13-01 Organizational Effectiveness Rated Marginally

Effective For 1st Trimester 2013

2013-09086 Potential Debris/Missile Material Stored Outside Of MB-100

2013-09461 Cross Cutting Aspect H(3).b For NCV 05000440/2013002-01 Not

Evaluated In CR2013-03863 Or CR2013-03781

2013-09486 SN-SA-2013-0144, CA 2011-97640-001 Not Implemented As Stated

In Corrective Action Closure Comments

2013-09601 Safety Concern Roof Top Workers

2013-09637 License Amendment Implementation Completed Prior To

Amendment Approval

2013-10222 Changes In Procedures Effect On MSPI Not Evaluated

2013-11771 Five Rosemount Trip Units Have Demonstrated Drifts That Warrants

Accelerated Replacement In Accordance With POD 2012-10238

2013-13040 MN-ID: Adverse Trend In Material Handling

2013-13272 NRC 95002 NCV, RWCU Valve Misposition, Elevated Temperatures

In Condenser Transfer Piping

2013-13274 NRC 95002 NCV, Unexpected RPV Level Transient During

Performance Of PTI-N27-P0012, Procedure Was Not Appropriate To

The Circumstances

2013-13420 RP Root Cause CR 2013-09891 Was Rejected By CARB On August

26, 2013 Due To Numerous Changes And Low Grading Score

2013-13992 FO-SA-2012-0025, PI&R: Review of CR-2011-06037, Maintenance

Corrective Action Implementation Issues

2013-16086 Unit 1 Start-up Transformer Oil Quality Exceeded Established Trend

Plan Limits

2013-18180 2013 NRC PI&R: Potential Improvement Item Was Identified

Regarding Justification For No Maintenance Rule Evaluation

5 Attachment

2013-18689 2013 NRC PI&R: TS 3.4.11 RCS P/T Limits Comprehension

2013-18696 2013 NRC PI&R: Deficiency Found In Execution Of Work Order 20056349, Replacement Of 1P11F0545

2013-18704 2013 NRC PI&R: Planning Deficiency In Work Order 200563495,

Replacement Of P11F0545

CR-G202-2009-56349 Loss Of Non-Essential 480 V BUS F-1-C And F-1-D.

CR-G202-2009-66058 Recirculation Pump A Trip On Failure To Transfer To Slow Speed

CR-G202-2010-76727 Reactor Scram

ML14003A186

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