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05000440/FIN-2018001-0131 March 2018 23:59:59PerryNRC identifiedFailure to Notify the NRC within 60 Days of a Condition Prohibited by Technical SpecificationsThe inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.73, Licensee Event Report System, for the licensees failure to report a condition that was prohibited by the plants Technical Specifications to the U.S. Nuclear Regulatory Commission (NRC) within 60 days. Specifically, the licensee did not report a condition that, as determined by the NRC, rendered the Division 2 Diesel Generator (DG) inoperable for a period longer than the Technical Specification allowed completion times of its associated required actions.
05000440/FIN-2017002-0130 June 2017 23:59:59PerryNRC identifiedFailure to Notify the NRC within Eight Hours of a Non -Emergency Event that Could Have Prevented the Fulfillment of Multiple Safety FunctionsSeverity Level IV. The inspectors identified a Severity Level IV Non- Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.72(b)(3)(v)(A) and (D), Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to report an event to the NRC within eight hours that at the time of discovery could have prevented the fulfillment of a safety function. Specifically, the licensee did not recognize there was a loss of safety function associated with multiple instrumentation functions as a result of a main steam turbine bypass valve opening at 100 percent reactor power. Therefore, the licensee did not make the required non- emergency eight hour report. After the inspectors questioned the licensees conclusion, the licensee recognized there was indeed a loss of safety function and submitted the eight -hour notification report on May 3, 2017. They also and entered this issue into the corrective action program (CAP) as condition report ( CR) 2017 04939, CR 201704868, and CR 201705022. The failure to make an applicable non- emergency eight -hour event notification report within the required time frame was a performance deficiency. The inspectors determined that traditional enforcement was applicable to the issue because it impacted the NRCs regulatory process. In accordance with Section 2.2.2.d, and consistent with the examples included in Section 6.9.d.9 of the NRC Enforcement Policy, this violation was screened as a Severity Level IV violation that was more than minor. In accordance with Inspection Manual Chapter 0612, because this violation involved traditional enforcement and does not have an associated finding that would be considered more- than -minor, a cross-cutting aspect was not assigned to this violation.
05000440/FIN-2016004-0431 December 2016 23:59:59PerryNRC identifiedFailure to Notify the NRC within Eight Hours of a Non-Emergency Event that Could Have Prevented the Fulfillment of a Safety FunctionSeverity Level IV. The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.72(b)(3)(v)(A) and (D), for the licensees failure to report to the NRC within eight hours, an event or condition that could have prevented the fulfillment of a safety function. The licensees evaluation of this condition, where both trains of the standby liquid control (SLC) system had been inoperable simultaneously, determined that it was not a reportable event. However, the inspectors determined that as described in NUREG 1022, Event Reporting Guidelines 50.72 and 50.73, Revision 3, Section 3.2.7, the licensee had failed to make a non-emergency eight hour report as required by 10 CFR 50.72(b)(3)(v)(A) and (D). The licensee submitted the eight-hour report on December 30, 2016, and entered this issue into the corrective action program (CAP) as CR 201700098. The failure to make an applicable non-emergency eight-hour event notification report within the required time frame was determined to be a performance deficiency. The inspectors determined that traditional enforcement was applicable to this issue because it impacted the NRC's regulatory process. In accordance with Section 2.2.2.d, and consistent with the examples included in Section 6.9.d.9 of the NRC Enforcement Policy, this violation was screened as a Severity Level IV violation that was more than minor. In accordance with IMC 0612, because this violation involved traditional enforcement and does not have an underlying technical violation that would be considered more-than-minor, a cross-cutting aspect was not assigned to this violation.
05000440/FIN-2014005-0431 December 2014 23:59:59PerryNRC identifiedFailure to Follow Procedures During Dry Cask OperationsThe inspectors identified a Severity Level IV NCV of very low safety significance of 10 CFR Part 72.150, Instructions, Procedures, and Drawings, for the licensees failure to follow procedures important to safety during dry cask operations. The licensee entered each example identified into its corrective action program as Condition Reports 201411637 and 201414279. The violation was determined to be more than minor in that both examples identified deficiencies in the performance of dry cask operations important to safety. In this determination, the inspectors considered example 4.a in IMC 0612, Appendix E, Examples of Minor Issues, dated August 11, 2009, and concluded that, while the errors did not result in any actual safety concern, there were multiple examples of procedural non-compliance. Additionally, if left uncorrected, a failed weld could lead to a release of radioactive materials to the environment and a malfunction of the Fuel Handling Building crane could lead to a more significant safety concern such as a load drop. The significance of the violation was found to be similar to SLIV example 6.5.d.3, of the NRCs Enforcement Policy, in that the licensee failed to adequately implement Quality Assurance processes or procedures. The issue was not found to be similar to any examples of higher significance; as such, the violation screened as a SLIV violation. Since traditional enforcement was used to disposition the violation, a cross-cutting aspect is not applicable.
05000440/FIN-2012005-0631 December 2012 23:59:59PerryNRC identifiedFailure to Follow Procedures That Ensure Safe Movement of a Dry Fuel Storage CanisterThe inspectors identified a Severity Level IV non-cited violation of very low safety significance of 10 CFR Part 72.150, Instructions, Procedures, and Drawings, for the failure by the licensee to follow procedures that ensured the safe loading of a dry fuel storage canister into a storage cask. The licensee corrected the issue to restore compliance with the procedure and placed the concern in its corrective action program (CR 2012-15087). The violation was determined to be of more than minor significance using IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, Example 2f, in that a procedural requirement was not met and the actual distance between the HI-STORM storage cask containing the dry fuel storage canister and the end of the rails on which the cask would be moved was less than the analyzed distance required to ensure safe transport operations. The inspectors determined that the violation could be evaluated using Section 6.5.d.3 of the NRC Enforcement Policy, as a Severity Level IV violation, in that the licensee failed to follow procedures affecting the safe transport of a HI-STORM. Cross-cutting aspects are not assigned to traditional enforcement violations. Since this violation was dispositioned using traditional enforcement, a cross-cutting aspect is not applicable.
05000440/FIN-2011005-0131 December 2011 23:59:59PerryNRC identifiedFailure To Comply With TS 5.5.11, TS Bases Control ProgramThe inspectors identified a finding of very low safety significance and an associated Severity Level IV NCV of Technical Specification (TS) 5.5.11 for failure to comply with the TS Bases Control Program. Specifically, the licensee made a change to the TS Bases, which affected TS 3.8.1, without receiving prior approval from the NRC. The licensee immediately declared equipment affected by TS 3.8.1 inoperable, namely one source of offsite power, and restored it in an expeditious manner. The licensee entered the issue into their corrective action program as CR 2011-02474. The inspectors determined that the violation was more than minor because in order to perform its regulatory function, the NRC relies on licensees to comply with their licensing basis documents and request prior approval for changes that may affect these documents. Because this issue affected the NRC\\\'s ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The inspectors determined that the underlying technical issue could be evaluated using the SDP. Specifically, the Unit 1 transformer, a source of offsite power, was unavailable for longer than allowed by TS 3.8.1. The finding was more than minor because it impacted the Human Performance attribute of the Initiating Events Cornerstone, and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Based on the Phase 3 analysis using IMC 0609, Appendix A, for At-Power situations, the inspectors, in conjunction with a regional senior reactor analyst (SRA), determined that the finding was of very low safety significance (Green). This finding has no cross-cutting aspect as it was not representative of current performance
05000440/FIN-2011008-0431 December 2011 23:59:59PerryNRC identifiedFailure to Report Unanalyzed Condition Related to Internal FloodingThe inspectors identified a Severity Level IV violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Reactors, for failure to report within eight hours an unanalyzed condition that significantly degrades plant safety. Specifically, the licensee failed to notify NRC upon discovery of a postulated internal flood in the control complex could result in loss of single failure capability of safety-related equipment. This violation was entered into the licensees corrective action program. The performance deficiency was determined to involve a traditional enforcement violation because it potentially impeded or impacted the regulatory process. The traditional enforcement violation was determined to be more than minor because the information that was not provided through the event notification had a material impact on safety and licensed activities. The traditional enforcement violation was determined to be a Severity Level IV violation because the failure to report within eight hours an unanalyzed condition did not result in an unacceptable change to the facility or procedures. An evaluation for cross-cutting aspect was not applicable because this was a traditional enforcement violation.
05000440/FIN-2011004-0430 September 2011 23:59:59PerryNRC identifiedFailure to Provide Complete and Accurate InformationThe inspectors identified a NCV of 10 CFR 50.9(a), Completeness and Accuracy of Information, that occurred when the licensee failed to report an Occupational Radiation Safety Performance Indicator (PI) occurrence to reflect an individual entering on April 22, 2011, a locked high radiation area in the drywell under vessel area without the appropriate radiological controls in place. The issue was entered into the licensees CAP as CR 11-00473. Corrective actions included the licensee submitting corrected occupational radiation safety PI data to the NRC. Violations of 10 CFR 50.9 that potentially impede or impact the regulatory process are dispositioned using traditional enforcement. The inspectors concluded that the licensee. The inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR 20.1201(c) for the failure to accurately assess occupational dose specific to effective dose equivalent (EDE) determinations. The issue has been entered into the licensees CAP as CR 11-02336. Corrective actions included a review of applicable guidance and revisions to applicable procedures. The inspectors reviewed a self-revealed finding of very low safety significance and an associated NCV of Technical Specification 5.7.1 for the failure of workers to comply with established radiological protective measures as specified for entry into and work within high radiation areas. The issue has been entered into the licensees corrective action program as condition reports (CR) 11-93976 and CR 11-94374. Corrective actions were implemented to address personal accountability and evaluate the need for procedure improvements. The inspectors reviewed the guidance in IMC 0612 Appendix E, Examples of Minor Issues, and determined that the issue was more than minor because the performance deficiency was similar to Example 6(h) in the guidance document. Using IMC 0609 Attachment C for the Occupational Radiation Safety SDP, the inspectors determined that the finding was of very low safety significance because the finding did not involve: (1) As-Low-As-Is-Reasonably-Achievable (ALARA) planning and controls; (2) a radiological overexposure; (3) a substantial potential for an overexposure; and there was no compromised ability to assess dose. The primary cause of this finding was related to the cross-cutting aspect of problem identification and resolution in the component of the corrective action program in that the licensee failed to take the appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance and complexity. Specifically, the licensee had previously identified issues with the effectiveness of radiological briefs for access to high radiation areas on four recent occasions.
05000440/FIN-2010008-0230 September 2010 23:59:59PerryNRC identifiedDeliberate Failure to Follow Portal Monitor Use ProcedureA willful violation was identified through an OI Investigation for the failure to comply with the procedure that governed portal radiation monitor usage. Specifically, a contract radiation protection technician deliberately violated a radiation protection procedure when the technician exited the Perry site without authorization from radiation protection supervision following three consecutive portal monitor alarms at the personal access facility. The significance of the violation was assessed using Traditional Enforcement because it was determined to be willful. A Severity Level IV violation was determined to be appropriate because the incident had more than minor safety significance given that the technician was radioactively contaminated and departed the site. The violation was cited since it was willful and because the licensee failed to: (1) timely and appropriately respond to the incident; (2) adequately assess the potential for offsite contamination; and (3) take corrective action to ensure against recurrence.
05000440/FIN-2008005-0431 December 2008 23:59:59PerryNRC identifiedFailure To Report All 10 CFR 50.73 Reportable Events Associated With the Discovery of Loose Containment GratingThe inspectors identified a non-cited violation of 10 CFR 50.73(a)(1), \\\"Licensee Event Reports.\\\" The inspectors determined that the licensee failed to submit a required Licensee Event Report (LER) within 60 days after discovery of conditions requiring a report. On August 26, 2007, the licensee identified improperly installed containment floor grating that affected safety system operability. The licensee failed to report conditions of operations prohibited by Technical Specification, operations in an unanalyzed condition, and loss of safety function from August 6 to August 9, 2007, that were associated with inoperability of low pressure core injection A. The licensee entered this issue into their corrective action program. The primary cause of this non-cited violation was related to the cross-cutting area of problem identification and resolution as defined in Inspection Manual Chapter 0305 P.1(c) because the licensee failed to thoroughly evaluate problems for reportability conditions. (Section 4OA3.2
05000440/FIN-2008003-0630 June 2008 23:59:59PerryLicensee-identifiedLicensee-Identified ViolationPerry Station TS 5.7.1 states in part, that each HRA shall be barricaded and conspicuously posted as an HRA and entrance thereto shall be controlled by issuance of an RWP. The TS further requires that entry into such areas be made after dose rate levels in the area have been established and personnel are aware of them. Contrary to the above, on May 1, 2007, on two occasions while performing a fire watch, a security officer entered a controlled, posted, and barricaded HRA in the turbine building lube oil room without being on a RWP which permitted access into the area. Additionally, the officer had not received a briefing from the radiation protection staff such that the officer was aware of the radiological conditions prior to entering the area. Specifically, when the officer opened the north door to the area, the officer observed a posted HRA boundary. The officer immediately shut the door and proceeded to the south door of the area and observed a similar posted HRA boundary. Although the officer was not on an RWP which allowed access into the area, the officer decided to finish the fire watch and proceeded across the boundary. The officer also entered the same area during a second fire watch tour later that day. Based on an OI investigation (OI Case No. 3-2007-021), the NRC staff concluded that the officers second entry into the HRA was a willful violation. However, because the violation had no actual radiological significance and minimal potential significance, the violation involved the acts of a low-level individual resulting from an isolated action without management involvement, there was no economic or other advantage gained as a result of the violation, and adequate remedial action was taken, the violation was categorized at Severity Level IV. Because the violation is of very low safety significance, it meets the additional criteria in Section VI.A.1 of the NRC Enforcement Policy, and it has been entered into the corrective action system (CR 19784), it is being treated, after consultation with the Director, Office of Enforcement, as an NCV
05000440/FIN-2008002-0731 March 2008 23:59:59PerryNRC identifiedFailure to Make 10 CFR 50.72 Report (Section 4OA1.b.1)Severity Level IV The inspectors identified a non-cited violation of 10 CFR Part 50.72(b)(2)(iv)(B), \\\"Four Hour Reports.\\\" The inspectors determined that the licensee failed to report a manual actuation of the reactor protection system when it was not part of a preplanned sequence. Specifically, on June 22, 2007, the \\\'B\\\' reactor recirculation pump failed during a plant shutdown sequence and the licensee inserted a manual scram above preplanned power levels and not in accordance with the preplanned sequence. Licensee operators decided to insert the manual scram earlier than planned due to the unexpected loss of flow in the \\\'B\\\' reactor recirculation system loop. (Section 4OA1.b.1
05000440/FIN-2005003-2630 June 2005 23:59:59PerryNRC identifiedInappropriate Use of HP Technican as Interim Oscc

A finding of very low safety significance and an associated Severity Level IV NCV of 10 CFR 50.54(q) was NRC-identified when licensee personnel failed to obtain prior NRC approval for a change to the Perry Emergency Plan concerning emergency response organization (ERO) staffing and response timeliness. Because the issue affected the NRCs ability to perform its regulatory function, it was processed through the traditional enforcement process and evaluated using the SDP

Using IMC 0612, Appendix B, \\\"Issue Dispositioning Screening,\\\" the inspectors determined that the finding was more than minor because it was associated with the ERO readiness and procedure quality attributes of the Emergency Preparedness cornerstone and affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency

The finding was considered to be of only very low safety significance since the period of vulnerability to the issue was short

As part of the licensees corrective actions, the issue was entered in the licensees corrective action program for resolution as CR 05-03271.

05000440/FIN-2005006-0830 June 2005 23:59:59PerryNRC identifiedUnreported SAFETY-STREAM Unavailability for RHRSeverity Level IV. The inspectors identified a Severity Level IV Non-Cited Violation associated with the failure to report residual heat removal (RHR) train 'B' unavailability from May 29, 2004, through June 3, 2004, while the emergency service water train B was inoperable for pump repairs. The second quarter 2004 data reported to the NRC included RHR 'A' unavailability following failure of the ESW 'A' pump on May 21, 2004, but did not include the subsequent RHR 'B' unavailability. Prior to removing the ESW 'B' pump from service, the licensee developed a reactor pressure vessel feed and bleed method which they subsequently credited as an alternate decay heat removal system when calculating RHR system unavailability. The inspectors, however, reviewed the definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Rev. 2, and could not conclude that the licensees method met the NRC approved method of decay heat removal. Due to the inspectors' concerns, the licensee submitted a Frequently Asked Question. On May 19, 2005, the NRC determined that NRC approval means a specific method or methods described in the technical specifications. As a result, the licensee recalculated and resubmitted RHR system unavailability on June 17, 2005. Had the performance indicator (PI) data been properly reported in the second quarter of 2004, the PI color would have been White. The failure to properly report the PI was considered a Severity Level IV Non- Cited Violation of 10 CFR 50.9.