IR 05000440/2023003

Integrated Inspection Report 05000440/2023003

ML23284A173
Person / Time
Site:	Perry
Issue date:	10/11/2023
From:	Karla Stoedter NRC/RGN-III/DORS/EB1
To:	Penfield R Energy Harbor Nuclear Corp
References
IR 2023003
Download: ML23284A173 (1)

Text

October 11, 2023

SUBJECT:

PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2023003

Dear Rod Penfield:

On September 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On October 5, 2023, the NRC inspectors discussed the results of this inspection with Chris Elliott, Plant General Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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. 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, Signed by Stoedter, Karla on 10/11/23 Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58

Enclosure:

As stated

Inspection Report

Docket Number: 05000440 License Number: NPF-58 Report Number: 05000440/2023003 Enterprise Identifier: I-2023-003-0055 Licensee: Energy Harbor Nuclear Corp.

Facility: Perry Nuclear Power Plant Location: Perry, OH Inspection Dates: July 01, 2023 to September 30, 2023 Inspectors: J. Beavers, Senior Resident Inspector G. Hansen, Senior Emergency Preparedness Inspector T. Hooker, Health Physicist V. Myers, Senior Health Physicist T. Ospino, Resident Inspector Approved By: Karla K. Stoedter, Chief Engineering Branch 1 Division of Operating Reactor Safety 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

Fuel Bundle Contact with Reactor Vessel During Fuel Handling Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.8] - 71153 NCV 05000440/2023003-01 Procedure Open/Closed Adherence A Green non-cited violation of Technical Specification 5.4.1.a was self-revealed on March 19, 2023, when the licensee failed to implement procedures required by Section 2.L, "Refueling and Core Alterations," of Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Specifically, the licensee failed to follow Step 2.43 of Standard Operating Instruction-F15, "Refueling and 360 Platforms," which directed specific movements of the refueling bridge when loading a fuel bundle into a peripheral core location to prevent catching the bottom of a fuel bundle on the core shroud's steam dam while lowering the bundle into position. As a result, the bottom of fuel bundle (S/N# 18P305) caught the bottom of the shroud's steam dam as the licensee attempted to lower the bundle into position. Once this occurred, the licensee took corrective actions to place the bundle in a safe location in the RP-1 storage pool and selected an alternate fuel bundle for placement in the reactor core.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On August 10, 2023, the unit was automatically shut down due to a reactor protection system trip. The unit was returned to rated thermal power on August 17, 2023, and operated at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

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

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of summer readiness for the following systems on July 25, 2023:

• switchyard, transformers, main generator, and steam tunnel cooling

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) reactor protection system on September 7 and 8, 2023

(2) control room emergency ventilation on September 27, 2023

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 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) fire zone at the 635' elevation, off-gas area on July 5, 2023

(2) fire zone at the 620 elevation, off-gas area on July 5, 2023

(3) fire zone at the control complex chiller area on August 1, 2023

(4) fire zone at the remote shutdown room on August 2, 2023

(5) fire zone at the 620' elevation, Unit 1 Division 1 electrical switchgear room on August 2, 2023

(6) fire zone at containment on August 28, 2023

(7) fire zone at the emergency service water pump house on August 29, 2023

(8) fire zone at control complex on September 5, 2023

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

The inspectors evaluated the performance and training of the on-site fire brigade during observation of the following drill activities:

(1) an unannounced fire protection drill on July 26, 2023

71111.06 - Flood Protection Measures

Flooding Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated external flooding mitigation protections in the areas with external outside vulnerability on August 28, 2023.

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 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during reactor plant automatic shutdown on August 10, 2023.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) Crew evaluation in the simulator on July 31, 2023.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (3 Samples)

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

(1) emergency diesel generator planned outage between July 31 and August 5, 2023

(2) reactor protection system power transfer switch failure on August 10, 2023

(3) actions characterizing potential trending issues associated with the 16 local power range monitors bypassed on September 7, 2023

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)

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) reactor recirculation circuit breaker 4A continuity bulb challenge on July 24, 2023

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

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

(1) functionality review of the Division 2 emergency diesel generator ventilation system after challenges on August 1, 2023

(2) operability review after issues related to the hydraulic control unit 14-51 and the associated accumulator level switch failure on September 5, 2023

71111.18 - Plant Modifications

Severe Accident Management Guidelines (SAMG) Update (IP Section 03.03) (1 Sample)

(1) The inspectors verified the site Severe Accident Management Guidelines were updated in accordance with the Boiling Water Reactor generic severe accident technical guidelines and validated in accordance with NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, Revision 1 on September 20, 2023.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated automatic reactor trip forced outage activities from August 10 to August 13, 2023.

71111.24 - Testing and Maintenance of Equipment Important to Risk

The inspectors evaluated the following testing and maintenance activities to verify system

operability and/or functionality: Post-Maintenance Testing (PMT) (IP Section 03.01)

(1) replacement of a 5V power supply as part of the rod control and information system monitor system on June 26, 2023

(2) replacement of mounted auxiliary contact related to the emergency closed cooling water pump July 28, 2023

(3) replacement of the Division 3 emergency diesel generator engine fuel pump and coupling spider on August 8, 2023

(4) replacement of the reactor protection system transfer switch after the August 10, 2023, SCRAM on August 31, 2023

(5) replacement of the level switch associated with the control rod drive hydraulic control unit 14-51 on September 8, 2023

Surveillance Testing (IP Section 03.01) (3 Samples)

(1) evaluation of the vibrations of the residual heat removal A pump on June 21, 2023

(2) traversing in-core probe system run on July 20, 2023

(3) Division 3 diesel generator testing on August 4, 2023

Inservice Testing (IST) (IP Section 03.01) (1 Sample)

(1) reactor core isolation quarterly pump and valve operability on July 25, 2023

71114.02 - Alert and Notification System Testing

Inspection Review (IP Section 02.01-02.04) (1 Sample)

(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 August 2021 to August 2023

• Weekly alert notification system (siren) tests for the period from August 2021 to August 2023

71114.03 - Emergency Response Organization Staffing and Augmentation System

Inspection Review (IP Section 02.01-02.02) (1 Sample)

(1) The inspectors evaluated the readiness of the Emergency Response Organization.

71114.05 - Maintenance of Emergency Preparedness

Inspection Review (IP Section 02.01 - 02.11) (1 Sample)

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

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1 Sample)

(1) Emergency Preparedness drill on August 3,

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1) turbine building supply plenum drain

(2) nuclear closed cooling system

(3) Unit 1 and 2 ventilation

(4) off-gas system

Sampling and Analysis (IP Section 03.02) (4 Samples)

Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:

(1) compensatory sampling of off-gas vent while the effluent monitor was inoperable

(2) compensatory continuous sampling of Unit 2 vent radiation monitor

(3) liquid composite sampling process

(4) gaseous effluent sample from Unit 1 vent

Dose Calculations (IP Section 03.03) (3 Samples)

The inspectors evaluated the following dose calculations:

(1) batch liquid release; discharge # 22-012L

(2) monthly dose assessment for March 2021

(3) monthly dose assessment for February 2022

Abnormal Discharges (IP Section 03.04) (2 Samples)

The inspectors evaluated the following abnormal discharges:

(1) auxiliary boiler liquid batch release in February 2022

(2) Nuclear Closed Cooling continuous liquid release in

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS08: Heat Removal Systems (IP Section 02.07) ===

(1) Unit 1 (October 1, 2022 through June 30, 2023)

MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) Unit 1 (October 1, 2022 through June 30, 2023)

MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) Unit 1 (October 1, 2022 through June 30, 2023)

BI01: Reactor Coolant System (RCS) Specific Activity Sample (IP Section 02.10) (1 Sample)

(1) Unit 1 (July 1, 2022 through June 30, 2023)

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

(1) Unit 1 (October 1, 2022 through June 30, 2023)

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) Unit 1 (July 1, 2022 through June 30, 2023)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) Unit 1 (July 1, 2022 through June 30, 2023)

EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12) (1 Sample)

(1) Unit 1 (July 1, 2022 through June 30, 2023)

EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13)

(1 Sample)

(1) Unit 1 (July 1, 2022 through June 30, 2023)

EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)

(1) Unit 1 (July 1, 2022 through June 30, 2023)

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) elevated groundwater tritium readings on July 10, 2023

71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)

(1) The inspectors evaluated a refrigerant leak and licensees performance and response on July 18, 2023.

(2) The inspectors evaluated an automatic reactor trip and the licensees performance and response on August 10, 2023.

Personnel Performance (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees performance and response to a fuel bundle to reactor vessel contact event on April 18,

INSPECTION RESULTS

Observation: Elevated Groundwater Tritium Readings 71152A In May of 2023, the licensee developed a sampling strategy to understand the underdrain system activity following a refueling outage. Sampling discovered elevated tritium in plant piezometers 6, 14, and 21. A cross functional team was formed, and an action plan developed to determine source of tritium.

In June 2023, tritium activity in piezometer 21 exceeded 20,000 pCi/L (40,200 pCi/L), and state, local, and Federal notifications were made as required. The cross functional team expanded and incorporated problem-solving processes. During this time, the tritium sampling plan expanded to include piezometers 5, 6, 9, 14, 15, 16 and 21 as well as underdrain manholes 20, 23, 10, and 11. Third party subject matter expert vendor assistance was established.

Three failure modes were investigated that included: degraded plant building and piping integrity, degraded underground piping with reactor interface, and existing source from past leakage. Proximate buildings, building interfaces with pipe penetrations, rattle spaces, and floor drains were inspected. No active leaks were identified. Condensate storage tank lines and radwaste discharge piping are buried pipes of interest. Eight soft drill wells were performed in the vicinity of these lines, which did not identify any licensee radioactive material.

In July 2023, Environmental Resource Management recommended to begin low volume continuous pump out of plant piezometer 21 at 4 gallons per day. This was developed as a strategy to determine active leak versus cyclic leak from the previous refueling outage. In September 2023, the licensee was still investigating the potential leak with piezometer 21 pump downs. Activity steadily decreased over the pump down period, which the site and vendor determined that the leak was not active. Once activity reaches < 5,000 pCi/L, the licensee plans to shut off the pump but continue daily sampling of piezometer 21 to trend activity. Normal non-investigative sampling will continue with in-plant piezometer tubes 2, 6, 7, 9 and 11 sampled semi-annually for gamma isotopic and tritium baseline monitoring. All other locations will be as required to support plume characterization assessment when radioactive contamination is identified. Manholes 20 and 23 will continue to be sampled on a quarterly basis for tritium and isotopic.

The inspectors evaluated the tritium identification and problem-solving efforts following the plant refueling outage. Data indicated no active leak in the underdrain system nor migration of the tritium outside of the underdrain system. No more than minor findings were identified with the licensees identification and response efforts.

Fuel Bundle Contact with Reactor Vessel During Fuel Handling Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.8] - 71153 NCV 05000440/2023003-01 Procedure Open/Closed Adherence A Green non-cited violation of Technical Specification 5.4.1.a was self-revealed on March 19, 2023, when the licensee failed to implement procedures required by Section 2.L, "Refueling and Core Alterations," of Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Specifically, the licensee failed to follow Step 2.43 of Standard Operating Instruction-F15, "Refueling and 360 Platforms," which directed specific movements of the refueling bridge when loading a fuel bundle into a peripheral core location to prevent catching the bottom of a fuel bundle on the core shroud's steam dam while lowering the bundle into position. As a result, the bottom of fuel bundle (S/N# 18P305) caught the bottom of the shroud's steam dam as the licensee attempted to lower the bundle into position. Once this occurred, the licensee took corrective actions to place the bundle in a safe location in the RP-1 storage pool and selected an alternate fuel bundle for placement in the reactor core.

Description:

Step 2.43 of Standard Operating Instruction (SOI)-F15, Refueling and 360 Platforms, states, When loading fuel into peripheral locations, the Refuel Bridge will index the location and lower the bundle to the ELEVATION LOADED position (~300) which is slightly above the top of the core shroud. The Bridge/Trolley should be moved toward the center of the core approximately 1 cell width to prevent catching the bottom of the bundle on the shrouds steam dam while lowering. With the bundled lowered to 320" - 350, the Bridge/Trolley should be realigned to the indexed location.

On March 19, 2023, the station was in Mode 5 with core alterations in progress. While performing Step 290 of the 1R19 Refuel Fuel Move Checklist, the fuel bundle (S/N#18P305)contacted the steam dam inside the reactor vessel. The fuel bundle was in the process of being lowered into location 19-60 at the peripheral of the core when contact occurred. The unit supervisor and outage control central were contacted immediately. Criteria to enter ONI-J11, "Fuel Handling Accidents," was not met as no immediately identifiable damage nor rising rad levels or fission product bubbles were identified. The refueling bridge operators were removed from duties and the human error checklist performed. The affected fuel bundle was placed in a safe location in the RP-1 fuel storage pools in the containment building. No damage to the steam dam was identified. Reactor engineering permitted core loading to continue without inserting this bundle. Calculation and selection of another twice burned bundle for that location was completed using updated fuel movement sheets, and the decision was made that the affected bundle would not go back into the reactor core. The licensee's investigation determined that the bridge was not moved toward the center of the core prior to lowering the fuel bundle below the steam dam per Step 2.43 of SOI-F15 for this peripherally located fuel bundle.

Corrective Actions: Immediate corrective actions included suspension of core alterations and completion of required management notifications. No indication of clad failure through visual or gaseous release was immediately identified. The licensee performed a stand down with the refueling bridge operators and operations management. Emphasis was placed on SOI-F15, Step 2.43 that provides direction on how to avoid fuel bundle contact with the steam dam. Engineering evaluated potential damage to the affected bundle and identified an alternate bundle to install into the core, which included updating the fuel movement sheets.

The affected bundle was moved to the spent fuel pool and replaced with an equivalent bundle. Document change request #ATA-2023-5737 was also written to revise Step 2.43 to, When loading fuel into peripheral core locations, the Refuel Bridge should be taken out of automatic operation prior to indexing on peripheral core locations. This should be done when approximately 2 cells out and toward the center of the core. The fuel bundle should then be lowered to Z position 320" - 350 followed by indexing onto the peripheral location. This prevents inadvertent contact with the steam dam (located ~ 300) by not allowing the fuel bundle to be positioned above the steam dam. Approach the peripheral location in a slow controlled manner to prevent the fuel bundle from swinging into the steam dam. This action is due December 27, 2024, which is prior to the next refueling outage.

Corrective Action References: CR-2023-02103, Fuel Bundle Made Contact with Steam Dam

Performance Assessment:

Performance Deficiency: The licensee failed to position the bridge/trolley toward the center of the reactor core to prevent catching the bottom of the bundle on the shrouds steam dam when lowering the bundle as required by Step 2.43 of SOI-F15. As a result, fuel bundle S/N#18P305 contacted the steam dam when being lowered into the core. This potential was specifically addressed in standard operation instruction for the refueling platform.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Cladding Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.

Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Per IMC 0609, Attachment 4, Table 3, Question A, the finding related to fuel handling issues, which then directs the inspector to evaluate the issue using IMC 0609, Appendix A. Per IMC 0609, Appendix A, Exhibit 3, "Barrier Integrity Screening Questions," Question 4, the finding resulted from a fuel handling errors, but was determined to be a Green finding since the fuel handling error did not challenge fuel cladding integrity or result in a release of radionuclides.

Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. The individuals failed to follow the standard operating instruction specifically written to prevent this event.

Enforcement:

Violation: Technical Specification Section 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Revision 2, Appendix A, Section 2 addresses General Plant Operating Procedures, and Section 2.L requires procedures for refueling and core alterations.

The licensee established Standard Operating Instruction SOI-F15, "Refueling and 360 Platforms," Revision 28, to address refueling and core alteration activities. Procedure SOI-F15, Step 2.43, states, "When loading fuel into peripheral locations, the Refuel Bridge will index the location and lower the bundle to the ELEVATION LOADED position (~300)which is slightly above the top of the core shroud. The Bridge/Trolley should be moved toward the center of the core approximately 1 cell width to prevent catching the bottom of the bundle on the shrouds steam dam while lowering. With the bundled lowered to 320" - 350, the Bridge/Trolley should be realigned to the indexed location.

Contrary to the above, on March 19, 2023, the licensee failed to implement procedures recommended in Section 2.L of Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, the licensee did properly implement Step 2.43 of SOI-F15 while moving fuel bundle S/N#18P305 to a peripheral location to prevent catching the bottom of the fuel bundle from catching on the shroud's steam dam while lowering the bundle.

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 October 5, 2023, the inspectors presented the integrated inspection results to Chris Elliott, Plant General Manager, and other members of the licensee staff.

• On August 17, 2023, the inspectors presented the radiation protection inspection results to Rod Penfield, Site Vice President, and other members of the licensee staff.

• On September 21, 2023, the inspectors presented the emergency preparedness inspection results to Rod Penfield, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.01 Miscellaneous none Certification of Summer Readiness 06/23/2023

71111.04 Procedures SOI-C71 RPS Power Supply Distribution 09/08/2023

SOI-M25/26 Control Room HVAC and Emergency Recirculating System 08/31/2023

71111.05 Fire Plans 0EW-1A and 1B Emergency Service Water Pumphouse 09/14/2018

1CC-3C Unit 1 - Div. 1 4160V and 480V Switchgear Room 620' - 6" 08/02/2023

Elev.

1CC-3d Unit 1 - Remote Shutdown Panel Room 620' - 6" Elev. 08/02/2023

1RB-1C-1A, 1B, Containment 599', 620', 642', 652', 664', and 689' 09/14/2018

1C, and 1D

FZ 1CC-1c Unit 1 - DIV 1 4160V and 480V Switchgear Room 620 - 6 09/05/2023

OCC-1C Control Complex Chiller Water System 574-10 Elevation 01/08/2023

OG - 620 01 Off Gas Bldg Elev. 620 01 07/05/2023

OG - 635 02 Off Gas Bldg Elev. 635 02 07/05/2023

71111.06 Corrective Action CR-2023-06575 ONI-ZZZ-1 Flood Barrier Storage is Not Organized to 08/23/2023

Documents Support Efficient Implementation if Needed

CR-2023-06672 Potential Flood Barrier Installation Issues Per ONI-ZZZ-1 08/26/2023

Required Doors

71111.11Q Miscellaneous Simulation Guide, Evaluation Scenario Guide OTLC-305820303-PY-SGCG 0

Cycle 202303 Copy 4/6

71111.12 Procedures FTI-A-0001 TIP Operation 13

SVI-C51-T5351 LPRM Calibration 18

Work Orders 200807714 SVI-E22T1319 HPCS D/G Start and Load 08/05/2023

200913922 SVI-C51T5351 TIP Run LPRM Calibration 07/27/2023

71111.13 Corrective Action CR 2023-05744 Reactor Recirc Circuit Breaker 4A Trip Coil Continuity Light 07/23/2023

Documents Not Lit

71111.15 Corrective Action CR 2022-01390 Div 2 DG Exhaust Dampers Indicate Dual Position with 02/22/2022

Documents Supply Fan Running

CR 2023-03551 Div. 2 DG Exhaust Louvers Show Dual Indication during 04/27/2023

Start

CR 2023-05795 Div 2 DG Supply Fan Dampers Failed to Open 07/25/2023

CR 2023-05909 Division 2 DG Room Exhaust Louver Indication Issues 07/28/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

CR 2023-06855 CRD Accumulator Level Switch Failed to Actuate 09/05/2023

Drawings 912-0619-00000 Diesel Generator Building Ventilation System S

71111.18 Procedures SAMG-1 RPV Control Severe Accident Management Guidelines 1

SAMG-2 Containment and Radioactivity Release 1

71111.24 Corrective Action 2023-05670 TIP drawer 1C51J0001E Ready Light Stuck on Not 07/20/2023

Documents Collecting Data

23-05690 Local Power Range Monitors (LPRM) Outside of 07/21/2023

Acceptance Criteria After Calibration

23-06215 Automatic Reactor SCRAM and MSIV Closure Following 08/10/2023

RPS Bus Shift from ALT to NORM B

23-06281 Minor Insulation Damage Found on Power Source Selector 08/21/2023

Switch Wire

CR 2020-08144 Freedom Series Auxiliary Contact Found Failed on 10/21/2020

EF1A08-C

Drawings 208-0070-00006 Leak Detection System DD

Engineering 23-1145-002 Temporary MOD for Removal of Jumper on Panel 08/10/2023

Changes 1H13P0710E

Procedures GEI-0029 Testing of Mold Case Circuit Breakers and Overload Heater 24

Relays

GEI-0138 Freedom Bucket Maintenance 9

PMI-0078 Division 3 HPCS Diesel Generator Fuel System 7

Maintenance

SVI-C11-T0009 Control Rod SCRAM Accumulator Pressure Detection 8

Functional/Calibration for HCU Accumulators

TAI-2000-2 Vibration Monitoring 6

Work Orders 200789681 Support SVI-C11T0009 Contingency 09/08/2023

200805508 Take Vibration Data - RHR Pump A (EQ) Take Vibration 06/21/2023

Data - RHR Pump A (EQ) Take Vibration Data - RHR

pump A (EQ) PM Planning Complete*

200807397 Replace Div. III Engine Fuel Pump Order Will Also Replace 08/08/2023

The Coupling Spider and Credit Maintenance Plan #25319

200807920 Perform EMI Testing Div 3 HPCS DG *PM Planning 08/04/2023

Complete

200816150 No work description issued 07/26/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

200913280 Fix TIP machine Common Channel/CR 07/20/2023

200921639 Replace RPS Transfer Switch Py-1C71S0701 08/31/2023

CR 2023-6215

WO 200556515 Replace 5V Power Supplies 1E31N0700B 06/26/2023

71114.02 Corrective Action CR 2021-07941 Perry Siren Backup Activation Point Failure 10/21/2021

Documents CR 2022-09852 2022 Siren Pole Top Siren Maintenance 12/29/2022

Miscellaneous Federal Signal Models 2001-130, Equinox, and 508-128 A5 0117

Sirens Installation, Operation, and Service Manual

Federal Signal DCB, DCFCB, and DCFCTB Models Battery LO 1015

Operated Mechanical Siren Control System Installation,

Operation, and Service Manual

Tempest T-112/ T-121 Omni-Directional Siren Installation, H

Operation, Maintenance and Parts Manual

Perry EPZ Siren System PI Test Schedules 01/01/2021 -

2/31/2023

Perry EPZ Siren System Test Data 09/01/2021 -

08/31/2023

Perry EPZ Siren Annual Maintenance Records 09/01/2021 -

08/31/2023

Perry Nuclear Power Plant Prompt Alert Siren System 0

(PASS) Design Report

FEMA Approval of Perry Nuclear Power Plant Prompt Alert 07/17/2015

Siren System (PASS) Design Report Update

Procedures NOBP-LP-5018 Siren Testing and Maintenance 4

NOP-LP-5005 Siren Testing and Maintenance 1

71114.03 Corrective Action CR-2022-00532 ERO Unannounced Communication Test Results 1/22/22: 01/24/2022

Documents No Response Recorded for One On-Duty Individual

CR-2022-04357 Untimely Response for 5/23/22 ERO Scheduled 05/23/2022

Communication Test

CR-2022-08800 Off Duty Individual Did Not Respond to ERO Unannounced 11/16/2022

Communication Test

CR-2023-03481 On Duty ERO Member Did Not Respond to Weekly 04/25/2023

Notification Test

CR-2023-06141 Emergency Response Organization Notification System 08/07/2023

Inspection Type Designation Description or Title Revision or

Procedure Date

(ERONS) Weekly Notification Test Issue

Miscellaneous Emergency Response Organization Roster 08/29/2023

Quarterly Testing of Emergency Pager System Records 08/01/2021 -

08/31/2023

PNPP ERO On-Shift Staffing Analysis Report 1

Procedures NOP-LP-5006 Emergency Response Organization Training Program 7

NOP-LP-5503 Emergency Notifications 1

NOP-LP-5505 Facility Activation, Operation and Deactivation 1

PTI-GEN-P0003 Quarterly Testing of the Emergency Pager System 15

PYBP-ERS-0037 Notification of Key Plant Personnel 8

71114.05 Corrective Action CR-2022-04909 Inconsistencies in NOP-LP-5503, Emergency Notifications 06/16/2022

Documents procedure

CR-2022-08718 Backup Method for ERO Notification Failed Testing 11/14/2022

CR-2023-00828 ERO Duty Transfer Issue 02/06/2023

CR-2023-05038 Loss of Power to Plant Emergency and Fire Alarms 06/23/2023

CR-2023-05362 ERO Training Issue 07/06/2023

Miscellaneous Monthly Testing of Emergency Response Telephone 09/01/2021 -

Systems in Onsite Emergency Response Facilities 08/31/2023

(Completed Survey Records)

Emergency Operations Facility Equipment Checklists 09/01/2021 -

(Completed Survey Records) 08/31/2023

Operations Support Center Equipment Checklists 09/01/2021 -

(Completed Survey Records) 08/31/2023

Technical Support Center Equipment Checklists (Completed 09/01/2021 -

Survey Records) 08/31/2023

Letters of Agreement / Memorandums of Understanding with 09/01/2021 -

Agencies Supporting Emergency Preparedness 08/31/2023

Emergency Preparedness Drill and Exercise Reports 09/01/2021 -

(Sample) 08/31/2023

Emergency Response Organization Training and 09/21/2023

Qualification Records (Sample 15 records)

EP-0000 Emergency Plan for Perry Nuclear Power Plant 61

KLD TR-1228 Perry Nuclear Power Plant Development of Evacuation Time 05/09/2022

Estimates

Inspection Type Designation Description or Title Revision or

Procedure Date

KLD TR-1319 Perry Nuclear Power Plant 2023 Population Update Analysis 05/08/2023

MS-C-21-11-24 Quality Assurance Audit Report of Emergency 12/07/2021

Preparedness

MS-C-22-11-24 Quality Assurance Audit Report of Emergency 12/20/2022

Preparedness

Procedures PSI-0018 Maintenance and Inventory of Emergency Equipment 13

71114.06 Miscellaneous ERO tabletop 2023 3rd Quarter ERO Table - Top Drill TSC-EOF 8/3/2023 0

through 8/31/2023

71124.06 Corrective Action CR 2022-07529 MIDAS Software Calculation Deviation 10/07/2022

Documents CR 20223-03554 Elevated Nuclear Closed Cooling Radiation Monitor 04/27/2023

CR 2023-03569 Short Lived Gamma Activity Detected at NCC from RWCU 04/27/2023

B Pump

Corrective Action CR 2023-06377 NRC RP Inspection Identified: The Required ODCM Lower 08/16/2023

Documents Limit of Detection, LLD, Misapplied in the 2022 Annual

Resulting from Radioactive Effluent Release Report

Inspection CR-2023-06408 NRC Identified: SVI-D17-T5268 Does Not Include All 08/17/2023

Required ODCM Documentation

Miscellaneous 06-Sep-22-10013 Floor Drain Sample Tank Gamma Spectrum Analysis 09/06/2022

06-Sep-22-10014 Floor Drain Sample Tank Gamma Spectrum Analysis 09/06/2022

2103030021 MIDAS Report for February 2021 Monthly Summary of February

Maximum Individual Doses 2021

208310953 MIDAS Report for Nuclear Closed Cooling 10/02/2022

208310953 MIDAS Report for Release 22-001L 08/31/2022

209010057 MIDAS Report for Release 22-002L 09/01/2022

209081259 MIDAS Report for Liquid Discharge 22-012L 09/08/2022

28-Feb-21-10010 OGVP NG, MDS Gamma Spectrum Analysis 02/28/2021

31-Jan-22-10008 NCC Week 5 Composite Gamma Spectrum Analysis 01/31/2022

L-22-105 2021 Annual Radiological Effluent Release Report 04/27/2022

L-23-121 2022 Annual Radiological Effluent Release Report 04/26/2023

Procedures CHI-0053A Counting Gamma Spectroscopy Samples Using Apex 6

NOP-SS-3300 Records Management Program 19

SOI-D17 Airborne Radiation Monitoring System (Effluents) 16

Work Orders 200777498 SVI-D17T5268 Eff Smpl/Analysis & Dose 02/23/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

200777499 SVI-D17T5268 Eff Smpl/Analysis & Dose 03/29/2021

200814178 SVI-D17T5268 Eff Smpl/Analysis & Dose 03/02/2022

200892277 Liquid Radwaste Release Permit Package 09/06/2022

71151 Miscellaneous NRC Performance Indicator Data; Emergency 07/01/2022-

Preparedness - ERO Readiness 06/30/2023

NRC Performance Indicator Data; Emergency 07/01/2022-

Preparedness - Alert and Notification System Reliability 06/30/2023

NRC Emergency Preparedness - Drill/Exercise Performance; 07/01/2022-

Performance 06/30/2023

Indicator Data

71152A Corrective Action CR-2023-05037 Tritium Groundwater Readings Elevated 06/23/2023

Documents

71153 Corrective Action CR-2023-02103 Fuel Bundle Made Contact with Steam Dam 03/19/2023

Documents CR-2023-05607 Entered ONI-ZZZ-5 due to Containment Vessel Chiller A 07/18/2023

Refrigerant Leak

CR-2023-06215 Automatic Reactor SCRAM and MSIV Closure Following 08/10/2023

RPS Bus Shift from ALT to NORM B

Miscellaneous LER Low Pressure Core Spray Inoperable due to Loss of 06/27/2022

05000440/2022- Minimum Flow Valve

001-00

18