IR 05000440/2022002
| ML22220A096 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/08/2022 |
| From: | Eve E NRC/RGN-III/DRP/B2 |
| To: | Penfield R Energy Harbor Nuclear Corp |
| References | |
| IR 2022002 | |
| Download: ML22220A096 (20) | |
Text
SUBJECT:
PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2022002
Dear Mr. Penfield:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On August 4, 2022, the NRC inspectors discussed the results of this inspection with Mr. Christopher Elliott, General Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Perry Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Perry Nuclear Power Plant.
August 8, 2022 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Elise C. Eve, Acting Chief Branch 2 Division of Reactor Projects Docket No. 05000440 License No. NPF-58
Enclosure:
As stated
Inspection Report
Docket Number:
05000440
License Number:
Report Number:
Enterprise Identifier:
I-2022-002-0052
Licensee:
Energy Harbor Nuclear Corp
Facility:
Perry Nuclear Power Plant
Location:
Perry, OH
Inspection Dates:
April 1, 2022 to June 30, 2022
Inspectors:
J. Corujo-Sandin, Senior Reactor Inspector
D. Melendez-Colon, Reactor Inspector
V. Myers, Senior Health Physicist
T. Ospino, Resident Inspector
J. Reed, Health Physicist
M. Siddiqui, Reactor Inspector
J. Steffes, Senior Resident Inspector
Approved By:
Elise C. Eve, Acting Chief
Branch 2
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Perry Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Survey Annulus During Moisture Separator Move Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000440/2022002-01 Open/Closed
[H.13] -
Consistent Process 71124.01 The inspectors reviewed a self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 20.1501 when the licensee failed to perform adequate surveys to demonstrate compliance with High Radiation Area (HRA) posting and controls required by 10 CFR 20.1902 and 20.1601 during moisture separator lifts.
Failure to Survey Worker After Alarming a Portal Monitor Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000440/2022002-02 Open/Closed
[H.8] -
Procedure Adherence 71124.04 The inspectors reviewed a self-revealed finding of very low safety significance (Green) and an associated non-cited violation (NCV) of 10 CFR 20.1501 (a)(1) Surveys and Monitoring,
General when the licensee did not make surveys to assure compliance with 10 CFR 20.1802 Control of material not in storage. Specifically, the licensee failed to perform an adequate survey of a worker who alarmed a portal monitor at the facility exit, resulting in the uncontrolled release of radioactive material to unrestricted areas.
Additional Tracking Items
None.
PLANT STATUS
The plant began the inspection period at 97 percent power due to ongoing "A" flow control valve position fluctuations without operator demand experienced during the previous reporting period.
On April 2, 2022, the unit again experienced an undemanded movement of the "A" flow control valve following restoration from troubleshooting efforts which required operators to reduce reactor power to approximately 88 percent in order to restore recirculation loop flows to required band. The plant was restored to near full power operations on April 6, 2022, following repair and modification activities to the "A" flow control valve control circuitry. The unit remained at or near 100 percent power for the remainder of the inspection period except for rod sequence exchanges, required testing, and in some instances power reductions to maintain condensate demineralizer outlet temperature and/or condenser circulating water outlet temperature at or below their respective upper limits due to environmental conditions. The power reductions varied between 1 to 12 percent of rated thermal power and lasted from a few hours to several days.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk-significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather thunderstorms and high winds on June 1, 2022.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Division 2 emergency diesel generator room 620' and 646' elevations on May 19, 2022
- (2) Division 3 emergency diesel generator room 620' and 646' elevations on May 27, 2022
- (3) Emergency service water pumphouse all elevations on May 27, 2022
- (4) Unit 1 auxiliary building 574 elevation on June 6, 2022
- (5) Unit 1 division 1 switchgear room 620 6 elevation fire zone 1CC-3c on June 22, 2022
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) Fire drill on June 24, 2022
71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger performance on the following:
- (1) Division 3 diesel jacket water heat exchanger (1E22B5002)
Ultimate Heat Sink (IP Section 03.04) (1 Sample)
The inspectors evaluated the ultimate heat sink performance on the following:
- (1) Reviewed operation of service water system and ultimate heat sink (per Section 03.04.b)
Performed a system walkdown and reviewed documentation for the selected service water systems (per Section 03.04.d)
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Division 3 emergency diesel generator jacket water heat exchanger maintenance on May 12, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Plant aggregate risk assessment with bus EF1E-1 removed from service for inspections on May 4 to 5, 2022
- (2) Division 3 emergency diesel generator work window from May 9 to 12, 2022
- (3) Plant aggregate risk assessment with maintenance on multiple safety systems on May 26, 2022
- (4) Low pressure core spray minimum flow valve failure on June 24, 2022 (5)
"B" annulus exhaust gas treatment recirculation fan damper failure as documented in CR 2022-05167 on June 27, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (3 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Division 3 emergency diesel generator lube oil leak following maintenance window on May 13, 2022
- (2) Upper containment airlock pneumatic test failure as documented in CR 2022-04314 on May 22, 2022
- (3) Low pressure core spray minimum flow valve failure during testing from June 27 to 29, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Reactor recirculation flow control valve "A" modification to disconnect linear velocity transducer following failure on May 9, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Division 3 diesel generator slow start following repairs on May 12, 2022
- (2) High pressure core spray system valve F0514 replacement on May 16, 2022
- (3) Test related to the fix of the upper containment airlock reactor door leak on May 27, 2022
- (4) Replacement of rod control information system branch amplifier card 1C11-K700J on June 7, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (1 Sample)
- (1) Division 3 diesel generator start and load on June 2,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (1 Sample)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Annulus controls during moisture separator move
71124.04 - Occupational Dose Assessment
Special Dosimetric Situations (IP Section 03.04) (1 Sample)
The inspectors evaluated the following special dosimetric situations:
- (1) Completed the review of skin dose assessment from CR-2021-02636 dated April 26, 2021, that was previously documented in the 2022 first quarter integrated report (Perry Nuclear Power Plant - Integrated Inspection Report
===05000440/2022001).
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01)===
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the Groundwater Protection Initiative program to identify incomplete or discontinued program elements.
INSPECTION RESULTS
Failure to Survey Annulus during Moisture Separator Move Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000440/2022002-01 Open/Closed
[H.13] -
Consistent Process 71124.01 The inspectors reviewed a self-revealed Green finding and associated non-cited violation (NCV) of 10 CFR 20.1501 when the licensee failed to perform adequate surveys to demonstrate compliance with High Radiation Area (HRA) posting and controls required by 10 CFR 20.1902 and 20.1601 during moisture separator lifts.
Description:
This facility has a cylindrical containment building which includes a refuel floor, where reactor disassembly and reassembly occurs. During disassembly, the reactors moisture separator, a highly contaminated piece of equipment, is lifted from the center of the refuel pool via a crane, moved to the north side of the pool, and lowered back into the pool. While the component is in the pool, substantial radiation shielding is provided by the water in the pool.
However, when the component is lifted from the pool, dose rates on the refuel floor become elevated. The containment is also surrounded by another cylindrical structure called the annulus. At elevations below the refuel floor there is substantial shielding, in the form of concrete and water, between radioactive components inside containment and the annulus.
However, at elevations at and above the refuel floor, the shielding provided is reduced to a steel liner ranging from 1 to 3 inches in thickness, which provides significantly less radiation shielding.
On March 11, 2021, two individuals, who were working in the annulus at about the same elevation as the refuel floor, received dose rate alarms on their electronic alarming dosimeters (EADs). These individuals placed their work in a safe condition, left the area and reported to Radiation Protection (RP). Maximum dose rates seen on the individuals EADs were 224 mrem/hr and 366 mrem/hr, with alarm setpoints of 75 mrem/hr. RP entered the annulus, which was posted and controlled as a radiation area, to perform follow-up surveys.
These surveys indicated dose rates of approximately 2 mrem/hr where the individuals were working. However, RP determined that at the time of the EAD alarms, the moisture separator lift was occurring inside containment and that the lift had been completed prior to RP entering the annulus to perform the EAD alarm follow-up surveys. Instead of performing a radiation survey prior to the moisture separator removal, the licensee relied on historical practices to determine the radiological controls, resulting in the area being posted and controlled as a radiation area.
Since RP could not validate the dose rates via follow-up surveys, they performed an evaluation using a software program that can model dose rates at various locations in relation to a radiation source. This evaluation utilized dose rates seen along the refuel pool railing during the moisture separator lift to estimate the dose rates inside the annulus. The dose rates seen along the refuel pool railing ranged from approximately 1.2 Rem/hr along the south railing (furthest from the moisture separator) to approximately 82 Rem/hr along the north railing (closest to the moisture separator). The licensees evaluation estimated radiation levels of approximately 400 mrem/hr in the location of the workers, which generally aligned with the dose rates seen on the EADs. Additionally, during the moisture separator move for reactor reassembly, the licensee posted and controlled accessible areas of the annulus at and above the refuel floor as HRAs and performed dose rate measurements at five locations. The maximum dose rate seen was approximately 350 mrem/hr at 1 foot from the steel liner.
The inspectors determined there were technical issues with the licensees evaluation. For example, the analysis performed via the software program had an error in which measurements that should have been in feet were entered as centimeters. Additionally, neither the analysis performed via the software program, nor the surveys conducted in the annulus during reassembly, established dose rates in accessible areas that would be expected to receive the highest dose rates during the moisture separator move. Specifically, the software program evaluation only looked at the location where the individuals who received the EAD dose rate alarms were, which was on the west-northwest side of containment. Additionally, although the surveys taken during reassembly were done at five different locations, none of the surveys were performed at the accessible locations closest to the north side of containment (the accessible areas closest to the moisture separator).
Irrespective of these issues, the inspectors determined that the areas within the annulus met the conditions requiring HRA postings and controls at the time of the moisture separator lift on March 11, 2021, during disassembly.
Corrective Actions: The licensee entered the issue into the corrective action program.
Corrective actions taken included updated procedure HPI-C0018, "Radiation Protection Response to Changing Plant Conditions, to include posting and controlling these accessible areas in the annulus as HRAs prior to commencing movement of various highly radioactive equipment in containment, as well as posting and controlling the annulus based on dose rates seen along the containment wall from the refuel floor. The licensee also plans to complete additional surveys of the annulus during the next moisture separator move to ensure that accessible areas expected to see the highest dose rates are surveyed.
Corrective Action References: CR-2021-01739, Two Unbriefed Dose Rate Alarms Received in Containment Annulus
Performance Assessment:
Performance Deficiency: The licensee failed to perform radiological surveys, as required by 10 CFR 20.1501, in the annulus to evaluate the impact from moisture separator lifts on the refuel floor in containment.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to survey resulted in inadequate controls for an HRA, which could lead to unintended dose to workers. The performance deficiency is similar to example 6F in IMC 0612 Appendix E, Examples of Minor Issues.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix C, Occupational Radiation Safety SDP. Specifically, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not related to ALARA [as low as reasonably achievable], did not result in an overexposure nor a substantial potential for an overexposure, and the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.13 - Consistent Process: Individuals use a consistent, systematic approach to make decisions. Risk insights are incorporated as appropriate. Specifically, the licensee did not incorporate risk insights into a systematic approach in evaluating radiologically significant components in accessible areas adjacent to the area the components are in.
Enforcement:
Violation: Title 10 CFR 20.1501 requires that the licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels. 10 CFR 20.1601 requires specific controls associated with HRA access and 10 CFR 20.1902 requires specific postings for HRAs.
Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present.
Contrary to the above, on March 11, 2021, the licensee failed to perform surveys in accordance with 20.1501 to demonstrate compliance with 20.1601 and 20.1902. Specifically, the licensee did not conduct radiological surveys to evaluate the radiation levels in the annulus for the movement of the moisture separator inside containment to ensure that HRA postings and controls were implemented based on radiation levels.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Survey Worker After Alarming a Portal Monitor Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000440/2022002-02 Open/Closed
[H.8] -
Procedure Adherence 71124.04 The inspectors reviewed a self-revealed finding of very low safety significance (Green) and an associated NCV of 10 CFR 20.1501 (a)(1) Surveys and Monitoring, General when the licensee did not make surveys to assure compliance with 10 CFR 20.1802 Control of material not in storage. Specifically, the licensee failed to perform an adequate survey of a worker who alarmed a portal monitor at the facility exit, resulting in the uncontrolled release of radioactive material to unrestricted areas.
Description:
On April 2, 2021, a decontamination technician completed their night shift work on the refuel floor during the Perry Nuclear Power Plant 1R18 refueling outage, which was the workers last day of work at the Perry site. The worker exited the site at the Primary Access Facility.
The worker entered a portal-style radiation monitor as part of the exit process and received an alarm. The worker indicated (in a subsequent statement/interview) that they then contacted a member of the RP staff to get support based upon the radiation alarms. Based upon this conversation with RP staff, the workers understanding was that they were to continue to monitor (while removing articles of clothing to determine where the contamination might be present) until RP responded to the area. After several more attempts, the worker exited the portal monitor and proceeded to call RP stating they had successfully passed the monitor and that no additional support was needed. The licensee's procedures require workers to contact RP after two monitor alarms. Additionally, licensee procedure instructs RP technicians to perform radiological surveys of individuals who alarm portal monitors twice.
Subsequently, neither of these procedural requirements were met when the worker exited the facility.
On April 5, 2021, the worker arrived at another nuclear reactor facility where they alarmed the portal monitor during in-processing activities. The other nuclear reactor facility performed radiological surveys that identified both internal and external contamination of the worker.
During decontamination activities, a discrete radioactive particle was identified with an activity of 80,000 disintegrations per minute. Additionally, low level contamination of clothing and shoes was identified. Once external decontamination efforts were completed, in-vivo bioassay was completed via a whole-body counter. The Radiation Protection Manager (RPM) of the other nuclear reactor facility contacted the RPM at Perry to inform them of the potential issue.
Perry Nuclear Power Plant performed a review of video footage that revealed the multiple portal monitor alarms by the worker on the morning of April 2, 2021. The video footage also appeared to show the worker moving off-camera and making attempts to contact the Perry RP staff for assistance (via a telephone in the immediate area). At no time during the 30 minutes did a member of the RP staff arrive to survey the worker. The licensee assessed the information (both onsite and from the other nuclear reactor facility) and determined that the dose to the individual was likely less than 5 mrem to the individuals whole body.
Corrective Actions: The radioactive material found on the worker was confiscated and returned to Perry Nuclear Power Plant for disposal. Additional radiological surveys were performed at the workers hotel. Training was conducted for onsite RP technicians and contractor RP technicians on portal monitor alarm responsiveness and radiological risk awareness.
Corrective Action References: CR-2021-02636
Performance Assessment:
Performance Deficiency: The licensee failed to perform adequate surveys to control licensed material within the facility. Specifically, the licensee did not perform required radiological surveys of a worker who alarmed the portal monitors. Subsequently, the failure to perform required surveys resulted in the uncontrolled release of radioactive material into unrestricted areas.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the licensee did not perform radiological surveys of a worker who alarmed a portal monitor which resulted in an uncontrolled release of the radioactive material into unrestricted areas.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. The inspectors determined that the finding was of very low safety significance (Green) because there was an uncontrolled release of radioactive material into unrestricted areas that resulted in dose to the public below 0.005 rem Total Effective Dose Equivalent.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, RP staff did not follow their procedures and processes to respond to a portal monitor alarm.
Enforcement:
Violation: Title 10 CFR 20.1501 requires, in part, that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.
Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present.
Title 10 CFR 20.1802, requires, in part, that the licensee control and maintain constant surveillance of licensed material that is in a controlled area or unrestricted areas and that is not in storage.
Contrary to the above, on April 2, 2021, the licensee failed to perform surveys to assure compliance with 10 CFR 20.1802. Specifically, on April 2, 2021, the licensees survey of a worker who alarmed the portal monitor did not control licensed material from inadvertently being carried outside of the controlled area and restricted areas of the site. A discrete radioactive particle of 80,000 disintegrations per minute was carried offsite by the worker.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On August 4, 2022, the inspectors presented the integrated inspection results to Mr. C. Elliott, General Plant Manager, and other members of the licensee staff.
On April 29, 2022, the inspectors presented the triennial heat sink inspection results to Mr. R. Penfield, Site Vice President, and other members of the licensee staff.
On June 9, 2022, the inspectors presented the radiation protection inspection results to Mr. C. Elliott, General Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
ONI-ZZZ-1
Acts of Nature - Severe Weather
22-05089
NRC Identified: Appendix R Light Charging Meter Erratic
06/23/2022
Corrective Action
Documents
Resulting from
Inspection
22-05101
NRC identified Prefire Plan has Incorrect Functional
Locations Referenced
06/24/2022
FPI-0CC
Control Complex
06/22/2022
FPI-0EW
Emergency Service Water Pumphouse
FPI-1AB
Auxiliary Building Unit 1
06/07/2022
Fire Plans
FPI-1DG
Diesel Generator Building
Miscellaneous
PNPP No 7015
Fire Drill Planning Guidance - SCENARIO #FD-1125-062322
06/23/2022
E22-037
Design-Basis Heat Load & Required ESW Flow for the
E22-042
Division 3 Emergency Diesel Generator Jacket Water Heat
Exchanger Performance Test
E22-042
Division 3 Emergency Diesel Generator Jacket Water Heat
Exchanger Performance Test
P45-081
Evaluation of Net Positive Suction Head (NPSH) and
Submergence Requirements for the Emergency Service
Water (ESW) System Pumps
Calculations
P45-084
Determine Allowable Silt and Zebra Mussel Accumulation in
2001-3711
Silt Removal Criteria for ESWPH
10/22/2001
2007-14120
Snapshot SA PY-SA-07-68 Found Design Silt Depth
Exceeded in the ESW Intake Tunnel
2/07/2007
20-06344
Zebra Mussel Treatment Postponed Due to Deteriorating
Lake Conditions
08/11/2020
20-06391
Zebra Mussel Treatment Postponed Due to Lake Conditions
08/13/2020
20-06416
Zebra Mussel Treatment Scheduled for Friday, August 14th,
was Postponed Due to Deteriorating Lake Conditions
08/14/2020
20-07541
Diving Inspection of Intake and Discharge Structures
09/28/2020
Corrective Action
Documents
20-08428
Emergency Service Water Normal Intake Tunnel
Silt/Zebra Mussel Debris Depth Exceeds 5 Feet
10/30/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21-06384
Diving Inspection of Intake and Discharge Structures
08/24/2021
21-09615
Emergency Service Water Normal Intake Tunnel Silt Level
High
2/20/2021
22-00950
Triennial Ultimate Heat Sink Self-Assessment: Division III
Diesel Generator Jacket Water Heat Exchanger
Performance Degradation
2/08/2022
G202-2008-
35631
Silt Levels in the ESW Pumphouse Suction Bays
(East & West)
2/20/2008
Corrective Action
Documents
Resulting from
Inspection
22-03618
Scaffolding Erected Too Close to Safety-Related Equipment
04/26/2022
Div. 3 Diesel Jacket Water Cooling System
2/08/2016
Drawings
2-0139-00000
Division III Diesel Generator
20-0065-000
Setpoint Revision for Emergency Service Water Flow
Switches and Alarm Units: 1P45N0053A/B
(ECC HX A/B), 1P45N0073A/B (DG HX A/B), and
1P45N0251A/B (RHR A/C & B/D HXs)
Engineering
Changes
DCP 00-5013
ESW Intake Sluice Gate Seal Modification
09/27/2001
Engineering
Evaluations
Engineering
Evaluation
Request
601358919
Evaluate Adverse Affect of Scaffolding
04/28/2022
Pump and Valve Inservice Testing Program Plan
281
Vendor Manual - Emergency Service Water Sluice Gates
- 14
Aquatic Sciences
LP Project RU12-
009
Discharge Tunnel Internal Inspection Using a Remotely
Operated Vehicle
2/06/2013
Aquatic Sciences
LP Project RU13-
030
Inspection of the Common Service Water Intake Tunnel with
a Remotely Operated Vehicle
08/28/2014
Miscellaneous
ASI Marine
Project
Reference: RU19-
Inspection of the Common Service Water Intake Tunnel with
a Remotely Operated Vehicle
06/11/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2
Design Input 223
Perry Nuclear Power Plant HPCS DGJW Heat Exchanger
Design Input
L02452
Upgrade the ESW Sluice Gate Seals to Safety Class
07/10/2001
L02452
Commitment to Upgrade the ESW Sluice Gate Seals to
Safety Class
10/19/2000
PLCO P22-P42-
158
Potential Limiting Condition of Operation for ECCs A Heat
Exchanger
03/16/2022
PY-CEI/N RR-
2492L
License Amendment Request Regarding a Modification to
the Emergency Service Water Alternate Intake Sluice Gate
Automatic Opening Function and the Use of a Non-Safety
Inflatable Seal
06/01/2000
PY-CEI/NRR-
2505L
Supplemental Letter to License Amendment Request
Regarding a Modification to the Emergency Service Water
Alternate Intake Sluice Gates
06/30/2000
SMRF 00-5013
Simple Modification Request Form (SMRF) 00-5013
Upgrades the ESW Sluice Gate Inflatable Seals and
Associated Inflation System to Safety Grade in Accordance
with 10 CFR Part 50 Appendix B Requirements for
Components Important to Safety Prior to Relying on the
Seals During the Summer of 2001
and 4
TAF 081999-06
As-Found Buried/Underground Examination Report for 48"
Emergency Service Water (P45) Piping
2/17/2013
TAF 081999-14
As-Found Buried/Underground Examination Report for 14"
Emergency Service Water Line per Order 200614309
05/07/2019
TAF 081999-15
As-Found Buried/Underground Examination Report for 14"
Emergency Service Water Line per Order 200614309
05/07/2019
TAF 81839
EMARP-0011 Diving Inspection Activities
Operability
Evaluations
2007-14120
Prompt Operability Determination for CR-2007-14120,
ESWPH Intake Tunnel Silt Buildup
EMARP-0011
Emergency Service Water System Monitoring Program
NOP-ER-2006
Service Water Reliability Management Program
NOP-WM-5008
Control of Scaffolding
Procedures
OAI-1701
Tracking of LCOs
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PTI-E22-P0007
HPCS Diesel Generator Jacket Water Heat Exchanger
Performance Testing
PYRM-ER-0001
Perry Service Water Reliability (Generic Letter 89-13)
Program Basis Document
SOI-P45/P49
Section 7.18
Emergency Service Water and Screen Wash Systems
SOI-R46/E22B
Division 3 Diesel Generator Jacket Water System
200340456
Clean, Inspect, Eddy Current, Leak Check Div III Diesel
Jacket Water Heat Exchanger
08/06/2010
200442907
PTI-E22P0007 1 (4Y) HPCS Diesel Generator Jacket Water
Heat Exchanger Performance Testing
10/13/2014
Work Orders
200645158
PTI-E22P0007 1 (4Y) HPCS Diesel Generator Jacket Water
Heat Exchanger Performance Testing
11/07/2018
Calculations
E22-046
Evaluation of Required Minimum Thickness of Partition Plate
for Division 3 Diesel Generator Jacket Water Heat
Exchanger
Corrective Action
Documents
22-03975
Acceptance Criteria not Identified in Division 3 Emergency
Diesel Generator Jacket Water Heat Exchanger Work Order
05/10/2022
Drawings
304-0805-00000
Emergency Service Water Diesel Generator Building
L
22-03961
Division 3 Diesel Fuel Line Sheared During Maintenance
Run on Number 8 Cylinder
05/10/2022
22-03969
Division 3 Diesel Generator #8 Cylinder Inspection Results
05/10/2022
22-03994
Division 3 Diesel #8 Cylinder Head Sleeve and Crab
Damaged
05/11/2022
22-05107
LPCS Minimum Flow Valve Blew 2 Main Line Fuses
06/24/2022
22-05140
MCC EF1A07-S Failed Under Voltage Relay
06/27/2022
Corrective Action
Documents
22-05167
Annulus Exhaust Gas Treatment Fan B Recirc Damper
Failed to Reposition
06/27/2022
NOP-OP-1007
Risk Management
Procedures
PAP-1924
Risk-Informed Safety Assessment and Risk Management
Work Orders
200887797
Perform Simple Troubleshooting / Rework
06/28/2022
22-04066
Lube Oil Clamp Plate Leakage Identified During Division 3
Diesel Generator Operation
05/13/2022
Corrective Action
Documents
22-04067
Oil Seepage Identified on Pipe Fitting During Division 3
05/13/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Diesel Generator Operation
22-04314
Failed Upper Containment Airlock Pneumatic System Leak
Test, Pen #312
05/22/2022
22-05141
Low Pressure Core Spray Minimum Flow Valve Torque
Switch Dimensions were Outside of Acceptance Criteria
06/27/2022
Work Orders
200790607
Add Washers to Ball Valves/ECP 19-0148/CR 2018-02435
5/28/2022
Engineering
Changes
2-0056-001
Temporary Modifications to Remove the 5 Volt Modicon
Clamp on the Velocity Controller Output
Work Orders
200879878
Implement Engineering Change 22-056
04/22/2022
19-0418-003
Containment Airlock 3-Way Ball Valve Return to Original
Design Configuration, PY-1P53F0591B, PY-1P53F0592B
(Upper Containment Airlock Inner Door)
05/28/2022
Engineering
Evaluations
601349509
Approve-Replace Valve with Ball Valve
2/08/2022
Procedures
PTI-E22-P0011
High Pressure Core Spray Diesel Generator Slow Speed
Start for Post-Maintenance Inspections
200461326
Replace Branch Amplifier Card 1C11-K700J (BJM22)
06/07/2022
200790607
Add Washers to Ball Valves/ECP 19-0148/CR 2018-02435
05/28/2022
Work Orders
20086670
Replacement of the Dresser Valve 1E22F0514 with a Ball
Valve
05/16/2022
Corrective Action
Documents
ATA-2022-12374
Remove Over Pressurization Step from SVI-P57-T0392A on
Page 12 of Rev 5. (Steps 27,28,29)
07/12/2022
Procedures
SVI-E22-T1319
Diesel Generator Start and Load Division 3
06/02/2022
Work Orders
200814203
Replace Fullers Earth Filter
05/02/2022
Radiation
Surveys
PY-M-20210312-
Refuel Floor During Moisture Separator Move
03/11/2021
Calculations
Calculation found
in CR-2021-
2636
Deep Dose Calculation
05/26/2022
Corrective Action
Documents
CR-2021-02636
Individual Supporting 1R18 Exited Site with Detectable
Activity
04/07/2021
NOP-OP-4413
PM-12 Calibration, Source Checks and Use
Procedures
NOP-OP-4503
Personnel Contamination Monitoring
Calibration
Records
PY-SVI-
D51T0305A
Meteorological Monitoring, System A, 10 Meter Wind Speed
05/02/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PY-SVI-
D51T0306A
Meteorological Monitoring, System A, 10 Meter Wind
Direction Channel Calibration
05/02/2022
PY-SVI-
D51T0308A
Meteorological Monitoring, System A, 60 Meter Wind
Direction
05/02/2022
PY-SVI-
D51T0311A
Meteorological Monitoring, System A, Air Temperature and
Delta Air Temperature Calibration for D51-N706 and
D51-N708
05/02/2022
CR-2020-01864
The 2020 Reactor Water to NCC Leakage Revealed that the
Methodology Developed in 2012 for Determination of Effluent
Dose Due to NCC Leakage was Inadequate for the Current
NCC Leak
03/06/2020
CR-2020-02119
REMP Air Samplers Found Not Operating
03/11/2020
CR-2020-05443
REMP Air Sampler (6) Found with No Flowrate
07/02/2020
Corrective Action
Documents
CR-2021-06690
August Vegetation Re-Sampled Due to Courier Disposal
09/03/2021
CR-2022-04738
NRC ID: August 2021 ODCM Required Vegetation
06/09/2022
Corrective Action
Documents
Resulting from
Inspection
CR-2022-04748
NRC ID: REMP Air Sampler Trees/Foliage Need Trimmed
06/09/2022
Miscellaneous
Event Log
10CFR50.75(g) Event Log Spreadsheet
05/12/2022
CHI-ODCM
Offsite Dose Calculation Manual
NOP-OP-2012
Groundwater Monitoring
NOP-OP-4705
Response to Contaminated Spills/Leaks
PAP-0808
Environmental Programs and Reports
PAP-0809
Radiological Environmental Contamination Response
PAP-1704
Preparation of the Annual Environmental and Effluent
Release Report
REMP-0012
Food Product Sampling
REMP-0018
REMP Sample Data Review and Reporting Requirements
REMP-0022
Processing Data from the PNPP Meteorological Tower
REMP-0023
Air Sample Collection
Procedures
REMP-0024
Air Sampler Maintenance and Calibration
ATA-2021-18921
22 REMP Self-Assessment
03/11/2022
Self-Assessments
Audit # 24879
NUPIC Audit of ATI Environmental Inc.
07/13/2020