ML21132A095

Integrated Inspection Report 05000440/2021001

ML21132A095
Person / Time
Site:	Perry
Issue date:	05/12/2021
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2021001
Download: ML21132A095 (25)

See also: IR 05000440/2021001

Text

May 12, 2021

Mr. Rod L. Penfield

Site Vice President

Energy Harbor Nuclear Corp.

Perry Nuclear Power Plant

10 Center Road

Perry, OH 44081

SUBJECT: PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT

05000440/2021001

Dear Mr. Penfield:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection

at Perry Nuclear Power Plant. On April 28, 2021, the NRC inspectors discussed the results of

this inspection with you and other members of your staff. The results of this inspection are

documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding

involved a violation of NRC requirements. We are treating this violation as a non-cited violation

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

If you contest the violation or the significance or severity of the violation documented in this

inspection report, you should provide a response within 30 days of the date of this inspection

report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional

Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector

at Perry Nuclear Power Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a

response within 30 days of the date of this inspection report, with the basis for your

disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the

NRC Resident Inspector at Perry Nuclear Power Plant.

R. Penfield 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 Title 10 of the Code of Federal Regulations 2.390, Public

Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Billy C. Dickson, Jr., Chief

Branch 2

Division of Reactor Projects

Docket No. 05000440

License No. NPF-58

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML21132A095

SUNSI Review

Non-Sensitive Publicly Available

Sensitive Non-Publicly Available

OFFICE RIII RIII

NAME RRiuz:ve via email BDickson via email

DATE 5/11/2021 5/12/2021

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number: 05000440

License Number: NPF-58

Report Number: 05000440/2021001

Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant

Location: Perry, Ohio

Inspection Dates: January 01, 2021 to March 31, 2021

Inspectors: S. Bell, Health Physicist

V. Myers, Senior Health Physicist

J. Neurauter, Senior Reactor Inspector

T. Ospino, Resident Inspector

J. Steffes, Senior Resident Inspector

T. Taylor, Fermi Resident Inspector

Approved By: Billy C. Dickson, Jr., Chief

Branch 2

Division of Reactor Projects

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees

performance by conducting an integrated inspection at Perry Nuclear Power Plant, in

accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs

program for overseeing the safe operation of commercial nuclear power reactors. Refer to

https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Human Performance Error Resulted in Unplanned RCIC Unavailability

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [H.12] - Avoid 71111.22

Systems NCV 05000440/2021001-01 Complacency

Open/Closed

A finding of very low safety significance (Green) and associated non-cited violation of

TS 5.4.1, "Procedures," was self-revealed on January 19, 2021, when an unexpected isolation

of the RCIC steam supply occurred. Specifically, during performance of SVI-E31-T5395A,

"RCIC Steam Line Flow High Channel Functional for E31-N684A," Revision 8, the licensee

failed to lift the lead from terminal B4 for relay 1E51-K24, resulting in the closure of the RCIC

steam supply outboard valve and an unplanned limiting condition for operation (LCO) entry

and unavailability of the RCIC system.

Additional Tracking Items

None.

2

PLANT STATUS

Perry Nuclear Power Plant began the inspection period at 97 percent of rated thermal power in

coastdown operations before a refueling outage. On January 10, 2021, the 1B feedwater heater

isolated. The isolation resulted in a power perturbation. In response to the power perturbation

and feedwater heater isolation, the operators lowered reactor power to 79 percent to maintain

margin to thermal limits per abnormal operating procedures. High water level conditions caused

the heater isolation. The high-water level condition resulted from a failed circuit card in the level

transmitter for the alternate level controller. Operators restored level using the normal level

controller. The operators returned the unit to maximum attainable power and continued

coastdown operations on January 11, 2021. On March 6, 2021, operators shutdown the

reactor to commence refueling outage 1R18. The reactor remained shut down in the refueling

outage for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in

effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with

their attached revision histories are located on the public website at http://www.nrc.gov/reading-

rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared

complete when the IP requirements most appropriate to the inspection activity were met

consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection

Program - Operations Phase. The inspectors 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President

of the United States on the public health risks of the Coronavirus Disease 2019

(COVID-19), resident inspectors were directed to begin telework and to remotely access

licensee information using available technology. During this time, the resident inspectors

performed periodic site visits each week; conducted plant status activities as described in

IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site

portions of IPs. In addition, resident and regional baseline inspections were evaluated to

determine if all or portions of the objectives and requirements stated in the IP could be

performed remotely. If the inspections could be performed remotely, they were conducted per

the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The

inspections documented below met the objectives and requirements for completion of the IP.

3

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) High pressure core spray (HPCS) system on February 9, 2021

(2) Division 2 diesel generator while division 1 vital bus was removed from service for

modification on March 13, 2021

(3) Residual heat removal (RHR) B partial alignment due to outage configuration on

March 14, 2021

(4) Electrical bus and load alignment due to outage configuration on March 15, 2021

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (1 Sample)

The inspectors evaluated the implementation of the fire protection program by conducting a

walkdown and performing a review to verify program compliance, equipment functionality,

material condition, and operational readiness of the following fire areas:

(1) Quarterly fire protection alarm test on January 14, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) Fire protection drill on January 27, 2021

71111.08G - Inservice Inspection Activities (BWR)

BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding

Activities (IP Section 03.01) (1 Sample)

(1) The inspectors verified that the reactor coolant system boundary, reactor vessel

internals, risk-significant piping system boundaries, and containment boundary were

appropriately monitored for degradation and that repairs and replacements were

appropriately fabricated, examined and accepted by reviewing the documentation of

the following activities from March 8, 2021 to March 18, 2021:

03.01.a - Nondestructive Examination and Welding Activities.

1. Ultrasonic Examination (UT) of Main Steam System 26 Inch Elbow to Pipe

Weld, American Society of Mechanical Engineers (ASME) Category R-A,

Component 1B21-0006

2. UT of Reactor Vessel Top Head Meridional Weld, ASME Category B-A,

Component 1B13-DM

3. UT of Reactor Vessel Feedwater Nozzle Weld, ASME Category R-A,

Component 1B13-N4E-KB

4

4. Liquid Penetrant Examination (PT) of Control Rod Drive System Piping

Support Welded Attachment, ASME Category C-C, Component

1C11-H0040-WA

5. Magnetic Particle Examination (MT) of Reactor Vessel Top Head to Top Head

Flange Meridional Weld, ASME Category B-A, Component 1B13-AG

6. MT of Main Steam System Flued Head Fitting to Process Pipe Attachment

Weld, ASME Category B-K, Component 1B21-P124-WA

7. Visual Examination (VT-3) of High-Pressure Core Spray System Pipe

Restraint, ASME Category F-A, Component 1E22-H0034

8. Visual Examinations of Chilled Water System: VT-3 of Pipe Anchor, ASME

Category F-A, Component 1P47-H0219 and VT-1 of Pipe Anchor Integral

Attachment Weld, ASME Category D-A, Component 1P47-H0219-WA

9. AVR-R17-01, ASME Section XI Flaw Evaluation, Weld ID 1B13-AE

10. Pipe Replacement of Essential Service Water System B Piping between

Valve 1P45F0541B and Heat Exchanger 1P42B0001B and between

Valve 1P45F0541B and Second Downstream Elbow; Weld Numbers

200726587-01, -02, -03, -04, -05, -06 and -07 (WO 200726587)

11. Pipe Replacement of Reactor Water Clean Up System; Spool Piece between

Heat Exchangers 1G33B0001C and 1G33B0002A; Weld Numbers

200724734-01, -02, -03, -04, -05, -06, and -07 (WO 200724734)

The above volumetric (UT) and surface (PT and MT) examination records were

selected from the previous outage in 2019 (1R17), since there were no ISI exams or

aging management related exams performed during this outage (1R18).

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the

Control Room during plant shutdown and cooldown activities for the 1R18 refueling

outage on March 6 to 7, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (4 Samples)

The inspectors evaluated the effectiveness of maintenance to ensure the following

structures, systems, and components (SSCs) remain capable of performing their intended

function:

(1) Combustible gas mixing system A failure on December 22, 2020

(2) Containment radiation monitor outboard isolation loss of indication on

January 15, 2021

(3) Inclined fuel transfer system failure on March 16, 2021

(4) Division 1 emergency core cooling systems (ECCS) integrated test failures and

resolution on March 22 to 24, 2021

5

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the

following planned and emergent work activities to ensure configuration changes and

appropriate work controls were addressed:

(1) Plant risk assessment related to D1A electrical bus emergent work started on

November 30, 2020

(2) Emergent work for annunciator system ground alarms on January 7, 2021

(3) Emergent work related to electro-hydraulic pump A leak and spill on

January 25, 2021

(4) Reactor feed pump turbine "B" emergent work on February 22 to 24, 2021

(5) Plant risk assessment during the Division 1 ECCS integrated test between

March 22 to 24, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the

following operability determinations and functionality assessments:

(1) Combustible gas mixing system A (CR 2020-09635) failure and common cause

review on December 22, 2020

(2) Operability review based on CR 2020-09501 related to the Technical Support Center

radiation monitor on January 4, 2021

(3) Reactor core isolation cooling (RCIC) system operability verification based on

CR 2021-00338 on January 19, 2021

(4) Operability review for SCRAM insertion times after shutdown on March 6, 2021

(5) Operability review for safety relief valves (SRV) after set pressure testing on

March 29, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

(3 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) Dedicated open phase control room annunciator modification on December 17, 2020

(2) Installation of temporary jumpers to bypass the rod block as part of outage emergent

activities on March 17, 2021

(3) Breaker EH1114 relay modification associated with Engineering Change 11-0559-002

on March 16, 2021

6

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system

operability and functionality:

(1) Technical support center testing following radiation monitor repair work on

December 16, 2020, to January 4, 2021

(2) Division 3 emergency service water testing following packing adjustment on

January 5, 2021

(3) Testing of the containment radiation monitor outboard isolation valve following blown

fuse replacement on January 15, 2021

(4) Testing following average power range monitor A and B power supply replacement

on January 19, 2021

(5) "B" reactor protection system trip channel Potter-Brumfield relay replacement for

1C71A-K012B, work order 200391663

(6) Testing following replacement of control rod drive mechanisms on March 17, 2021

(7) Testing following replacement of "A" RHR relays on March 22 to 24, 2021

(8) SRV test following replacement on March 29, 2021

71111.20 - Refueling and Other Outage Activities

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

(1) (Partial)

The inspectors evaluated refueling outage 1R18 activities from March 6 to

March 31, 2021. Activities evaluated by the inspectors included, but were not limited

to, shutdown and cooldown operations, reduced inventory control, containment

walkdown, reactor vessel disassembly for heavy load controls, refueling operations,

reactor coolant system instrumentation, outage plan and shutdown risk.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (6 Samples)

(1) SRV pressure actuation channel A test on January 20, 2021

(2) HPCS pump test on February 1, 2021

(3) Fuel pool cooling and cleanup system surveillance on February 3, 2021

(4) Control rod maximum scram-based insertion time on March 6, 2021

(5) Division 1 standby diesel generator load rejection test on March 8, 2021

(6) Division 1 ECCS integrated test between March 22 to 24, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) "C" RHR system pump and valve operability test, work order 200792521.

7

Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)

(1) Leak rate test for the shutdown cooling A to the feedwater shutdown isolation valve

1E12-F050A on March 22, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) Calibration check of FLEX fuel pool level transmitter on January 27, 2021

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of

radiation levels and the concentrations and quantities of radioactive materials and

how the licensee assesses radiological hazards.

Instructions to Workers (IP Section 03.02) (1 Sample)

The inspectors evaluated instructions to workers including radiation work permits used to

access high radiation areas.

(1) The inspectors evaluated radiological protection related instructions to plant workers

for emergent diving activities on the inclined fuel transfer system.

Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)

The inspectors evaluated licensee processes for monitoring and controlling contamination

and radioactive material.

(1) The inspectors observed workers exiting the radiologically controlled area (RCA).

(2) The inspectors observed licensee surveys of potentially contaminated material

leaving the radiologically controlled area.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and

observation of the following radiological work activities.

(1) Inclined fuel transfer system diving activities under RWP 210910

(2) Flow accelerated corrosion exams in the reactor water cleanup heat exchanger and

pump room under RWP 210602

(3) Control rod drive mechanism exchange under RWP 210518

8

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very

High Radiation Areas:

(1) Locked high radiation area for reactor water clean-up pump repair in the auxiliary

building 599'

(2) Locked high radiation area for the fuel pool cooling pump room in the intermediate

building 574'

(3) Locked high radiation area established for fuel moves in containment 620'

Radiation Worker Performance and Radiation Protection Technician Proficiency

(IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician

performance as it pertains to radiation protection requirements.

71124.02 - Occupational ALARA Planning and Controls

Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (3 Samples)

The inspectors reviewed as low as reasonably achievable practices and radiological work

controls for the following work activities.

(1) Inclined fuel transfer system diving activities under RWP 210910

(2) Flow accelerated corrosion exams in the reactor water cleanup heat exchanger and

pump room under RWP 210602

(3) Control rod drive mechanism exchange under RWP 210518

Radiation Worker Performance (IP Section 03.04) (1 Sample)

The inspectors evaluated radiation worker and radiation protection technician performance

during:

(1) Inclined fuel transfer system diving activities under RWP 210910

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (5 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant

walkdowns:

(1) Radiation monitors (portal monitor, personnel contamination monitor and small article

monitor) located at the RCA exit.

(2) Portable radiation survey instrumentation located at the RCA exit and the

Instrumentation Calibration Facility (Geiger Mueller contamination monitoring

instruments and dose rate survey instruments including ion chambers, pressurized

ion chambers and Telepoles).

(3) Gamma spectroscopy systems and liquid scintillation instrumentation located within

the Chemistry Counting Room.

9

(4) JL Shepherd Model 89 instrumentation calibrator.

(5) Area Radiation Monitors and Continuous Air Monitors in the Fuel Handling Building

Calibration and Testing Program (IP Section 03.02) (1 Sample)

The inspectors evaluated the calibration and testing of the following radiation detection

instruments:

(1) Canberra Argos Personal Contamination Monitor, SN L70L004V

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

& Transportation

Radioactive Material Storage (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's performance in controlling, labelling and securing

radioactive materials in the following locations.

(1) Outside radioactive material storage locations

(2) Radiation protection radioactive source storage locations (calibration facility and RCA

exit)

Radioactive Waste System Walkdown (IP Section 03.02 (1 Sample)

(1) Inspectors walked down accessible portions of the solid radioactive waste systems

located in the radioactive waste handling building and evaluated system configuration

and functionality.

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

(1) The inspectors evaluated the licensees characterization and classification of

shipment 19-1030 consisting of reactor water cleanup resin radioactive waste

(2) The inspectors evaluated the licensees characterization and classification of

shipment 20-1026 consisting of spent resin radioactive waste

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed shipment number 21-008, containing radioactive

contaminated laundry.

Shipping Records (IP Section 03.05) (5 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through

a record review:

(1) Radioactive waste shipment 19-1030 consisting of reactor water cleanup resin

transported in a Type B package

(2) Radioactive waste shipment 20-1026 consisting of dewatered resin transported in

a general design package

(3) Radioactive waste shipment 19-1025 consisting of reactor water cleanup resin

transported in a Type B package

10

(4) Radioactive material shipment 19-3033 consisting of control rod drive mechanisms

transported in a Type A package

OTHER ACTIVITIES - BASELINE

71153 - Follow-up of Events and Notices of Enforcement Discretion

Event Report (IP Section 03.02) (1 Sample)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 2020-002-00, Standby Liquid Control System Rendered Inoperable due to Valve

Misposition (ADAMS Accession No. ML20293A204). The inspection conclusions

associated with this LER are documented in this report under Inspection Results

Section 71153.

INSPECTION RESULTS

Human Performance Error Resulted in Unplanned RCIC Unavailability

Cornerstone Significance Cross-Cutting Report

Aspect Section

Mitigating Green [H.12] - Avoid 71111.22

Systems NCV 05000440/2021001-01 Complacency

Open/Closed

A finding of very low safety significance (Green) and associated non-cited violation of

TS 5.4.1, "Procedures," was self-revealed on January 19, 2021, when an unexpected

isolation of the RCIC steam supply occurred. Specifically, during performance of

SVI-E31-T5395A, "RCIC Steam Line Flow High Channel Functional for E31-N684A,"

Revision 8, the licensee failed to lift the lead from terminal B4 for relay 1E51-K24, resulting in

the closure of the RCIC steam supply outboard valve and an unplanned limiting condition for

operation (LCO) entry and unavailability of the RCIC system.

Description:

On January 19, 2021, during the performance of SVI-E31-T5395A, RCIC Steam Line Flow

High Channel Functional for E31-N684A, Revision 8, the licensee received several control

room alarms and identified that the RCIC steam supply outboard valve was closed. The

licensee determined that an inadvertent isolation of the RCIC system and an unplanned

inoperability had occurred. The inspectors determined that procedural steps were not

implemented during the surveillance test, as written. Specifically, the licensee failed to

perform Section 5.1 appropriately, steps 72a and 72b, and complete the independent

verification to ensure the correct lead was lifted from terminal B4 associated with relay

1E51-K24. This failure resulted in the closure of the RCIC steam supply outboard valve and

the RCIC system unavailability.

Corrective Actions: Immediate corrective actions included securing from the surveillance,

restoration of the RCIC steam supply flow path and RCIC system operability.

Corrective Action References: CR 2021-00338, Wrong Lead lifted during Surveillance

Performance 1/19/2021.

11

Performance Assessment:

Performance Deficiency: The resident inspectors determined that the licensees failure to

implement Section 5.1, Steps 72a and 72b of SVI-E31-T5395A, RCIC steam line flow high

channel functional for E31-N684A, Revision 8, was a performance deficiency. Specifically,

the failure to ensure the correct lead was lifted from terminal B4 of the relay 1E51-K24 in

accordance with the procedure directly led to the inoperability and unavailability of the RCIC

system.

Screening: The inspectors determined the performance deficiency was more than minor

because it was associated with the Human Performance attribute of the Mitigating Systems

cornerstone and adversely affected the cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. The resident inspectors determined the performance deficiency was more

than minor because it was associated with the Human Performance attribute of the Mitigating

Systems cornerstone and adversely affected the cornerstone objective to ensure the

availability, reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Specifically, the licensee failed to lift the correct lead from

terminal B4 of relay 1E51-K24, which directly led to the closure of the RCIC steam supply

outboard valve and steam flow path isolation, thus negatively impacting the availability of the

RCIC system.

Significance: The inspectors assessed the significance of the finding using Appendix A, The

Significance Determination Process (SDP) for Findings At-Power. The inspectors screened

the finding against the Mitigating Systems screening questions in Exhibit 2 and answered

"NO" to all screening questions. Therefore, the finding screened to very low safety

significance (Green).

Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the

possibility of mistakes, latent issues, and inherent risk, even while expecting successful

outcomes. Individuals implement appropriate error reduction tools. Specifically, the licensee

failed to implement error reduction tools from Section 4.2.5.3 of NOBP-LP-2601, "Human

Performance Program," Revision 13, independent verification which resulted in the failure to

implement the procedure as written.

Enforcement:

Violation: Technical Specification 5.4.1, "Procedures," requires, in part, that written

procedures/instructions be established, implemented, and maintained covering the following

activities: the applicable procedures recommended in Regulatory Guide (RG) 1.33,

Revision 2, Appendix A, dated February 1978. RG 1.33, Revision 2, Appendix A,

Section 8b(2)(r), states, in part, that for the reactor core isolation system "Specific procedures

for surveillance tests, inspections, and calibrations should be written (implementing

procedures are required for each surveillance test, inspection, or calibration listed in the

technical specifications."

Contrary to the above, on January 19, 2020, while performing an activity affecting quality, the

licensee did not accomplish a surveillance test in accordance with the procedure and

incorrectly performed a step in surveillance procedure SVI-E31-T5395A, and failed to lift the

proper lead. Specifically, the licensee failed to lift the lead from terminal B4 from relay

1E51A-K24 resulting in an unplanned entry into Technical Specification 3.5.3, Condition A,

and adversely affected the availability of the RCIC system.

12

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Minor Violation 71153

Minor Violation: Licensee Event Report (LER) 05000440/2020-002 documented a condition

where the standby liquid control (SLC) system was rendered inoperable due to a valve

alignment issue. The event occurred on August 21, 2020, from 0953 to 1307 hours0.0151 days <br />0.363 hours <br />0.00216 weeks <br />4.973135e-4 months <br />

(approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />). The licensee submitted the LER to the NRC according to

10 CFR 50.73 (a)(2)(v)(A) and 50.73 (a)(2)(v)(D) for a condition that could have prevented

the fulfillment of the safety function of a system needed to shut down the reactor and mitigate

the consequences of an accident.

The LER stated that on August 20, 2020, Periodic Test Instruction, PTI-C41-P0001, Standby

Liquid Control Transfer System Pump, and Valve Operability Test, was being performed on

the SLC system. During the test on August 20, 2020, at 1248 hours0.0144 days <br />0.347 hours <br />0.00206 weeks <br />4.74864e-4 months <br />, a valve misposition

resulted in the inadvertent addition of 226 gallons of water to the SLC storage tank, causing

an unintended dilution of the boron solution. On August 21, 2020, at 0953 hours0.011 days <br />0.265 hours <br />0.00158 weeks <br />3.626165e-4 months <br />, the SLC

system was declared inoperable when the sample results for the SLC storage tank confirmed

the boron solution concentration did not meet Technical Specification (TS) 3.1.7 criteria. The

licensee restored operability on August 21, 2020, at 1307 hours0.0151 days <br />0.363 hours <br />0.00216 weeks <br />4.973135e-4 months <br />.

While reviewing LER 05000440/2020-002, the inspectors identified that the diluted boron

solution concentration existed for a time longer than permitted by TS 3.1.7. Following the

guidance in NUREG-1022 Revision 3 "Event Report Guidelines 10 CFR 50.72 and 50.73, the

inspectors determined that the licensee should have reported the diluted boron solution

concentration to the NRC as a condition which was prohibited by the plant's Technical

Specifications, pursuant to 10 CFR 50.73 (a)(2)(i)(B). Specifically, the diluted boron solution

concentration existed for longer (approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) than the total 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> allowed for

restoration and shutdown outage time per Technical Specifications. The licensee plans on

submitting a revised LER in response to the minor violation.

Screening: The inspectors determined the performance deficiency was minor. Specifically,

the failure to identify 10 CFR 50.73 (a)(2)(i)(B) on a Licensee Event Report did not impact the

completeness or accuracy of performance indicator data or other information provided to the

agency, as is provided in Enforcement Policy Example 6.9(d)(10).

Enforcement: This failure to comply with 10 CFR 50.73 (a)(2)(i)(B) constitutes a minor

violation that is not subject to enforcement action in accordance with the NRCs Enforcement

Policy.

13

EXIT MEETINGS AND DEBRIEFS

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

• On April 28, 2021, the inspectors presented the integrated inspection results to

Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

• On February 5, 2021, the inspectors presented the radiation protection baseline

inspection results to Mr. R. Penfield, Site Vice President, and other members of the

licensee staff.

• On March 18, 2021, the inspectors presented the Inservice Inspection results to

Mr. C. Elliott, Plant General Manager, and other members of the licensee staff.

• On March 25, 2021, the inspectors presented the radiation protection baseline

inspection results to Mr. R. Penfield, Site Vice President, and other members of the

licensee staff.

• On April 28, 2021, the inspectors presented the integrated inspection results inspection

results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

14

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Drawings 302-0351-00000 Standby Diesel Generator Starting Air GG

302-0352-00000 Standby Diesel Generator Fuel Oil System LL

302-0353-00000 Standby Diesel Generator Lube Oil T

Procedures ELI-R22 15KV and 5KV Metal Clad Switchgear 3/15/2021

VLI-E12 Residual Heat Removal System 3/14/2021

VLI-E22A High Pressure Core Spray 10

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

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

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

71111.05 Procedures FPI-A-B02 Fire Brigade Drills 01/27/2021

Work Orders 200750956 Quarterly Fire Alarm 01/14/2021

71111.08G Corrective Action CR-2019-02185 Foreign Material Head Tensioner Lock Washer Dropped in 03/19/2019

Documents Cavity

CR-2019-02328 Relevant Indication Identified During Containment Surface 03/14/2019

Exams

CR-2019-02523 1C22D0012B Found with Internal Parts Missing - Potential 03/19/2019

Foreign Material

CR-2019-02677 During IVVI Piece of Foreign Material Identified Between Jet 03/22/2019

Pumps 16 and 17

CR-2019-02704 During IVVI Piece of Foreign Material Identified at Jet Pump 03/23/2019

17

CR-2019-02893 Foreign Material Found Inside Reactor Vessel During Core 03/28/2019

Verification

CR-2019-02956 Legacy Foreign Material Discovered in Inner Bellows 03/29/2019

CR-2019-02990 Foreign Material - Piece of Rope Found in Inner Bellows 03/30/2019

After Draindown

CR-2019-03147 Leakage Identified During Reactor Pressure Vessel Test 04/03/2019

CR-2019-03157 Documentation of Identified Mechanical Joint Leakage 04/04/2019

Identified During Reactor Pressure Vessel Leak Test (1R17)

CR-2019-03358 Roll-Up Condition Report Following 1R17 Refuel - Foreign 04/09/2019

Material Focused Observations

CR-2019-04170 Additional Pitting Discovered in Piping Downstream of 05/07/2019

15

Inspection Type Designation Description or Title Revision or

Procedure Date

Emergency Service Water

CR-2020-02539 Mechanical Leakage Identified During ISI-P2-T2200-3 03/23/2020

CR-2020-06809 1R16 Snubber As-Built Discrepancy 08/31/2020

Corrective Action ATA-2021-4926 Remove "Snubbers" from Definition of VT-3 in NQI-1042, 03/12/2021

Documents Paragraph 3.15 to Align with Language Contained in ASME

Resulting from Section XI (2013 Edition), IWA-2213

Inspection

Drawings 304-672-105 Piping Isometric, Reactor Water Clean-Up System, Reactor D

Building

305-002-113 ISI Piping Isometric, System P47 Chilled Water System Loop A

B

305-006-103 Reactor Vessel Closure Head, Circumferential and A

Meridional Weld Arrangement

305-006-108 ISI, System 1B13, Reactor Vessel Feedwater Nozzle Weld D

Arrangement

305-605-103 ISI Piping Isometric, System B21, Main Steam Loop C C

305-605-107 ISI Piping Isometric, System B21, Main Steam Loop A, D

Steam Tunnel Elevation 620-6

305-701-102 ISI Piping Isometric, High Pressure Core Spray D

305-871-104 System C11, Control Rod Drive, Loop B, Reactor Building C

Elevation 620-6

92-701-0034 Pipe Support Mark Number 1E22-H0034 A

92-871-0040 Pipe Support Mark 1C11-H0040 2

B-312-641 Containment Penetration Detail, Type K F

Miscellaneous RRP 200724734 Repair Replacement Plan: Remove and Replace Reactor 0

Water Clean Up Heat Exchanger 4 Spool Piece Between

Heat Exchangers 1G33B0001C and 1G33B0002A

RRP 200726587 Repair Replacement Plan: Remove 3" Bypass 0

Piping/Components and Replace 14" Spool Piece Between

Valve 1 P45F0541 B and Heat Exchanger 1 P4280001 B.

Also Replace Portion of Spool Piece Between Valve

1 P45F0541 B and Second Elbow Downstream of the Valve.

Reference ECP 18-0162-002

WPS 1.1.2-001 Welding Procedure Specification: P1 Gr. 1 & 2 to P1 Gr, 13

16

Inspection Type Designation Description or Title Revision or

Procedure Date

1&2

NDE Reports 0941-19A-003 Liquid Penetrant Examination (PT): Piping Support Welded 03/13/2019

Attachment: Component 1C11-H0040-WA

0942-19A-008 Magnetic Particle Examination (MT): Top Head to Top Head 03/21/2019

Flange: Component 1B13-AG

0942-19A-010 Magnetic Particle Examination (MT): P124 Flued Head 03/25/2019

Fitting to Process Pipe Attachment Weld: Component

1B21-P124-WA

0942-19B-009 Magnetic Particle Examination (MT): 14 Pipe to 14 Elbow 03/13/2019

0942-19B-014 Magnetic Particle Examination (MT): Flange to Pipe 03/13/2019

0942-19B-015 Magnetic Particle Examination (MT): Pipe to Elbow Butt 03/13/2019

Welds

0942-19B-016 Magnetic Particle Examination (MT): (2) Half Coupling to 03/13/2019

Pipe and Flange to Pipe Welds

0942-19B-017 Magnetic Particle Examination (MT): 14 Flange to 14 Elbow 03/13/2019

Butt Weld (Repair)

0942-19B-025 Magnetic Particle Examination (MT): 14 Pipe to 14 Elbow 03/25/2019

FW-07

0942-19B-031 Magnetic Particle Examination (MT): 4 Spool Piping 03/07/2019

1042-19B-018 Visual Examination System Leakage (VT-2): Order 03/27/2019

200726587 Piping Replacement

1042-21-023 Visual Examination of Pipe Hanger, Support, or Restraint 03/04/2021

(VT-3): Chilled Water System, Pipe Anchor, Component

1P47-H0219 Located on ISI Drawing 305-002-113

1042-21-024 Visual Examination of Welds (VT-1): Chilled Water System 03/08/2021

Pipe Anchor Integral Attachment, Component

1P47-H0219-WA Located on ISI Drawing 305-002-113

1042-21-029 Visual Examination of Pipe Hanger, Support, or Restraint 03/04/2021

(VT-3): Mechanical Snubber, Drawing 305-701-102,

Component 1E22-H0034

APR-R17-02 Ultrasonic Examination Summary Sheet, System 1B13, Weld 03/282019

Number 1B13-N4E-KB, Safe-End to Nozzle

MVR-004 UT Report with Calibration Records C-007 and C-008: 03/23/2019

Component 1B13-DM

17

Inspection Type Designation Description or Title Revision or

Procedure Date

UT-19-E006 UT Calibration/Examination Report: Component 1B21-006 03/15/2019

Procedures GEH-UT-247 Procedure for Phased Array Ultrasonic Examination of 4

Dissimilar Metal Welds

GEH-UT-300 Procedure for Manual Examination of Reactor Vessel 12

Assembly Welds in Accordance with PDI

NOP-CC-5762 Appendix VIII Procedure for Ultrasonic Examination of 3

Ferritic Welds

NQI-0941 Liquid Penetrant Examination 22

NQI-0942 Magnetic Particle Examination 22

NQI-1042 Visual Examination 20

Work Orders 200718215 Reactor Vessel Top Head Meridional Weld Examination 03/21/2019

200718218 Piping Weld Exams on Main Steam Lines 04/17/2019

200724734 Replace 4 Piping - RWCU Piping Between Heat 04/11/2019

Exchangers 1G33B0001C and 1G33B0002A

200726587 Replace 14 Piping - ESW B Piping Between 1P45F0541B 04/09/2019

and Heat Exchanger 1P42B0001B and Between Valve

1P45F0541B and Second Elbow Downstream of Valve

200728323 1B13 Reactor and Internals Non-Destructive Examination 04/18/2019

200794288 System P47 Exams: Pre-1R18 03/12/2021

200794289 ISI of Piping, Supports, and Components of P42, P47, and 03/12/2021

E22 Systems

71111.11Q Miscellaneous Evolution Specific Perry Nuclear Power Plant End of Cycle 18 Shutdown 0

Reactivity Plan

Procedures IOI-3 Power Changes 81

IOI-4 Shutdown 26

71111.12 Corrective Action 2021-00266 Loss of Indication for Containment Radiation Monitor 01/15/2021

Documents Outboard Isolation

2021-01834 IFT Cable Damaged During Transfer 03/14/2021

Miscellaneous NOP-ER-3004-03 Maintenance Rule Failure Review Form 04

NOP-SS-3001-02 Procedure Approval Form 12

71111.13 Corrective Action 2021-00128 Multiple Alarms Received Coincident with Annunciator 01/7/2021

Documents System Ground

2021-00455 EHC Pump A Leak 01/25/2021

18

Inspection Type Designation Description or Title Revision or

Procedure Date

2021-01200 Planned Work Not Able to be Released as Scheduled Due to 02/23/2021

Leakby Aux Condenser B Air Removal Suction Valve

2021-02121 Unplanned Division 1 DG Start During Integrated 03/23/2021

LOOP/LOCA Test

Work Orders 200840213 Determine and Correct the Cause Ground on Electrical Bus 11/30/2020

D1A CR 2020-09061

71111.15 Corrective Action 2020-09501 Ventilation Radiation Monitor Gas Channel Reading Erratic 12/16/2020

Documents 2021-00338 Wrong Lead Lifted During Surveillance Performance 01/20/2021

2021-01707 Rod SCRAM Time Recorder Did Not Perform as Expected 03/10/2021

2021-09635 Combustible Gas Mixing Compressor Suction Valve Would 12/22/2020

Not Re-Open Following Compressor Start

Work Orders 200798943 Safety Relief Valve Removes, Replaces and Offsite Testing 03/23/2021

71111.18 Engineering 11-0559-002 Spring Charging Motor Margin Improvement - EH 1114 0

Changes ECP 15-0057 Installation of U1/U2 Startup Transformer 02/26/2018

Engineering ECP 19-0203-002 Dedicated Open Phase Control Room Annunciators - Unit 2 07/10/2020

Evaluations

Work Orders 200846449 Jumper Request to Remove Rod Block 03/17/2021

71111.19 Corrective Action 2021-00266 Loss of Indication for Containment Radiation Monitor 01/15/2021

Documents Outboard Isolation

Procedures SVI-B21-T2100 Safety Relief Valve (SRV) Set Pressure Testing 7

SVI-D17-T2001 Plant Radiation Monitoring Isolation Valves Operability Test 8

Work Orders 100841399 Technical Support Center Ventilation Radiation Monitor Gas 01/4/2021

Channel Reading Erratic Replacement

200391663 Replace Relay 1C17A-K0112B Reactor Protection System 0

Trip Channel B

200536387 Replace Relays 1E12-K18A/19A 03/22/2021

200594427 Replace Power Supply PS22 01/12/2021

200727023 Install ECP-11-0559-002 74 Power Monitoring Relay in 03/14/2021

Breaker EH1114

200762809 Inspect/Tighten Packing-ESW PMP Div III 01/5/2021

200795982 Control Unit Hydraulic 03/17/2021

71111.20 Corrective Action 2021-01545 Condensate Booster Pump C Tripped Following Reactor 03/6/2021

Documents Recirculation Pump Downshift

19

Inspection Type Designation Description or Title Revision or

Procedure Date

2021-01557 Feedwater Heater 3A Isolated on High Level Following 03/6/2021

Recirculating Pump Downshift to Slow Speed

2021-01564 Control Rod 02-27 Did Not Settle at 00 03/7/2021

2021-01604 Scaffold Level Inadvertently Dropped in the Suppression 03/8/2021

Pool During Scaffold Erection

2021-01829 Leak in High Pressure Core Spray Room 03/14/2021

2021-01857 As Found Blockage of 3-Inch Fire Protection System to 03/15/2021

Emergency Service Water Pipe Connection

2021-01939 Fuel Assembly 18P568 Identified as Cycle 18 Fuel Defect 03/17/2021

2021-02011 Design Discrepancies Contained Within the Engineering 03/19/2021

Change Package for the 1B33-F060B Side Drain Appendage

2021-02117 Ground Detected on DC Bus 03/22/2021

2021-02159 Loose Bushing Terminal Lead Connectors Found in Unit 1 03/24/2021

Start-Up Transformer

2021-02237 Issues Noted on Post Maintenance Tests for Scram 03/25/2021

Discharge Volume Vent and Drain Valves

2021-02312 Control Rod Drive Mechanism Temperature for Rod 34-43 03/27/2021

Indicates Failed

2021-02428 Hard Ground Indicated on DC Bus D-1-B 03/31/2021

Miscellaneous 1R18 Shutdown Defense-In-Depth Report 1

Procedures SVI-B21-T1176 Reactor Coolant System Heat Up and Cooldown 03/7/2021

Surveillance

71111.22 Procedures GMI-0067 Under-Vessel Maintenance Activities 19

IMI-E2-47 Installation of Reactor Refuel Level Instrumentation for 03/9/2021

IOI-9

SVI-B21-T2100 Safety Relief Valve (SRV) Set Pressure Testing 7

SVI-E12-T2210 Leak Rate Test for RHR to FWD Injection Valves 03/24/2021

1E12-F050A and 1E12-F053A

SVI-G41-T2002 Fuel Pool Cooling and Cleanup System Operability Test 02/3/2021

SVI-R43-T7000-A Division 1 ECCS Integrated Test 12

TXI-0460 Division 1 Standby Diesel Generator Load Rejection Test 03/8/2021

Work Orders 200751888 SRV Pressure Actuation Channel a Functional for 01/20/2021

1B21-N668A

200778903 Spent Fuel Pool Level Instrument 1X13N0003 Calibration 01/27/2021

20

Inspection Type Designation Description or Title Revision or

Procedure Date

Check

200778904 Level Sensor Calibration 02/3/2021

200778926 Standby Oil Pump Testing 1N27C0006A 12/30/2020

200783921 Control Rod Maximum SCRAM Insertion Time 03/6/2021

200792417 High Pressure Core Spray Pump and Valve Operability Test 02/1/2021

71124.01 Corrective Action CR-2021-01739 Two Unbriefed Dose Rate Alarms Received in Containment 03/11/2021

Documents Annulus 690' Elevation

Corrective Action CR-2021-01952 NRC Comment During Radiological Hazards/ALARA 03/16/2021

Documents Inspection for Loss of Telemetry

Resulting from

Inspection

Radiation N/A Radiological Surveys for Lower Inclined Fuel Transfer 03/15/2021

Surveys System

PY-M-20210310- Reactor Water Cleanup Heat Exchanger Room Post Pump 03/09/2021

7 Failure Verification Survey for Flow Accelerated Corrosion

Exam Work

PY-M-20210312- Scaffold Extension for Flow Accelerated Corrosion Exam 03/12/2021

37

Radiation Work 210518 Undervessel Activities 0

Permits (RWPs) 210602 Flow Accelerated Corrosion Exams in the Reactor Water 0

Clean-Up Heat Exchanger and Pump Room

210910 Inclined Fuel Transfer System Diving Activities and Support 0

Work

71124.02 ALARA Plans ALARA Plan Undervessel Activities 0

210518

ALARA Plan Flow Accelerated Corrosion Exams in the Reactor Water 0

210602 Clean-Up Heat Exchanger Room

ALARA Plan ALARA Plan for Inclined Fuel Transfer System Diving and 0

210910 Support Activities

71124.05 Calibration Canberra Argos Personal Contamination Monitor; 02/17/2021

Records SN L70L004V

71124.08 Corrective Action 2019-03353 Radwaste Processing Inventory Issues 04/09/2019

Documents 2019-06245 Radwaste Tanks Require Multiple Iterations of Processing in 07/24/2019

Order to Become Transfer Quality

21

Inspection Type Designation Description or Title Revision or

Procedure Date

2020-07918 Pre NRC-Assessment ATA 2020-10589 Identified 10/13/2020

Deficiencies in Closure Packages for SVI-E31-T5190

Miscellaneous 20118 Radioactive Material Transportation Training Record 07/09/2020

451802001 10 CFR 61 Laboratory Analysis of Reactor Water Clean-Up 05/25/2018

Resin

510237001 10 CFR 61 Laboratory Analysis of Spent Resin 02/25/2020

Procedures NOP-OP-4502 Control of Radioactive Material 7

NOP-OP-5201 Shipment of Radioactive Material-Waste 10

PCP-0000 Process Control Program 15

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

Radiologically Controlled Areas and Onsite Interim Storage

Self-Assessments ATA-2020-10589 Pre NRC-Inspection - Radioactive Solid Waste Processing 11/13/2020

and Radioactive Material Handling, Storage, and

Transportation

Shipping Records 19-1025 Radioactive Waste Shipment of Reactor Water Cleanup 06/05/2019

Resin

19-1030 Radioactive Waste Shipment of Reactor Water Cleanup 07/23/2019

Resin

19-3033 Radioactive Material Shipment of Control Rod Drive 07/18/2019

Mechanisms

20-1026 Radioactive Waste Shipment of Dewatered Resin 11/30/2020

21-2008 Radioactive Material Shipment Containing Radiologically 03/18/2021

Contaminated Laundry

Work Orders 200752735 Radioactive Source Inventory/Leak Test Record 09/03/2020

22