IR 05000440/2021013

Biennial Problem Identification and Resolution Inspection Report 05000440/2021013

ML22005A330
Person / Time
Site:	Perry
Issue date:	01/10/2022
From:	Billy Dickson NRC/RGN-III/DRP/B2
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2021013
Download: ML22005A330 (13)

Text

SUBJECT:

PERRY NUCLEAR POWER PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2021013

Dear Mr. Penfield:

On December 14, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Perry Nuclear Power Plant and 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.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.January 10, 2022 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: 05000440/2021013

Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Inspection Dates: November 15, 2021 to December 14, 2021

Inspectors: V. Meghani, Reactor Inspector G. O'Dwyer, Reactor Engineer T. Ospino, Resident Inspector R. Ruiz, Project Engineer 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 a biennial problem identification and resolution 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.

INSPECTION SCOPES

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

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Division I and II emergency diesel generators.

Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Effectiveness:

The inspectors assessed the licensees corrective action program (CAP) and its effectiveness in identifying, prioritizing, evaluating, and correcting problems. Based on the samples reviewed, the team determined that the licensees performance in these areas adequately supported nuclear safety.

Problem Identification:

Overall, the licensee effectively identified issues at a low threshold and correctly entered them into the CAP as required by Fleet procedures. The inspectors determined that the station was generally effective at identifying trends that could potentially impact nuclear safety. The inspectors also performed plant walkdowns of various areas/systems important-to-safety, including the division 1 and division 2 emergency diesel generators (EDGs) and the service water pump house. For the samples reviewed, the inspectors did not identify any regulatory issues of concern in the area of problem identification.

Regarding problem identification, the team identified three examples of the inconsistent use of the repair tag process outlined in procedure NOP-WM-1003, Nuclear Maintenance Notification Initiation and Screening, which could adversely affect the staffs ability to enter issues into the CAP appropriately. These examples included: a known minor leak on a safety-related valve which had a catch-container installed but no repair tag present; a repair tag hanging in the division 2 EDG room for a condition that maintenance staff had already fixed; and a known oil leak on the division 2 EDG starting air compressor that had no repair tag, whereas a nearly identical leak on the division 1 EDG stating air compressor had a repair tag. Although such inconsistencies are not prohibited by procedure under specific circumstances (such as a prevailing desire to preclude the tags from becoming foreign material), if prevalent, such inconsistent use of the repair tag process could result in a situation where staff may fail to enter conditions into the CAP based on assumptions made in the field that an issue may already be known and entered into the CAP when its not.

Problem Prioritization and Evaluation:

In-depth reviews of a risk-informed sampling of condition reports (CRs), work orders (WOs),and causal evaluations were completed, including a 5-year review of CAP issues and trends associated with the division 1 and division 2 EDGs. The inspectors concluded that the licensee generally prioritized and evaluated issues for resolution appropriately commensurate with their safety significance.

Corrective Actions:

The team concluded that the licensee was generally effective in developing corrective actions (CAs) that were appropriately focused on correcting the identified problem and correcting conditions adverse to quality. The team reviewed a sample of CA assignments developed for selected NRC documented violations, selected licensee event reports, licensee self-assessments, and licensee-identified issues. Based on the samples reviewed, the team determined that the licensee adequately implemented corrective actions.

Operating Experience, Self-Assessments and Audits:

The inspectors assessed the effectiveness of the stations processes for the use of operating experience, audits, and self-assessments. Based on the samples reviewed, the team determined that the licensee's performance in these areas adequately supported nuclear safety.

Safety Conscious Work Environment:

The team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed a representative cross-section of station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, workers at the Perry plant expressed freedom to raise and enter safety concerns through any of the various avenues available. The team encountered no indications of chilling or retaliation. Finally, all plant personnel interviewed were aware of the Employee Concerns Program (ECP) and expressed a willingness to use it as an avenue to raise concerns, if desired.

The team communicated two observations based on comments received during interviews.

The first observation was regarding a supervisor who expressed a lack of clear understanding concerning the initial categorization of issues as adverse to quality versus Non-adverse to quality. Although this was only one individual, given their position as a supervisor, this lack of clarity may extend to their workgroup. Additionally, a lack of clarity in this area could lead to instances where the Management Review Board is challenged as the barrier to catch potential categorization errors in condition reports. The team did not identify any such instances through its reviews. During its follow-up, the team also learned that plant leadership already knew of this topic, and actions were underway to address the categorization clarification area.

The second observation is related to a theme of comments that the team received throughout many of the interviews regarding workforce staffing levels. Specifically, the team encountered a high percentage of comments regarding workforce staffing levels being notably lower than in the past with the same amount of work existing, resulting in longer hours, more overtime, and lowering morale. Industry operating experience has shown that sustained low workforce morale and resource pressures can reduce the quality of work, which can lead to future events or challenges to regulatory limits. Additionally, such sustained pressures can exacerbate the effect of driving staff out of an organization. During its follow-up, the team recognized that this topic was already known by plant leadership and is a focus area with actions being taken. Although the inspection team did not identify any such instances of regulatory challenges, the Resident Inspectors will continue to track and monitor station performance for any potential impacts on safety margin or regulatory limits.

EXIT MEETINGS AND DEBRIEFS

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

On December 14, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Rod Penfield, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action ATA-2021-4992 Pre-NRC Inspection on Problem Identification & Resolution 04/01/2021

Documents ATL-2018-0166-CR 2020-08686 will be Included in the Electrical Training 02/17/2021

ATA-150 Program for Electrical Safety

CA-2020-08383-Label the Sewage Pump House Quincy 400 AMP Disconnect 12/16/2020

001 Switch with a Warning Sign

CA-2020-08383-Replace the Quincy Feed Cable from Pole 9525 02/05/2021

2

CR-2019-01671 Main Generator/Main Turbine Trip Resulting in a Reactor 02/25/2019

Scram

CR-2019-02529 Request to Use Longer Bolt or Heli Coil to Repair 03/19/2019

1B21F0022A Control Air Pack Mounting

CR-2019-02533 B21-029B Failed Leak Rate Test 03/19/2019

CR-2019-02796 Threads Damaged During Air Blow of "C" inboard MSIV 03/25/2019

CR-2019-02861 Oil Leaking from Outboard MSIV D 03/27/2019

CR-2019-02939 Inboard MSIV 'D' 1B21F0022D Slow Speed Adjustment 03/29/2019

Found Damaged

CR-2019-03273 High Main Generator Casing Liquid Level Requires Manual 04/07/2019

Trip of Main Turbine

CR-2019-05852 General Causal Evaluation for Proper Categorization of 07/11/2019

Previous CRs and Associated Maintenance Rule Applicability

CR-2020-00032 Error Identified in USAR Section 9A.4.23.5 (Unit 2 Turbine 01/03/2020

Building Fire Hazards Analysis)

CR-2020-00284 PY-PTI-R50-P0001 Portion Failure Due to E-plan 5-way 01/15/2020

Notification Line Not Connecting to All Parties

CR-2020-00611 Cause Evaluation: Issue identified with the RCIC Turbine 01/26/2020

Mechanical Overspeed Trip While Performing Overspeed

Trip Testing

CR-2020-00622 RCIC Waterleg Pump Vertical Velocity Vibration Reading is 01/26/2020

in the Alert Range

CR-2020-00623 Alarm Wouldn't Clear Div 2 DG 01/26/2020

CR-2020-00843 Combustible Gas Mixing Compressor Tripped on Degraded 02/04/2020

Thermal Overloads.

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-2020-01878 Potential Past Operability Concerns with Combustible Gas 11/01/2019

Mixing Compressor B

CR-2020-02630 Drawing 302-730 has an Incorrect "Fails Open" Annotation 03/25/2020

for Solenoid Control Valve 0G50F057 (Seal Water to Floor

Drain Filtrate Pump)

CR-2020-02939 Perry 3 Minute Audible Test Not Performed Per County 04/06/2020

Request

CR-2020-03062 Emergency Notification System Phone (Red Phone) is not 04/10/2020

Working

CR-2020-03770 Div 2 DG Fuel Oil Press Low Alarm 04/28/2020

CR-2020-04340 MS-C-20-05-07: Record Copy of Work Order Missing 05/18/2020

Signature for Submitting As-Built Drawings

CR-2020-04341 MS-C-20-05-07: Record Copy of Work Order Missing 05/18/2020

Signature for Document Verification

CR-2020-04439 MS-C-20-05-07: Procedure Approval Form Administrative 05/21/2020

Discrepancies - Maintenance

CR-2020-04440 Review of 21 completed Procedure Approval Form Record 05/18/2020

Packages (Quality Records) Identified Discrepancies

CR-2020-04686 Received Aux. Building and Steam Tunnel Cooling HVAC 05/30/2020

Trouble

CR-2020-04955 Concrete Spalling and Leakage in Emergency Service Water 06/09/2020

Pump House, 586' Elevation

CR-2020-06467 ERO Drill - Unplanned Controller Injects Performed During 08/12/2020

the 8/12/2020 Dry Run Drill

CR-2020-06471 ERO-Drill: Timeliness of General Emergency Classification 08/12/2020

During 8/12/2020 Dry Run Drill

CR-2020-07230 NRC EPlan Drill - Objective F.18 Met with Comments due to 09/15/2020

Shortfalls in Rigor Regarding Communication Standards.

CR-2020-07231 Cause Evaluation: NRC EPlan Drill Objective F6 for Dose 09/16/2020

Assessment, Not Met

CR-2020-08383 General Causal Evaluation for Live Electrical Cable Identified 10/28/2020

During Work being Performed

CR-2020-08383-Threat Assessment of Outbuildings for Safety Issues 03/19/2021

ATA-01

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-2020-09635 (MPFF) - Combustible Gas Mixing Compressor Suction 12/22/2020

Valve Would Not Reopen Following Compressor Start

CR-2021-01124 Inconsequential Latent Error Identified in Control Blade 02/19/2021

Lifetime Monitoring Software

CR-2021-01197 Weekly E-Plan Pager Test Did Not Call the Control Room 02/22/2021

Shift Manager Notification Device

CR-2021-01650 (MPFF) - RWCU Pump A and B Failed During 1R18 03/09/2021

CR-2021-01724 Monthly 5 Way Communication Test - Lake County 03/10/2021

Equipment Deficiency Identified

CR-2021-01759 Leakage Rate of 1B21F0028B Outboard MSIV Steam Line B 03/12/2021

Exceeds Acceptance Criteria in SVI-B21-T9000

CR-2021-01759 Leakage Rate Of 1B21F0028B Outboard MSIV Steam Line B 03/12/2021

Exceeds Acceptance Criteria In SVI-B21-T9000

CR-2021-02036 Chain Fall with Incorrect (Short) Pull Chain Rigged to the 03/20/2021

Reactor Dry Tube Strong Back

CR-2021-02292 Second MSIV Accumulator Supply Leaking During ISLT 03/27/2021

CR-2021-02297 SVI-B21-T9000 Step 5.3.5 Acceptance Criteria Not Met 03/27/2021

CR-2021-02894 Cause Evaluation: Reactor Water Cleanup System (RWCU) 04/14/2021

Containment Isolation Valves (Penetration (P132)) Issues

CR-2021-04817 REMP Fish Samples Lost During Transit to Offsite Vendor 06/21/2021

CR-2021-05006 Document ANS Siren L17 Out of Service 06/29/2021

CR-2021-05033 Service Water Building Intake REMP Location # 34 Water 06/30/2021

Sampling Pump is Malfunctioning

CR-2021-05353 General Cause Evaluation for CR-2021-05353, Cycle 18 07/13/2021

Maintenance Rule Periodic Assessment Report Identifies

Potential Adverse Trend

CR-2021-DBAI POV Inspection: RCIC Steam Supply Isolation Valves 09/17/2021

054082021 Questionable Calculation Justification

CR-2021-05435 Addition - 2021 DBAI POV Inspection: JOG Classification of 07/16/2021

RCIC Steam Supply Isolation Valves

CR-2021-05580 Site Projects Exceeded Annual Dose Budget 07/22/2021

CR-2021-06362 Rad-Cal Standard for Calibrator Verification is Broken 08/23/2021

CR-2021-06976 EPLAN Drill, Near Miss with Incorrect Pager Message for 09/15/2021

Unusual Event

Inspection Type Designation Description or Title Revision or

Procedure Date

CR-2021-07221 Hi Fuel Oil Filter Differential Pressure for Division 2 Diesel 09/26/2021

Generator

CR-2021-07223 Div 2 DG Lube Oil Strainer High DP Alarm Coming in During 09/26/2021

DG Run

Corrective Action CR-2021-09144 NRC Identified: Div 1 DG High Crankcase Pressure Trip 12/02/2021

Documents Valve, 1R43N0711A, Leaking from Sensing Line

Resulting from

Inspection

Miscellaneous Commitment Closed Commitment L02393 and Changed TS Bases to 1

Change notice Remove Requirement to Restore Leakage Within 25 SCFH

21-023 When MSL Leakage Rate Exceeds 100 SCFH

Commitment If the Leakage Rate on Any Main Steam Line Exceeds 100 1

L02393 SCFH, the Leakage Rate Will Be Restored to Within 25

SCFH When Tested at > = PA

OE-2020-0072-1 OE468879R20200310 Auxiliary Feedwater System Declared 0

Inoperable Due to Check Valve Leakage

OE-2020-0255-1 OE485135R20200918 Error in Basis for Emergency Action 0

Levels for Fission Product Barrier Containment

Radiation/Reactor Coolant System Activity Thresholds

OE-2020-0272-1 NRC IN 20-02, Flex Diesel Generator Operational 0

Challenges

Procedures NOBP-LP-2003 Employee Concerns Program 6

NOBP-LP-2013 Safety Conscious Work Environment Review Team 5

NOP-LP-2001 Corrective Action Program 48

NOP-WM-0001 Work Management Process 13

NOP-WM-1003 Nuclear Maintenance Notification Initiation and Screening 16

Self-Assessments ATA-2020-10929 Attached is the Self-Assessment for the 2020 Drill from 08/12/2020

8/12/2020

ATL-2021-0467-Assessment of Current Primary Strategic Chemistry Plan 07/29/2021

ATA-01

ATL-2021-0521-Assessment of Emergent Scope of Last Three Refueling 08/26/2021

ATA-02 Outages R16, R17 and R18

CR-2020-06562-Engineering Change Package (ECP) Product Quality 10/22/2020

ATA-01

Inspection Type Designation Description or Title Revision or

Procedure Date

MS-C-20-01-13 Audit: Design Control/Engineering Programs/ASME 03/05/2020

MS-C-20-03-01 Fleet Oversight Audit Report: Audit Area: Operations Audit03/01/2020

MS-C-20-05-07 Maintenance/Work Management Quality Assurance Audit 6/30/2020

MS-C-20-11-24 Audit: Emergency Preparedness 12/04/2020

MS-C-21-08-03 Quality Assurance Audit Report for Radiation 09/23/2021

Protection/Radwaste

MS-C-21-09-22 Quality Assurance Audit Report; Corrective Action Program 10/11/2021

21

Work Orders Work Order Repair Oil Leak from Shaft Seal on Engine Driven Jacket 11/22/2016

200700044 Water Coolant Pump

Work Order In 1R18, 1B21-F028B was Found to be Leaking 52.2 SLM 04/01/2021

200784128 (110.6 SCFH)

Work Order 1B21-F0028B Passed on April 1, 2021 04/01/2021

200848877

Work Order Repair Oil Leak on Air Dryer Tower Pressure Gauge 07/09/2021

200858837

Work Order Repair Fuel Oil Leak on Diesel Generator Engine Fuel Oil 11/21/2021

200868755 Pump Mechanical Seal

10