ML21132A095
| 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
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
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
Enterprise Identifier: I-2021-001-0045
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
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
(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
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
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
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