IR 05000440/2024501
| ML25028A363 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/29/2025 |
| From: | Michael Ziolkowski NRC/RGN-III/DRSS |
| To: | Penfield R Vistra Operations Company |
| References | |
| IR 2024501 | |
| Download: ML25028A363 (1) | |
Text
SUBJECT:
PERRY NUCLEAR POWER PLANT - EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000440/2024501
Dear Rod Penfield:
On December 18, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No NRC-identified or self-revealing findings were identified during this inspection.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. 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.
January 29, 2025 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, Michael E. Ziolkowski, Chief Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security Docket No. 05000440 License No. NPF-58
Enclosure:
As stated
Inspection Report
Docket Number:
05000440
License Number:
Report Number:
Enterprise Identifier:
I-2024-501-0014
Licensee:
Vistra Operations Company, LLC
Facility:
Perry Nuclear Power Plant
Location:
Perry, OH
Inspection Dates:
September 23, 2024 to December 18, 2024
Inspectors:
J. Cassidy, Sr Health Physicist
J. Kutlesa, Sr Emergency Preparedness Inspector
T. Ospino, Sr Project Engineer
J. Steward, Sr Resident Inspector
J. Nance, Operations Engineer
Approved By:
Michael E. Ziolkowski, Chief
Security, Emergency Preparedness, and Incident Response Branch
Division of Radiological Safety and Security
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an emergency preparedness biennial exercise 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. A licensee-identified non-cited violation is documented in report section: 71114.0
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71114.01 - Exercise Evaluation
Inspection Review (IP Section 02.01-02.11) (1 Sample)
- (1) The inspectors observed the biennial exercise and evaluated emergency plan performance on September 24, 2024. The exercise scenario simulated an event at the Perry Nuclear Power Plant that initiated with the declaration and notification of an Alert in response to a condensate resin trap failure releasing resin into the condensate system and plugging fuel channels resulting in fuel clad damage. The scenario conditions simulated the escalation of the significance of the event, requiring the declaration of a General Emergency which was communicated to the required state and local government agencies.
71114.08 - Exercise Evaluation - Scenario Review
Inspection Review (IP Section 02.01 - 02.04) (1 Sample)
- (1) The inspectors reviewed and evaluated the proposed scenario for biennial emergency plan exercise on August 21,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (DEP) Sample (IP Section 02.12)===
- (1) July 1, 2023 through September 30, 2024 EP02: Emergency Response Organization (ERO) Drill Participation (IP Section 02.13) (1 Sample)
- (1) July 1, 2023 through September 30, 2024 EP03: Alert And Notification System (ANS) Reliability Sample (IP Section 02.14) (1 Sample)
- (1) July 1, 2023 through September 30,
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71114.01 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: 10 CFR Part 50.47(b)(2) states, in part, that on-shift facility licensee responsibilities for emergency response are adequately staffed to provide initial facility accident response in key functional areas is maintained at all times. Contrary to the above, from July 4, 2023 through August 22, 2024 the licensee failed to maintain on-shift facility licensee responsibilities for emergency response that were adequately staffed to provide initial facility accident response in key functional areas at all times. Specifically, on several occasions during this timeframe, the licensee, did not have an Emergency Coordinator (EC) trained shift manager (SM) on-shift. The Perry Emergency Plan requires that an individual having the authority and the responsibility to initiate any emergency actions within the provisions of the plan, including providing protective action recommendations to offsite authorities is onsite at all times. This individual is the Shift Manager, who initially assumes the position of Emergency Coordinator when an emergency occurs and is in command of the ERO and remains in that position until relieved by the Emergency Coordinator in the Technical Support Center.
Significance/Severity: Green. The inspectors determined that the violation was more than minor because it was associated with the ERO Performance attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that the licensee can implement adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the licensees failure to maintain adequate staffing to provide initial facility accident response in key functional areas is maintained at all times reduced the licensees capabilities to respond to an emergency. The inspectors assessed the significance of the finding using IMC 0609 Appendix B, Emergency Preparedness SDP. The inspectors determined that this finding is of very low safety significance (Green), consistent with table 5.2-1 - significance examples for 50.47(b)(2) and is an example of a staffing process that would allow two or more shifts to go below E-plan minimum staffing requirements within 30 days from July 4, 2023 through August 22, 2024. Section 5.0.3 (Significance Determination) states that the examples provided for each Planning Standard Function are not intended to be all-inclusive or all exclusive and extenuating circumstances may need to be considered. Since the SM had successfully completed numerous EP related training, simulations, and DEP opportunities the inspectors accounted for this mitigating information in determining the significance of the violation.
Corrective Actions: The licensee entered the issue into their corrective action program and initiated an action in condition report CR-2024-06756 to verify all currently qualified Shift Managers are qualified as Emergency Coordinators. All 15 qualified Shift Managers did have the Emergency Coordinator Fleet qualifications assigned and complete. The licensee also verified that all SROs that fill the Unit Supervisor Position also have the Emergency Coordinator position assigned and are qualified to fulfil this role which builds bench strength in the Emergency Coordinator Position on shift if the Shift Manager becomes incapacitated.
Corrective Action References: CR-2024-06756
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On December 18, 2024, the inspectors presented the Emergency Preparedness Biennial Exercise inspection results to Rod Penfield and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
CR-2024-06756
EPLAN Emergency Coordinator Curricula not added to a
Shift Manager when promoted to the new position.
08/22/2024
Procedures
EP 0000
Emergency Plan for Perry Nuclear Power Plant
Rev 63
Miscellaneous
Perry Nuclear Power Plant Emergency Preparedness
Evaluated Exercise Manual
07/23/2024
71151
Procedures
NOBP-LP-4012
Industry Reporting and Information System (IRIS) for DEP,
07/01/2023 -
09/30/2024