IR 05000440/2018001

NRC Integrated Inspection Report 05000440/2018001

ML18129A406
Person / Time
Site:	Perry
Issue date:	05/09/2018
From:	Billy Dickson NRC/RGN-III/DRP/B5
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
IR 2018001
Download: ML18129A406 (20)

Text

UNITED STATES May 9, 2018

SUBJECT:

PERRY NUCLEAR POWER PLANTNRC INTEGRATED INSPECTION REPORT 05000440/2018001

Dear Mr. Hamilton:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline inspection at your Perry Nuclear Power Plant. On April 4, 2018, 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.

Based on the results of this inspection, the NRC has identified one issue that was evaluated under the traditional enforcement process. The NRC determined that the issue was a NRC-identified Severity Level IV violation. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation, 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Billy Dickson, Chief Branch 5 Division of Reactor Projects Docket No. 50-440 License No. NPF-58 Enclosure:

Inspection Report 05000440/2018001 cc: Distribution via ListServ

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting an integrated quarterly inspection at Perry Nuclear Power Plant Unit 1 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. An NRC violation and additional items are summarized in the tables below.

List of Findings and Violations Failure to Notify the NRC within 60 Days of a Condition Prohibited by Technical Specifications Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable Severity Level IV Not Applicable 71153 NCV 05000440/2018001-01 Closed The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.73, Licensee Event Report System, for the licensees failure to report a condition that was prohibited by the plants Technical Specifications to the U.S. Nuclear Regulatory Commission (NRC) within 60 days. Specifically, the licensee did not report a condition that, as determined by the NRC, rendered the Division 2 Diesel Generator (DG) inoperable for a period longer than the Technical Specification allowed completion times of its associated required actions.

Additional Tracking Items Type Issue Number Title Report Status Section LER 05000440/2018-001-00 Loss of Safety Function 71153 Closed and Violation of Technical Specifications due to Diode Failure LER 05000440/2017-007-00 High Pressure Core Spray 71153 Closed Inoperability due to System Leak LER 05000440/2017-006-00 Loss of Safety Function 71153 Closed due to the Inoperability of Both Trains of Motor Control Center Ventilation LER 05000440/2017-002-00 Loss of Safety Function 71153 Closed due to Main Turbine Bypass Valve Opening

TABLE OF CONTENTS

PLANT STATUS

INSPECTION SCOPES

............................................................................................................

REACTOR SAFETY

.................................................................................................................

RADIATION SAFETY

...............................................................................................................

OTHER ACTIVITIES - BASELINE

...........................................................................................

INSPECTION RESULTS

..............................................................................................................

EXIT MEETINGS AND DEBRIEFS

............................................................................................ 11

DOCUMENTS REVIEWED

......................................................................................................... 11

PLANT STATUS

The plant operated at, or near, full power from January 1, 2018, until February 24, 2018, when

power was lowered to approximately 60 percent power to perform a rod sequence exchange

and to perform corrective maintenance on the steam system. The plant returned to full power

on February 25, 2018, and remained at, or near, full power for the remainder of the inspection

period with minor reductions in power to support routine surveillances.

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 plant status activities described

in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152,

Problem Identification and Resolution. 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.

REACTOR SAFETY

71111.01Adverse Weather Protection

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the

onset of extremely cold weather.

71111.04Equipment Alignment

Partial Walkdown (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) High Pressure Core Spray and Division 3 DG on February 28, 2018;

(2) Emergency Service Water (ESW) 'A' on February 26 and 27, 2018; and

(3) Division 2 DG on February 16, 2018.

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the Standby

Liquid Control system the week of January 29, 2018.

71111.05AQFire Protection Annual/Quarterly

Quarterly Inspection (4 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Control Complex 574 foot elevation; Fire Zones 0CC-1A, B, and C on

February 16, 2018;

(2) Control Complex 599 and 654 foot elevations; Fire Zones 2 and 5A on March 2, 2018;

(3) Intermediate Building 574, 585, and 599 foot elevations; Fire Zones 0IB-1 and 0IB-2 on

February 27, 2018; and

(4) Division 3 DG room; Fire Zone 1DG-1b on February 9, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated a crew of licensed operators responses to an

Anticipated-Transient-Without-Scram accident in the licensees simulator during licensed

operator requalification training on February 12, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated licensed operators response to alarms and control and

coordination of activities involving heightened risk in the control room on January 9, 18, 29,

and 30, 2018. Observed activities included an ESW surveillance, crew response to a

service water header low pressure alarm, and an invalid area high radiation alarm in the

turbine building.

71111.12Maintenance Effectiveness

Routine Maintenance Effectiveness (2 Samples)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) Vital Direct Current electrical systems; and

(2) High Pressure Core Spray System.

71111.13Maintenance Risk Assessments and Emergent Work Control (5 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) Division 2 DG abnormal noise during run on January 31, 2018;

(2) Division 1 Residual Heat Removal (RHR) out-of-service for Division 1 Remote Shutdown

Panel testing on February 20, 2018;

(3) Control Rod Drive (CRD) Pump 'A' replacement from February 26 through

March 1, 2018;

(4) Average Power Range Monitoring (APRM) System C upscale alarm repair on

March 7, 2018 through March 8, 2018; and

(5) The ESW Sluice Gate A maintenance; Hydrant 24 (fast fire water) repairs; Service

Water Pump C maintenance on March 19 through March 20, 2018.

71111.15Operability Determinations and Functionality Assessments (7 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) Flex Bay 2 equipment availability determination from January 2 through 5, 2018;

(2) Area radiation monitors, functionality assessment on January 9, 19, and

February 9, 2018;

(3) Fast fire water alternate injection availability determination from January 31 through

February 1, 2018;

(4) Division 2 DG abnormal noise during run on January 31 and February 1, 2018;

(5) Class 1E 480 VAC bus voltage indicating high out-of-band operability determination on

February 5, 2018;

(6) Reactor Core Isolation Cooling (RCIC) waterleg pump high vibrations on

February 12, 2018; and

(7) Scaffolding and housekeeping issue from February 9 through March 1, 2018.

71111.18Plant Modifications (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) High Pressure Core Spray system minimum flow piping through wall leak weld overlay.

71111.19Post Maintenance Testing (5 Samples)

The inspectors evaluated the following post maintenance tests:

(1) The RCIC maintenance outage on January 30, 2018;

(2) Division 2 DG abnormal noise troubleshooting/repairs on February 1, 2018;

(3) Unit 1 Division 3 battery replacement from February 5 through February 20, 2018;

(4) CRD Pump A replacement from February 26 through March 1, 2018;

(5) ESW Sluice Gate A maintenance from March 19, 2018 through March 23, 2018.

71111.22Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (4 Samples)

(1) Standby Liquid Control B pump and valve operability test on February 2, 2018;

(2) Division 1 Remote Shutdown Panel testing on February 20 and 21, 2018;

(3) Reactor Pressure Vessel (RPV) Steam Dome and RHR cut-in permissive high pressure

channel 'B' calibration on February 28 and March 1, 2018; and

(4) Emergency Core Cooling System (ECCS) Drywell pressure high channel 'B' calibration

on March 1, 2018.

In-service (1 Sample)

(1) ESW Pump 'B' and valve operability test on January 29, 2018.

71114.06Drill Evaluation

Drill/Training Evolution (1 Sample)

The inspectors observed a simulator evolution for licensed operators on

February 12, 2018, which required emergency plan implementation and included in the

licensees performance indicator for drill and exercise performance.

RADIATION SAFETY

71124.01Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours - 1 Sample (January 1, 2017, through

December 31, 2017);

(2) IE03: Unplanned Power Changes per 7000 Critical Hours - 1 Sample (January 1, 2017,

through December 31, 2017); and

(3) IE04: Unplanned Scrams with Complications - 1 Sample (January 1, 2017, through

December 31, 2017).

71152Problem Identification and Resolution

Semiannual Trend Review (1 Sample)

The inspectors reviewed the licensees corrective action program from July 1, 2017, through

December 31, 2017, for trends that might be indicative of a more significant safety issue.

Annual Follow-Up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) CR 2017-12527; Flex Storage Bay #2 ambient temperature before 40 degrees

Fahrenheit, and multiple temporary heaters not being pre-staged for extreme cold

weather preparations; and

(2) CR 2018-00132; Effects of internal flooding in the Control Complex 620 elevation

hallway and switchgear rooms.

71153Follow-Up of Events and Notices of Enforcement Discretion

Licensee Event Reports (4 Samples)

The inspectors evaluated the following licensee event reports which can be accessed at

https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) Licensee Event Report (LER) 05000440/2017007-00; High Pressure Core Spray

Inoperability due to System Leak on March 14, 2018;

(2) LER 05000440/2017006-00; Loss of Safety Function due to the Inoperability of Both

Trains of Motor Control Center Ventilation on March 15, 2018;

(3) LER 05000440/2017002-00; Loss of Safety Function due to Main Turbine Bypass Valve

Opening on March 16, 2018; and

(4) LER 0500440/2018001-00; Loss of Safety Function and Violation of Technical

Specifications due to Diode Failure on March 31, 2018.

INSPECTION RESULTS

71152Problem Identification and Resolution

Observation 71152Semi-Annual Trend Review

The licensee and other external organizations noted several trends during reviews of

activities, events, and issues that occurred in the last six months of 2017. Two trends stood

out. The first was that the causes of important recurring issues were not broadly investigated.

The trend also questioned if remaining planned actions were sufficient to arrest the issues.

The result has been longstanding performance issues in the areas of controlling foreign

material, industrial safety, chemical control, and lifting and rigging. The second trend was

more broadly focused on procedure use and adherence, which the inspectors determined

from two more narrowly focused trends identified by the licensee. These two trends were

shortfalls in the application of maintenance fundamentals contributing to some recent

operational challenges and workers did not always recognize the importance of conscious

implementation of error prevention techniques during planned daily activities. The results

were unplanned entries into Technical Specification limiting condition of operations action

statements, increased potential for damage to equipment, missed Technical Specification

surveillance requirements, unavailability of safety systems, material falling into open fuel

pools, improper dose control, and preventable injuries. Each issue was minor in terms of

significance, but, when reviewed in aggregate, revealed a trend in behaviors that might lead to

more significant issues in the future. The inspectors determined that the licensee had and

continued to take actions to address the identified issues and the behaviors that contributed to

the trends.

Observation 71152Annual Follow-Up of Selected

Issues

For each sample documented in this inspection report (IR), the inspectors confirmed that both

the actions taken and the actions planned by the licensee were appropriate based on the

individual circumstances identified in the condition reports. Specifically, for the Flex

equipment maintained in Storage Bay No. 2, the licensee removed the diesel fuel from the

N+1 air compressor to prevent the diesel fuel from gumming up the injectors at reduced

temperatures. In addition, the licensee developed an action plan to install heaters in the

storage bay to maintain temperatures above 40 degrees Fahrenheit before the onset of

extremely cold weather in the fall of 2018. For the flooding concerns, the licensee has

updated the calculations regarding the effects of internal flooding in the Control Complex 620

elevation switchgear rooms for the fire water piping that was not previously accounted for.

The new calculations showed that additional water would not adversely affect the equipment

in the switchgear rooms.

71153Follow-Up of Events and Notices of Enforcement Discretion

Failure to Notify the NRC within 60 Days of a Condition Prohibited by Technical Specifications

Cornerstone Severity Cross-Cutting Aspect Report

Section

Not Applicable Severity Level IV Not Applicable 71153

NCV 05000440/2018001-01

Closed

The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.73, Licensee

Event Report System, for the licensees failure to report a condition that was prohibited by

the plants Technical Specifications to the NRC within 60 days. Specifically, the licensee did

not report a condition that, as determined by the NRC, rendered the Division 2 DG inoperable

for a period longer than the Technical Specification allowed completion times of its associated

required actions.

Description:

In a letter dated August 24, 2017 (IR 05000440/2017010; ML17236A187), the NRC provided

the final significance determination of the preliminary White finding discussed in NRC

IR 05000440/2017009, dated June 5, 2017 (ML17156A750). The August 24 letter and its

enclosures document the NRCs position that a performance deficiency associated with a

diode installation on the Division 2 DG emergency start circuit rendered the DG inoperable

from April 2, 2015 until November 8, 2016. Technical Specification 3.8.1 allow a 14-day

completion time to restore an inoperable D

G. If the DG is not restored in 14 days, there are

required actions to be in Mode 3 and Mode 4 with completion times of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

respectively. Since the DG was not restored within the required completion times and the

plant was not in Mode 3 with the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the NRC determined that a violation of the

Technical Specifications occurred. As such, the inspectors determined a License Event

Report (LER) for a condition which was prohibited by the plants Technical Specifications was

required. An LER is required if a condition existed for a time longer than permitted by the TS

(i.e., greater than the total allowed restoration and shutdown outage time (or completion time

in the STS)), even if the condition was not discovered until after the allowable time had

elapsed and the condition was rectified immediately upon discovery.

Although the NRC documented the violation of a condition prohibited by the plants Technical

Specifications in an IR, a LER is still required. NUREG 1022 provides additional guidance for

such a situation. Despite the fact the NRC identified a reportable event or condition to the

licensee via inspection activities, Section 2.6 of the NUREG states, in part, that such

conditions do not satisfy 10 CFR 50.73. The regulations in 10 CFR 50.73 specifically require

a submittal of a written LER for an event or condition that meets the criteria stated in those

rules. Therefore, a LER was required within 60 days of August 24, 2017, the date of the final

significance determination letter. No LER was submitted until March, 2018.

Corrective Action: The licensee submitted LER 05000440/2018-001-00 on

March 28, 2018.

Corrective Action Reference: CR 2018-01763

Performance Assessment:

The inspectors determined this violation was associated with a minor performance deficiency.

Enforcement:

The Reactor ROPs significance determination process does not specifically consider the

regulatory process impact in its assessment of licensee performance. Therefore, it is

necessary to address this violation which impedes the NRCs ability to regulate using

traditional enforcement to adequately deter non-compliance.

Violation: Title 10 CFR 50.73(a)(2)(i)(B), Licensee Event Report System, requires, in part

that the licensee shall report any operation or condition which was prohibited by the plants

Technical Specifications within 60 days of discovery of the condition.

Contrary to the above, the licensee failed to notify the NRC within 60 days of receiving the

final determination that the licensee was in a condition prohibited by technical specifications.

Specifically, as determined by the NRC on August 24, 2017, the Division 2 DG was

inoperable from April 2, 2015, until November 8, 2016, which exceeded the allowed

completion times. The licensee did not submit the LER until March 28, 2018.

Severity: IV

Disposition: This violation is being treated as a NCV, consistent with Section 2.3.2 of the

NRC Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public

disclosure. No proprietary information was documented in this report.

• On March 30, 2018, an interim exit meeting was conducted for the inspection results of the

Radiation Safety Program review with Mr.

F. Payne, Plant General Manager, and other

members of the licensee staff.

• On April 4, 2018, the inspector presented the resident inspector quarterly report inspection

results to Mr. D. Hamilton and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.01Adverse Weather Protection

- CR 2017-12527; Flex Storage Bay No. 2 Ambient Temp Below 40F; December 31, 2017

- CR 2017-12528; Temp Heaters not Staged per Needs of ONI-R36-2; December 31, 2017

- ECP 14-0283-000; Flex Storage Modifications; Revision 4

- eSOMS Plant Narrative Logs; January 1,2, 6, and 7, 2018

- IOI-0015; Seasonal Variations; Revision 29

- ONI-R36-2; Extreme Cold Weather; Revision 8

71111.04Equipment Alignment

- CR 2018-01018; Standby Liquid Control Storage Tank Level Rising; February 5, 2018

- PDB-H0001; 125 VDC Bus ED-1-A; Revision 2

- PDB-H0007; EF-1-A Load List; Revision 2

- PDB-H0008; EF-1-B Load List; Revision 2

- PDB-H0009; EF-1-C Load List; Revision 1

- PDB-H0010; EF-1-D Load List; Revision 2

- VLI-C41; Standby Liquid Control System; Revision 8

- VLI-E22A; High Pressure Core Spray; Revision 10

- VLI-P45; Emergency Service Water System; Revision 19

- VLI-R44/E22B; Division 3 Diesel Generator; Revision 10

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

- VLI-R45/E22B; Division 3 Diesel Generator; Revision 3

- VLI-R45; Division 1 and 2 Diesel Generator Fuel Oil System (Unit 1); Revision 5

- VLI-R46/E22B; Division 3 Diesel Generator; Revision 6

- VLI-R46; Division 1 and 2 Diesel Generator Jacket Water Systems (Unit 1); Revision 4

- VLI-R47/E22B; Division 3 Diesel Generator; Revision 4

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

- VLI-R48/E22B; Division 3 Diesel Generator; Revision1

- VLI-R48; Division 1 and 2 Diesel Generator Exhaust, Intake and Crankcase Systems;

Revision 6

71111.05AQFire Protection Annual/Quarterly

- CR 2018-02027; U.S. Nuclear Regulatory Commission (NRC) ID: Electrical Wiring in the

Unit 2 NLO Break, Brief, and Locker Area is not Permanent; March 6, 2018

- FPI-0CC; Control Complex; Revision 10

- FPI-0IB; Intermediate Building; Revision 9

- FPI-1DG; Diesel Generator Building; Revision 8

- FPI-1RB; Reactor Building; Revision 4

- FPI-A-A01; Preparation, Review and Approval of Pre-Fire Plan and Fire Protection

Instructions; Revision 5

- FPI-A-B01; Fire Brigade Station, Equipment Inspection and Maintenance; Revision 8

- PAP-1910; Fire Protection Program; Revision 39

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

- eSOMS Plant Narrative Logs; February 1 and 2, 2018

- eSOMS Plant Narrative Logs; January 9, 18, 29, 30, 2018

- NOBP-TR-1151; Nuclear Operating Business Practice; Revision 4

- NOP-OP-1002; Conduct of Operations; Revision 12

- NOP-OP-1009; Operability Determinations and Functionality Assessments; Revision 7

- OTLC-30582806-PY-SGC2 Cycle 6 2018 Evaluate Scenario C2; Revision 0

71111.12Maintenance Effectiveness

- CR 2014-16991; Sludge Found In High Pressure Core Spray (HPCS) Fast Fire Water

Injection Line; November 13, 2014

- CR 2017-09920; Unit 1 Division 3 Reserve Battery Charger Identified Minor Oil Leakage on

the C2, C3, and C4 Capacitors; August 17, 2016

- CR 2018-02185; NRC ID: Documentation Concerns Identified with the Replacement of the

Unit 1 Division 3 Battery; March 9, 2018

- Drawing Number 302-0701-00000; High Pressure Core Spray System; Revision KK

- ECP 17-03760; Temporary Repair of a Pinhole Leak in High Pressure Core Spray Elbow with

a Weld Overlay; December 24, 2017

- Perry Nuclear Power Plant, Plant Health Report 2017-01-E22A-High Pressure Core Spray

System; July 31, 2017

- Perry Nuclear Power Plant, Plant Health Report 2017-02-E22A-High Pressure Core Spray

System; January 31, 2018

- Perry Nuclear Power Plant, Plant Health Report 2017-02-R42-DC Systems (Batteries,

Chargers, and Switchgear); January 31, 2018

- SVI-E22-T5213; Service Test of Battery Capacity-Division 3 (Unit 1); Revision 11

- SVI-E22-T5217; Performance Test of Battery Capacity-Division 3 (Unit 1); Revision 13

- WO 200189778; Replace HPCS Pump Discharge Pressure Transmitter; May 14, 2016

- WO 200451459; Replace All Cells in the Unit 1 Division 3 Battery; February 20, 2018

- WO 200623170; Sludge Downstream of 1E22F0031 CR 2014-16991 Documents the Sludge

Condition. Remove Subject Sludge; May 12, 2016

- WO 200630320; Repair Unit 1 Division 1 Normal Charger; January 28, 2015

- WO 200644355; Partial PMI-0030 HPCS Test Return to Suppression Pool Valve; May 9, 2017

- WO 200644356; Partial PMI-0030 HPCS Suppression Pool Suction Valve; May 11, 2017

- WO 200644361; Partial PMI-0030 HPCS Injection Valve; May 9, 2017

- WO 200647793; Inservice Inspection (ISI) Examinations of HPCS Snubber; March 3, 2017

- WO 200657000; Partial PMI-0030 HPCS Condensate Storage Tank (CST) Suction Isolation;

August 7, 2017

- WO 200673604; Repair Normal Charger EFD-1-A, Float Voltage would not Adjust in Band;

February 16, 2016

- WO 200690712; Replace Capacitors C3, C4, and C5 (Minor Leaking) on Division 3 Battery

Charger; June 9, 2017

- WO 200690740; Local Leak-Rate Test (LLRT) Support-E22T9409 (1E22D0005);

March 14, 2017

- WO 200702207; Repair Instrument Root for HPCS Test Pressure Instrument;

January 14, 2017

71111.13Maintenance Risk Assessments and Emergent Work Control

- CR 2018-02059; APRM C Upscale Alarm Locked in; March 7, 2018

- NOP-OP-1007; Risk Management; Revision 24

- NOP-WM-1001; Order Planning Process; Revision 28

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

- SOI-C51; APRM; Revision 19

- SOI-P45/49; Emergency Service Water and Screen Wash Systems; Revision 31

- SOI-P45/49; Sluice Gate Maintenance; Revision 7

- WO 200170891; Clean and Inspect Bus L21; March 19, 2018

- WO 200612097; Replace Control Rod Drive (CRD) Pump A; February 26, 2018

- WO 200674968; Inspect/Lubricate/Test Sluice Gate; March 19, 2018

- WO 200741192; Investigate Abnormal Noises Division 2 EDG; February 1, 2018

- WO 200744564; T/S Repair APRM C Upscale Locked in; March 8, 2018

71111.15Operability Determinations and Functionality Assessments

- Calculation PSTG-0001; PNPP Class 1E Power Distribution System Voltage Study;

Revision 8

- CR 2018-00208; 1D21-K162 (Area Rad Monitor Turbine Room West) Alert and High Alarms;

January 9, 2018

- CR 2018-00755; Underground Fire Service Water Leak Identified; January 28, 2018

- CR 2018-00825; Post Event 4.0 Crew Critique for the ONI-ZZZ-06 Entry for the Fire Water

Leak at Hydrant 24, January 30, 2018

- CR 2018-00905; Class 1E 480 Bus Voltage Indicating High out of Band per Plant Equipment

Rounds; February 1, 2018

- CR 2018-01060; Div. 3 Diesel Supply Fan, 1M43C0002C, Relay Chattering During Operation;

February 6, 2018

- CR 2018-01193; NRC ID: CR 2018-00208 May not have Fully Identified the Issue;

February 9, 2018

- CR 2018-01227; RCIC Water Leg Pump Vibrations High; February 12, 2018

- CR 2018-01407; NRC ID: Control Complex 574 Elevation Scaffold Laydown Area Storage in

Close Proximity to Control Complex Chill Wwater; February 16, 2018

- CR 2018-01741; NRC ID: IB 599 Scaffold Storage Area Improperly Stored;

February 27, 2018

- CR 2018-01741; NRC ID: IB 599 Scaffold Storage; February 27, 2018

- CR 2018-01785; NRC Identified Shielding Equipment not Stabilized; February 28, 2018

- CR 2018-0887, Abnormal Noise during Division 2 EDG Run; January 1, 2018

- CR G202-2008-40964; Component Design Basis Inspection (CDBI) Concern Grid Voltage

Above Maximum Analyzed Limit; May 28, 2008

- ECP 14-0283-000; Flex Storage Modifications; Revision 4

- EOP-SPI4.6; Fast Fire Water Alternate Injection; Revision 1

- eSOMS Plant Narrative Log; January 9, 2018

- eSOMS Plant Narrative Logs; January 1 and 2, 2018

- eSOMS Plant Narrative Logs; January 28 and 29, 2018

- FCR 24484; Scaffold Storage; November 12, 1997

- ICI-B22-2; AC Switchboard and Panel Voltmeters (B22-2); Revision 4

- IOI-0015; Seasonal Variations; Revision 29

- NOP-LP-7300; FLEX Program for the Perry Nuclear Power Plant (PNPP); Revision 1

- NOP-MM-5008; Control of Scaffolding; Revision 1

- NORM-OP-1012; Material Readiness and Housekeeping Inspection Program Areas and

Owners; Revision 4

- ONI-R36-2; Extreme Cold Weather; Revision 8

- ONI-S11; Hi/Low Voltage; Revision 10

- PAP-0204; Housekeeping / Cleanliness Control Program; Revision 29

- PAP-0204; Housekeeping/Cleanliness Control Program; Revision 29

- PDB-H0007; EF-1-A Load List; Revision 2

- PDB-H0008; EF-1-B Load List; Revision 2

- PDB-H0009; EF-1-C Load List; Revision 1

- PDB-H0010; EF-1-D Load List; Revision 2

- PDB-R0003; Flex Specifications; Revision 2

- SOI-D21; Area Radiation Monitoring System; Revision 4

- SVI-R10-T5228; On-Site Power Distribution System Verification; Revision 7

- Updated Safety Analysis Report (USAR) 9.4; Revision 12

71111.18Plant Modifications

- 1E22G003A Addendum No. A-01; Pipe Stress Analysis 1E22G003A; Revision 3

- CR 2017-12407; Through-Wall Leak in HPCS Min Flow Piping Elbow; December 23, 2017

- ECP No. 17-0423-001; Weld Overlay on Through-Wall Leak in HPCS Minimum Flow Piping

Elbow; Revision 0

- NOP-CC-5762; Appendix VIII Procedure for Ultrasonic Examination of Ferritic Pipe Welds;

Revision 2

- NOP-M-5008; Control of Scaffolding; Revision 1

- NQI-0946; Digital Ultrasonic Thickness Measurement; Revision 12

- Report No. 0942-17B-051; Magnetic Particle Examination; December 24, 2017

- WO 200737512; Perform Weld Overlay of Pin Hole in 4 Elbow; ECP No. 17-0423-001;

January 5, 2018

71111.19Post Maintenance Testing

- CR 2018-01462; Unit 1 Div 3 Battery Without 200451459 Surveillance Test Cover Sheets

Raised Questions to Operations in Reference to Vendor Testing; February 19, 2018

- FTI-F0036; Post-Maintenance Test Manual; Revision 11

- GEI-0049; AC and DC Motor Testing; Revision 8

- NOP-ER-3030; Surveillance Frequency Control Program, Revision 0

- NOP-WM-1005; Work Management Order Testing Process; Revision 6

- PDB-R0002; Perry Surveillance Test Interval List; Revision 2

- SOI-C11; Control Rod Drive Hydraulic System; Revision 29

- SOI-P45/49; Emergency Service Water and Screen Wash Systems; Revision 31

- SOI-P45/49; Sluice Gate Maintenance; Revision 7

- TAI-2000-2; Vibration Monitoring; Revision 5

- TAI-2000-5; Electric Motor Predictive Monitoring Program; Revision 6

- WO 200451459; Replace All Cells in the Unit 1 Division 3 Batter; February 5, 2018

- WO 200518410; Lube Oil Cooler Inspection and Cleaning; January 27, 2018

- WO 200612097; Replace CRD Pump A; February 26, 2018

- WO 200674968; Inspect/Lubricate / Test Sluice Gate; March 19, 2018

- WO 200675074; Replace RCIC Waterleg Pump; January 25, 2018

- WO 200690671; Change Oil Filter, Sample Oil, Inspect RCIC Turbine; January 27, 2018

- WO 200701700; Perform Static MOV Test RCIC Steam Shutoff SMB-0 on Four Inch Borg

Warner Globe; January 27, 2018

- WO 200741192; Investigate Abnormal Noises Division 2 EDG; February 1, 2018

71111.22Surveillance Testing

- CR 2018-01018; Standby Liquid Control Storage Tank Level Rising; February 5, 2018

- CR 2018-01550; Division 1 Shutdown Surveillance Step Unable to be Performed as Written;

February 21, 2018

- CR 2018-01817; SVI-B21-T0138B (200675187) Data Exceeded PMMD Program Drift Limit

Criteria; March 1, 2018

- Partial, SVI-C41-T2001-B; Standby Liquid Control B Pump and Valve Operability Test;

February 5, 2018

- SVI-B21-T0033-B; RPV Steam Dome and RHR Cut-In Permissive High Pressure Channel B

Calibration for 1B21-N678B; February 28, 2018

- SVI-B21-T0138-B; ECCS Drywell Pressure High Channel 'B' Calibration for 1B21-N094B;

March 1, 2018

- SVI-C41-T1026; Standby Liquid Control Boron Concentration; February 5, 2018

- SVI-C41-T2001-B; Standby Liquid Control B Pump and Valve Operability Test;

February 3, 2018

- SVI-C61-T1201; Remote Shutdown Panel 1C61-P001 Control Operability Test RHR A,

ESW A, ECC A, and Division 1 Diesel Generator; Revision 15

- SVI-P45-T2002; ESW Pump B and Valve Operability Test; Revision 39

- WO 200674925; (24M) RPV Steam Dome and RHR Cut-In Permissive High Pressure Channel

B Calibration for 1B21-N678B; February 28, 2018

- WO 200675187; (24M) ECCS Drywell Pressure High Channel B Calibration for

1B21- N094B; March 1, 2018

- WO 200680426; Standby Liquid Control B Pump and Valve Operability Test;

February 3, 2018

- WO 200680470; ESW Pump B and Valve Operability Test; January 29, 2018

- WO 200681295; SVI-C61T1201; February 19, 2018

- WO200741544; Partial, Standby Liquid Control B Pump and Valve Operability Test;

February 5, 2018

71114.06Drill Evaluation

- OTLC-30582806-PY-SGC2 Cycle 6 2018 Evaluate Scenario C2; Revision 0

71124.01Radiological Hazard Assessment and Exposure Controls

- CR 2017-02582; Elevated Counts on Radiological Air Sample Containment 690 Refueling

Floor; March 9, 2017

- CR 2017-02770; Emerging Trend in Radiological Performance; March 12, 2017

- CR 2017-03241; Radiological Stop Work Criteria was Met for Work on 1B33F0023B Plug

Drain Appendage; March 22, 2017

- CR 2017-03617; Airborne Radioactivity on the Refuel Floor Stopped Work; March 30, 2017

- CR 2017-03754; Worker Received Dose Rate Alarm During Close Out Inspection;

April 2, 2018

- CR 2017-05573; Radiation Protection Periodic Barrier/Barricade Surveillance Performed by

Unqualified Personnel; May 16, 2017

- CR 2017-08708; MS-C-17-08-03; Improper ALARA WIP Documentation; August 23, 2017

- CR 2017-10762; Radiological Survey PY-M-20170718-1 Contains Incomplete Information;

October 25, 2017

- Electronic Dosimetry Dose and Dose Rate Alarms; April 1, 2017 to present

- National Source Tracking System 2018 Reconciliation; January 8, 2018

- NOP-OP-4101; Access controls for Radiologically Controlled Areas; Revision 14

- Periodic Barrier/Barricade Surveillance; March 22, 2018

- Radioactive Source Leak Test Data; August 20, 2017

- Radioactive Source Leak Test Data; February 22, 2018

- Radioactive Storage Yard Inventory Logs; March 2018

- Radiological Air Sample Records; Various Records

- Radiological Survey Records; Various Records

- RWP 17-0113; 1N23D0001 F Septa Filter Replacement; Revision 0

- RWP 18-0203; RW Liner Processing/Storing/Shipments <50R; Revision 0

- RWP 18-0309; RW Area-Waste Collector/Floor Drain Collector Filter; Revision 0

- RWP 18-0312; OG Preheater/Recombiner Steam Leak; Revision 0

- SVI-E31-T5190; Sealed Source Leak Test and Inventory; Revision 8

71151Performance Indicator Verification

- NOBP-LP-4012; NRC Performance Indicators; Revision 5

- NOBP-LP-4012; NRC Performance Indicators; Revision 6

- NOBP-LP-4012-01; Unplanned Scrams per 7,000 Critical Hours; Revision 2; January, 2017

through December, 2017

- NOBP-LP-4012-02; Unplanned Scrams with Complications (USwC); Revision 3;

January, 2017 through December, 2017

- NOBP-LP-4012-03; Unplanned Power Changes per 7,000 Critical Hours; Revision 2;

January, 2017 through December, 2017

71152Problem Identification and Resolution

- CR 2018-00916; Cognitive Trending has Identified a Rise in Operations Worker Practices

- CR 2018-01018; SLC Storage Tank Level Rising; February 5, 2018

- CRs for January, 2018; February 1, 2018

71153Follow-Up of Events and Notices of Enforcement Discretion

- CR 2018-01763; NRC ID: LER Required for DG Diode Failure; February 28, 2018

- NRC IR 05000440/2017009 (ML17156A750); NRC Inspection Report and Preliminary White

Finding; June 5, 2017

- NRC IR 05000440/2017010 (ML17236A187): Final Significance Determination of a White

Finding and Notice of Violation; August 24, 2017

- NUREG 1022; Event Report Guidelines 10 CFR 50.72 and 50.73; Revision 3

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, ILLINOIS 60532-4352

May 9, 2018

Mr. David B. Hamilton

Site Vice President

FirstEnergy Nuclear Operating Company

Perry Nuclear Power Plant

Reg Affairs-A210

Center Road, P.O. Box 97

Perry, OH 44081-0097

SUBJECT: PERRY NUCLEAR POWER PLANTNRC INTEGRATED INSPECTION REPORT

05000440/2018001

Dear Mr. Hamilton:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline

inspection at your Perry Nuclear Power Plant. On April 4, 2018, 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.

Based on the results of this inspection, the NRC has identified one issue that was evaluated

under the traditional enforcement process. The NRC determined that the issue was a

NRC-identified Severity Level IV violation. The NRC is treating this violation as a non-cited

violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation, 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 the Perry Nuclear Power Plant

D. Hamilton -2-

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 10 CFR 2.390, Public Inspections, Exemptions, Requests for

Withholding.

Sincerely,

/RA/

Billy Dickson, Chief

Branch 5

Division of Reactor Projects

Docket No. 50-440

License No. NPF-58

Enclosure:

Inspection Report 05000440/2018001

cc: Distribution via ListServ

D. Hamilton -3-

Letter to David Hamilton from Billy Dickson dated May 9, 2018

SUBJECT: PERRY NUCLEAR POWER PLANTNRC INTEGRATED INSPECTION REPORT

05000440/2018001