IR 05000440/2019004
| ML20030A575 | |
| Person / Time | |
|---|---|
| Site: | Perry  (NPF-058) |
| 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 | |
| Preceding documents: |
|
| Download: ML20030A575 (29) | |
Text
January 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:
Report Number:
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
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 Overspeed Reset Limit Switch Results in an Extension in USAR Described Test Frequency 71111.18 Open
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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.04) (1 Sample)
(1)
- Diesel generator rooms; and
- Emergency service water pump house
71111.04Q - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
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 Sample)
- (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) (5 Samples)
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.) (1 Sample)
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) (1 Sample)
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 Sample)
- (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 Sample)
- (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) (4 Samples)
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) (3 Samples)
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) (2 Samples)
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) (4 Samples)
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 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 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 Sample)
- (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 Sample)
- (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 Sample)
- (1) The inspectors evaluated the maintenance of the emergency preparedness program
RADIATION SAFETY
71124.02 - Occupational ALARA Planning and Controls
Radiological Work Planning (IP Section 02.01) (1 Sample)
The inspectors evaluated the licensees radiological work planning.
- (1) The inspectors reviewed the following 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:
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 Sample)
- (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 Sample)
- (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:
- (2) Review of plant aggregate risk assessment
INSPECTION RESULTS
Unresolved Item (Open)
Degraded Turbine Overspeed Reset Limit Switch Results in an Extension in USAR Described Test Frequency URI 05000440/2019004-01 71111.18
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 Secondary Containment Control Emergency Operating Procedure Entry 71152 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
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
ONI-ZZZ-1
Tornado or High Winds
Work Orders
200794255
Flood Mitigation Actions - ONI-ZZZ-1
71111.04Q Drawings
2-0641-00000
Residual Heat Removal System
KKK
2-0642-00000
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
2-0605-00000
Reactor Building Annulus Exhaust Gas Treatment
Y
2-0610-00000
Control Room HVAC and Emergency Recirculation System
Procedures
SVI-E12-T1182B
RHR B LPCI Valve Lineup Verification and System Venting
VLI-C41
Standby Liquid Control System
VLI-E12
Residual Heat Removal System
VLI-M15
Annulus Exhaust Gas Treatment System
VLI-M25/M26
Control Room HVAC and Emergency Recirculation System
VLI-P45
Emergency Service Water System
Corrective Action
Documents
CR 2019-03480
Valve Indicates Open Testable Check Valve
04/12/2019
Drawings
2-0631-00000
Reactor Core Isolation Cooling System
HH
Procedures
VLI-E51
Reactor Core Isolation Cooling System
71111.05Q Fire Plans
FPI-0CC
Control Complex
FPI-0EW
Emergency Service Water Pump House
FPI-0IB
Intermediate Building
FPI-1AB
Auxiliary Building Unit 1
FPI-1DG
Diesel Generator Building Hallway
Procedures
PAP-1910
Work Orders
200717072
Portable Fire Extinguishers Maintenance Inspection
05/09/2019
Calculations
IF-8
Flood Zone 21: Critical Volumes, Flood Heights, Flow Rates,
Flood and Alarm Chronology
JL-083
Flooding Analysis of CCB, IB, and FHB - Floor Elevation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
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
Procedures
ARI-H13-P970-
0001
Common Long Response Benchboard
ONI-R10
Loss of AC Power
Calculations
E22-042
Division 3 Emergency Diesel Generator Jacket Water Heat
Exchanger Performance Test
Work Orders
200645158
HPCS Diesel Generator Jacket Water Heat Exchanger
Performance Testing
06/04/2019
Calculations
E12-089
Required ESW Flow for the RHR HXs
E12-102
RHR System Heat Exchanger "B" Loop Performance Test
Evaluation
P42-039
Design Basis Heat Load & Required ESW Flow for the ECC
P42-051
Emergency Closed Cooling Heat Exchanger "B" Loop
Performance Test Evaluation
P45-044
Keepfill Check Valve Leak Rate/Standpipe Draindown Level
Corrective Action
Documents
CR-2011-91278
Results of ESW Related Diver Inspections (March 2011)
03/18/2011
CR-2016-09504
Emergency Service Water (ESW) Loop "C" Flow Rates
Degraded
08/03/2016
CR-2016-12106
High Pressure Core Spray Emergency Service Water Flow
in the Alert Low Range
10/10/2016
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
West Pump Bays
09/19/2017
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
Pump Bays and Forebay
09/14/2018
Corrective Action
Documents
Resulting from
Inspection
CR-2019-10102
2019 Triennial Heat Sink Inspection: Drawing 21-0016-
00001 Rev. B has Incorrect Work Order Listed
2/03/2019
CR-2019-10124
2019 Triennial Heat Sink Inspection: Housekeeping
Deficiencies Identified in RHR B HX Room 599' and RHR B
2/04/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Pump Room 574'
CR-2019-10148
2019 Triennial Heat Sink Inspection: Silt Data not Recorded
in Order 200725355 for Intake and Discharge Structures in
the Lake
2/05/2019
CR-2019-10155
2019 Triennial Heat Sink Inspection: CR not Written on Silt
Buildup in Forebay at Time of Diver Inspection for WO 200474126
2/05/2019
CR-2019-10165
2019 Triennial Heat Sink Inspection: Global EMARP-0011
Concerns
2/05/2019
CR-2019-10175
2019 NRC Triennial Heat Sink Inspection, Documentation
for Heat Exchanger Bracing Adequacy can not be Located
2/06/2019
CR-2019-10185
2019 Triennial Heat Sink Inspection: Inadequate Technical
Justification for Deferral of RHR B Eddy Current and Visual
Inspections
2/06/2019
CR-2019-10233
2019 Triennial Heat Sink Inspection: Roll Up CR
2/09/2019
Drawings
015-0002
Emergency Service Water Pump House Plans and
Elevations
F
21-0016-00002
Residual Heat Removal Heat Exchanger 1E12B001B Tube
Sheet Drawing
A
2-0140-00002
Emergency Closed Cooling Heat Exchanger Loop "B"
(1P42B0001B) Tube Sheet Drawing
A
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
Evaluations
Spec-625
Seismic Qualification Report for Emergency Closed Cooling
Water Heat Exchangers
Miscellaneous
600925874
Revision Notification for First Time Performance -
1E12B0001B/D
04/27/2015
601199944
Revision Notification for Performing PM Less Often -
1E12B0001B
2/31/2018
DI-220
Perry Nuclear Power Plant RHR Heat Exchanger
Performance Program
EMARP-0011
North and West Intake Structures and Discharge Structure
11/13/2017
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Emergency
Monitoring
Program Report
Sheet
Inspections
EMARP-0011-
Emergency
Monitoring
Program Report
Sheet
Visual Inspection of Emergency Service Water
Pump/Forebay and ESW Normal/Alternate Tunnel
11/27/2017
Procedures
D-726-201
Intake Tunnel Plan and Profile
E
EMARP-0011
Emergency Service Water System Monitoring Program
IOI-0015
Seasonal Variations
ONI-P40
ESW or SW Sunction Path Blockage
ONI-P41
Loss of Service Water
PTI-GEN-P0024
Mussel Treatment
PTI-P45-P0004
Emergency Service Water Manual Valve Operability Test
PTI-P45-P0009A
ESW Forebay Low Level Functional for P45-D004A
SOI-E12
Residual Heat Removal System
SOI-P42
Emergency Closed Cooling System
SOI-P45/P49
Section 7.2
Emergency Service Water and Screen Wash Systems
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
Keep Fill Line
2/27/2007
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
Performance Testing
11/09/2015
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
200617665
Inspect East/West Pump Bay and Alternate Intake Tunnel
2/05/2018
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
Test
08/30/2019
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
04/06/1999
Miscellaneous
Perry Annual Licensed Operator Requalification Program
Summary Results for 2019
2/16/2019
71111.11Q Miscellaneous
Evolution Specific
Reactivity Plan
December 2019 Power Suppression Test
OT-3070 RP2E
Simulator Scenario Guide
OT-3070-005-
RP1B
Simulator Scenario Guide
Corrective Action
Documents
CR 2018-10660
HPCS Agastat TD Relay Outside Times Permitted but
Within Allowable TS Times
2/04/2018
CR 2018-11210
AEGTS Train A Flow Oscillations
2/24/2018
CR 2019-02590
Valve PMT Stroke Issue - Contact Problem on Switch
1C61S0080
03/21/2019
CR 2019-05821
Diesel Procedure Step Performed Out of Order
07/09/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 2019-09208
RHR B Containment Spray 1st Isolation Valve Lost all
Position Indication
11/01/2019
CR 2019-09212
Combustible Gas Mixing Compressor B Trip on Thermal
Overloads
11/01/2019
CR 2019-09358
10CFR21-2017: EMD Fuel Injector - Seized Plunger and
11/05/2019
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
Documents
Resulting from
Inspection
CR 2019-10361
Maintenance Rule Evaluation Required on 1E12F0024B and
2/13/2019
CR 2019-10375
NRC Identified: Infantile Failure of 1C61S0080 - November
2018 to March 2019
2/13/2019
CR 2019-10523
NRC Identified: CR 2019-09212 Maintenance Rule
Evaluation Conclusion was Questioned
2/19/2019
Drawings
208-0039-00004
Remote Shutdown System Division 2 Switch Development
and Locations
L
208-0055-00025
Containment Spray Valve - F028B
Y
208-0055-00036
V
208-0206-00037
4.16KV Bus EH13 Diesel Brkr. EH1301
Z
Miscellaneous
A Miniature Instrument & Control Switch for Power Industry
Applications (ElectroSwitch)
11/05/1984
Maintenance Rule
System Basis
Document System
E_C
System Name: Electrical Component Group - Indication
Notification
601219728
BLC2000-721 Control Unit (Blind Controller) Qualification
Report
PY-M51-F-1610
Combustible Gas Control Function Basis Document
Procedures
GEI-0046
Division 3 125Vdc Relays
GEI-0100
Maintenance and Calibration of Power Relay 12ICW52B
NOP-ER-3004
FENOC Maintenance Rule Program
PYBP-PES-0001
Maintenance Rule Reference Guide
SVI-C61-T1202
Remote Shutdown Control Test - Division 2 RHR, ECC, and
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SVI-M51-T2003-B
Combustible Gas Mixing System B Operability Test
Work Orders
200341689
Inspect Remote Shutdown Switch 1C61A-S80 as Extent of
Condition for CR 08-46021
11/14/2018
200516341
Relay ICW52B 32B EH13 Bus Reverse Power
2/17/2018
200701831
PY-1E2207038 Cal Check Agastat E7000 TD Relay
05/06/2019
200713648
Perform Static MOV [Motor Operated Valve] Test RHR 'B'
Test VLV [Valve] to Supr [Suppression] Pool
03/21/2019
200730436
Replace PY-1M15R0060B-1 Annulus Differential Pressure
Controller B
200752416
PY-1E2207032 - Calibrate Agastat E7000 DC TD Relay
05/06/2019
200775158
Troubleshoot Cause of AEGTS Train A Flow Oscillations
200775159
Replace Control Unit
200775160
Bailey 721 Controller Non-Safety Stock Code 90895255 to
be Dedicated to Allow Use as Commercial Grade Stock
Code 100027602
200783496
Post Maintenance Testing of Valve 1E12F0024B per Order
200713648 Identified that the Valve would not Stroke Closed
03/21/2019
200804189
While Stroking Open E12F028B for the Div 2 Combustible
Gas Mixing Compressor Run, Valve E12-F028B Lost All
Indication
11/01/2019
200804866
Div 3 DG Tripped on Reverse Power
11/06/2019
Combustible Gas Mixing System Compressor B Tripped on
Thermal Overloads
11/04/2019
Corrective Action
Documents
CR2019-09378
Div 3DG Tripped on Reverse Power
11/05/2019
Procedures
NOP-OP-1007
Risk Management
SVI-E22-T1319
Diesel Generator Start and Load Division 3
Work Orders
200542705
Perform Static MOV Test for RHR C Minimum Flow Valve
200574288
Control Room HVAC
200749548
Perform Static MOV Test for the RHR C Suppression Pool
Suction Valve
200804866
Div 3 DG Tripped on Reverse Power
11/06/2019
Corrective Action
Documents
CR-2019-09208
RHR B Containment Spray 1st Isolation Valve Lost All
Position Indication
11/01/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2019-09228
Inability to Select Control Rods
11/01/2019
Drawings
208-0055-00025
Residual Heat Removal System, Containment Spray Valve -
F028B
Y
Procedures
NOP-OP-1009
Operability Determinations and Functionality Assessments
SOI-C11(RCIS)
Rod Control and Information System
Calculations
H-1G33-112
Design Verification Record of 1G33-Reactor Water Cleanup
System
Corrective Action
Documents
CR 2015-08036
PFA [Prompt Functionality Assessment] Needed for Site
Flooding Issues
07/08/2015
CR 2019-03298
Reactor Water Cleanup Drain Valves (G33F066) Leaking By
04/08/2019
Corrective Action
Documents
Resulting from
Inspection
CR 2019-10368
Discrepancy Between Intermediate Building Roof Drawing
and Calculation Live Load
2/13/2019
Engineering
Changes
19-0178-001
Interim Flooding Protection for Plant Structures - Ground
Level Vulnerabilities
19-0178-002
Temporary Roof Protection for Flood Mitigation
ECP No. 19-0091-
000
Engineering Change Package Design Report to Change the
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
Evaluations
NORM-LP-7322
Perry Nuclear Power Plant Flooding Focused Evaluation
Report
11/22/2019
Notification
601216082
Evaluate Kill of Downstream Pipe/Cap
04/09/2019
Miscellaneous
TCC-1-G33-LR-
2
Temporary Configuration Change that Installs a Line Kill
Procedures
ONI-ZZZ-1
Tornado or High Winds
PAP-0204
Housekeeping/Cleanliness Control Program
Work Orders
200794255
Flood Mitigation Actions - ONI-ZZZ-1
200799298
Stage Sandbags at Gross Openings (Vents, Louvres,
Penetrations) and Roof Door Openings
09/17/2019
Penetration P131 Outboard Test Connection Second
04/16/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Isolation Valve
Drawings
208-0055-00025
Residual Heat Removal System, Containment Spray Valve -
F028B
Y
Procedures
SVI-E12-T2002
RHR B Pump and Valve Operability Test
Work Orders
200290508
Replacing the 1C71K051C Relay for Scram Discharge
Volume Level Hi
11/07/2019
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
Miscellaneous
FEMA Approval Letter for Perry Nuclear Power Plant Prompt
Alert Siren System (PASS) Design Report Update, Revision
07/17/2015
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
Sirens Installation, Operation, and Service Manual
A5 0017
Tempest T-112/ T-121 Omni-Directional Siren Installation,
Operation, Maintenance and Parts Manual
H
Perry EPZ Siren PI Test Schedules
09/01/2017-
2/31/2019
Procedures
Perry Nuclear Power Plant Prompt Alert Siren System
(PASS) Design Report
NOBP-LP-5018
FENOC Siren Testing and Maintenance
NOP-LP-5005
FENOC Siren Testing and Maintenance
PTI-GEN-P0003
Quarterly Testing of the Emergency Pager System
Corrective Action
Documents
CR-2018-07283
ERO Drill - During 8/15/2018 Drill Objective B.1, Notification
of ERO Personnel Not Met
08/16/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR-2019-04530
ERO Drill - Objective B.1 Not Met - ERO Not Notified in
Minutes
05/20/2019
Miscellaneous
Technical Support Center Equipment Checklists (Completed
Survey Records)
2/01/2018 -
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
(completed survey records);
2/01/2018 -
09/30/2019
Procedures
NOP-LP-5006
Emergency Response Organization Training Program
PYBP-ERS-0037
Notification of Key Plant Personnel
Miscellaneous
Perry Station 10 CFR 50.54(q) Evaluator Qualification and
Training Records Spreadsheet
06/25/2019
PY-2019-013-00
CFR 50.54(q)2
Analysis
Emergency Plan Change - Public Information Response
Team Relocation
05/22/2019
PY-2019-013-00
CFR 50.54(q)3
Screen/Evaluation
Emergency Plan Change - Public Information Team
Relocation
06/03/2019
PY-2019-06-00 10
CFR 50.54(q)2
Analysis
Emergency Plan Change - Elimination of EOF Plant
Operations Assistant Position
04/30/2019
PY-2019-06-00
CFR 50.54(q)3
Screen/Evaluation
Emergency Plan Change - Elimination of EOF Plant
Operations Assistant Position
04/30/2019
PY-2019-09-00 10
CFR 50.54(q)2
Analysis
Emergency Plan Revision 53 - Editorial Changes
05/22/2019
PY-2019-09-00 10
CFR 50.54(q)3
Screen/Evaluation
Emergency Plan Revision 53 - Editorial Changes
05/22/2019
Procedures
Emergency Plan for Perry Nuclear Power Plant
Emergency Plan for Perry Nuclear Power Plant
NOP-LP-5002
Evaluation of Changes to Emergency Plans and Supporting
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents 10 CFR 50.54(q)
Corrective Action
Documents
CR-2017-11819
Lake County Letter of Agreement was Expired for Two
Months
11/30/2017
CR-2018-05456
ERO Drill 6-6-18: Objective F.6 Not Met - Release Start
Time
06/12/2018
CR-2018-07292
ERO Drill: Objective C1 - Not Met, Failure to Notify Offsite
Agencies within 15 Minutes
08/17/2018
CR-2018-08213
ERO Exercise - Objective U11 and U12 Not Met - Dose
Assessment
09/18/2018
CR-2018-08245
ERO Exercise - Objective C.2 Demonstrate Ability to Notify
NRC within One Hour Not Met
09/19/2018
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
News Statement
09/20/2018
CR-2018-09836
10/18/18 EOF General Emergency Classification Made
Using Alternate EAL
11/06/2018
CR-2019-00834
Negative Trend Noted in Drill & Exercise Performance for
the Month of January 2019
01/28/2019
CR-2019-04480
ERO Drill - Objective E.6 Was Not Met During 5/15/2019
Integrated Drill
05/17/2019
CR-2019-04730
Protective Action Flow Chart Recommendation
05/18/2019
Corrective Action
Documents
Resulting from
Inspection
CR-2019-08255
NRC EPlan Inspection: NOBP-LP-5018 "FENOC Siren
Testing and Maintenance" Scope of Review Discrepancy
10/09/2019
Miscellaneous
Letters of Agreement with Agencies Supporting Emergency
Preparedness (Sample)
09/01/2017 -
09/30/2019
Emergency Preparedness Drill and Exercise Records
(Sample)
09/01/2017-
09/30/2019
Emergency Response Organization Training and
Qualification Records (Sample)
10/10/2019
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
Estimates
10/01/2012
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
KLD TR-997
Perry Nuclear Power Plant Evacuation Time Estimate
Sensitivity Study Due to the Vrooman Road Closure
05/04/2018
Procedures
Emergency Plan for Perry Nuclear Power Plant
PYBP-ERS-0003
Emergency Plan Facility/ Equipment Inventory Checklists
Self-Assessments MS-C-17-11-24
Fleet Oversight Audit Report of Emergency Preparedness
2/08/2017
MS-C-18-11-24
Fleet Oversight Audit Report of Emergency Preparedness
2/07/2018
ALARA Plans
190522
1R17 Bioshield ISI Activities
190903
1R17 In Vessel Inspection Activities
190904
1R17 Reactor Reassembly Activities
0-4
Corrective Action
Documents
CR 2019-02298
Hydraulic Oil Spill into Refueling Cavity
03/13/2019
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
Draindown
04/08/2019
Miscellaneous
1R17 Outage Alara Report
06/12/2019
190522
1R17 Bioshield ISI Work in Progress Reviews
190522
1R17 Bioshield ISI Activities Alara Post Job Review
08/19/2019
190903
1R17 In Vessel Inspection Activities Work in Progress
Reviews
190903
1R17 In Vessel Inspection Activities Alara Post Job Review
08/20/2019
190904
1R17 Reactor Reassembly Activities Work in Progress
Reviews
0-4
190904
1R17 Alara Post Job Review
07/24/2019
Procedures
NOP-OP-4107
Radiation Work Permits
Radiation Work
Permits (RWPs)
190522
1R17 Bioshield ISI Activities
190903
1R17 In Vessel Inspection Activities
190904
1RF17 Reactor Reassembly Activities
0-4
71151
Miscellaneous
NRC Performance Indicator Data; Emergency Preparedness
- Drill/Exercise Performance (DEP)
07/01/2018 -
06/30/2018
NRC Performance Indicator Data; Emergency Preparedness
- ERO Readiness
07/01/2018 -
06/30/2019
NRC Performance Indicator Data; Emergency Preparedness
- Alert and Notification System Reliability
07/01/2018 -
06/30/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NOBP-LP-4012-
Reactor Coolant System Leakage
10/01/2018 -
09/30/2019
Procedures
NOBP-LP-4012
NRC Performance Indicators
Corrective Action
Documents
CR 2018-08732
2018 NRC Fire Protection Inspection - Obstructed Sprinkler
Head on CC-574 Overhead Suppression System
10/04/2018
CR 2018-08805
Motor Fire Pump Pin Hole Leak Downstream of Pump Relief
Valve
10/07/2018
CR 2019-01465
Packing Leak Has Returned on RHR & RCIC Steam Supply
Second Drain Isolation Valve
2/18/2019
CR 2019-05479
Packing Leak on RHR & RCIC Steam Supply Second Drain
Isolation Valve
06/25/2019
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-
P54-P0064A
10/09/2019
CR 2019-09579
Three Clogged Nozzles Discovered During Interbus
Transformer LH2A Deluge Testing per PTI-P54-P0065A
11/12/2019
Drawings17-936 Sh37
Interbus Transformer Plan View
05/30/1980
Procedures
NOBP-OP-0012
Operator Work-Arounds, Burdens, Control Room
Deficiencies and Operations Aggregate Assessment
NOP-LP-2001
Corrective Action Program
NOP-OP-1009
Operability Determinations and Functionality Assessments
NOP-OP-1010
Operational Decision-Making
PAP-1910
PTI-P54-P0064A
Water Spray Flow Test for Unit 1 Interbus Transformer A
SOI-P54 (WTR)
Fire Protection System - Water
Work Orders
200694434
PTI-P54P0065A LH-2-A Spray Flow Test
11/11/2019