IR 05000440/2019004

Integrated Inspection Report 05000440/2019004

ML20030A575
Person / Time
Site:	Perry
Issue date:	01/29/2020
From:	Billy Dickson Division Reactor Projects III
To:	Payne F FirstEnergy Nuclear Operating Co
References
EPID L-2019-004-0055 IR 2019004
Download: ML20030A575 (29)

Text

{{#Wiki_filter:ary 29, 2020

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2019004

Dear Mr. Payne:

On December 31, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On January 17, 2020, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Sincerely, /RA/ 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: 05000440/2019004 Enterprise Identifier: I-2019-004-0055 Licensee: FirstEnergy Nuclear Operating Company Facility: Perry Nuclear Power Plant Location: Perry, OH Inspection Dates: October 01, 2019 to December 31, 2019 Inspectors: L. Alvarado Guilloty, Resident Inspector S. Bell, Health Physicist G. Hansen, Sr. Emergency Preparedness Inspector J. Nance, Resident Inspector L. Rodriguez, Reactor Inspector J. Rutkowski, Project Engineer E. Sanchez Santiago, Senior Reactor Inspector J. Steffes, Senior Resident Inspector J. Winslow, Resident Inspector Approved By: Billy C. Dickson, Jr, Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Perry Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items Type Issue Number Title Report Section Status URI 05000440/2019004-01 Degraded Turbine 71111.18 Open Overspeed Reset Limit Switch Results in an Extension in USAR Described Test Frequency

PLANT STATUS

The plant began the inspection period at rated thermal power. On December 6, 2019, the licensee identified elevated offgas pretreat chemistry results, which was indicative of a fuel defect, from a routine sample. On December 10, 2019, the licensee lowered reactor power to approximately 52 percent to perform power suppression testing and identify potential fuel defects. Following completion of the power suppression testing, Perry began a gradual power ascension on December 12, 2019, and achieved full power on December 14, 2019. The reactor remained at approximately 100 percent power for the remainder of the inspection period.

On April 25, 2018, FirstEnergy Solutions (FES) / FirstEnergy Nuclear Operating Company (FENOC) notified the U.S. Nuclear Regulatory Commission (NRC) that they intend to shut down all four of their operating nuclear power plants (ADAMS Accession Number ML18115A007). On March 21, 2018, FES, FirstEnergy Nuclear Generation (FENGEN), and FENOC filed for bankruptcy. On July 26, 2019, FES/FENOC submitted a letter to the NRC withdrawing the April 25, 2018, certification of permanent cessation of power operations for Davis-Besse Nuclear Power Station and Perry Nuclear Power Plant (ADAMS Accession Number ML19207A097). The NRC continues to maintain focus on public health and safety and the protection of the environment. This will include a continuous evaluation by inspectors to determine whether the licensee's financial condition is impacting safe operation of the plant.

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 plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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 External Flooding Sample (IP Section 03.04)

    (1)

• Diesel generator rooms; and
• Emergency service water pump house

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains: (1) "B" train of control room ventilation and emergency recirculation system on October 15 - 17, 2019 (2) "A" train of emergency service water system on October 23, 2019 (3) "B" train of residual heat removal (RHR) system on October 30, 2019 (4) "A" train of standby liquid control system on November 12, 2019 (5) "A" train of annulus exhaust gas treatment system on November 13, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

(1) The inspectors evaluated system configurations during a complete walkdown of the reactor core isolation cooling system on November 12-15, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Emergency service water pump house on October 18, 2019

(2) Diesel generator hallway 620 and 646 foot elevations on October 22, 2019

(3) Auxiliary building 620 foot elevation fire zones 1AB-3A/B on October 24, 2019

(4) Control complex 620 elevation fire zones 1CC-3B/D on October 30, 2019

(5) Intermediate building 654, 665, and 682 foot elevations fire zones 0IB-4/5 on October 31, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a.)

The inspectors evaluated internal flooding mitigation protections in the:

(1) Unit 1, Division 1 and 2, and Unit 2, Division 1, motor control center switchgear rooms from a break in a fire protection main line break

71111.07A - Heat Sink Performance Annual Review (IP Section 02.01)

The inspectors evaluated readiness and performance of:

(1) Division 3 emergency diesel generator jacket water heat exchanger during the weeks of November 3 and 18, 2019

71111.07T - Heat Sink Performance Triennial Review (IP Section 02.02)

The inspectors evaluated heat exchanger/sink performance on the following:

(1) Residual Heat Removal (RHR) Heat Exchanger "B" (1E12B0001B), cooled by the service water system, Section 02.02.b

(2) Emergency Closed Cooling Water (ECCW) Heat Exchanger "B" (1P42B0001B),cooled by the service water system, Section 02.02.b

(3) Ultimate Heat Sink, Sections 02.02.d.5 and 02.02.d.7

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03)

(1) The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification biennial written examinations and annual operating tests administered from October 28 - December 9, 2019

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) The inspectors observed and evaluated licensed operator performance in the Control Room during the downpower and rod pattern adjust associated with power suppression testing on December 10 - 11, 2019 Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated an operations crew-evaluated scenario in the plant training simulator on November 19, 2019

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

   (1)     "B" combustible gas mixing compressor failure, CR 2019-09212, during surveillance test on November 1, 2019

(2) Division 3 emergency diesel generator following a diesel generator trip, CR 2019-09378, on reverse power relay actuation on December 5, 2019

(3) Remote shutdown panel switches following, CR 2019-09208, RHR "B" containment spray 1st isolation valve lost all position indication on December 7, 2019

(4) Review of licensee's maintenance rule program periodic review on December 13, 2019

Quality Control (IP Section 02.02) (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance activities:

(1) Component grade dedication of Bailey BLC2000-721 control unit to replace annulus differential pressure controller following unit failure on November 25 - 27, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Plant risk assessment with the "B" train of control room HVAC and emergency recirculation systems out of service for planned work and hot weather in the area with a grid alert on October 2, 2019

(2) Emergent troubleshooting after Division 3 emergency diesel generator tripped on November 5, 2019

(3) Plant risk assessment with the Division 2 RHR systems unavailable for divisional work window and power suppression testing on December 10 - 11, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Past operability evaluation associated with CR 2019-09208, RHR B Containment Spray 1st Isolation Valve Lost All Position Indication on November 1, 2019

(2) Control rod drive system during inability to select control rods on November 1, 2019

==71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples) The inspectors evaluated the following temporary or permanent modifications:

(1) Review of the licensee's extension of USAR described turbine overspeed testing frequency due to degraded test circuitry on November 13 - December 14, 2019

(2) Interim flooding measures in response to a re-evaluation of the local intense precipitation flooding hazard on December 7, 2019

(3) Modification of reactor water cleanup system isolation due to a steam leak on December 16 - 19, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

[[IP sample::=

=IP 71111.18|count=4}}

The inspectors evaluated the following post maintenance tests:

(1) Partial RHR "B" pump and valve operability test after troubleshooting of 1E12-F028B, containment spray "B" first shutoff valve on November 1, 2019

(2) Control rod exercising after troubleshooting and replacement of the malfunctioning beam control card in the Rod Control and Information system on November 2, 2019

(3) Testing following replacement of the channel "C" scram discharge volume high level relay on November 7, 2019

(4) Emergency closed cooling pump "A" test following preventative maintenance window on November 18, 2019

71114.02 - Alert and Notification System Testing Inspection Review (IP Section 02.01-02.04)

(1) The inspectors evaluated the following maintenance and testing of the alert and notification system:

• Annual siren inspection and maintenance records for the period from September 2017 to September 2019
• Monthly alert notification system (siren) tests for the period from September 2017 to September 2019

71114.03 - Emergency Response Organization Staffing and Augmentation System Inspection Review (IP Section 02.01-02.02)

(1) The inspectors evaluated the readiness of the Emergency Preparedness Organization

71114.04 - Emergency Action Level and Emergency Plan Changes Inspection Review (IP Section 02.01-02.03)

(1) The inspectors completed an evaluation of submitted Emergency Action Level and Emergency Plan changes on November 21, 2019. This evaluation does not constitute NRC approval

71114.05 - Maintenance of Emergency Preparedness Inspection Review (IP Section 02.01 - 02.11)

(1) The inspectors evaluated the maintenance of the emergency preparedness program

71124.02 - Occupational ALARA Planning and Controls Radiological Work Planning (IP Section 02.01)

The inspectors evaluated the licensees radiological work planning.

(1) The inspectors reviewed the following activities:

• RWP 190904 and associated ALARA plans; 1R17 Reactor Reassembly
• RWP 190522 and associated ALARA plans, 1R17 Bioshield In-Service Inspection Activities
• RWP 190903 and associated ALARA plans; 1R17 In-Vessel Inspection Activities Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02) (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

(1) The inspectors reviewed the following as low as reasonably achievable planning documents:

• RWP 190904 and Associated ALARA Plans; 1R17 Reactor Reassembly
• RWP 190522 and associated ALARA plans; 1R17 Bioshield In-Service Inspection Activities
• RWP 190903 and associated ALARA plans; 1R17 In-Vessel inspection Activities Additionally, the inspectors reviewed the following radiological outcome evaluations:
• RWP 190904; 1R17 Reactor Reassembly post job evaluation
• RWP 190522; 1R17 Bioshield In-Service Inspection Activities post job evaluation
• RWP 190903; 1R17 In-Vessel inspection Activities post job evaluation

==71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Partial) The inspectors evaluated self-contained breathing apparatus program implementation.

   (1)    (Partial)

This augments the inspection sample documented in NRC Inspection Report

===05000440/2018004

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: EP01: Drill/Exercise Performance (IP Section 02.12)==

(1) 07/01/2018 - 06/30/2019 EP02: ERO Drill Participation (IP Section 02.13) ===

(1) 07/01/2018 - 06/30/2019 EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)

(1) 07/01/2018 - 06/30/2019 BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) 10/01/2018 - 09/30/2019

BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)

(1) 10/01/2018 - 09/30/2019 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) 10/01/2018 - 09/30/2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors reviewed licensee-identified water fire protection system issues to determine if a trend existed that could, if allowed to continue, compromise the installed spray nozzles' functionality and adversely impact the system ability to suppress fires impacting plant electrical transformers and fires occurring within plant areas with fire protection spray nozzles. The inspectors did not find an adverse trend that would cause the inspectors to question the plant's water fire protection system ability to carry out its design function.

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples) The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) RCIC Steam supply second drain isolation valve leak caused EOP-3 entry CR2019-10360

(2) Review of plant aggregate risk assessment

INSPECTION RESULTS

Unresolved Item Degraded Turbine Overspeed Reset Limit Switch Results in 71111.18 (Open) an Extension in USAR Described Test Frequency URI 05000440/2019004-01

Description:

On July 27, 2019, a turbine trip and reactor scram occurred during performance of weekly turbine overspeed testing. The turbine trip occurred during performance of step 5.1.2.3 of PTI-N32-P0001, which tests the mechanical overspeed trip, as documented in CR 2019-06321, Turbine Trip during Weekly Turbine Overspeed Test. Troubleshooting efforts identified several discrepant conditions which were addressed during the forced outage, except for one. A ground was discovered associated with the reset limit switch of the turbine overspeed system. The inspectors noted, through review of CR 2019-06587, "Limit Switch Causes - 125 VDC Ground," that the licensee decided not to replace the reset limit switch upon discovery due to personnel safety and the potential for another turbine trip.

Updated Safety Analysis Report (USAR) Section 10.2.2.3 states, in part, that each compartment of the mechanical and electrical overspeed protection systems will be tested at each startup and during normal operations, on a weekly basis, by the following tests: a. A mechanical overspeed trip test at the the EHC panel to test for operation of the overspeed trip device and mechanical trip valve.

b. A mechanical trip piston test at the EHC panel to test for electrical activation of the trip mechanism.

c. An electrical trip test at the EHC panel to test for operation of the electrical trip valve.

d. A backup overspeed trip test at the EHC panel to test the 2 out of 3 logic circuits.

Updated Safety Analysis Report 10.2.3.6.1.1 states, in part that, turbine assembly inspection interval was selected on the basis of acceptably low probabilities [less than 1.0 E-5] of Perry turbine missile generation. Turbine missile generation probabilities are calculated by using either a methodology by General Electric or a methodology developed by Siemens-Westinghouse.

The methodology for determination of missile probability contains three major components:

 -   The probability of the turbine attaining speeds higher than those occurring during normal operation.

 -   The estimation of wheel burst probability as a function of speed.

 -   The probability of wheel fragment penetrating the turbine casing and thus generating an external missile.

The inspectors reviewed the prompt functionality assessment contained in CR 2019-06321 and determined the licensee contracted with an outside vendor to assess the impacts of changing the turbine overspeed testing on turbine missile probability. The inspectors determined the missile probability analysis, to increase testing frequency from weekly to semi-annually, used a Monte Carlo methodology rather than a methodology by General Electric or Siemens-Westinghouse, as stated in USAR 10.2.3.6.1.1. The inspectors further concluded that the prompt functionality assessment documented that, the use of an alternate analytical method in lieu of the General Electric methodology is judged to be acceptable for this application and consistent with NRC Inspection Manual [Chapter (IMC)] 0326 Appendix C.04 guidance. The NRC inspectors noted that IMC 0326 was revised on October 1, 2019 and changed the Appendix C.04 guidance to Section 08 of IMC 0326.

Following review of the prompt functionality assessment the inspectors developed questions associated with the appropriateness to change USAR described testing frequencies using the prompt functionality assessment process rather than the 10 CFR 50.59 process. The licensee developed a white paper which established the following position.

Guidance for implementation of the requirements of 10 CFR 50.59 is addressed in FENOC procedure NOP-LP-4003 and FENOC Business Practice NOBP-LP-4003A. This procedure [NOP-LP-4003] includes references to NRC Regulatory Guide (RG) 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments and NEI 96-07, Revision 1, "Guidelines for 10 CFR 50.59 Implementation. In November 2000, RG 1.187 (Revision 0), endorsed Nuclear Energy Institute (NEI) 96-07, Revision 1, as acceptable for complying with the NRC regulations in 10 CFR 50.59.

The guidance provided in NEI 96-07 regarding applicability of 10 CFR 50.59 to nonconforming and degraded condition is addressed in section 4.4: Three general courses of action are available to licensees to address non-conforming and degraded conditions. Whether or not 10 CFR 50.59 must be applied, and the focus of a 10 CFR 50.59 evaluation if one is required, depends on the corrective action plan chosen by the licensee, as discussed below: If the licensee intends to restore the SSC back to its as-designed condition then this corrective action should be performed in accordance with 10 CFR 50, Appendix B (i.e., in a timely manner commensurate with safety). This activity is not subject to 10 CFR 50.59.

If an interim compensatory action is taken to address the condition and involves a temporary procedure or facility change, 10 CFR 50.59 should be applied to the temporary change. The intent is to determine whether the temporary change/compensatory action itself (not the degraded condition) impacts other aspects of the facility or procedures described in the UFSAR. In considering whether a temporary change impacts other aspects of the facility, a licensee should pay particular attention to ancillary aspects of the temporary change that result from actions taken to directly compensate for the degraded condition.

If the licensee corrective action is either to accept the condition as-is resulting in something different than its as-designed condition, or to change the facility or procedures, 10 CFR 50.59 should be applied to the corrective action, unless another regulation applies, e.g., 10 CFR 50.55a. In these cases, the final corrective action becomes the proposed change that would be subject to 10 CFR 50.59.

It is expected the degraded condition of the turbine overspeed protection test circuit ground will be restored to its as designed configuration in a timely manner commensurate with its safety significance. The less frequent test interval that is implemented by the PFA is not viewed to be a compensatory action for the degraded condition, as it does not restore or maintain functionality for the turbine overspeed trip test system. The PFA is not intended to accept the degraded condition as-is, or to change the facility or its procedures. As such, the less frequent turbine trip test interval that is implemented by the PFA was concluded to not require further review under 10 CFR 50.59.

Planned Closure Actions: The inspectors require further evaluation and assessment as to whether the change in overspeed testing frequency, i.e. non-performance on a weekly basis, constitutes a compensatory measure for the degraded equipment and required review in accordance with the 10 CFR 50.59 process. This review is to determine whether a violation exists. Thus, the issue is considered and unresolved item pending completion of inspector review and evaluation and discussion with the Office of Nuclear Reactor Regulation.

Corrective Action References: CR 2019-06321 Turbine Trip During Weekly Turbine Overspeed Test Minor Violation 71124.03 Minor Violation: The inspectors identified that the licensee failed to perform fit testing, as required by 10 CFR 20.1703(c)(6), for all models and configuration of respirators used at its facility. Specifically, the licensee credited its fit testing of a full face respirator with a rubber strap enclosure for its SCBA type of respirator that is configured with a different harness (Kevlar harness closure system).

Screening: The inspectors determined the performance deficiency was minor. The failure to perform fit testing on each model of respirator was a performance deficiency, in that, the licensee failed to implement a regulatory requirement that was within the licensees ability to foresee and to prevent. The inspectors evaluated the performance deficiency against the criteria contained in IMC 0612. The inspectors determined that the performance deficiency was not a precursor to a significant event; if left uncorrected, did not have the potential to lead to a more significant safety concern; did not impact a performance indicator; and did not adversely affect the cornerstone objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the inspectors evaluated the potential for the differing configurations to impact the fit of the respirators. In addition, the licensee performed fit testing for individual for both models of respirators, which determined that results were acceptable when individuals were tested with both configurations. Based on the inspectors' review and the licensees testing data, the inspector concluded that differing configurations did not appear to reduce the licensees ability to control and limit the intake of airborne radioactivity and other hazards.

Enforcement:

Title 10 CFR 20.1703(c)(6) requires, in part, that the licensee implement and maintain a Respiratory Protection Program that includes fit testing before the first field use of tight fighting, face-sealing respirators and periodically thereafter at a frequency not to exceed one year. However, the licensees program did not perform fit testing prior to field use on the SCBA full face respirator with the Kevlar harness closure system as required by 10 CFR 20.1703(c)(6). Instead, the licensee performed fit testing on the air purifying style of respirator, with the rubber harness, and took credit for that fit test for the SCBA style of respirator, with the Kevlar harness. The licensee has restored compliance by performing fit testing using respirators with the Kevlar closure system.

The licensee entered this issue into the Corrective Action Program as AR 2018-09900.

This failure to comply with 10 CFR 20.1703(c)(6) constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

The disposition of this violation closes URI: 05000440/2018004-03.

Observation: Semi-Annual Trend Review - Fire Protection System (Water) 71152 The inspectors noted that the licensee had experienced two cases of clogged water spray nozzles during this inspection period. On October 9, 2019, CR 2019-08262 listed 13 clogged water spray nozzles found while performing a surveillance test of the water system protection for interbus transformer LH1A. On November 12, 2019, CR 2019-09579 listed three clogged water spray nozzles found while performing a surveillance test of the water system protection for interbus transformer LH2A. The CRs and/or associated test procedures did state that the nozzles were cleaned, and the surveillance tests successfully completed.

The inspectors knew that the spray systems for these outdoor transformers, after the water flow testing, are drained but usually some moisture remains in the steel lines. Since moisture and air produce an environment conducive to corrosion in carbon steel pipes and that there were two instances of clogged nozzles within an approximately one-month period, the inspectors initiated a search of the licensee's condition report system to determine if an adverse trend existed.

The inspectors originally searched CRs for period extending back eight months and then one year with no more reports of clogged water spray nozzles or internal corrosion of firewater spray lines. Then the inspectors searched back greater than four years since the flow testing of transformer spray nozzles is a once every 24 months test. During this expanded review, the inspectors did not identify any water spray nozzle clogging issues or instances of found clogging or fouling of nozzle spray supply lines.

The inspectors also noted that the number of found clogged spray nozzles would have degraded fire suppression capability but would not have incapacitated fire suppression capability for the interbus transformers. The inspectors did not identify an adverse trend associated with the design function of fire protection water spray nozzles and did not identify any concerns.

Observation: Review of Plant Aggregate Risk Assessment 71152 The inspectors reviewed the aggregated effects of operator burdens, workarounds, control room deficiencies and deficient conditions on plant risk. The inspection included a review of programmatic requirements and processes which resulted in discussions with operations and engineering personnel to determine whether the conditions identified, in aggregate, were manageable and being addressed in a timely manner commensurate with their safety significance. The inspectors reviewed the conditions, monitoring plans and trigger points to assess if the adverse conditions were being appropriately tracked and trended. The inspectors determined, overall, that the licensee was effectively managing adverse conditions and no concerns were identified as part of this review.

Observation: RCIC Steam Supply Second Drain Isolation Valve Leak Caused 71152 Secondary Containment Control Emergency Operating Procedure Entry On December 13, 2019, the control room received the RCIC Pump Room Sump Level High alarm and entered EOP-3, Secondary Containment Control, emergency operating procedure. The inspectors determined that the licensee dispatched an operator to the RCIC pump room and discovered that a previously identified steam leak from the RHR and RCIC Steam Supply Second Drain Isolation valve packing had degraded and that a real emergency did not exist. The inspectors reviewed condition reports, operation narrative logs, operational decision-making issues and the operations aggregate assessment of plant impacts from deficient conditions. The inspectors determined that prior to December 13, 2019, the steam leak on RHR and RCIC Steam Supply Second Drain Isolation valve had been identified three previous times. The inspectors reviewed work orders and notifications written as a direct result of the corrective action documents. In most cases the inspectors were able to determine that the licensee addressed each steam leak identification by adjusting the valve packing and either reducing or eliminating the leak. However, the inspectors noted that during the identification of the steam leak on August 25, 2019, the licensee was not able to eliminate the leak as documented in Notification 601236676, Packing Leak on RHR & RCIC Steam Supply.. The inspectors determined that the licensee put into place a method to monitor the leak using operator rounds and drained the associated sump as needed. During review of narrative logs the inspectors determined that the frequency between sump drains decrease from every two weeks in August to every two and a half days, on average, in December. The licensee documented the emergency procedure entry due to steam leak degradation in CR 2019-10360, Unplanned Entry Into EOP-03 Secondary Containment Control. Corrective actions identified following the EOP-3 procedure entry included continuing to monitor the steam leak using operator rounds but changed the sump drain frequency to shiftly. The steam leak was scheduled to be addressed during the system outage in January 2020. The inspectors did not identify any concerns as part of this review.

EXIT MEETINGS AND DEBRIEFS

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

• On January 17, 2020, the inspectors presented the integrated inspection results to Mr. F. Payne, Site Vice President and other members of the licensee staff.
• On October 10, 2019, the inspectors presented the Emergency Preparedness Inspection inspection results to Mr. C. Elliott, Operations Manager and other members of the licensee staff.
• On November 20, 2019, the inspectors presented the radiation protection baseline inspection results to Mr. F. Payne, Site Vice President and other members of the licensee staff.
• On November 21, 2019, the inspectors presented the Emergency Action Level and Emergency Plan Changes Inspection inspection results to Mr. T. Kledzik, Emergency Response Supervisor and other members of the licensee staff.
• On December 6, 2019, the inspectors presented the Heat Sink Performance inspection results to Mr. F. Payne, Site Vice President and other members of the licensee staff.
• On December 17, 2019, the inspectors presented the Licensed Operator Requalification program annual examination results review inspection results to Mr. R. Torres, Fleet Exam Team Lead and other members of the licensee staff.
• On January 17, 2020, the inspectors presented the integrated inspection results inspection results to Mr. F. Payne, Site Vice President 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 Tornado or High Winds 31 Work Orders 200794255 Flood Mitigation Actions - ONI-ZZZ-1 0 71111.04Q Drawings 302-0641-00000 Residual Heat Removal System KKK 2-0642-00000 Residual Heat Removal NN 2-0643-00000 Residual Heat Removal System CCC 2-0691-00000 Standby Liquid Control System Z 2-0692-00000 Standby Liquid Control Transfer System V 2-0791-00000 Emergency Service Water System BBB 2-0792-00000 Emergency Service Water System RR 2-0605-00000 Reactor Building Annulus Exhaust Gas Treatment Y 2-0610-00000 Control Room HVAC and Emergency Recirculation System CC Procedures SVI-E12-T1182B RHR B LPCI Valve Lineup Verification and System Venting 14 VLI-C41 Standby Liquid Control System 8 VLI-E12 Residual Heat Removal System 15 VLI-M15 Annulus Exhaust Gas Treatment System 4 VLI-M25/M26 Control Room HVAC and Emergency Recirculation System 7 VLI-P45 Emergency Service Water System 20 71111.04S Corrective Action CR 2019-03480 Valve Indicates Open Testable Check Valve 04/12/2019 Documents Drawings 302-0631-00000 Reactor Core Isolation Cooling System HH Procedures VLI-E51 Reactor Core Isolation Cooling System 10 71111.05Q Fire Plans FPI-0CC Control Complex 11 FPI-0EW Emergency Service Water Pump House 7 FPI-0IB Intermediate Building 10 FPI-1AB Auxiliary Building Unit 1 4 FPI-1DG Diesel Generator Building Hallway 9 Procedures PAP-1910 Fire Protection Program 41 Work Orders 200717072 Portable Fire Extinguishers Maintenance Inspection 05/09/2019 71111.06 Calculations IF-8 Flood Zone 21: Critical Volumes, Flood Heights, Flow Rates, 0 Flood and Alarm Chronology JL-083 Flooding Analysis of CCB, IB, and FHB - Floor Elevation 3 Inspection Type Designation Description or Title Revision or Procedure Date 574'-10" Drawings 105-0013-00000 Control Complex Floor Plan - El. 620'-6" K 304-0804-00000 ESW - Control Buillding Plan Above 574'-10" l Miscellaneous PRA-PY1-AL Internal Flooding Notebook 0 Procedures ARI-H13-P970- Common Long Response Benchboard 27 0001 ONI-R10 Loss of AC Power 15 71111.07A Calculations E22-042 Division 3 Emergency Diesel Generator Jacket Water Heat 4 Exchanger Performance Test Work Orders 200645158 HPCS Diesel Generator Jacket Water Heat Exchanger 06/04/2019 Performance Testing 71111.07T Calculations E12-089 Required ESW Flow for the RHR HXs 3 E12-102 RHR System Heat Exchanger "B" Loop Performance Test 4 Evaluation P42-039 Design Basis Heat Load & Required ESW Flow for the ECC 2 HXs P42-051 Emergency Closed Cooling Heat Exchanger "B" Loop 3 Performance Test Evaluation P45-044 Keepfill Check Valve Leak Rate/Standpipe Draindown Level 2 Corrective Action CR-2011-91278 Results of ESW Related Diver Inspections (March 2011) 03/18/2011 Documents CR-2016-09504 Emergency Service Water (ESW) Loop "C" Flow Rates 08/03/2016 Degraded CR-2016-12106 High Pressure Core Spray Emergency Service Water Flow 10/10/2016 in the Alert Low Range CR-2017-07247 Received ESW to RHR HX Flow Low Annunciator Alarm 07/07/2017 CR-2017-09641 Silt Levels in Emergency Service Water (ESW) East and 09/19/2017 West Pump Bays CR-2018-08003 Small Margin Remaining in RHR Heat Exchanger Loop "B" 09/10/2018 CR-2018-08122 Silt Levels in Emergency Service Water East and West 09/14/2018 Pump Bays and Forebay Corrective Action CR-2019-10102 2019 Triennial Heat Sink Inspection: Drawing 21-0016- 12/03/2019 Documents 00001 Rev. B has Incorrect Work Order Listed Resulting from CR-2019-10124 2019 Triennial Heat Sink Inspection: Housekeeping 12/04/2019 Inspection Deficiencies Identified in RHR B HX Room 599' and RHR B Inspection Type Designation Description or Title Revision or Procedure Date Pump Room 574' CR-2019-10148 2019 Triennial Heat Sink Inspection: Silt Data not Recorded 12/05/2019 in Order 200725355 for Intake and Discharge Structures in the Lake CR-2019-10155 2019 Triennial Heat Sink Inspection: CR not Written on Silt 12/05/2019 Buildup in Forebay at Time of Diver Inspection for WO 200474126 CR-2019-10165 2019 Triennial Heat Sink Inspection: Global EMARP-0011 12/05/2019 Concerns CR-2019-10175 2019 NRC Triennial Heat Sink Inspection, Documentation 12/06/2019 for Heat Exchanger Bracing Adequacy can not be Located CR-2019-10185 2019 Triennial Heat Sink Inspection: Inadequate Technical 12/06/2019 Justification for Deferral of RHR B Eddy Current and Visual Inspections CR-2019-10233 2019 Triennial Heat Sink Inspection: Roll Up CR 12/09/2019 Drawings 015-0002 Emergency Service Water Pump House Plans and F Elevations 21-0016-00002 Residual Heat Removal Heat Exchanger 1E12B001B Tube A Sheet Drawing 2-0140-00002 Emergency Closed Cooling Heat Exchanger Loop "B" A

                                      (1P42B0001B) Tube Sheet Drawing

304-0791 Emergency Service Water Piping T 743-0013 Topography and Storm Drain G D-726-210 Offshore Multiport Intake Structure M D-726-213 Discharge Structure E Engineering Spec-625 Seismic Qualification Report for Emergency Closed Cooling 0 Evaluations Water Heat Exchangers Miscellaneous 600925874 Revision Notification for First Time Performance - 04/27/2015 1E12B0001B/D 601199944 Revision Notification for Performing PM Less Often - 12/31/2018 1E12B0001B DI-220 Perry Nuclear Power Plant RHR Heat Exchanger 1 Performance Program EMARP-0011 North and West Intake Structures and Discharge Structure 11/13/2017 Inspection Type Designation Description or Title Revision or Procedure Date Emergency Inspections Service Water Monitoring Program Report Sheet EMARP-0011- Visual Inspection of Emergency Service Water 11/27/2017 Emergency Pump/Forebay and ESW Normal/Alternate Tunnel Service Water Monitoring Program Report Sheet Procedures D-726-201 Intake Tunnel Plan and Profile E EMARP-0011 Emergency Service Water System Monitoring Program 6 IOI-0015 Seasonal Variations 33 ONI-P40 ESW or SW Sunction Path Blockage 6 ONI-P41 Loss of Service Water 19 PTI-GEN-P0024 Mussel Treatment 21 PTI-P45-P0004 Emergency Service Water Manual Valve Operability Test 10 PTI-P45-P0009A ESW Forebay Low Level Functional for P45-D004A 4 SOI-E12 Residual Heat Removal System 75 SOI-P42 Emergency Closed Cooling System 23 SOI-P45/P49 Emergency Service Water and Screen Wash Systems 34 Section 7.2 Work Orders 200208230 Cal Check - ESW Keep Fill Pressure Gauge 05/16/2008 200294673 Calibrate Pressure Gauge Per ICI-B2-0, SEE 302-792, ESW 12/27/2007 Keep Fill Line 200342060 Eddy-Inspect/Clean P42 HX 05/05/2011 200428423 (4Y) RHR Heat Exchangers B and D Performance Testing 11/19/2014 200474126 Inspect ESW Forebay and Normal Intake Tunnel 10/24/2017 200474126 Inspect ESW Forebay and Normal Intake Tunnel 10/24/2017 200518858 Inspect ESW Forebay and Normal Intake Tunnel 09/07/2018 200553883 Inspect East/West Pump Bay and Alternate Intake Tunnel 10/23/2017 200560618 (4Y) Emergency Closed Cooling B Heat Exchanger 11/09/2015 Performance Testing Inspection Type Designation Description or Title Revision or Procedure Date 200617665 Inspect East/West Pump Bay and Alternate Intake Tunnel 12/05/2018 200624207 (4Y) RHR Heat Exchangers B and D Performance Testing 09/04/2018 200632868 Emergency Service Water Manual Valve Operability Test 03/03/2017 200656789 Inspect SW/ESW Intake/Discharge Ports 08/09/2016 200656790 Inspect SW/ESW Intake/Discharge Ports 09/13/2017 200661237 ESW System Loop C Flow and Differential Pressure Test 07/08/2019 200690654 Lube/Megger ESW Intake Screen "B" Motor 07/23/2018 200710562 ESW Pump B and Valve Operability Test 04/30/2019 200711981 Inspect SW/ESW Intake/Discharge Ports 09/12/2018 200712729 Emergency Service Water Manual Valve Operability Test 10/06/2018 200714996 ESW Loop A Flow and Differential Pressure Test 04/24/2019 200718770 ESW System Loop and Differential Pressure Test 06/08/2019 200718850 ESW Pump B and Valve Operability Test 08/16/2019 200725357 ESW Forebay Low Level Funtional for P45-D004B 10/14/2018 200728962 (92D) ESW System Loop B Flow and Differential Pressure 08/30/2019 Test 200728965 ESW System Loop A Flow and Differential Pressure Test 07/21/2019 200729052 HPCS ESW Pump and Valve Operability Test 07/08/2019 200764994 Cal Check - Keep Fill Pressure Gauge HPCS ESW 07/09/2019 98-826 RHR B/D HX Inspection 04/06/1999 71111.11A Miscellaneous Perry Annual Licensed Operator Requalification Program 12/16/2019 Summary Results for 2019 71111.11Q Miscellaneous Evolution Specific December 2019 Power Suppression Test 0 Reactivity Plan OT-3070 RP2E Simulator Scenario Guide 0 OT-3070-005- Simulator Scenario Guide 0 RP1B 71111.12 Corrective Action CR 2018-10660 HPCS Agastat TD Relay Outside Times Permitted but 12/04/2018 Documents Within Allowable TS Times CR 2018-11210 AEGTS Train A Flow Oscillations 12/24/2018 CR 2019-02590 Valve PMT Stroke Issue - Contact Problem on Switch 03/21/2019 1C61S0080 CR 2019-05821 Diesel Procedure Step Performed Out of Order 07/09/2019 Inspection Type Designation Description or Title Revision or Procedure Date CR 2019-09208 RHR B Containment Spray 1st Isolation Valve Lost all 11/01/2019 Position Indication CR 2019-09212 Combustible Gas Mixing Compressor B Trip on Thermal 11/01/2019 Overloads CR 2019-09358 10CFR21-2017: EMD Fuel Injector - Seized Plunger and 11/05/2019 Bushing CR 2019-09378 Div 3 DG Tripped on Reverse Power 11/05/2019 CR 2019-09421 Common Cause Evaluation for Division 3 DG Inoperability 11/06/2019 Corrective Action CR 2019-10361 Maintenance Rule Evaluation Required on 1E12F0024B and 12/13/2019 Documents 1C61-S80 Resulting from CR 2019-10375 NRC Identified: Infantile Failure of 1C61S0080 - November 12/13/2019 Inspection 2018 to March 2019 CR 2019-10523 NRC Identified: CR 2019-09212 Maintenance Rule 12/19/2019 Evaluation Conclusion was Questioned Drawings 208-0039-00004 Remote Shutdown System Division 2 Switch Development L and Locations 208-0055-00025 Containment Spray Valve - F028B Y 208-0055-00036 RHR "B" Test Return MOV F024B V 208-0206-00037 4.16KV Bus EH13 Diesel Brkr. EH1301 Z Miscellaneous A Miniature Instrument & Control Switch for Power Industry 11/05/1984 Applications (ElectroSwitch) Maintenance Rule System Name: Electrical Component Group - Indication 0 System Basis Document System E_C Notification BLC2000-721 Control Unit (Blind Controller) Qualification 0 601219728 Report PY-M51-F-1610 Combustible Gas Control Function Basis Document 0 Procedures GEI-0046 Division 3 125Vdc Relays 5 GEI-0100 Maintenance and Calibration of Power Relay 12ICW52B 4 NOP-ER-3004 FENOC Maintenance Rule Program 5 PYBP-PES-0001 Maintenance Rule Reference Guide 15 SVI-C61-T1202 Remote Shutdown Control Test - Division 2 RHR, ECC, and 9 ESW Inspection Type Designation Description or Title Revision or Procedure Date SVI-M51-T2003-B Combustible Gas Mixing System B Operability Test 13 Work Orders 200341689 Inspect Remote Shutdown Switch 1C61A-S80 as Extent of 11/14/2018 Condition for CR 08-46021 200516341 Relay ICW52B 32B EH13 Bus Reverse Power 02/17/2018 200701831 PY-1E2207038 Cal Check Agastat E7000 TD Relay 05/06/2019 200713648 Perform Static MOV [Motor Operated Valve] Test RHR 'B' 03/21/2019 Test VLV [Valve] to Supr [Suppression] Pool 200730436 Replace PY-1M15R0060B-1 Annulus Differential Pressure 0 Controller B 200752416 PY-1E2207032 - Calibrate Agastat E7000 DC TD Relay 05/06/2019 200775158 Troubleshoot Cause of AEGTS Train A Flow Oscillations 0 200775159 Replace Control Unit 0 200775160 Bailey 721 Controller Non-Safety Stock Code 90895255 to 0 be Dedicated to Allow Use as Commercial Grade Stock Code 100027602 200783496 Post Maintenance Testing of Valve 1E12F0024B per Order 03/21/2019 200713648 Identified that the Valve would not Stroke Closed 200804189 While Stroking Open E12F028B for the Div 2 Combustible 11/01/2019 Gas Mixing Compressor Run, Valve E12-F028B Lost All Indication 200804866 Div 3 DG Tripped on Reverse Power 11/06/2019 WO 200804216 Combustible Gas Mixing System Compressor B Tripped on 11/04/2019 Thermal Overloads 71111.13 Corrective Action CR2019-09378 Div 3DG Tripped on Reverse Power 11/05/2019 Documents Procedures NOP-OP-1007 Risk Management 30 SVI-E22-T1319 Diesel Generator Start and Load Division 3 28 Work Orders 200542705 Perform Static MOV Test for RHR C Minimum Flow Valve 0 200574288 Control Room HVAC 0 200749548 Perform Static MOV Test for the RHR C Suppression Pool 0 Suction Valve 200804866 Div 3 DG Tripped on Reverse Power 11/06/2019 71111.15 Corrective Action CR-2019-09208 RHR B Containment Spray 1st Isolation Valve Lost All 11/01/2019 Documents Position Indication Inspection Type Designation Description or Title Revision or Procedure Date CR-2019-09228 Inability to Select Control Rods 11/01/2019 Drawings 208-0055-00025 Residual Heat Removal System, Containment Spray Valve - Y F028B Procedures NOP-OP-1009 Operability Determinations and Functionality Assessments 8 SOI-C11(RCIS) Rod Control and Information System 32 71111.18 Calculations H-1G33-112 Design Verification Record of 1G33-Reactor Water Cleanup 15 System Corrective Action CR 2015-08036 PFA [Prompt Functionality Assessment] Needed for Site 07/08/2015 Documents Flooding Issues CR 2019-03298 Reactor Water Cleanup Drain Valves (G33F066) Leaking By 04/08/2019 Corrective Action CR 2019-10368 Discrepancy Between Intermediate Building Roof Drawing 12/13/2019 Documents and Calculation Live Load Resulting from Inspection Engineering 19-0178-001 Interim Flooding Protection for Plant Structures - Ground 0 Changes Level Vulnerabilities 19-0178-002 Temporary Roof Protection for Flood Mitigation 0 ECP No. 19-0091- Engineering Change Package Design Report to Change the 0 000 Safety/Quality Classification of Selected Piping for Test, Vent, and Drain Connections to ASME Class 1, 2, or 3 Piping to Non-Nuclear Safety (NNS)/quality Group D Engineering NORM-LP-7322 Perry Nuclear Power Plant Flooding Focused Evaluation 11/22/2019 Evaluations Report Notification Evaluate Kill of Downstream Pipe/Cap 04/09/2019 601216082 Miscellaneous TCC-1-G33-LR- Temporary Configuration Change that Installs a Line Kill 1 2 Procedures ONI-ZZZ-1 Tornado or High Winds 31 PAP-0204 Housekeeping/Cleanliness Control Program 31 Work Orders 200794255 Flood Mitigation Actions - ONI-ZZZ-1 200799298 Stage Sandbags at Gross Openings (Vents, Louvres, 09/17/2019 Penetrations) and Roof Door Openings WO 200785169 Penetration P131 Outboard Test Connection Second 04/16/2019 Inspection Type Designation Description or Title Revision or Procedure Date Isolation Valve 71111.19 Drawings 208-0055-00025 Residual Heat Removal System, Containment Spray Valve - Y F028B Procedures SVI-E12-T2002 RHR B Pump and Valve Operability Test 39 Work Orders 200290508 Replacing the 1C71K051C Relay for Scram Discharge 11/07/2019 Volume Level Hi 200753726 SVI-C11-T1003B Control Rod Exercise Part 2 11/02/2019 200753785 SVI-C11-T1103A Control Rod Exercise Part 1 11/02/2019 200770274 Emergency Closed Cooling Pump "A" 11/18/2019 200804181 Inability to Select Control Rods 11/02/2019 200804189 Containment Spray B First Shutoff 11/01/2019 71114.02 Miscellaneous FEMA Approval Letter for Perry Nuclear Power Plant Prompt 07/17/2015 Alert Siren System (PASS) Design Report Update, Revision Perry EPZ Siren Test Data 09/01/2017- 09/30/2019 Perry 2017 EPZ Siren Annual Maintenance Records 09/01/2017 - 2/31/2017 Perry 2018 EPZ Siren Annual Maintenance Records 01/01/2018 - 2/31/2018 Federal Signal Models 2001-130, Equinox, and 508-128 A5 0017 Sirens Installation, Operation, and Service Manual Tempest T-112/ T-121 Omni-Directional Siren Installation, H Operation, Maintenance and Parts Manual Perry EPZ Siren PI Test Schedules 09/01/2017- 2/31/2019 Procedures Perry Nuclear Power Plant Prompt Alert Siren System 0

                                           (PASS) Design Report

NOBP-LP-5018 FENOC Siren Testing and Maintenance 3 NOP-LP-5005 FENOC Siren Testing and Maintenance 0 PTI-GEN-P0003 Quarterly Testing of the Emergency Pager System 10 71114.03 Corrective Action CR-2018-07283 ERO Drill - During 8/15/2018 Drill Objective B.1, Notification 08/16/2018 Documents of ERO Personnel Not Met Inspection Type Designation Description or Title Revision or Procedure Date CR-2019-04530 ERO Drill - Objective B.1 Not Met - ERO Not Notified in 05/20/2019 Minutes Miscellaneous Technical Support Center Equipment Checklists (Completed 12/01/2018 - Survey Records) 09/30/2019 Emergency Response Organization Roster 09/20/2019 ERO Augmentation Quarterly Pager Test Records 09/01/2017 - 09/30/2019 Emergency Operations Facility Equipment Checklists 12/01/2018 -

                                          (completed survey records);                               09/30/2019

Procedures NOP-LP-5006 Emergency Response Organization Training Program 4 PYBP-ERS-0037 Notification of Key Plant Personnel 3 71114.04 Miscellaneous Perry Station 10 CFR 50.54(q) Evaluator Qualification and 06/25/2019 Training Records Spreadsheet PY-2019-013-00 Emergency Plan Change - Public Information Response 05/22/2019 CFR 50.54(q)2 Team Relocation Analysis PY-2019-013-00 Emergency Plan Change - Public Information Team 06/03/2019 CFR 50.54(q)3 Relocation Screen/Evaluation PY-2019-06-00 10 Emergency Plan Change - Elimination of EOF Plant 04/30/2019 CFR 50.54(q)2 Operations Assistant Position Analysis PY-2019-06-00 Emergency Plan Change - Elimination of EOF Plant 04/30/2019 CFR 50.54(q)3 Operations Assistant Position Screen/Evaluation PY-2019-09-00 10 Emergency Plan Revision 53 - Editorial Changes 05/22/2019 CFR 50.54(q)2 Analysis PY-2019-09-00 10 Emergency Plan Revision 53 - Editorial Changes 05/22/2019 CFR 50.54(q)3 Screen/Evaluation Procedures EP-0000 Emergency Plan for Perry Nuclear Power Plant 52 EP-0000 Emergency Plan for Perry Nuclear Power Plant 53 NOP-LP-5002 Evaluation of Changes to Emergency Plans and Supporting 7 Inspection Type Designation Description or Title Revision or Procedure Date Documents 10 CFR 50.54(q) 71114.05 Corrective Action CR-2017-11819 Lake County Letter of Agreement was Expired for Two 11/30/2017 Documents Months CR-2018-05456 ERO Drill 6-6-18: Objective F.6 Not Met - Release Start 06/12/2018 Time CR-2018-07292 ERO Drill: Objective C1 - Not Met, Failure to Notify Offsite 08/17/2018 Agencies within 15 Minutes CR-2018-08213 ERO Exercise - Objective U11 and U12 Not Met - Dose 09/18/2018 Assessment CR-2018-08245 ERO Exercise - Objective C.2 Demonstrate Ability to Notify 09/19/2018 NRC within One Hour Not Met CR-2018-08276 ERO Exercise - Weaknesses in Dose Assessment 09/19/2018 CR-2018-08293 ERO Exercise - Objective K.7 Not Met - Accuracy of Alert 09/20/2018 News Statement CR-2018-09836 10/18/18 EOF General Emergency Classification Made 11/06/2018 Using Alternate EAL CR-2019-00834 Negative Trend Noted in Drill & Exercise Performance for 01/28/2019 the Month of January 2019 CR-2019-04480 ERO Drill - Objective E.6 Was Not Met During 5/15/2019 05/17/2019 Integrated Drill CR-2019-04730 Protective Action Flow Chart Recommendation 05/18/2019 Corrective Action CR-2019-08255 NRC EPlan Inspection: NOBP-LP-5018 "FENOC Siren 10/09/2019 Documents Testing and Maintenance" Scope of Review Discrepancy Resulting from Inspection Miscellaneous Letters of Agreement with Agencies Supporting Emergency 09/01/2017 - Preparedness (Sample) 09/30/2019 Emergency Preparedness Drill and Exercise Records 09/01/2017-

                                          (Sample)                                                     09/30/2019

Emergency Response Organization Training and 10/10/2019 Qualification Records (Sample) KLD TR-1029 Perry Nuclear Power Plant 2018 Population Update Analysis 09/27/2018 KLD TR-481 Perry Nuclear Power Plant Development of Evacuation Time 10/01/2012 Estimates Inspection Type Designation Description or Title Revision or Procedure Date KLD TR-997 Perry Nuclear Power Plant Evacuation Time Estimate 05/04/2018 Sensitivity Study Due to the Vrooman Road Closure Procedures Emergency Plan for Perry Nuclear Power Plant 54 PYBP-ERS-0003 Emergency Plan Facility/ Equipment Inventory Checklists 21 Self-Assessments MS-C-17-11-24 Fleet Oversight Audit Report of Emergency Preparedness 12/08/2017 MS-C-18-11-24 Fleet Oversight Audit Report of Emergency Preparedness 12/07/2018 71124.02 ALARA Plans 190522 1R17 Bioshield ISI Activities 0 190903 1R17 In Vessel Inspection Activities 0 190904 1R17 Reactor Reassembly Activities 0-4 Corrective Action CR 2019-02298 Hydraulic Oil Spill into Refueling Cavity 03/13/2019 Documents CR 2019-02512 In Vessel Inspection Outage Project Elevated Dose Levels 03/19/2019 CR 2019-02607 1R17 Bioshield ISI RWP 190522 Estimate Challenged 03/21/2019 CR 2019-03322 1R17 Elevated Reactor Cavity Dose Rates after Second 04/08/2019 Draindown Miscellaneous 1R17 Outage Alara Report 06/12/2019 190522 1R17 Bioshield ISI Work in Progress Reviews 0 190522 1R17 Bioshield ISI Activities Alara Post Job Review 08/19/2019 190903 1R17 In Vessel Inspection Activities Work in Progress 0 Reviews 190903 1R17 In Vessel Inspection Activities Alara Post Job Review 08/20/2019 190904 1R17 Reactor Reassembly Activities Work in Progress 0-4 Reviews 190904 1R17 Alara Post Job Review 07/24/2019 Procedures NOP-OP-4107 Radiation Work Permits 18 Radiation Work 190522 1R17 Bioshield ISI Activities 0 Permits (RWPs) 190903 1R17 In Vessel Inspection Activities 0 190904 1RF17 Reactor Reassembly Activities 0-4 71151 Miscellaneous NRC Performance Indicator Data; Emergency Preparedness 07/01/2018 -

                                          - Drill/Exercise Performance (DEP)                         06/30/2018

NRC Performance Indicator Data; Emergency Preparedness 07/01/2018 -

                                          - ERO Readiness                                            06/30/2019

NRC Performance Indicator Data; Emergency Preparedness 07/01/2018 -

                                          - Alert and Notification System Reliability                06/30/2019

Inspection Type Designation Description or Title Revision or Procedure Date NOBP-LP-4012- Reactor Coolant System Leakage 10/01/2018 - 09/30/2019 Procedures NOBP-LP-4012 NRC Performance Indicators 7 71152 Corrective Action CR 2018-08732 2018 NRC Fire Protection Inspection - Obstructed Sprinkler 10/04/2018 Documents Head on CC-574 Overhead Suppression System CR 2018-08805 Motor Fire Pump Pin Hole Leak Downstream of Pump Relief 10/07/2018 Valve CR 2019-01465 Packing Leak Has Returned on RHR & RCIC Steam Supply 02/18/2019 Second Drain Isolation Valve CR 2019-05479 Packing Leak on RHR & RCIC Steam Supply Second Drain 06/25/2019 Isolation Valve CR 2019-07109 Packing Leak on RHR & RCIC Steam Supply 08/25/2019 CR 2019-08262 L -H-1-A Clogged Nozzles Found During Deluge Test PTI- 10/09/2019 P54-P0064A CR 2019-09579 Three Clogged Nozzles Discovered During Interbus 11/12/2019 Transformer LH2A Deluge Testing per PTI-P54-P0065A Drawings 17-936 Sh37 Interbus Transformer Plan View 05/30/1980 Procedures NOBP-OP-0012 Operator Work-Arounds, Burdens, Control Room 8 Deficiencies and Operations Aggregate Assessment NOP-LP-2001 Corrective Action Program 46 NOP-OP-1009 Operability Determinations and Functionality Assessments 8 NOP-OP-1010 Operational Decision-Making 8 PAP-1910 Fire Protection Program 42 PTI-P54-P0064A Water Spray Flow Test for Unit 1 Interbus Transformer A 6 SOI-P54 (WTR) Fire Protection System - Water 30 Work Orders 200694434 PTI-P54P0065A LH-2-A Spray Flow Test 11/11/2019 27| ]]