IR 05000440/2024004
| ML25042A066 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/13/2025 |
| From: | Robert Ruiz NRC/RGN-III/DORS/RPB2 |
| To: | Penfield R Vistra Operations Company |
| References | |
| IR 2024004 | |
| Download: ML25042A066 (1) | |
Text
SUBJECT:
PERRY NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000440/2024004
Dear Rod Penfield:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Perry Nuclear Power Plant. On January 15, 2025, 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.
Three findings of very low safety significance (Green) are documented in this report. Three of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Perry Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Perry Nuclear Power Plant.
February 13, 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, Robert Ruiz, Chief Reactor Projects Branch 1 Division of Operating Reactor Safety Docket No. 05000440 License No. NPF-58
Enclosure:
As stated
Inspection Report
Docket Number:
05000440
License Number:
Report Number:
Enterprise Identifier:
I-2024-004-0062
Licensee:
Vistra Operations Company, LLC
Facility:
Perry Nuclear Power Plant
Location:
Perry, OH
Inspection Dates:
October 01, 2024 to December 31, 2024
Inspectors:
J. Beavers, Senior Resident Inspector
J. Kutlesa, Senior Emergency Preparedness Inspector
V. Myers, Senior Health Physicist
J. Nance, Operations Engineer
T. Ospino, Senior Project Engineer
G. Roach, Senior Operations Engineer
Approved By:
Robert Ruiz, Chief
Reactor Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Perry Nuclear Power Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Store Radioactive Waste Appropriately Results in Contamination Spill in an Outside Storage Yard Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000440/2024004-01 Open/Closed
[H.3] - Change Management 71124.08 A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 20.1406,
Minimization of Contamination, was identified when the licensee failed to follow radioactive waste handling and storage procedures, resulting in a contamination spill in an outside storage yard. This was a failure to conduct operations as described by stations radiation protection program necessary to minimize residual radioactivity required by 10 CFR 20.1406(c).
LER 2024-004-00 for Perry Nuclear Power Plant, Division 3 Diesel Generator Inoperable due to Low Output Voltage Resulting in Loss of Safety Function Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2024004-02 Open/Closed None (NPP)71153 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Technical Specification (TS) Section 5.4.1.a, Procedures, when the licensee failed to perform preventative maintenance on the division 3 emergency diesel generator system's voltage regulator potentiometers, which resulted in an unplanned inoperability of the system.
Failure to Return Division 3 Emergency Diesel Generator to Service Resulting in Event Notification 57444 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2024004-03 Open/Closed
[H.5] - Work Management 71153 A Green finding and associated Non-cited Violation (NCV) of Technical Specification (TS)
Section TS 3.8.1, AC Sources Operating, was self-revealed when the licensee failed to identify the division 3 diesel generator (DG) was not restored properly to service and therefore failed to perform the required surveillance and actions for an inoperable division 3 emergency diesel generator.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000440/2024-004-00 LER 2024-004-00 for Perry Nuclear Power Plant,
Division 3 Diesel Generator Inoperable due to Low Output Voltage Resulting in Loss of Safety Function 71153 Closed
PLANT STATUS
Unit 1 started the inspection period at or near rated thermal power. On the weekend of December 27, 2024, the plant reduced power for planned non-safety system maintenance and returned to full power on December 31,
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
Integrated Inspection Report 05000440/2024002 credited an inspection sample of summer readiness to IP 71111.01 Section 03.02 rather than 03.01. The Reactor Program System has been updated to properly account for that inspection sample under IP Section 03.01.
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal cold temperatures for the following systems:
- building heating and ventilation, power transformers, and protected area radwaste storage on November 2, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)remote shutdown system on October 25, 2024 (2)residual heat removal 'C' train on November 8, 2024 (3)standby liquid control 'B' train on November 14, 2024
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)fuel handling building on October 24, 2024 (2)essential service water and service water buildings on November 13, 2024 (3)division 2 emergency diesel generator room on December 16 and 17, 2024 (4)division 3 emergency diesel generator room on December 16 and 17, 2024 (5)service building 604' on December 16 through 19, 2024 (6)service building 620' on December 16 through 19, 2024 (7)service building 640' on December 16 through 19, 2024 (8)service building 654' on December 16 through 19, 2024
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) residual heat removal heat exchangers 'B' and 'D' on November 19, 2024
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 annual operating examination and biennial written examination administered between September 30, 2024, and December 6, 2024.
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
- (1) Biennial Requalification Written Examinations The inspectors evaluated the quality of the licensed operator biennial requalification written examination administered on November 21, 2024.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test administered on November 19 and 20, 2024.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
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 control room crew on division 2 diesel generator outage activities the week ending on December 13, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated annual simulator requalification exam on October 2, 2024.
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)planned maintenance down power to 10% and generator separation from grid on December 27, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)functionality assessment of 'A' reactor recirculating pump motor cooler leakage (2)functionality assessment of diesel driven fire pump (3)functionality assessment of the plant computer and emergency response data system (4)operability assessment of division 3 emergency diesel generator
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 Sample)
(1)division 3 emergency diesel generator post-maintenance repair on October 31, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1)high pressure core spray integrated test from November 5 through 7, 2024
Reactor Coolant System Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1)reactor coolant system leakage through December 2024
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated the following submitted Emergency Action Level and Emergency Plan changes.
- Emergency Plan for Perry Nuclear Power Plant, Revision 62
- PY-2024-002-00, 10 CFR 50.54(q) Analysis for Revision 62 to the Emergency Plan dated March 4, 2024
- KLD TR - 1407, Perry Nuclear Power Plant 2024 Population Update Analysis of May 7, 2024
- PSI-0019, Emergency Action Level (EAL) Bases Document, Revision 23 This evaluation does not constitute NRC approval.
RADIATION SAFETY
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling,
Storage, & Transportation
Radioactive Material Storage (IP Section 03.01)
The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:
- (1) Material stored in the On-Site Storage Container (OSSC) Yard
- (2) Material stored in the Waste Abatement and Reclamation Facility
- (3) Material stored in the radioactive waste building truck bay area
Radioactive Waste System Walkdown (IP Section 03.02) (1 Sample)
The inspectors walked down the following accessible portions of the solid radioactive waste systems and evaluated system configuration and functionality:
- (1) Avantech processing equipment
Waste Characterization and Classification (IP Section 03.03) (2 Samples)
The inspectors evaluated the following characterization and classification of radioactive waste:
- (1) Part 61 analysis for shipment 23-3053
- (2) Part 61 analysis for shipment 24-1016
Shipping Records (IP Section 03.05) (3 Samples)
- (1) Shipment 24-1016; LSA-II
- (2) Shipment 24-1010; LSA-II
- (3) Shipment 23-3025; Type A
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===
- (1) July 1, 2023 through September 30, 2024 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) July 1, 2023 through September 30, 2024
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)radioactive storage container leak in outside radiological controlled storage area on October 14, 2024
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)
- (1) The inspectors evaluated event notification 57444, division 3 emergency diesel generator inoperable due to starting air issue, on November 16, 2024.
Event Report (IP Section 03.02) (1 Sample)
The inspectors evaluated the following licensee event reports (LERs):
- (1) LER 05000440/2024-004-00, Perry Nuclear Power Plant, Division 3 Diesel Generator Inoperable due to Low Output Voltage Resulting in Loss of Safety Function (ADAMS Accession No. ML24354A144). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section 71153. This LER is Closed.
INSPECTION RESULTS
Failure to Store Radioactive Waste Appropriately Results in Contamination Spill in an Outside Storage Yard Cornerstone Significance Cross-Cutting Aspect Report Section Public Radiation Safety Green NCV 05000440/2024004-01 Open/Closed
[H.3] - Change Management 71124.08 A self-revealed finding of very low safety significance (Green) and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 20.1406, Minimization of Contamination, was identified when the licensee failed to follow radioactive waste handling and storage procedures, resulting in a contamination spill in an outside storage yard. This was a failure to conduct operations as described by stations radiation protection program necessary to minimize residual radioactivity required by 10 CFR 20.1406(c).
Description:
What was Found On October 14, 2024, radiation protection workers identified that the lid to a top loaded radioactive waste shielding container was askew and using a skid loader, pushed the lid back into position. When this occurred, they noticed that about five gallons of water spilled out of the top of the shielding container. This shielding container was being stored in an outside radioactive material storage yard called the On-Site Storage Container (OSSC) yard.
Follow-up gamma isotopic surveys of the water in the container, the outside of the container, and soil samples in the area confirmed that the water that spilled was contaminated with Co-60 and Mn-54. The inspectors reviewed the circumstances that led to this event, which are described below.
Initial Use In 2016, the licensee purchased two Solids Collection Filters (SCFs) for reactor cavity water cleanup in future refueling outages. This was the first time this type of filtration system was used at Perry. The SCF is manufactured such that the filters are permanently installed in a steel liner, which has a lid that can be installed after use. The licensee also purchased a radiation shielding container that the SCF can be placed in to reduce radiation levels around the SCF. This shielding container is loaded from the top and has a lid that is installed after the SCF is placed inside. The individuals involved in the purchase of these shielding containers understood that the shields were not rain tight and not intended for outdoor use without a rain cover. The licensee did not purchase the rain covers in the purchase as they did not anticipate these containers would be stored outside.
For reference, two pictures are provided below. One picture shows an unused SCF liner (blue container) being lowered into the radiation shielding container. The SCF liner contains the filter system and has an opening on top where the liner lid can be installed. The radiation shielding container also has a lid that can be set on top and bolted into place once the SCF liner is placed inside. A picture showing how the SCF liner and shielding container were stored after use is also provided.
When in use for reactor cavity water cleanup, the SCF and shielding container are located on the refuel floor inside containment and reactor cavity water is pumped into the system for filtration and then returned to the reactor cavity. Once the filters are spent (used up), the shielding container, with the SCF inside, is removed from the refuel floor. One SCF was used for the refueling outages in in the spring of 2017 and 2019 and remained on the refuel floor until the spring of 2021, when it was to be moved out and replaced with a new SCF.
In February 2021, the site performed an inspection of the shielding container for the new SCF that would be going into containment to replace the spent SCF. This shielding container had been stored outside and the inspection identified that the lid was askew and that the probable cause was the presence of water in the shielding container and freezing temperatures. A condition report was generated to document the observation and recommended actions included moving the shielding container to a warmer location to thaw and then performing an inspection of the container. The inspectors reviewed the work order and logs associated with the follow-up inspection of the shielding container, which included the need to pump rainwater out of the shielding container, replacement of damaged gaskets, and repairs to damaged bolt holes. The site identified the issue and corrected it for the new shielding container; however, as described below, the site did not fully evaluate the information to incorporate this knowledge with respect to the spent SCFs shielding container.
Initial Storage in On-Site Storage Container Yard In March 2021, the site removed the spent SCF and its shielding container from the refuel floor. Typically, a liner with spent filters would be moved to the truck bay in the radioactive waste building where it is dewatered and, using the installed crane, moved to a shielded vault designed for liner storage. These liners are typically stored in this vault without the liner lids installed until the liner is again craned over to the truck bay area and placed into a shipping container for shipment. It is at this time, that the liner lid would be installed. The normal process of storing a liner inside the radioactive waste building could not be followed with the SCF liner as the rigging setup for this liner is different than the sites standard liners and the crane did not have the clearance needed to move the liner into the storage vault. As such, the licensee installed the shielding container lid and moved the liner and shielding container to the OSSC yard for storage.
The OSSC yard is an outside storage area that is designed to store dry radioactive waste in sealed containers and is not used for processing waste. As such, the procedures and controls related to this area are focused on periodically inspecting containers for signs of degradation and verifying external radiation levels are maintained below regulatory limits. This area is a fenced in area that is posted for radiological conditions and is locked when not being accessed by personnel. The ground consists mostly of gravel with some concrete slabs and has a storm drain system that runs underneath the area.
Procedure RPI-1301, which governs radioactive material storage and control, contains criteria for storing radioactive waste in the OSSC yard. Section 4.2.1 requires that liners containing material with contact radiation levels equal to or greater than 200 mR/hr be packaged into an OSSC. A radiological survey from October 6, 2021, shows dose rates of 10,500 mrem/hr. This dose rate is taken at the surface of the SCF liner prior to putting the radiation shielding container lid on and is not accessible to people while in storage. General area dose rates outside of the radiation shield were less than 15 mrem/hr. Section 4.2.2 lists two approved models of OSSCs and requires that if other models are used, they be evaluated for compliance with GL 81-38, Storage of Low-level Radioactive Wastes at Power Reactor Sites, prior to use. The shielding container was not one of the approved OSSCs and this evaluation was not completed for the shielding container prior to use, as the site did not recognize the need for this liner to be stored in an OSSC. Section 4.2.2 also states that waste not placed in an OSSC shall be stored in a certified closed strong tight metal container or certified sealand container. As the site did not recognize the need for the SCF to go into an OSSC, this is the criteria the site thought was applicable. However, the site did not verify the shielding container was certified as a strong tight container (weatherproof). In addition, section 4.2.2 states that containers of wet waste materials shall be dewatered in accordance with the Process Control Program (PCP) prior to being placed in storage. The SCF was not dewatered in accordance with the PCP prior to being stored in the OSSC yard.
Dewatering Inside Plant In October 2021, the site moved the SCF liner and shielding container from the OSSC yard into the truck bay of the radioactive waste building to perform dewatering prior to risk from freezing temperatures outside. At this time, the lid of the shielding container is removed to gain access to the SCF liner inside for dewatering. Logs from this time indicate that water was seen on top of the liner, indicating there may be water in the area between the liner and the shielding container. This observation was not placed in the corrective action program and the inspectors could not identify any action that was taken based on this information. This observation could have been indication that rainwater had been seeping into the shielding container during the time it was stored outside (March to October 2021). In addition, the work order for the dewatering evolution referenced a gasket on the shielding container lid but there was no gasket. After dewatering was complete, the site made a conscious decision to not install the SCF liner lid because this liner was not being prepared for shipment (consistent with the process for liners being stored inside the radioactive waste building vault) and instead, just reinstalled the shielding container lid.
Second Storage Period In On-Site Storage Container Yard After dewatering, the SCF liner and shielding container was moved back out to the OSSC yard, where it remained until October 2024. Procedure RPI-1301 requires quarterly inspections of this area, and a sampling of containers are inspected each quarter such that each container is inspected at least once a year. For this container, it was inspected in November of 2022 and 2023. However, during the sites review of this event, they identified that staff were not inspecting the top of this container to ensure lid integrity, and the radiological survey conducted to check for contamination leakage consisted of a contamination survey that was performed on the side of the shield and not the top, where the lid was. RPI-1301 also requires an annual inspection of liners in the OSSC yard to include performing air sampling on the interior of the OSSC to assess liner integrity. This annual inspection was not performed.
Discovery Phase On October 14, 2024, while performing work in the OSSC yard, radiation protection personnel noticed the shielding container lid was askew and while repositioning the lid back into place, about five gallons of water spilled out. The probable cause for this was that rainwater had been seeping into the shielding container and liner while stored outside and that freezing temperatures in the winter of 2023/2024 caused the lid to be pushed up from the expansion of the water when freezing. As the SCF liner lid was not installed, the rainwater came into contact with the filter media, causing it to become contaminated. The licensee performed a calculation based on historical rainfall and the surface area through which rain could enter the shielding container. This calculation determined approximately 80 gallons of water could have spilled from the shielding container from January 2024 to the time of discovery.
Surveys conducted by the licensee indicated that the soil around the perimeter of the OSSC yard was not contaminated. However, surveys did indicate soil contamination inside the OSSC yard and that some of the contamination entered a storm drain located inside the OSSC yard. This storm drain discharges to the minor stream, which is an engineered stream on the owner-controlled area that discharges to Lake Erie. Surveys of the minor stream have indicated low levels of radioactive material.
Dose Impact In accordance with NEI 07-07, Industry Ground Water Protection Initiative, the site performed a conservative bounding dose calculation for the spill. The site assumed all of the contamination from the spilled water (about 80 gallons) made it to Lake Erie via the minor stream, which is not the case, as much of the contamination is expected to be contained within the soil in the OSSC yard. However, this calculation shows that the dose impact to the public, had that occurred, would have been less than 1 mrem, which is a small fraction of any NRC regulatory requirements. The site will be required to assess any off-site releases in accordance with the Offsite Dose Calculation Manual. The NRC continues to monitor the response to storm drain and minor stream contamination and will assess the sites effluent control program in relation to the spill through our routine inspection program.
Corrective Actions: Immediate actions included moving the container into the radioactive waste building and covering the impacted area to help mitigate the further spread of contamination. The site also initiated sampling of the minor stream. Subsequently, the site installed a storm drain cover to prevent further introduction of contamination into the storm drain and minor stream. The site has hired a third party to evaluate the OSSC yard contamination and to conduct remediation of the area, which was ongoing at the time of the inspection exit. Future corrective actions also include continued monitoring of the minor stream and procedure revisions.
Corrective Action References: CR-2024-08053; CR-2024-08238
Performance Assessment:
Performance Deficiency: The failure to follow radioactive waste handling and storage procedures was a performance deficiency that was reasonably within the licensees ability to foresee and correct and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the multiple failures to follow radioactive waste handling and storage procedures rendered this radiation protection program barrier ineffective.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix D, Public Radiation Safety SDP. Specifically, the inspectors determined that this finding is of very low safety significance (Green) because it involved radioactive material control, was not related to transportation, and the public exposure was not greater than 5 mrem.
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
Specifically, changes to the types of filters used were not evaluated to ensure a success path for cradle to grave use of these SCFs. This resulted in the site being outside of its normal processes without having ensured that procedures and processes, such as work instructions, were sufficient to deal with this new filtration system.
Enforcement:
Violation: NRC requirements set forth in 10 CFR 20.1406, Minimization of Contamination, Paragraph (c), stipulate, in part, that licensees shall, to the extent practical, conduct operations to minimize the introduction of residual radioactivity into the site, including the subsurface, in accordance with the existing radiation protection requirements.
Contrary to these requirements, from March 2021 to October 2024, the licensee failed to conduct operations to minimize the introduction of residual radioactivity into the site in accordance with the existing radiation protection requirements. Specifically, the licensee failed to follow established radiation protection procedures, designed to control radioactive material stored in outdoor locations, which resulted in a contamination spill and the introduction of residual radioactive into the soil within the OSSC yard, storm drains, and the minor stream.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Picture 1: SCF Liner Lowered Into Shielding Container Picture 2: SCF Liner Stored Inside Shielding Container in OSSC Yard LER 2024-004-00 for Perry Nuclear Power Plant, Division 3 Diesel Generator Inoperable due to Low Output Voltage Resulting in Loss of Safety Function Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2024004-02 Open/Closed None (NPP)71153 The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Technical Specification (TS) Section 5.4.1.a, Procedures, when the licensee failed to perform preventative maintenance on the division 3 emergency diesel generator system's voltage regulator potentiometers, which resulted in an unplanned inoperability of the system.
Description:
The division 3 emergency diesel generator (DG) system provides emergency alternating current (AC) power to the high pressure core spray system, which performs an inventory control function during loss of coolant accidents.
On October 29, 2024, at 1152, with the reactor in Mode 1 and 100 percent rated thermal power, during a preventative maintenance run of the division 3 DG, it was noticed that the generator output voltage had dropped below the TS acceptance value of 3994 volts (3900 volts, adjusted for instrument inaccuracy). The division 3 DG was declared inoperable, but available, and TS 3.8.1, AC Sources - Operating, Condition B, one required DG inoperable, was entered. Event Notification 57406, Inoperability of the Division 3 Diesel Generator Supporting High Pressure Core Spray, was submitted as an eight-hour, non-emergency notification per 10 CFR 50.72(b)(3)(v).
During troubleshooting, it was discovered that an oxidation layer had built up on the R1 potentiometer in the output voltage regulator. Exercising the potentiometer throughout its range caused the oxidation layer to be removed, thereby eliminating the high resistance point and allowing the voltage regulator to function normally. A post-maintenance run of the division 3 DG was performed resulting in a normal and steady output voltage. On October 31, 2024, the division 3 DG was declared operable, and TS 3.8.1 was met.
The licensee's causal investigation determined the direct cause of voltage fluctuations was oxidation on the R1, R3 and R4 voltage regulator potentiometers. The preventive maintenance frequency and scope was developed during initial startup and did not align with the current Electric Power Research Institute (EPRI) standards which prevents buildup of oxidations on voltage regulator potentiometers. Perry currently performs tap tests on the R3 and R4 and cleans the wiper arm and wire wound portion of the R1 potentiometer every 4 years. The EPRI standard, as documented in EPRI Technical Report 1011109, Basler SR8A Voltage Regulator for Emergency Diesel Generators, is to run the R1 potentiometer from end to end while monitoring for a smooth resistance change and perform a tap test of R3 and R4 potentiometers every 2 years. This EPRI document was developed in 2004 specifically for SR8A voltage regulators, which is utilized for Perrys Div 3 DG. The R1 potentiometer at Perry was not cycled from end to end while monitoring for a smooth resistance change. The potentiometer maintenance was performed on June 3, 2024, but the R1 potentiometer was not verified to be operating properly with a smooth resistance change prior to returning the equipment to service. On December 19, 2024, the licensee submitted Licensee Event Report (LER) 2024-004, Division 3 Diesel Generator Inoperable due to Low Output Voltage Resulting in Loss of Safety Function.
Engineering evaluation EER 601474442 for the October 29, 2024, maintenance run, determined the lowest voltage observed 3947 volts was adequate to support equipment downstream of bus EH13 in accident conditions and would not have prevented the high pressure core spray system from accomplishing its safety function. The inspectors reviewed the operability, functionality, and notification requirements of the issue and identified that the failure to schedule and perform appropriate preventative maintenance on the division 3 DG systems voltage regulator, which resulted in an unplanned inoperability of the system division 3 DG, was a performance deficiency that is within the licensees ability to foresee and correct and should have been prevented.
Corrective Actions: The immediate corrective action was to wipe the R1, R3, and R4 potentiometers during troubleshooting. The long-term corrective action will be to increase the maintenance plan scope to operate the R1 potentiometer from end to end while monitoring output and wipe, clean, the R3 and R4 potentiometers every 2 years. Additionally, an action will be implemented to cycle the control room voltage regulator switch (R1) prior to stopping the engine.
Corrective Action References: CR-2024-08482
Performance Assessment:
Performance Deficiency: The licensee's failure to exercise the division 3 DG R1 potentiometer from end to end was contrary to TS 5.4, Procedures, and a performance deficiency that was within the licensees ability to foresee and correct and should have been prevented.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees preventive maintenance procedure failed to prevent buildup of oxidations on voltage regulator potentiometers, which resulted in an inoperable division 3 DG, a mitigating system.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Exhibit 2 - Mitigating Systems Screening Questions, answering question A.1 through A.6 No as the deficiency did not affect the design or qualification of a mitigating SSC, and the deficiency did not represent a loss of PRA function. This screens the issue as Green.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. The procedure was developed outside the 3-year period for present performance.
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.
Contrary to the above, since the start of the plant till correction on October 31, 2024, the licensee failed to establish a procedure recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, Regulatory Guide 1.33, Section 9, "Procedure for Performing Maintenance," Section 9.d(1) recommended procedures covering "Exercise of equipment that is normally idle but that must operate when required." However, the licensee did not establish a procedure to exercise the normally idle division 3 DG voltage regulator potentiometers. The insufficient preventive maintenance resulted in an unplanned inoperability of the division 3 DG.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Return Division 3 Emergency Diesel Generator to Service Resulting in Event Notification 57444 Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000440/2024004-03 Open/Closed
[H.5] - Work Management 71153 A Green finding and associated Non-cited Violation (NCV) of Technical Specification (TS)
Section TS 3.8.1, AC Sources Operating, was self-revealed when the licensee failed to identify the division 3 diesel generator (DG) was not restored properly to service and therefore failed to perform the required surveillance and actions for an inoperable division 3 emergency diesel generator.
Description:
The division 3 DG system provides emergency AC power to the high pressure core spray system, which performs an inventory control function during loss of coolant accidents.
On November 26, 2024, the division 3 DG performed abnormally during a surveillance run.
The local operator noticed the right bank air receiver pressure did not decrease as expected during the start, which indicated the right bank air start motors failed to engage/start.
Historically, there is a drop of 20-25 pound per square inch gauge (psig) in each air receiver when starting. During this surveillance run, the right bank air pressure dropped by 5 psig, with no subsequent start of the right bank air compressor, which was noted by an observant operator. During the previous monthly runs, the local operator did not notice these discrepancies as these parameters are not required to be observed nor documented in the surveillance. Subsequent inspection identified that the right bank air start supply and jumper air lines were in the wrong configuration. The division 3 DG was declared inoperable. Event Notification 57444, Inoperability of the Division 3 Diesel Generator Supporting High Pressure Core Spray, was submitted as an eight-hour, non-emergency notification per 10 CFR 50.72(b)(3)(v).
Maintenance reconfigured the lines to the proper configuration per troubleshooting order 200962499. Operations started the division 3 DG with expected indications. On November 27, 2024, the division 3 DG was declared operable, and TS 3.8.1 was met.
A review of past work orders identified that on June 3, 2024, work order 200807263 was performed to replace the division 3 DGs lower air start motors. This work order directed implementation of PMI-0040, Division 3 Air Start Motor Maintenance. Step 5.10.6 of this procedure specifies the correct connection of the air supply lines. The licensee determined that the air lines were misconfigured at that time and the division 3 DG was inoperable per TS 3.8.1. Therefore, June 3, 2024 to November 26, 2024 was determined to be the inoperable period of the affected DG, totaling 177 days. There are two starting air systems for the division 3 DG. With the air lines for the right bank air start motors misconfigured, the right bank air start motors were not properly engaging with the engine flywheel to aid in starting the diesel generator. However, the left bank motors were properly engaging, and the DG achieved the required rated speed within the 13 second time frame each of the approximately dozen starts during the June through November 2024 affected period. This indicated no loss of function for the division 3 DG during the inoperability time period.
The inspectors reviewed the operability, functionality, and notification requirements of the issue and identified the failure to restore the correct configuration of the right bank air start system, which resulted in an unplanned inoperability of the division 3 DG system, was a performance deficiency.
Corrective Actions: A troubleshooting team discovered that the supply and jumper air lines were in the wrong configuration. Maintenance reconfigured the lines to the proper configuration per troubleshooting order 200962499. Operations started the division 3 DG with expected indications and declared the system operable.
Corrective Action References: CR-2024-09243
Performance Assessment:
Performance Deficiency: The licensee's failure to correctly restore the division 3 DG air start subsystem configuration upon completion of work as described in work order 200807263 and PMI-0040 before returning the DG system to service was a performance deficiency that was within the licensee's ability to foresee and correct and should have been prevented. This resulted in the licensee's failure to take the appropriate TS actions for an inoperable DG.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to control configuration of the division 3 DG air start subsystem did not ensure the availability of the division 3 DG because the nonconforming lineup resulted in the isolation of a required subsystem and an unplanned inoperability declaration of the division 3 DG, a mitigating system.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors used Exhibit 2 - Mitigating Systems Screening Questions, answering question A.1 through A.6 No as the deficiency did not affect the design or qualification of a mitigating SSC, and the deficiency did not represent a loss of PRA function. This screens the issue as Green.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee's work management process did not incorporate a procedural step in the planning of the work order such that standard practice independent verification would occur to ensure configuration control during the execution phase of the work management process in the June 2024 division 3 DG maintenance window.
Enforcement:
Violation: Perry Technical Specifications (TS) Section 3.8.1, AC Sources-Operating, requires, in part, that while in Modes 1, 2, and 3, three diesel generators shall be operable. The TS ACTION B statement requires that with one required DG inoperable, perform SR 3.8.1.1 for OPERABLE required offsite circuit within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND declare required features supported by the inoperable diesel generator inoperable when the redundant required features are inoperable AND determine operable diesel generators are not inoperable due to common cause failure OR perform SR 3.8.1.2 for OPERABLE diesel generators AND restore required diesel generator to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The TS ACTION F statement requires, with ACTION B and associated completion time not met, to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
Contrary to the above, between June 3, 2024, and November 27, 2024, while the plant was in Mode 1, the division 3 emergency diesel generator was inoperable, and ACTION B was not taken to perform SR 3.8.1.1 for OPERABLE required offsite circuit within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. In addition, with ACTION B not taken within the associated completion time, ACTION F was not taken to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
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 January 15, 2025, the inspectors presented the integrated inspection results to R. Penfield, Site Vice President, and other members of the licensee staff.
- On November 21, 2024, the inspectors presented the Perry biennial licensed operator requalification inspection results to D. Benyak, Plant General Manager, and other members of the licensee staff.
- On December 17, 2024, the inspectors presented the emergency action level and emergency plan changes inspection results to J. Archer, Emergency Preparedness Manager, and other members of the licensee staff.
- On January 8, 2025, the inspectors presented the radiation protection inspection results to R. Penfield, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Certification of
Winter Readiness
Perry Site Certification Letter for Winter Readiness 2024
10/31/2024
SOI-C61
Remote Shutdown System
Revision 11
SVI-E12-T1182C
RHR C LPCI Valve Lineup Verification and System Venting
Revision 22
Procedures
VLI-C41
Standby Liquid Control System
11/14/2024
Work Orders
200806989
SVI-E12T1182C RHR 'C' LPCI Vlv L/U
09/25/2024
Corrective Action
Documents
CR 2023-08340
NRC Identified Incorrect Functional Location Number on
Service Water Pre-Fire Plan (FPI-SWB)
11/07/2023
Emergency Service Water Pump House
11/13/2024
Unit 1 - Division 2 Diesel Generator Building 620 6 and
646 6 Elevation
Unit 1 - Division 3 Diesel Generator Building 620 6 and
646 6 Elevation
FPI-0FH
Fuel Handling Building
SB 604'
Service Building 604' Elevation
SB-620'
Service Building 620' Elevation
SB-640'
Service Building 640' Elevation
SB-654'
Service Building 654' Elevation
Fire Plans
SW-620
Service Water Bldg. 620 Elev.
11/13/2024
Procedures
PTI-E12-P0003
RHR Heat Exchangers B and D Performance Testing
Miscellaneous
Email from Bryant
Udell, Exam
Author, Vistra
Operations
Company to
Senior Operations
Engineer, U.S.
NRC
Completion Results Perry 2024 Annual/Biennial Exam
2/06/2024
CR 2022-02694
Flow Control Valve A Position Fluctuations
03/27/2022
CR 2022-08509
Main Trip of Turbine during Startup
11/07/2022
Corrective Action
Documents
CR 2023-00100
Reactor SCRAM due to Temporary Loss of Feedwater
01/05/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CR 2023-05721
Site Documentation Updates Were Not Completed Prior to
Effective Date of the Technical Specifications for Flooding
07/21/2023
CR 2023-06141
Emergency Response Organization Notification System
(ERONS) Weekly Notification Test Performed Incorrectly
08/07/2023
CR 2023-06215
Automatic Reactor SCRAM and MSIV Closure Following
RPS BUS Shift from Alt to NORM B
08/10/2023
CR 2023-09416
Reactor Water Clean-Up 'A' Pump Trip during surveillance
2/27/2023
CR 2024-00642
Trip of Reactor Feed Pump Turbine B
01/24/2024
Corrective Action
Documents
Resulting from
Inspection
CR 2024-09061
Potential Exam Compromise While Performing In Plant Job
Performance Measures for 2024 Licensed Operator
Requalification Examination. NOP-TR-1010 Sec. 4.6
11/19/2024
23 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2023 B.2.2.1.5 Single
Recirculation Pump Trip
05/09/2023
23 Simulator
ANSI Testing
Real Time ANSI Test
04/06/2023
23 Simulator
ANSI Testing
Simulator Physical Fidelity Evaluation
05/09/2023
23 Simulator
ANSI Testing
Simulator Heat Balance Testing at 100%, 75%, and 40%
08/17/2023
23 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing B.2.2.1.1 Manual Scram
05/09/2023
23 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2023 B.2.2.1.2
Simultaneous Trip of All Feedwater Pumps
05/09/2023
23 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2023B.2.2.1.4
Simultaneous Trip of all Recirculation Pumps
05/09/2023
23 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2023 B.2.2.1.3
Simultaneous Closure of all MSIVs
05/09/2023
24 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2024 B.2.2.1.6 Main
Turbine Trip from Maximum Power Level
03/28/2024
24 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2024 B.2.2.1.7 Maximum
Rate Power Ramp (100% to 75% to 100%) Using Flow
Control Valves
03/28/2024
Miscellaneous
24 Simulator
Cycle 20 ANSI Transient Testing 2024 B.2.2.1.8 Maximum
03/28/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ANSI Testing
24 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2024 B.2.2.1.9 Maximum
Size Unisolable Main Steam Line Rupture
03/28/2024
24 Simulator
ANSI Testing
Cycle 20 ANSI Transient Testing 2024 B.2.2.1.10
Simultaneous Closure of all MSIVs with Single SRV Stuck
Open
03/28/2024
24 Simulator
ANSI Testing
Real Time ANSI Test
03/13/2024
24 Simulator
ANSI Testing
Simulator Heat Balance Testing at 100%, 75%, and 49%
03/14/2024
24 Simulator
ANSI Testing
Simulator Physical Fidelity Evaluation
06/10/2024
ESOMS Watch
Logs
Watch Standing Credit for Maintaining Proficiency
10/01/2023-
11/18/2024
Licensed
Operator
Requalification
Cycle 2023-01
through 2024-09
Attendance Sheets
01/01/2023 -
09/12/2024
OT3701 B21_506
In Plant Job Performance Measure
OT3701ADM 021
Reactor Operator Administrative Job Performance Measure
OT3701ADM 308
Senior Reactor Operator Administrative Job Performance
Measure
OT3701C61_002
In Plant Job Performance Measure
OT3701E21_503
Simulator Job Performance Measure
OT3701M15_501
Simulator Job Performance Measure
OT3701P43_502
Simulator Job Performance Measure
OT3710ADM 306
Senior Reactor Operator Job Performance Measure
OT3710C11_513
Simulator Job Performance Measure
OT3710C41_007
In Plant Job Performance Measure
PC1E
Licensed Operator Annual Examination Simulator Scenario
Guide
Post Event
Simulator Testing
Reactor Recirculation Pump A Trip to Off
01/09/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Post Event
Simulator Testing
Digital Feedwater Control System Scram
01/05/2023
Post Event
Simulator Testing
Automatic Scram due to Inadvertent RPS Actuation
06/11/2024
Post Event
Simulator Testing
Scram from 37% for Entry into 1RFO19
2/26/2023
Post Event
Simulator Testing
Reactor Feed Pump Turbine B
01/24/2024
RP1E
Licensed Operator Annual Examination Simulator Scenario
Guide
RP2A
Licensed Operator Annual Examination Simulator Scenario
Guide
RP5A
Licensed Operator Annual Examination Simulator Scenario
Guide
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - July 31st from 1200-1250 in TEC 207 and via
Teams
07/31/2023
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - May 15th from 1200-1250 in TEC 128 and
via Teams
05/15/2023
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - February 8th from 1300-1350 in TEC 207
and via Teams
2/08/2023
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - December 6th, 1300-1400 in TEC 207 and
via Teams
2/06/2023
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - September 26th from 1300-1350 in TEC 209
and via Teams
09/26/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - May 20th from 1300-1345 in TEC 209 and
via Teams
05/20/2024
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - February 12th from 1200-1245 in TEC 207
and via Teams
2/12/2024
Simulator Review
Committee
Meeting Minutes
final approved
SRC Meeting - November 14th from 1300-1345 in TEC 207
and via Teams
11/14/2023
Simulator
Scenario Guide
OLTC-
3058202410_PY-
SGD
10: Simulator Scenario Based Testing Form
10/18/2020
Simulator
Scenario Guide
OT-3403-05B
10: Simulator Scenario Based Testing
07/19/2024
Simulator
Scenario Guide
OTLC-
3058202407_PY-
SGC3
10: Simulator Scenario Based Testing Form
03/06/2024
Simulator
Scenario Guide
OTLC-
3058202408_PY-
SGC
10: Simulator Scenario Based Testing Form
05/21/2024
NOBP-TR-0001-
Remediation
Procedures
NOBP-TR-1271
Operator License Administration, Attachment 2: Inactive
License Retraining Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NOP-TR-1200-06
Qualification Revocation
PYBP-PTS-0015
JPM Preparation, Review, Revision, Approval and
Administration - Job Performance Measure Evaluation
Record Sheets for Eight Individuals on Crew 1
11/19/2024
PYBP-PTS-0033,
Simulator
Configuration
Control
Simulator Performance Testing - Cycle 20 BOL Core
Installation Testing
04/04/2023
PYBP-PTS-0033,
Simulator
Configuration
Control
Simulator Performance Testing, Cycle 20 MOL Core Testing
2/12/2024
PYPB-PTS-0005
Perry Operator Continuing Training Program Administration
Quality Assurance
Audit Report MS-
C-24-04-17
Audit Area: Training for Beaver Valley, Davis-Besse, Perry
and Fleet Training
05/30/2024
Self-Assessments
Snapshot
Assessment ATL-
22-0759-ATA-
25-NRC
71111.11b
Licensed Operator Requalification Program and Licensed
Operator Performance Assessment
GN-0000302-1-1
Reactor Control and Information System (RC&IS) Simulation
Site Acceptance Test Report
01/23/2023
Simulator Minor
0003
1-LOT-22 DEC700 Terminal Server Not Driving P680 Digital
Displays
05/25/2023
Simulator Minor
0007
1-LOT-22 RCIC Trip Throttle Valve Switch Sticky Contacts
2/16/2023
Simulator Minor
Work Order
Summary
Open and Closed Orders Filtered: Sorted by Order Number
11/18/2024
Work Orders
Simulator Work
Order Summary
Open and Closed Orders Filtered: Sorted By Order Number
11/18/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Simulator Work
Request 23-0005
1-LOT-22 Several Spurious Rad Mon Alarms
2/16/2023
Simulator Work
Request 23-0006
1-LOT-22 Computer Failed Resulting in Ability to Delete
Malfunctions
2/16/2023
Simulator Work
Request 23-0006
1-LOT-22 Computer Failed Resulting in Ability to Delete
Malfunctions
2/16/2023
Simulator Work
Request 23-004
1-LOT-22 SPDS Locked up While Implementing EOPs
during Sim Scenario
2/16/2023
Simulator Work
Request 24-0024
Intermittent Rad Monitor Alarms (Remains Open)
11/20/2024
IOI-3
Procedures
ONI-ZZZ-5
Radioactive or Chemical Spill
CR 2024-07736
Recirc Pump B Motor Cooler Leakage HI Alarm
10/02/2024
CR 2024-08405
Diesel Fire Pump High Water Temp Alarm during Run
10/25/2024
CR 2024-08894
Level 3 Plant Computer Splunk Software Not Indexing or
Forwarding Data
11/12/2024
Corrective Action
Documents
CR 2024-09078
Past Operability Review - Div 3 Voltage Fluctuations Were
Identified in June 2024
11/19/2024
SVI-E22-T2680
Procedures
TSR-Modes
1,2,&3-1
Modes 1, 2, and 3 Technical Specifications Rounds
08/01/2024
Work Orders
200960587
Potentiometer Wiping and Diesel Generator Voltage
Verification
10/31/2024
KLD TR - 1407
Perry Nuclear Power Plant 2024 Population Update Analysis
05/07/2024
Calculations
PY-2024-002-00
CFR 50.54(q) Analysis for Revision 62 to the Emergency
Plan dated 03/04/2024
03/04/2024
N/A
Emergency Plan for Perry Nuclear Power Plant
Procedures
PSI-0019
Emergency Action Level (EAL) Bases Document
CR 2021-00841
New SCF Cask Found in an Unexpected Condition
2/09/2021
CR 2024-08053
Container Leaked outside in the Radiologically Controlled
OSSC Storage Yard
10/14/2024
Corrective Action
Documents
CR 2024-08238
Minor Stream Contaminated with Co-60 in Water Sample
10/21/2024
Engineering
Evaluations
10-00208
CFR 50.59 Evaluation for Radioactive Material/Waste
Storage Areas
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NOP-OP-4705
Response to Contaminated Spills/Leaks
04/08/2024
PAP-0809
Radiological Environmental Contamination Response
Procedures
RPI-1301
Movement of Radioactive Material/Waste outside of
Radiologically Controlled Areas and Onsite Interim Storage
PY-M-20211006-
Dewater SCF
10/06/2021
Radiation
Surveys
PY-M-20241023-
Radioactive Waste Truck Bay
10/23/2024
23-3025
Type A Shipping Package
04/12/2023
24-1010
LSA-II Shipping Package
06/12/2024
Shipping Records
24-1016
LSA-II Shipping Package
08/26/2024
200829754
Removal of Existing SCF and Replacement with New SCF
04/02/2021
200856297
Dewatering SCF
10/18/2021
200872779
Quarterly Survey of OSSC Yard and RISB
11/13/2023
200872780
Quarterly Survey of OSSC Yard and RISB
03/04/2024
200875121
Quarterly Survey of OSSC Yard and RISB
06/24/2024
Work Orders
200875703
Quarterly Survey of OSSC Yard and RISB
09/25/2024
PI Monthly Data
Occupation Exposure Control Effectiveness (OR01) Unit 1
July 1, 2023 through September 30, 2024
Revision 0
71151
Miscellaneous
PI Monthly Data
RETS/OCDM Radiological Effluent Occurrence (PR01) Unit
July 1, 2023 through September 30, 2024
Revision 0
Corrective Action
Documents
CR 2024-08053
Container Leaked in the Outside Radiological Controlled
OSSC Storage Yard
October 14,
24
Procedures
NOP-OP-4706
Response to Contaminated Spills/Leaks
Corrective Action
Documents
CR 2024-08482
Division 3 DG Output Voltage Oscillating Following Start
October 29,
24
Corrective Action
Documents
CR 2024-09226
Minimal Pressure Drop on Division 3 Right Bank Starting Air
Receiver during Engine Start
November
26, 2024
Procedures
NOP-WM-4006
Conduct of Maintenance
Revision 12