IR 05000440/2022002

Integrated Inspection Report 05000440/2022002

ML22220A096
Person / Time
Site:	Perry
Issue date:	08/08/2022
From:	Eve E NRC/RGN-III/DRP/B2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2022002
Preceding documents:	ML22005A178 (10 January 2022)
Download: ML22220A096 (20)

Text

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2022002

Dear Mr. Penfield:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On August 4, 2022, the NRC inspectors discussed the results of this inspection with Mr. Christopher Elliott, General Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations 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.August 8, 2022 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, Elise C. Eve, Acting 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: 05000440/2022002

Licensee: Energy Harbor Nuclear Corp

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Inspection Dates: April 1, 2022 to June 30, 2022

Inspectors: J. Corujo-Sandin, Senior Reactor Inspector D. Melendez-Colon, Reactor Inspector V. Myers, Senior Health Physicist T. Ospino, Resident Inspector J. Reed, Health Physicist M. Siddiqui, Reactor Inspector J. Steffes, Senior Resident Inspector

Approved By: Elise C. Eve, Acting 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

Failure to Survey Annulus During Moisture Separator Move Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.13] - 71124.01 Radiation Safety NCV 05000440/2022002-01 Consistent Open/Closed Process The inspectors reviewed a self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 20.1501 when the licensee failed to perform adequate surveys to demonstrate compliance with High Radiation Area (HRA) posting and controls required by 10 CFR 20.1902 and 20.1601 during moisture separator lifts.

Failure to Survey Worker After Alarming a Portal Monitor Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [H.8] - 71124.04 Safety NCV 05000440/2022002-02 Procedure Open/Closed Adherence The inspectors reviewed a self-revealed finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 20.1501 (a)(1) Surveys and Monitoring,

General when the licensee did not make surveys to assure compliance with 10 CFR 20.1802 Control of material not in storage. Specifically, the licensee failed to perform an adequate survey of a worker who alarmed a portal monitor at the facility exit, resulting in the uncontrolled release of radioactive material to unrestricted areas.

Additional Tracking Items

None.

PLANT STATUS

The plant began the inspection period at 97 percent power due to ongoing "A" flow control valve position fluctuations without operator demand experienced during the previous reporting period.

On April 2, 2022, the unit again experienced an undemanded movement of the "A" flow control valve following restoration from troubleshooting efforts which required operators to reduce reactor power to approximately 88 percent in order to restore recirculation loop flows to required band. The plant was restored to near full power operations on April 6, 2022, following repair and modification activities to the "A" flow control valve control circuitry. The unit remained at or near 100 percent power for the remainder of the inspection period except for rod sequence exchanges, required testing, and in some instances power reductions to maintain condensate demineralizer outlet temperature and/or condenser circulating water outlet temperature at or below their respective upper limits due to environmental conditions. The power reductions varied between 1 to 12 percent of rated thermal power and lasted from a few hours to several days.

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

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather thunderstorms and high winds on June 1, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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) Division 2 emergency diesel generator room 620' and 646' elevations on May 19, 2022

(2) Division 3 emergency diesel generator room 620' and 646' elevations on May 27, 2022

(3) Emergency service water pumphouse all elevations on May 27, 2022

(4) Unit 1 auxiliary building 574 elevation on June 6, 2022

(5) Unit 1 division 1 switchgear room 620 6 elevation fire zone 1CC-3c on June 22, 2022

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

(1) Fire drill on June 24, 2022

71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)

The inspectors evaluated heat exchanger performance on the following:

(1) Division 3 diesel jacket water heat exchanger (1E22B5002)

Ultimate Heat Sink (IP Section 03.04) (1 Sample)

The inspectors evaluated the ultimate heat sink performance on the following:

(1) Reviewed operation of service water system and ultimate heat sink (per Section 03.04.b)

Performed a system walkdown and reviewed documentation for the selected service water systems (per Section 03.04.d)

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) Division 3 emergency diesel generator jacket water heat exchanger maintenance on May 12, 2022

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 aggregate risk assessment with bus EF1E-1 removed from service for inspections on May 4 to 5, 2022

(2) Division 3 emergency diesel generator work window from May 9 to 12, 2022

(3) Plant aggregate risk assessment with maintenance on multiple safety systems on May 26, 2022

(4) Low pressure core spray minimum flow valve failure on June 24, 2022 (5) "B" annulus exhaust gas treatment recirculation fan damper failure as documented in CR 2022-05167 on June 27, 2022

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)

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

(1) Division 3 emergency diesel generator lube oil leak following maintenance window on May 13, 2022

(2) Upper containment airlock pneumatic test failure as documented in CR 2022-04314 on May 22, 2022

(3) Low pressure core spray minimum flow valve failure during testing from June 27 to 29, 2022

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Reactor recirculation flow control valve "A" modification to disconnect linear velocity transducer following failure on May 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) Division 3 diesel generator slow start following repairs on May 12, 2022

(2) High pressure core spray system valve F0514 replacement on May 16, 2022

(3) Test related to the fix of the upper containment airlock reactor door leak on May 27, 2022

(4) Replacement of rod control information system branch amplifier card 1C11-K700J on June 7, 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) Division 3 diesel generator start and load on June 2,

71124.01 - Radiological Hazard Assessment and Exposure Controls

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (1 Sample)

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

(1) Annulus controls during moisture separator move

71124.04 - Occupational Dose Assessment

Special Dosimetric Situations (IP Section 03.04) (1 Sample)

The inspectors evaluated the following special dosimetric situations:

(1) Completed the review of skin dose assessment from CR-2021-02636 dated April 26, 2021, that was previously documented in the 2022 first quarter integrated report (Perry Nuclear Power Plant - Integrated Inspection Report

===05000440/2022001).

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01)===

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

GPI Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.

INSPECTION RESULTS

Failure to Survey Annulus during Moisture Separator Move Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.13] - 71124.01 Radiation Safety NCV 05000440/2022002-01 Consistent Open/Closed Process The inspectors reviewed a self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 20.1501 when the licensee failed to perform adequate surveys to demonstrate compliance with High Radiation Area (HRA) posting and controls required by 10 CFR 20.1902 and 20.1601 during moisture separator lifts.

Description:

This facility has a cylindrical containment building which includes a refuel floor, where reactor disassembly and reassembly occurs. During disassembly, the reactors moisture separator, a highly contaminated piece of equipment, is lifted from the center of the refuel pool via a crane, moved to the north side of the pool, and lowered back into the pool. While the component is in the pool, substantial radiation shielding is provided by the water in the pool.

However, when the component is lifted from the pool, dose rates on the refuel floor become elevated. The containment is also surrounded by another cylindrical structure called the annulus. At elevations below the refuel floor there is substantial shielding, in the form of concrete and water, between radioactive components inside containment and the annulus.

However, at elevations at and above the refuel floor, the shielding provided is reduced to a steel liner ranging from 1 to 3 inches in thickness, which provides significantly less radiation shielding.

On March 11, 2021, two individuals, who were working in the annulus at about the same elevation as the refuel floor, received dose rate alarms on their electronic alarming dosimeters (EADs). These individuals placed their work in a safe condition, left the area and reported to Radiation Protection (RP). Maximum dose rates seen on the individuals EADs were 224 mrem/hr and 366 mrem/hr, with alarm setpoints of 75 mrem/hr. RP entered the annulus, which was posted and controlled as a radiation area, to perform follow-up surveys.

These surveys indicated dose rates of approximately 2 mrem/hr where the individuals were working. However, RP determined that at the time of the EAD alarms, the moisture separator lift was occurring inside containment and that the lift had been completed prior to RP entering the annulus to perform the EAD alarm follow-up surveys. Instead of performing a radiation survey prior to the moisture separator removal, the licensee relied on historical practices to determine the radiological controls, resulting in the area being posted and controlled as a radiation area.

Since RP could not validate the dose rates via follow-up surveys, they performed an evaluation using a software program that can model dose rates at various locations in relation to a radiation source. This evaluation utilized dose rates seen along the refuel pool railing during the moisture separator lift to estimate the dose rates inside the annulus. The dose rates seen along the refuel pool railing ranged from approximately 1.2 Rem/hr along the south railing (furthest from the moisture separator) to approximately 82 Rem/hr along the north railing (closest to the moisture separator). The licensees evaluation estimated radiation levels of approximately 400 mrem/hr in the location of the workers, which generally aligned with the dose rates seen on the EADs. Additionally, during the moisture separator move for reactor reassembly, the licensee posted and controlled accessible areas of the annulus at and above the refuel floor as HRAs and performed dose rate measurements at five locations. The maximum dose rate seen was approximately 350 mrem/hr at 1 foot from the steel liner.

The inspectors determined there were technical issues with the licensees evaluation. For example, the analysis performed via the software program had an error in which measurements that should have been in feet were entered as centimeters. Additionally, neither the analysis performed via the software program, nor the surveys conducted in the annulus during reassembly, established dose rates in accessible areas that would be expected to receive the highest dose rates during the moisture separator move. Specifically, the software program evaluation only looked at the location where the individuals who received the EAD dose rate alarms were, which was on the west-northwest side of containment. Additionally, although the surveys taken during reassembly were done at five different locations, none of the surveys were performed at the accessible locations closest to the north side of containment (the accessible areas closest to the moisture separator).

Irrespective of these issues, the inspectors determined that the areas within the annulus met the conditions requiring HRA postings and controls at the time of the moisture separator lift on March 11, 2021, during disassembly.

Corrective Actions: The licensee entered the issue into the corrective action program.

Corrective actions taken included updated procedure HPI-C0018, "Radiation Protection Response to Changing Plant Conditions, to include posting and controlling these accessible areas in the annulus as HRAs prior to commencing movement of various highly radioactive equipment in containment, as well as posting and controlling the annulus based on dose rates seen along the containment wall from the refuel floor. The licensee also plans to complete additional surveys of the annulus during the next moisture separator move to ensure that accessible areas expected to see the highest dose rates are surveyed.

Corrective Action References: CR-2021-01739, Two Unbriefed Dose Rate Alarms Received in Containment Annulus

Performance Assessment:

Performance Deficiency: The licensee failed to perform radiological surveys, as required by 10 CFR 20.1501, in the annulus to evaluate the impact from moisture separator lifts on the refuel floor in containment.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to survey resulted in inadequate controls for an HRA, which could lead to unintended dose to workers. The performance deficiency is similar to example 6F in IMC 0612 Appendix E, Examples of Minor Issues.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. Specifically, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not related to ALARA [as low as reasonably achievable], did not result in an overexposure nor a substantial potential for an overexposure, and the ability to assess dose was not compromised.

Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the licensee did not incorporate risk insights into a systematic approach in evaluating radiologically significant components in accessible areas adjacent to the area the components are in.

Enforcement:

Violation: Title 10 CFR 20.1501 requires that the licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels. 10 CFR 20.1601 requires specific controls associated with HRA access and 10 CFR 20.1902 requires specific postings for HRAs.

Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present.

Contrary to the above, on March 11, 2021, the licensee failed to perform surveys in accordance with 20.1501 to demonstrate compliance with 20.1601 and 20.1902. Specifically, the licensee did not conduct radiological surveys to evaluate the radiation levels in the annulus for the movement of the moisture separator inside containment to ensure that HRA postings and controls were implemented based on radiation levels.

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

Failure to Survey Worker After Alarming a Portal Monitor Cornerstone Significance Cross-Cutting Report Aspect Section Public Radiation Green [H.8] - 71124.04 Safety NCV 05000440/2022002-02 Procedure Open/Closed Adherence The inspectors reviewed a self-revealed finding of very low safety significance (Green) and an associated NCV of 10 CFR 20.1501 (a)(1) Surveys and Monitoring, General when the licensee did not make surveys to assure compliance with 10 CFR 20.1802 Control of material not in storage. Specifically, the licensee failed to perform an adequate survey of a worker who alarmed a portal monitor at the facility exit, resulting in the uncontrolled release of radioactive material to unrestricted areas.

Description:

On April 2, 2021, a decontamination technician completed their night shift work on the refuel floor during the Perry Nuclear Power Plant 1R18 refueling outage, which was the workers last day of work at the Perry site. The worker exited the site at the Primary Access Facility.

The worker entered a portal-style radiation monitor as part of the exit process and received an alarm. The worker indicated (in a subsequent statement/interview) that they then contacted a member of the RP staff to get support based upon the radiation alarms. Based upon this conversation with RP staff, the workers understanding was that they were to continue to monitor (while removing articles of clothing to determine where the contamination might be present) until RP responded to the area. After several more attempts, the worker exited the portal monitor and proceeded to call RP stating they had successfully passed the monitor and that no additional support was needed. The licensee's procedures require workers to contact RP after two monitor alarms. Additionally, licensee procedure instructs RP technicians to perform radiological surveys of individuals who alarm portal monitors twice.

Subsequently, neither of these procedural requirements were met when the worker exited the facility.

On April 5, 2021, the worker arrived at another nuclear reactor facility where they alarmed the portal monitor during in-processing activities. The other nuclear reactor facility performed radiological surveys that identified both internal and external contamination of the worker.

During decontamination activities, a discrete radioactive particle was identified with an activity of 80,000 disintegrations per minute. Additionally, low level contamination of clothing and shoes was identified. Once external decontamination efforts were completed, in-vivo bioassay was completed via a whole-body counter. The Radiation Protection Manager (RPM) of the other nuclear reactor facility contacted the RPM at Perry to inform them of the potential issue.

Perry Nuclear Power Plant performed a review of video footage that revealed the multiple portal monitor alarms by the worker on the morning of April 2, 2021. The video footage also appeared to show the worker moving off-camera and making attempts to contact the Perry RP staff for assistance (via a telephone in the immediate area). At no time during the 30 minutes did a member of the RP staff arrive to survey the worker. The licensee assessed the information (both onsite and from the other nuclear reactor facility) and determined that the dose to the individual was likely less than 5 mrem to the individuals whole body.

Corrective Actions: The radioactive material found on the worker was confiscated and returned to Perry Nuclear Power Plant for disposal. Additional radiological surveys were performed at the workers hotel. Training was conducted for onsite RP technicians and contractor RP technicians on portal monitor alarm responsiveness and radiological risk awareness.

Corrective Action References: CR-2021-02636

Performance Assessment:

Performance Deficiency: The licensee failed to perform adequate surveys to control licensed material within the facility. Specifically, the licensee did not perform required radiological surveys of a worker who alarmed the portal monitors. Subsequently, the failure to perform required surveys resulted in the uncontrolled release of radioactive material into unrestricted areas.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the licensee did not perform radiological surveys of a worker who alarmed a portal monitor which resulted in an uncontrolled release of the radioactive material into unrestricted areas.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (Green) because there was an uncontrolled release of radioactive material into unrestricted areas that resulted in dose to the public below 0.005 rem Total Effective Dose Equivalent.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, RP staff did not follow their procedures and processes to respond to a portal monitor alarm.

Enforcement:

Violation: Title 10 CFR 20.1501 requires, in part, that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present.

Title 10 CFR 20.1802, requires, in part, that the licensee control and maintain constant surveillance of licensed material that is in a controlled area or unrestricted areas and that is not in storage.

Contrary to the above, on April 2, 2021, the licensee failed to perform surveys to assure compliance with 10 CFR 20.1802. Specifically, on April 2, 2021, the licensees survey of a worker who alarmed the portal monitor did not control licensed material from inadvertently being carried outside of the controlled area and restricted areas of the site. A discrete radioactive particle of 80,000 disintegrations per minute was carried offsite by the worker.

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 August 4, 2022, the inspectors presented the integrated inspection results to Mr. C. Elliott, General Plant Manager, and other members of the licensee staff.

On April 29, 2022, the inspectors presented the triennial heat sink inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.

On June 9, 2022, the inspectors presented the radiation protection inspection results to Mr. C. Elliott, General Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Procedures ONI-ZZZ-1 Acts of Nature - Severe Weather 34

71111.05 Corrective Action 2022-05089 NRC Identified: Appendix R Light Charging Meter Erratic 06/23/2022

Documents 2022-05101 NRC identified Prefire Plan has Incorrect Functional 06/24/2022

Resulting from Locations Referenced

Inspection

Fire Plans FPI-0CC Control Complex 06/22/2022

FPI-0EW Emergency Service Water Pumphouse 7

FPI-1AB Auxiliary Building Unit 1 06/07/2022

FPI-1DG Diesel Generator Building 10

Miscellaneous PNPP No 7015 Fire Drill Planning Guidance - SCENARIO #FD-1125-062322 06/23/2022

71111.07T Calculations E22-037 Design-Basis Heat Load & Required ESW Flow for the 2

HPCS DGJW HX

E22-042 Division 3 Emergency Diesel Generator Jacket Water Heat 3

Exchanger Performance Test

E22-042 Division 3 Emergency Diesel Generator Jacket Water Heat 4

Exchanger Performance Test

P45-081 Evaluation of Net Positive Suction Head (NPSH) and 0

Submergence Requirements for the Emergency Service

Water (ESW) System Pumps

P45-084 Determine Allowable Silt and Zebra Mussel Accumulation in 0

ESW and SW Intake SSC's

Corrective Action 2001-3711 Silt Removal Criteria for ESWPH 10/22/2001

Documents 2007-14120 Snapshot SA PY-SA-07-68 Found Design Silt Depth 02/07/2007

Exceeded in the ESW Intake Tunnel

20-06344 Zebra Mussel Treatment Postponed Due to Deteriorating 08/11/2020

Lake Conditions

20-06391 Zebra Mussel Treatment Postponed Due to Lake Conditions 08/13/2020

20-06416 Zebra Mussel Treatment Scheduled for Friday, August 14th, 08/14/2020

was Postponed Due to Deteriorating Lake Conditions

20-07541 Diving Inspection of Intake and Discharge Structures 09/28/2020

20-08428 Emergency Service Water Normal Intake Tunnel 10/30/2020

Silt/Zebra Mussel Debris Depth Exceeds 5 Feet

Inspection Type Designation Description or Title Revision or

Procedure Date

21-06384 Diving Inspection of Intake and Discharge Structures 08/24/2021

21-09615 Emergency Service Water Normal Intake Tunnel Silt Level 12/20/2021

High

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

Diesel Generator Jacket Water Heat Exchanger

Performance Degradation

G202-2008-Silt Levels in the ESW Pumphouse Suction Bays 02/20/2008

35631 (East & West)

Corrective Action 2022-03618 Scaffolding Erected Too Close to Safety-Related Equipment 04/26/2022

Documents

Resulting from

Inspection

Drawings 1E22-S001 Div. 3 Diesel Jacket Water Cooling System 02/08/2016

2-0139-00000 Division III Diesel Generator 0

Engineering 20-0065-000 Setpoint Revision for Emergency Service Water Flow 0

Changes Switches and Alarm Units: 1P45N0053A/B

(ECC HX A/B), 1P45N0073A/B (DG HX A/B), and

1P45N0251A/B (RHR A/C & B/D HXs)

DCP 00-5013 ESW Intake Sluice Gate Seal Modification 09/27/2001

Engineering Engineering Evaluate Adverse Affect of Scaffolding 04/28/2022

Evaluations Evaluation

Request

601358919

Miscellaneous Pump and Valve Inservice Testing Program Plan 26

281 Vendor Manual - Emergency Service Water Sluice Gates 2 - 14

Aquatic Sciences Discharge Tunnel Internal Inspection Using a Remotely 12/06/2013

LP Project RU12-Operated Vehicle

009

Aquatic Sciences Inspection of the Common Service Water Intake Tunnel with 08/28/2014

LP Project RU13-a Remotely Operated Vehicle

030

ASI Marine Inspection of the Common Service Water Intake Tunnel with 06/11/2019

Project a Remotely Operated Vehicle

Reference: RU19-

Inspection Type Designation Description or Title Revision or

Procedure Date

2

Design Input 223 Perry Nuclear Power Plant HPCS DGJW Heat Exchanger 1

Design Input

L02452 Upgrade the ESW Sluice Gate Seals to Safety Class 07/10/2001

L02452 Commitment to Upgrade the ESW Sluice Gate Seals to 10/19/2000

Safety Class

PLCO P22-P42-Potential Limiting Condition of Operation for ECCs A Heat 03/16/2022

158 Exchanger

PY-CEI/N RR-License Amendment Request Regarding a Modification to 06/01/2000

2492L the Emergency Service Water Alternate Intake Sluice Gate

Automatic Opening Function and the Use of a Non-Safety

Inflatable Seal

PY-CEI/NRR-Supplemental Letter to License Amendment Request 06/30/2000

2505L Regarding a Modification to the Emergency Service Water

Alternate Intake Sluice Gates

SMRF 00-5013 Simple Modification Request Form (SMRF) 00-5013 3 and 4

Upgrades the ESW Sluice Gate Inflatable Seals and

Associated Inflation System to Safety Grade in Accordance

with 10 CFR Part 50 Appendix B Requirements for

Components Important to Safety Prior to Relying on the

Seals During the Summer of 2001

TAF 081999-06 As-Found Buried/Underground Examination Report for 48" 12/17/2013

Emergency Service Water (P45) Piping

TAF 081999-14 As-Found Buried/Underground Examination Report for 14" 05/07/2019

Emergency Service Water Line per Order 200614309

TAF 081999-15 As-Found Buried/Underground Examination Report for 14" 05/07/2019

Emergency Service Water Line per Order 200614309

TAF 81839 EMARP-0011 Diving Inspection Activities 6

Operability 2007-14120 Prompt Operability Determination for CR-2007-14120, 0

Evaluations ESWPH Intake Tunnel Silt Buildup

Procedures EMARP-0011 Emergency Service Water System Monitoring Program 8

NOP-ER-2006 Service Water Reliability Management Program 6

NOP-WM-5008 Control of Scaffolding 2

OAI-1701 Tracking of LCOs 20

Inspection Type Designation Description or Title Revision or

Procedure Date

PTI-E22-P0007 HPCS Diesel Generator Jacket Water Heat Exchanger 7

Performance Testing

PYRM-ER-0001 Perry Service Water Reliability (Generic Letter 89-13) 00

Program Basis Document

SOI-P45/P49 Emergency Service Water and Screen Wash Systems 35

Section 7.18

SOI-R46/E22B Division 3 Diesel Generator Jacket Water System 8

Work Orders 200340456 Clean, Inspect, Eddy Current, Leak Check Div III Diesel 08/06/2010

Jacket Water Heat Exchanger

200442907 PTI-E22P0007 1 (4Y) HPCS Diesel Generator Jacket Water 10/13/2014

Heat Exchanger Performance Testing

200645158 PTI-E22P0007 1 (4Y) HPCS Diesel Generator Jacket Water 11/07/2018

Heat Exchanger Performance Testing

71111.12 Calculations E22-046 Evaluation of Required Minimum Thickness of Partition Plate 0

for Division 3 Diesel Generator Jacket Water Heat

Exchanger

Corrective Action 2022-03975 Acceptance Criteria not Identified in Division 3 Emergency 05/10/2022

Documents Diesel Generator Jacket Water Heat Exchanger Work Order

Drawings 304-0805-00000 Emergency Service Water Diesel Generator Building L

71111.13 Corrective Action 2022-03961 Division 3 Diesel Fuel Line Sheared During Maintenance 05/10/2022

Documents Run on Number 8 Cylinder

22-03969 Division 3 Diesel Generator #8 Cylinder Inspection Results 05/10/2022

22-03994 Division 3 Diesel #8 Cylinder Head Sleeve and Crab 05/11/2022

Damaged

22-05107 LPCS Minimum Flow Valve Blew 2 Main Line Fuses 06/24/2022

22-05140 MCC EF1A07-S Failed Under Voltage Relay 06/27/2022

22-05167 Annulus Exhaust Gas Treatment Fan B Recirc Damper 06/27/2022

Failed to Reposition

Procedures NOP-OP-1007 Risk Management 37

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

Work Orders 200887797 Perform Simple Troubleshooting / Rework 06/28/2022

71111.15 Corrective Action 2022-04066 Lube Oil Clamp Plate Leakage Identified During Division 3 05/13/2022

Documents Diesel Generator Operation

22-04067 Oil Seepage Identified on Pipe Fitting During Division 3 05/13/2022

Inspection Type Designation Description or Title Revision or

Procedure Date

Diesel Generator Operation

22-04314 Failed Upper Containment Airlock Pneumatic System Leak 05/22/2022

Test, Pen #312

22-05141 Low Pressure Core Spray Minimum Flow Valve Torque 06/27/2022

Switch Dimensions were Outside of Acceptance Criteria

Work Orders 200790607 Add Washers to Ball Valves/ECP 19-0148/CR 2018-02435 5/28/2022

71111.18 Engineering 22-0056-001 Temporary Modifications to Remove the 5 Volt Modicon 0

Changes Clamp on the Velocity Controller Output

Work Orders 200879878 Implement Engineering Change 22-056 04/22/2022

71111.19 Engineering 19-0418-003 Containment Airlock 3-Way Ball Valve Return to Original 05/28/2022

Evaluations Design Configuration, PY-1P53F0591B, PY-1P53F0592B

(Upper Containment Airlock Inner Door)

601349509 Approve-Replace Valve with Ball Valve 02/08/2022

Procedures PTI-E22-P0011 High Pressure Core Spray Diesel Generator Slow Speed 5

Start for Post-Maintenance Inspections

Work Orders 200461326 Replace Branch Amplifier Card 1C11-K700J (BJM22) 06/07/2022

200790607 Add Washers to Ball Valves/ECP 19-0148/CR 2018-02435 05/28/2022

20086670 Replacement of the Dresser Valve 1E22F0514 with a Ball 05/16/2022

Valve

71111.22 Corrective Action ATA-2022-12374 Remove Over Pressurization Step from SVI-P57-T0392A on 07/12/2022

Documents Page 12 of Rev 5. (Steps 27,28,29)

Procedures SVI-E22-T1319 Diesel Generator Start and Load Division 3 06/02/2022

Work Orders 200814203 Replace Fullers Earth Filter 05/02/2022

71124.01 Radiation PY-M-20210312-Refuel Floor During Moisture Separator Move 03/11/2021

Surveys 14

71124.04 Calculations Calculation found Deep Dose Calculation 05/26/2022

in CR-2021-

2636

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

Documents Activity

Procedures NOP-OP-4413 PM-12 Calibration, Source Checks and Use 0

NOP-OP-4503 Personnel Contamination Monitoring 14

71124.07 Calibration PY-SVI-Meteorological Monitoring, System A, 10 Meter Wind Speed 05/02/2022

Records D51T0305A

Inspection Type Designation Description or Title Revision or

Procedure Date

PY-SVI-Meteorological Monitoring, System A, 10 Meter Wind 05/02/2022

D51T0306A Direction Channel Calibration

PY-SVI-Meteorological Monitoring, System A, 60 Meter Wind 05/02/2022

D51T0308A Direction

PY-SVI-Meteorological Monitoring, System A, Air Temperature and 05/02/2022

D51T0311A Delta Air Temperature Calibration for D51-N706 and

D51-N708

Corrective Action CR-2020-01864 The 2020 Reactor Water to NCC Leakage Revealed that the 03/06/2020

Documents Methodology Developed in 2012 for Determination of Effluent

Dose Due to NCC Leakage was Inadequate for the Current

NCC Leak

CR-2020-02119 2 REMP Air Samplers Found Not Operating 03/11/2020

CR-2020-05443 REMP Air Sampler (6) Found with No Flowrate 07/02/2020

CR-2021-06690 August Vegetation Re-Sampled Due to Courier Disposal 09/03/2021

Corrective Action CR-2022-04738 NRC ID: August 2021 ODCM Required Vegetation 06/09/2022

Documents CR-2022-04748 NRC ID: REMP Air Sampler Trees/Foliage Need Trimmed 06/09/2022

Resulting from

Inspection

Miscellaneous 10CFR50.75(g) 10CFR50.75(g) Event Log Spreadsheet 05/12/2022

Event Log

Procedures CHI-ODCM Offsite Dose Calculation Manual 24

NOP-OP-2012 Groundwater Monitoring 13

NOP-OP-4705 Response to Contaminated Spills/Leaks 9

PAP-0808 Environmental Programs and Reports 15

PAP-0809 Radiological Environmental Contamination Response 4

PAP-1704 Preparation of the Annual Environmental and Effluent 10

Release Report

REMP-0012 Food Product Sampling 8

REMP-0018 REMP Sample Data Review and Reporting Requirements 8

REMP-0022 Processing Data from the PNPP Meteorological Tower 5

REMP-0023 Air Sample Collection 8

REMP-0024 Air Sampler Maintenance and Calibration 3

Self-Assessments ATA-2021-18921 2022 REMP Self-Assessment 03/11/2022

Audit # 24879 NUPIC Audit of ATI Environmental Inc. 07/13/2020

17