IR 05000440/2022001

Integrated Inspection Report 05000440/2022001

ML22132A120
Person / Time
Site:	Perry
Issue date:	05/12/2022
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2022001
Download: ML22132A120 (11)

Text

May 12, 2022

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2022001

Dear Mr. Penfield:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On April 19, 2022, 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.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Billy C. Dickson, Jr., Chief Branch 2 Division of Reactor Projects Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440 License Number: NPF-58 Report Number: 05000440/2022001 Enterprise Identifier: I-2022-001-0066 Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant Location: Perry, OH Inspection Dates: January 01, 2022 to March 31, 2022 Inspectors: G. Edwards, Health Physicist T. Ospino, Acting Sr Resident Inspector J. Reed, Health Physicist J. Steffes, Senior 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

PLANT STATUS

The plant began the inspection period at 85 percent power due to an ongoing 5A feedwater heater tube leak from the condensate system. The licensee made feedwater and condensate system manipulations that allowed the plant to slowly raise power and obtain 100 percent power on January 27, 2022. The unit remained at or near full power the remainder of the inspection period with a few noted exceptions. On March 11, 2022, reactor power was lowered to 65 percent to conduct rod sequence exchange and returned to 100 percent power on March 12, 2022. Additionally, on March 27, 2022, the plant experienced fluctuations of the "A" flow control valve position without operator demand which caused power fluctuations until the operators locked up "A" flow control valve. The unit did not exceed the licensed thermal limit and remained in this condition through the rest of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) Adverse weather preparations for winter storms in the area on February 2 to 4, 2022

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (1 Sample)

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

(1) High pressure core spray alignment during the reactor core isolation cooling system outage on January 19, 2022

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Control complex 574 foot elevation on February 10, 2022

(2) Fuel handling building 620 foot elevation on February 18, 2022

(3) Division 1 diesel generator building 620 and 646 foot elevations on February 23, 2022

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Inaccessible safety-related cable vaults on March 16 to 18, 2022

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 a rod sequence exchange on March 11 to 12, 2022.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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) Emergent work related to the Nuclear Closed Cooling (NCC) system process radiation counts rise associated with CR 2021-09436 on January 24 to 25, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) Control room suppression system fire impairment

(2) Division 3 diesel generator jacket water heat exchanger performance degradation on February 8 to 9, 2022

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) "B" residual heat removal heat exchanger system high point vent isolation valve replacement on December 15, 2021 (2) "B" control room HVAC return fan contactor EF1D09-L replacement on December 21, 2021

(3) Technical support center radiation monitor replacement on January 10, 2022

(4) Transformer LF-2-B breaker F2B03 replacement on January 13, 2022

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) "F" average power range monitor response time on January 10,

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Permanent Ventilation Systems (IP Section 03.01) (1 Sample)

The inspectors evaluated the configuration of the following permanently installed ventilation systems:

(1) Radiological Waste Building ventilation.

Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees use of respiratory protection devices.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)

(1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.

71124.04 - Occupational Dose Assessment

Source Term Characterization (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.

External Dosimetry (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.

Internal Dosimetry (IP Section 03.03) (2 Samples)

The inspectors evaluated the following internal dose assessments:

(1) Internal dose assessment conducted for an individual working on the refuel floor on 03/16/2021; PCE 21-006

(2) Internal dose assessment conducted for an individual working on the refuel floor on 03/16/2021; PCE 21-007 Special Dosimetric Situations (IP Section 03.04) (1 Sample 1 Partial)

The inspectors evaluated the following special dosimetric situations:

(1) Dose assessment for a declared pregnant worker in 2021 (2) (Partial)

Began the review of skin dose assessment from CR-2021-02636 dated 04/26/2021

OTHER ACTIVITIES - BASELINE

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

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) ===

(1) Unit 1 (January 1, 2021 through December 31, 2021)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)

(1) Unit 1 (January 1, 2021 through December 31, 2021)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)

(1) Unit 1 (January 1, 2021 through December 31, 2021)

71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Nuclear closed cooling system elevated activity

INSPECTION RESULTS

Observation: Nuclear Closed Cooling System Elevated Activity 71152A As documented in condition report (CR) 2021-09436, Nuclear Closed Cooling Process Radiation Monitor Counts Continue to Rise, on December 13, 2021, licensee chemistry sample results showed a step increase in radioactivity. Further analysis showed elevated amounts of Sodium-24 in the sample, and simple troubleshooting pointed to the reactor water cleanup (RWCU) system as the source of the leak. The inspectors previously reviewed licensee performance, response to pump failures, and corrective actions associated with the reactor water cleanup system. The inspectors focused on the licensees maintenance practices and organizational response to the increased nuclear-closed cooling (NCC) system activity. The licensee had recently replaced RWCU pumps and previously noted an increase in tritium from onsite sampling.

The inspectors followed the licensee's progress to remove and replace the suspected failed part and return the A RWCU pump to service. The licensee determined that they had replaced the A RWCU pump with a newly manufactured pump. The new pump had a different style thermal neck than the original design. The function of the thermal neck is to provide a pressure boundary between the motor casing and the pump casing and contains an internal cooling passage for the NCC of the RWCU pump motor and casing. During the review, the inspectors determined that the newly manufactured thermal neck included bored holes to attach the NCC piping that passed through the thermal neck and into the process side. The process side pressure boundary was sealed using plugs and further welded to ensure a proper seal.

The inspectors reviewed CR 2022-00784, Reactor Water Cleanup Pump A Confirmed Thermal Neck Failure, and determined from a review of licensee investigation that a plug weld failure had occurred and likely contributed to NCC activity observed in December 2021. The licensee replaced the failed thermal neck with a previously removed part, and the operators placed the A RWCU pump back in service without issue. The licensee documented additional corrective actions in CR 2022-00784, these included replacing the thermal neck components that eliminated the thermal neck bore hole. As a result of this review, the inspector did not identify any findings or violations.

EXIT MEETINGS AND DEBRIEFS

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

• On April 19, 2022, the inspectors presented the integrated inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

• On March 24, 2022, the inspectors presented the radiation protection inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Corrective Action 2022-00833 Work Hour Compliance Issue - Radiation Protection 02/03/2022

Documents

Procedures ONI-ZZZ-1 Acts of Nature - Severe Weather 33

71111.04 Procedures SOI-E22A High Pressure Core Spray System 01/19/2022

VLI-E22A High Pressure Core Spray System 11

71111.05 Corrective Action 2022-01461 NRC Identified Functional Location Referenced on Gai- 02/24/2022

Documents tronics Does Not Align to Pre-fire Plan FPI-1DG

Resulting from

Inspection

Procedures 1DG-1C Unit 1 Division 1 Diesel Generator Building 6206 and 646 02/23/2022

FPI-0FH Fuel Handling Buidling 6

PFI-0CC Control Complex 12

71111.06 Corrective Action 2022-01005 Cable Condition Monitoring Program Needs Improvement 02/10/2022

Documents

71111.11Q Miscellaneous Evolution Specific March 2022 Sequence Exchange 0

Reactivity Plan

71111.13 Corrective Action 2021-09436 NCC Process Rad Monitor Counts Continue to Raise 12/13/2021

Documents

71111.15 Corrective Action 2022-00612 Delivery of Carbon Dioxide to CO2 Tanks Not Made 01/26/2022

Documents 2022-00670 Fire Impairment Not Deactivated When No Longer Needed 01/28/2022

22-00950 Triennial Ultimate Heat Sink Self-Assessment: Division 3 02/08/2022

Diesel Generator Jacket Water Heat Exchanger

Performance Degradation

71111.19 Corrective Action 2021-09562 Control Room HVAC Return B Disconnect Making Abnormal 12/17/2021

Documents Noises

Work Orders 200802020 Clean Transformer LF-2-B 01/11/2022

200817802 Replace Kerotest with Ball Valve 12/15/2021

200869081 Clean Chamber for Technical Support Center Ventilation 11/29/2021

Radiation Monitor

71111.22 Work Orders 200812417 APRM F Response Time for 1C51-K605F 01/10/2022

71124.03 Corrective Action ATA-2022-5485 Update NOP-OP-4303 Respirator Quantitative Fit Test 03/17/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents Portacount 8030

Resulting from

Inspection

Miscellaneous MSA Operating Manual OptimAir TL Powered Air-Purifying 2020

Respirator (PAPR)

LAA 249600 MSA Firehawk M7 Annual Calibration Testing 09/22/2021

Procedures HPI-G0007 Maintenance of Respiratory Protective Equipment and 25

Operation of The Respirator Cleaning/Issue Facilities

NOP-OP-4303 Respirator Quantitative Fit Test Portacount Pro 8030 Revision 6

NOP-OP-4310 FireHawk M7 Self Contained Breather Apparatus 10

71124.04 Calibration L70L003A ABACOS 2000 Whole Body Counter Calibration Report 11/16/2021

Records

Corrective Action CR-2021-01899 Two Individuals Were Contaminated During Installation of 03/16/2021

Documents the Solids Collection Filter with Positive Whole Body Counts

CR-2021-02636 Individual Supporting 1R18 Exited Site with Detectable 04/07/2021

Activity

Engineering 11-30 Fleet 11-30 Alpha Assessment 2020 2020

Evaluations

Miscellaneous Dose assessment for a Declared Pregnant Worker 12/07/2021

Procedures HPI-B0003 Processing of Personnel Dosimetry 28

Self-Assessments MS-C-21-08-03 Quality Assurance Audit Report 09/20/2021

71151 Miscellaneous ATL-2022-0036- NRC Resident Request Indicator Data 03/28/2022

ATA-34

Logs Narrative Logs 03/31/2022

71152A Corrective Action 2022-00784 Reactor Water Cleanup Pump "A" Confirmed Thermal Neck 02/02/2022

Documents Failure

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