IR 05000440/2023002

Integrated Inspection Report 05000440/2023002

ML23213A130
Person / Time
Site:	Perry
Issue date:	08/02/2023
From:	Karla Stoedter NRC/RGN-III/DORS/RPB2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2023002
Download: ML23213A130 (1)

Text

August 2, 2023

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2023002

Dear Rod Penfield:

On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On July 17, 2023, 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. 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, Signed by Stoedter, Karla on 08/02/23 Karla K. Stoedter, Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440 License Number: NPF-58 Report Number: 05000440/2023002 Enterprise Identifier: I-2023-002-0057 Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant Location: Perry, OH Inspection Dates: April 01, 2023 to June 30, 2023 Inspectors: J. Beavers, Senior Resident Inspector V. Myers, Senior Health Physicist T. Ospino, Resident Inspector Approved By: Karla K. Stoedter, Chief Reactor Projects Branch 2 Division of Operating Reactor Safety 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

LER 2023-002-00 for Perry Nuclear Power Plant, Main Steam Line Leakage Exceeded Technical Specification Limit Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.6] - Design 71153 NCV 05000440/2023002-01 Margins Open/Closed A self-revealed Green finding and a non-cited violation of Technical Specification 3.6.1.3,

"Primary Containment Isolation Valves," was identified when the licensee failed to maintain the B main steam isolation valves operable in Modes 1, 2, and 3.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000440/2023-002-00 LER 2023-002-00 for Main 71153 Closed Steam Line Leakage Exceeded Technical Specification Limit

PLANT STATUS

Unit 1 began the inspection period in a refueling outage. On April 20, 2023, the unit was returned to service with return to rated thermal power on April 22, 2023. On June 17, 2023, the unit was down powered to approximately 65 percent for a control rod sequence exchange. The unit was returned to rated thermal power later that day and operated at or near rated thermal power 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 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.

71111.04 - 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) annulus gas exhaust treatment system on June 21, 2023

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) class 1E alternating current electrical sources on April 12 and 13, 2023

71111.05 - Fire Protection

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

(1) The inspectors evaluated on-site fire brigade performance during a generator exciter breaker fire on April 7, 2023.

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 startup and shutdown activities on April 11 through 13, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated simulator performance on May 30, 2023.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (6 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) re-test of drywell equipment hatch after the local leak rate testing (LLRT) failure on April 4, 2023

(2) actions after elevated temperatures on the lower thrust bearing presented while running the recirculation pump A in fast speed on April 7, 2023

(3) discovery of the wrong inlet gasket on the C41F0029A and C41F0029B relief valves associated with the standby liquid control system on April 10, 2023

(4) reactor pressure control system issues during plant startup in Mode 1 on April 17, 2023

(5) emergency actions after wrong thermocouple readings, and the discovery of a miswiring associated to the reactor recirculating pump "A" upper guide bearing on April 7, 2023

(6) failure of "A" residual heat removal pump minimum flow valve and unplanned corrective maintenance on May 22, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (9 Samples)

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

(1) operability review of the A reactor recirculation system flow control valve after emergent maintenance work, April 2 through 5, 2023

(2) operability review of standby liquid control system after emergent work on April 11, 2023

(3) operability review of the rod control and instrumentation system after the INSERT BLOCK light stays ON on April 26, 2023

(4) operability review of the reactor core isolation system for pedestal bolt torque on April 27, 2023

(5) operability review of control rod drive mechanisms in response to Part 21 communication on May 8, 2023

(6) operability review of reactor pressure instrument after drifting high on May 8, 2023

(7) operability review of "A" residual heat removal on minimum flow valve failure on May 21, 2023

(8) operability review of upper containment airlock door failure on May 21, 2023

(9) operability review of emergency notification system and emergency response data system on May 30, 2023

71111.18 - Plant Modifications

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

(2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1) implementation of the instrument air permanent modification during the 1R19 outage between March 3 and 31, 2023

(2) implementation of the replacement and permanent modification of recirculation pump "A" cable from SB1-3644 to motor between March 3 and 26, 2023

71111.20 - Refueling and Other Outage Activities

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

(1) The inspectors evaluated refueling outage 1R19 activities from April 1 through April 20, 2023.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality: Post-Maintenance Testing (PMT) (IP Section 03.01)

(1) Tests validations to include limit switch(es) and/or stroke(s) time(s) for the outboard main steam isolation valve D after outage work on March 27, 2023.

(2) Standby liquid control system post-maintenance pump and valve operability for emergent maintenance on April 11, 2023.

(3) "A" reactor recirculating pump flow control valve functional test following replacement on April 5 and April 20, 2023.

(4) Replacement of check valve as part of the residual heat removal B system work during the outage between March 16 and April 12, 2023.

(5) Replacement of reheat steam valve N11-F170 during the outage between March 16 and April 12, 2023.

(6) Replacement of safety relief valve 1B21F0047B during outage activities between February to May 1,2023.

(7) Replacement of the safety relief valve 1B21F0047D as part of planned outage activities between February 27 and May 1, 2023.

(8) Replacement of the accumulator check valve,1B21-F024D, due to the failure to pass the surveillance SVI-B21-T2200 on March 29, 2023.

(9) Replacement of reactor recirculation pump A cable between February 27 and May 1, 2023.

(10) Replacement of the upper train of the limit switch as part of emergent work related to the residual heat removal A minimum flow valve on May 20, 2023.

(11) Replacement of amplifier card BJM-14 as part of the new rod control and information system on June 5, 2023.

(12) Replacement of the jacket water circulating pump (1R46-C0005A) on May 17, 2023.

(13) Replacement of "B" annulus exhaust gas treatment system damper control card on

===June 21, 2023.

Surveillance Testing (IP Section 03.01) (6 Samples)===

(1) Surveillance related to the functional test of the reactor recirculation flow control valve 1B33-F060A on March 21 and April 5, 2023.

(2) Ultrasonic test performed on the divider plate of the residual heat removal A heat exchanger on March 31, 2023.

(3) Safety relief valve pressure actuation channel E functional check on May 16, 2023.

(4) Core verification for the outage 1R19 on June 12, 2023.

(5) Reactor coolant system leakage pressure test on April 6, 2023.

(6) Drywell and containment leak rate tests on April 7, 2023.

Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)

(1) Licensee Action Level 1 for reactor coolant system monitoring on April 26, 2023.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)

The inspectors evaluated:

(1) emergency response organization drill on June 7,

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (7 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1) Portal monitor at radiologically controlled area exit

(2) Personal contamination monitors at radiologically controlled area exit

(3) Portal monitors at plant exit

(4) Telepoles staged for use

(5) Friskers staged for use

(6) Auxiliary building 574 area radiation monitor

(7) RM-20 frisker in fuel handling building

Calibration and Testing Program (IP Section 03.02) (11 Samples)

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

(1) ARGOS personal contamination monitors; L70L004V

(2) PM-12 Portal Monitor; L70L009S

(3) MGP Telepole; L70-L072G

(4) AMP 100; L70L076W

(5) AVS-28A; L70L2814

(6) Ludlum 12; L70L0966

(7) BC-4; L70L006A

(8) Drywell High Range Monitor; 1D19-K100

(9) PM-12 Portal Monitor; L70L009R

(10) Multi Channel Analyzer; MCA#1

(11) Liquid Scintillation Detector; 106776 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1) Off-Gas Vent; 1D17-K0836

(2) Liquid Radioactive Waste to Emergency Service Water Radiation Monitor; D17-K606

(3) Unit 1 Vent; 1D17-K786

OTHER ACTIVITIES - BASELINE

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

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) Unit 1 (April 1, 2022 through March 31, 2023)

MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) Unit 1 (April 1, 2022 through March 31, 2023)

MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) Unit 1 (April 1, 2022 through March 31, 2023)

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) incorrect gaskets installed on the standby liquid control system A and B relief valve inlet, C41-F0029A and C41-F0029B

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)

(1) The inspectors performed a semiannual review of the licensee's potential adverse trend in configuration control, specifically wire landing, for the previous six months.

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

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

(1) LER 05000440/2023-002-00, (ADAMS Accession No. ML23117A063). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.

INSPECTION RESULTS

Minor Violation 71152A Minor Violation: On April 11, 2023, the licensee identified a non-conforming condition with the standby liquid control (SLC) system after discovering incorrect gaskets were installed on both pump relief valves. At the time of discovery, the reactor was operating in Mode 4, and Technical Specification (TS) 3.1.7 for the SLC system was not applicable. The licensee determined the gaskets had been installed earlier in the refueling outage and were identified as non-conforming during a plant walkdown by an in-field operator. The licensee replaced gaskets with the appropriate gaskets, performed post-maintenance testing, and returned the SLC system to an operable status prior to entering an operating mode that required the SLC system. The inspectors determined a similar issue was documented in 2009 via Condition Report 200956238. The inspectors also determined the incorrect gaskets were installed because Schematic 304-0691-00111, Sheet 5, Revision E, "Standby Liquid Control System,"

contained incorrect gasket information.

The inspectors determined the failure to have the correct gasket information on Schematic 304-0691-00111, Sheet 5, Revision E, was a performance deficiency because the failure to have drawings appropriate to the circumstance for activities affecting quality was contrary to the requirements of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures and Drawings."

Screening: The inspectors determined the performance deficiency was minor. Specifically, the incorrect gasket material was installed and corrected while the reactor was operating in Mode 4, and the SLC system was not required to be operable. As a result, this issue did not adversely impact the mitigating systems cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences.

Enforcement:

This failure to comply with 10 CFR 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Semiannual Review of Potential Adverse Trend in Configuration 71152S Control, Wire Landing The inspectors performed a semiannual review of the licensee's potential adverse trend in procedure adherence where individuals follow processes, procedures, and work instructions.

During the inspection period, the inspectors evaluated more than 10 instances of miswiring identified prior to and during refueling outage 19 in 2023. Some issues were latent issues identified during maintenance activities while others were introduced during the inspection period and revealed during post-maintenance testing. However, all issues were corrected before returning equipment to service. Both in house and contract workers demonstrated behaviors that resulted in miswiring and subsequent loss of configuration control. The consequences included rework and an extended refueling outage that impacted overall maintenance scope changes and the triaging of assets. The inspectors did provide preliminary observations early in the refueling outage to alert licensee management of this potential trend.

Included in this sample were the following corrective action program documents:

CR 2023-02779, Control Relay Found Incorrectly Wired CR 2023-02064, Wrong cable identification number was recorded for Safety Relief Valve (SRV) 47D CR 2023-02365, Battery Test switch connection terminated on incorrect cell terminal CR 2023-02394, Reactor Recirculation HPU A valves wired backwards during replacement in 1R19 CR 2023-02356, Reactor Recirc A Flow Control Valve will not move for PMI-115 The safety culture common language associated behavior was WP.4: Procedure Adherence:

Individuals follow processes, procedures, and work instructions. Specifically, the behavior in question was individuals manipulate plant equipment only when appropriately authorized and directed by approved plant procedures or work instructions. The inspectors completed the objectives of the inspection procedure and trended the behavior to consider potential safety culture weaknesses and to encourage the licensee to take appropriate actions before significant performance degradation occurs as stated in NUREG-2165, "Safety Culture Common Language."

LER 2023-002-00 for Perry Nuclear Power Plant, Main Steam Line Leakage Exceeded Technical Specification Limit Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.6] - Design 71153 NCV 05000440/2023002-01 Margins Open/Closed A self-revealed Green finding and a non-cited violation of Technical Specification 3.6.1.3, "Primary Containment Isolation Valves," was identified when the licensee failed to maintain the B main steam isolation valves operable in Modes 1, 2, and 3.

Description:

Technical Specifications (TS) 3.6.1.3, Primary Containment Isolation Valves, requires each primary containment isolation valve, except containment vacuum breakers, shall be operable in Modes 1, 2, and 3. For main steam isolation valve (MSIV) line local leak rate tests (LLRTs),the TS surveillance limits were 100 standard cubic feet per hour (scfh) per individual steam line, both inboard and outboard MSIVs, and 250 scfh for all four steam lines.

In April 2021, the 1R18 refueling outage as-left LLRT documented the main steam line B leakage results being 96.9 scfh against the TS surveillance limit of 100 scfh. The total leakage of all four main steam lines was 193.8 scfh against the TS surveillance limit of 250 scfh. In November 2022, the licensee performed a rated-pressure walkdown of the outboard MSIVs during a unit forced outage shutdown and identified a packing gland leak on the B outboard MSIV with wetting and minor evidence of spray on the bottom of the valve flange. At that time, the licensee determined this leak had no impact on the operability of the valve. On January 5, 2023, the plant incurred an unexpected reactor trip providing the licensee an opportunity to revisit the previously identified B outboard MSIV packing. However, the inspectors did not find any documented evaluation updating the valve degradation.

On March 4, 2023, with the unit shutdown and in Mode 5 for a planned refueling outage, the main steam line LLRT for containment penetrations was performed. The testing found that the leakage on the B main steam line was unable to be measured due to an active packing leak on the outboard B MSIV. Reperformance of the test following the packing replacement, showed that the B main steam line combined leakage was 158.96 scfh, with the overall leakage for all main steam lines at 304.3 scfh. The licensee identified the direct cause of the B inboard MSIV leakage was valve seating surface wear/degradation over the previous operating cycle. The plausible cause of the outboard MSIV B leakage from the packing gland was stem misalignment during the work on the valve during the refueling outage in 2021, which then caused gouges on the stem and ultimately the packing gland leakage. The licensee performed a Probabilistic Risk Assessment (PRA) bounding evaluation for the March 2023 event, assuming a full 1-year unavailability and using the full power PRA model.

Fire and other external hazards were qualitatively addressed to be of low risk. The analysis of this event results in delta Core Damage Frequency and delta Large Early Relief Frequency (LERF) values below the acceptable thresholds of 1.0E-06/yr and 1.0E-07/yr, as discussed in Regulatory Guide 1.17 4. Sensitivities performed that added the postulated unavailability of the Inboard MSIV for the same 1-year period did not change these conclusions.

On April 26, 2023, based upon the preliminary cause and history, the licensee determined firm evidence existed to demonstrate that the excessive main steam line leakage condition existed during the last operating cycle for longer than allowed by TS SR 3.6.1.3.10. The condition was reported in accordance with 10 CFR 50. 73(a)(2)(i)(B) as a condition prohibited by technical specifications. The condition is also being reported under 10 CFR 50.73(a)(2)(ii)(B) as an unanalyzed condition and under 10 CFR 50.73(a)(2)(v)(C) as a condition that could have prevented the fulfillment of a safety function of structures or systems needed to control the release of radioactive material.

The inspectors reviewed the various corrective action program documents, testing data, and conferred with regional PRA analysts regarding this event. The inspectors concurred with the licensees conclusion that determined firm evidence of licensee failure to meet TS 3.6.1.3 during the last operating cycle. Licensee Event Report 2023-002 for Perry is considered closed.

Corrective Actions: The licensee reworked the "B" inboard and outboard MSIVs during the refueling outage. The valve stem and packing on the B outboard MSIV have been replaced, and the disc and seat were machined on the B inboard MSIV. The as-left LLRT leakage results were 4.0 scfh for main steam line B, and 153.4 scfh for all four main steam lines, both of which were within the TS surveillance requirement limits.

Corrective Action References: CR-2023-02047, 1R19 LLRT: Main Steam Line Penetrations Leakage exceeds SVI-B21-T9000 Step 5.3.4 Acceptance Criterion.

Performance Assessment:

Performance Deficiency: A self-revealed performance deficiency was identified when the licensee failed to have each required primary containment isolation valve operable in Modes 1, 2, and 3 as required by TS 3.6.1.3, Primary Containment Isolation Valves. Specifically, there was firm evidence, as stated in License Event Report 2023-002-00 for Perry Nuclear Power Plant, that the main steam line B inoperable condition existed during the last operating cycle for longer than allowed by TS 3.6.1.3 while the reactor was operating in Modes 1, 2, and 3.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. IMC 0612, Appendix E, "Examples of Minor Issues," Example 3.k:

The performance deficiency adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors identified the licensee had not appropriately challenged the operability conclusion given initial minimal operability margin in as-left leakage in refueling outage in April 2021 and the identification of existing spray and wetting of the valve flange in November 2022.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix H, Containment Integrity SDP. Per IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Section C, "Reactor Containment," Question 1, the inspectors determined the finding represented an actual open pathway in the physical integrity of reactor containment valves and required further evaluation using IMC 0609, Appendix H, "Containment Integrity Significance Determination Process."

Per IMC 0609, Appendix H, Table 4.1, findings related to MSIVs in boiling water reactor Mark III containments are not identified as contributing to LERF in high pressure accident sequences. Per phase 1 screening decision criteria for type B findings, Mark III containment type MSIV leakage is not applicable. The plant design includes main steam shutoff valves, which are safety class, remote manual motor operated valves. The post-accident function of the main steam shutoff valves is to be remote manually closed in order to provide a reduction of post-accident dose associated with the main steam line leakage path. The accident sequence related to the finding is not significant to LERF and characterized as Green (very low safety significance).

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety-related equipment. Specifically, the licensee failed to ensure: the work process ensures focus on maintaining fission product barriers, defense-in-depth, and safety-related equipment; design and operating margins are carefully guarded; and safety-related equipment is operated and maintained well within design requirements.

Enforcement:

Violation: TS 3.6.1.3, Primary Containment Isolation Valves, requires each primary containment isolation valve, except containment vacuum breakers, shall be operable in Modes 1, 2, and 3. Contrary to the above, from November 2022 until March 2023, the licensee failed to maintain each primary containment isolation valve operable when the reactor was operating in Modes 1, 2 and 3. Specifically, firm evidence existed during the operating cycle when the plant was in Modes 1, 2, or 3 to demonstrate the B main steam isolation valves operable, which are primary containment isolation valves, were not operable due to excessive leakage.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

On July 17, 2023, the inspectors presented the integrated inspection results to R. Penfield and other members of the licensee staff.

On June 29, 2023, the inspectors presented the radiation protection inspection results to R. Penfield, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Procedures SOI-M15 Annulus Exhaust Gas Treatment System 14

71111.11Q Miscellaneous Evaluation LOR Cycle 202302 Evaluation Scenario Guide - OTLC- 0

Scenario Guide 3058202302_PY-SGC1 copy 4 of 6

May 30, 2023, May 30, 2023, Simulator Scenario 05/30/2023

Scenario

71111.13 Corrective Action 2023-02589 O-Rings for Drywell Equipment Hatch Were Incorrect Length 04/03/2023

Documents (Too Long) for Installation

23-02599 PTI-P53-P0002 (Drywell Equipment Hatch) Unable to 04/04/2023

Establish Test Pressure

CR 2023-02768 Recirculation B Pump Lower Thrust Bearing Thermocouple 04/08/2023

Inaccurate Reading

CR-2023-02769 Reactor Recirculation Pump A Upper Guide Bearing 04/08/2023

Thermocouple Inaccurate Reading

CR-2023-02770 Reactor Recirculation Pump A Lower Thrust Bearing 04/08/2023

Elevated Temperature

CR-2023-03123 Turbine Stop Valves Failed to Open 04/16/2023

Miscellaneous White paper White Paper Related to CR 2023-02770 04/08/2023

Work Orders 200911643 Verify Thermocouple Temp Element Wiring 04/09/2023

71111.15 Corrective Action 2023-03326 Rod Block Annunciator Locked in 04/21/2023

Documents CR-2023-02862 Standby Liquid Control Pump A Relief Valve Inlet Gasket 04/11/2023

CR-2023-02863 Standby Liquid Control Pump B Relief Valve Inlet Gasket 04/11/2023

Worn

CR-2023-03747 10 CFR Part 21 Communication: Failure of the Control Rod 05/03/2023

Drive Collet Retainer Tube Outer Tube Weld

CR-2023-03840 Reactor Protection System Press Trip Unit High Reading 05/06/2023

CR-2023-04222 RHR A Min Flow Valve Main Fuse Failure 05/20/2023

CR-2023-04253 Upper Airlock Inner Door Failed LLRT 05/21/2023

CR-2023-04447 Loss of Network Resulting in Loss of NRC ENS line and 05/30/2023

ERDS

Procedures SOI-C11(RCIS) Rod Control and Information System 37

SVI-B33-T1158A Reactor Recirculation Flow Control Valve 1B33-F060A 04/05/2023

Functional test

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.18 Engineering 12-0214-002 Installation of Isolation Valves and Appendages on 03/31/2023

Changes Instrument Air Piping Inside Drywell to Isolate MSIV and

SRV Accumulators

ECP 23-1029- Replacement Recirc Pump A cable from SB1-3644 to Motor 03/05/2023

0001

Work Orders 200581668 $ECP#12-0214-002-Instrument Air Mod. Piping 03/31/2023

200900958 "No Definition on the Work Description Box" 03/26/2023

71111.24 Corrective Action 2023-01787 Power Leads Feeding Recirc Pump A Motor Found 03/10/2023

Documents Degraded

23-02064 Wrong Cable Identification Number Was Recorded for SRV 03/17/2023

47D

23-02065 Damaged cable on SRV 47B 03/17/2023

23-02260 RHR A and C Heat Exchanger Inspection Results 03/24/2023

23-04222 RHR A Min Flow Valve Main Fuse Failure 05/20/2023

23-04593 Damaged Div 1 Jacket Water Pump MCC Terminal Block 06/05/2023

Found During Inspection

CR 2023-02200 1R19 LLRT - MSIV Accumulator Supply Check Valve D 03/22/2023

Failed SVI-B21-T2200 Acceptance Criterion

Procedures GMI-0013 Check Valve Disassembly/Exercise Instruction 17

ISI-B21-T1300-1 Reactor Coolant System Leakage Pressure Test Revision 22

PYBP-SITE-0029 Reactor Coolant System Leakage Monitoring Revision 3

SVI-B21-T0369-E SRV and Low-Low Set Pressure Actuation Channel 05/16/2023

Functional for 1B21-N668E

SVI-B21-T2012 SRV Uncoupled Stroke Testing with GMI-0017A 7

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

SVI-B33-T1158A Reactor Recirculation Flow Control Valve 1b33-F060A 04/05/2023

Functional test

SVI-B33-T1158A Reactor Recirculation Flow Control Valve 1b33-F060A 04/05/2023

Functional test

SVI-B33-T1158A Reactor Recirculation Flow Control Valve 1B33-F060A Revision 0

Functional Test

SVI-T23-T0400 Drywell and Containment Leak Rate Tests Revision 11

Work Orders 200900958 Contingent to Replace Cables Determined Unsat per WO 03/26/2023

200900234 Cable Testing

Inspection Type Designation Description or Title Revision or

Procedure Date

200910297 No Official Work Description 06/05/2023

200461325 Replace Amplifier 06/05/2023

200850251 Perform Core Verification - FTI-D0001 06/12/2023

200850793 SVI-C71T0038H OTBD MSIVC Closure CH D 03/27/2023

200866718 SRV - Remove, Replace, & Offsite Shipping 05/01/2023

200866719 SRV - Remove, Replace, & Offsite Shipping 05/01/2023

200871131 (24M-STB) SVI-B33T1158B 03/21/2023

200871131 (24M-STB) SVI-B33T1158B 03/21/2023

200871691 Open/Clean/UTT RHR A HX Open Heat Exchanger, Clean 03/31/2023

Tube Side Channel, and Tubes, Perform UTT of Divider

Plate/, and Any Suspect Areas of the Channel

200890728 Replace check valve 03/07/2023

200896237 Red Indicating Light Does Not Work. Rev. 0 - Minor Order 03/12/2023

200900104 Reactor Recirc pump A Motor Lockout. Perform 01/09/2023

Troubleshooting and Rework as Required to Correct the

Cause

200910297 Rework MSIV Accumulator Check Valve D 03/29/2023

200915456 "No definition on the Work Description Block" 05/22/2023

200915457 Perform Static/MOV (Diagnostic) testing CC-Perform Static 05/22/2023

Mov Test

WO 200902141 "A" Standby Liquid Control Pump Discharge Valve Repair 04/11/2023

WO 200902242 "B" Standby Liquid Control Pump Discharge Valve Repair 04/11/2023

71124.05 Calibration Liquid Scintillator Quench Curve Data Set 05/11/2023

Records Efficiency Data Sheet for MCA#1 11/23/2021

264 Air Sampler Calibration Record for L70L2814 11/07/2022

264 AMP Calibration Record for L70L076W 05/13/2023

10360 MGP Telepole Calibration Record for L70-L072G 09/07/2022

10467 Model 12 Calibration Record for L70L0966 01/31/2022

273 BC-4 Calibration Record for L70L006A 12/05/2020

NOP-OP-4413 PM-12 Calibration Record for L70L009R 07/07/2022

NOP-OP-4413 PM-12 Calibration Record for L70L009S 09/06/2022

Corrective Action CR-2022-01405 Off Gas Post Treatment 'B' Radiation Monitor Reading 02/23/2022

Documents Lowered with No Change in 'A'

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-2022-06776 Offgas Vent Pipe Radiation Monitor set points need adjusted 09/03/2022

CR-2022-08458 Radwaste Building Area Radiation Monitor in Alarm 11/06/2022

Miscellaneous SCN 1502 Source Certificate 08/05/2022

23 Rad Verification of 89 Shepard Calibrator 01/13/2023

Portal Monitor Alarm Setpoint Justification 03/14/2023

SCN 864.00 Source Certificate 05/06/2004

Offsite Dose Calculation Manual 24

ATA-2021-6393 Performance Checks for Contamination Monitors and Portal 07/07/2022

Monitors

ATA-2022-13798 Radiation Monitoring Instrumentation Self-Assessment 01/31/2023

Report

CR-2022-06782 Radwaste to Emergency Service Water Radiation Monitor 09/04/2022

Trips

Procedures CHI-0006 Radiation Monitoring Alarm Setpoint Determination 25

CHI-0009 Tritium 17

CHI-0053B Calibration and Other Gammy Spectroscopy System 6

Operations Using APEX

NOP-OP-4401 Radiation Protection Instrumentation Program 03

NOP-OP-4416 ARGOS-5 Personnel Contamination Monitor Calibration and 00

Use

Work Orders 200798817 Drywell High Range Monitor Channel A Electronic 08/04/2021

Calibration

200816241 Liquid Radioactive Waste to Emergency Service Water 02/09/2022

Radiation Monitor Channel Calibration

200823628 Drywell High Range Monitor Channel A Calibration 05/05/2022

200854071 Unit 1 Vent Noble Gas Radiation Monitor Calibration 05/10/2023

200891964 Off-Gas Radiation Monitor Setpoint Adjustment 09/08/2022

71152A Corrective Action 2009-56238 Incorrect Gaskets Installed for 1C41F0029A and -29B 03/28/2009

Documents Valves

23-02862 Standby Liquid Control Pump B Relief Valve Inlet Gasket 04/11/2023

Worn

23-02863 Standby Liquid Control Pump A Relief Valve Inlet Gasket 04/11/2023

71152S Corrective Action CR 2022-02930 Cable Designation Mismatch on Drawings 04/02/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents CR 2023-00100 Reactor SCRAM Due to Temporary Loss of Feedwater 01/05/2023

CR 2023-02064 Wrong Cable Identification Number Was Recorded for SRV 03/17/2023

47D

CR 2023-02356 Rx Recirc A Flow Control Valve Will Not Move for PMI-115 03/27/2023

CR 2023-02365 Battery Test Switch Connection Terminated on Incorrect Cell 03/27/2023

Terminal

CR 2023-02394 Reactor Recirculation HPU A Valves Wired Backwards 03/29/2023

during Replacement in 1R19

CR 2023-02591 HPU A2 Servo Valve Conductors Inadvertently Flipped 04/03/2023

CR 2023-02769 Reactor Recirculation Pump A Upper Guide Bearing 04/08/2023

Thermocouple Inaccurate Reading

CR 2023-02779 Control Relay Found Incorrectly Wired 04/08/2023

Engineering ECP 21-0154-002 Replace Both TSC UPS Units / Install Additional Batteries 03/14/2023

Changes

Miscellaneous NUREG-2165 Safety Culture Common Language 03/2014

17