ML25162A014
| ML25162A014 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/11/2025 |
| From: | Thomas Briley NRC/RGN-III/DORS/EB1 |
| To: | Penfield R Vistra Operations Company |
| References | |
| IR 2025011 | |
| Download: ML25162A014 (1) | |
See also: IR 05000440/2025011
Text
Rod Penfield
Site Vice President
Vistra Operations Company, LLC
Perry Nuclear Power Plant
10 Center Road
Perry, OH 44081
SUBJECT:
PERRY NUCLEAR POWER PLANT - REQUEST FOR INFORMATION FOR
THE NRC COMMERCIAL-GRADE DEDICATION INSPECTION: INSPECTION
REPORT 05000440/2025011
Dear Rod Penfield:
On July 14, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a
commercial-grade dedication (CGD) inspection at Perry Nuclear Power Plant. This inspection
will be performed in accordance with NRC Inspection Procedure 71111.21N.03, Commercial
Grade Dedication.
The inspection will evaluate the implementation of Perrys process for dedicating
commercial-grade items, as required in applicable portions of Title 10 of the Code of Federal
Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power
Plants and Fuel Reprocessing Plants, to ensure reasonable assurance is provided that these
items will perform their intended safety function. Additionally, the inspection will evaluate
implementation of Perrys procurement process for safety-related components, as required in
Appendix B.
Experience with previous baseline inspections of similar depth and length has shown that this
type of inspection is resource intensive, both for the NRC inspectors and the licensee staff. To
minimize the inspection impact on the site and to ensure a productive inspection for both
parties, we have enclosed a request for information. The first request (Enclosure 1) is generally
for information that will be used to choose the inspection samples or information that will be
applicable to all inspection samples throughout the inspection. The second request
(Enclosure 2) is for information that is specific to an individual sample.
We have discussed the schedule for inspection activities with your staff and understand that our
regulatory contact for this inspection will be George Dujanovic of your organization.
If there are any questions about the material requested, or the inspection in general, please
contact the lead inspector, Thomas Briley, at 630-829-9595 or Thomas.Briley@nrc.gov.
June 11, 2025
R. Penfield
2
This letter contains voluntary information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections (approval number 3150-0011). The burden to the public
for these information collections is estimated to average 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> per response. Send
comments regarding this information collection to the FOIA, Library and Information Collection
Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and
to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)
OMB, Washington, DC 20503.
The NRC may not conduct nor sponsor, and a person is not required to respond to, a request
for information or an information collection requirement unless the requesting document
displays a currently valid OMB control number.
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding,
of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your response (if any)
will be available electronically for public inspection in the NRCs Public Document Room or from
the Publicly Available Records System (PARS) component of NRC's Agencywide Document
Access and Management System (ADAMS). ADAMS is accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Thomas Briley, Senior Reactor Inspector
Engineering Branch 1
Division of Operating Reactor Safety
Docket No. 05000440
License No. NPF-58
Enclosure:
1.
Requested Information to Support
Commercial-Grade Dedication
Sample Selection
2.
Requested Information to Support
Commercial-Grade Dedication
Inspection
cc: Distribution via Listserv
Signed by Briley, Thomas
on 06/11/25
R. Penfield
3
Letter to Rod Penfield from Thomas Briley dated June 11, 2025.
SUBJECT:
PERRY NUCLEAR POWER PLANT - REQUEST FOR INFORMATION FOR
THE NRC COMMERCIAL-GRADE DEDICATION INSPECTION:
INSPECTION REPORT 05000440/2025011
DISTRIBUTION:
Tim Steadham
RidsNrrPMPerry Resource
RidsNrrDorlLpl3
RidsNrrDroIrib Resource
R3-DORS
ADAMS Accession Number: ML25162A014
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
TBriley:gmp
DATE
06/11/2025
OFFICIAL RECORD COPY
Enclosure 1
Enclosure 1 - Requested Information to Support Commercial-Grade Degradation Sample
Selection
The documents and information requested below should generally be made electronically
available to the inspection team for the teams use both on-site and off-site. At the end of the
inspection, the documents in the teams possession should not be retained. This document
request is based on typical documents that a generic plant might have. As such, this document
request is not meant to imply that any specific plant is required to have all the listed documents.
In addition, your plant-specific document titles may vary from the document titles listed below.
The following information is requested by June 23, 2025, or sooner, to facilitate sample
selection.
Documents requested, if available:
1.
Copy of procedures for dedicating commercial-grade items/services, procuring
safety-related structures, systems, and components (SSCs), performing receipt
inspections, controlling counterfeit, fraudulent, and suspect items, and 10 CFR Part 21
evaluations and reporting.
2.
List of commercial-grade items, with a brief description of application, that have been
dedicated for safety-related application within the past six years. These items may be
dedicated by Perry or dedicated by a vendor (or other licensee) and procured by Perry.
Please note whether the item has been installed in the plant. The list should identify the
systems/components where the items were installed or were intended to be installed for
use.
3.
List of components procured as safety-related within the past six years. Please note
whether the item has been installed in the plant. The list should identify the
systems/components where the items were installed or were intended to be installed for
use.
4.
List of corrective action program documents, with descriptions, related to
commercial-grade items, procurement, or storage, including any items that failed after
completing the dedication process. The list should encompass the past six years of
these activities.
5.
List components procured as safety-related or commercial-grade items intended to be
dedicated for safety-related applications that are on hold because of concerns identified
during receipt, dedication, or from operating experience/corrective action program as
applicable. The list should identify the systems/components where the items were
intended to be installed for use.
6.
Copies of any self-assessments/audits of the safety-related procurement or the
commercial-grade dedication and procurement processes that were completed within
the two-years prior to the start date of this inspection.
2
7.
List of components procured as safety-related or commercial-grade items dedicated for
safety-related applications, in the past six years, where the procurement/dedication
process was expedited to support rapid turnaround (less than seven days). The list
should identify the systems/components where the expedited items were installed or
were intended to be installed for use. It should also identify whether the item has been
installed.
8.
List of systems (system numbers/designators and corresponding names)
9.
Copy of qualifications, as applicable, of personnel who performed commercial-grade
dedication, safety-related component procurement, and/or receipt inspection/testing
activities within the past six years.
10. Copy of updated final safety analysis report, technical specifications (and bases), and
technical requirements manual.
11. Copy of simplified plant drawings (if available). Note: these may be uncontrolled
documents such as big notes, training diagrams, etc.
Enclosure 2
Enclosure 2: Requested Information to Support Commercial-Grade Degradation Inspection
The team lead will identify samples (i.e., structures and components) following receipt of
information contained in Enclosure 1. The documents and information requested below should
generally be made electronically available to the inspection team for the team's use both on-site
and off-site. At the end of the inspection, the documents in the teams possession should not be
retained. This document request is based on typical documents that a generic plant might have.
As such, this document request is not meant to imply that any specific plant is required to have
all the listed documents. In addition, your plant-specific document titles may vary from the
document titles listed below. We also request that the information provided be sorted by the list
below for each sample.
The following information is requested by July 7, 2025, or sooner, to facilitate the inspection.
Documents requested, if available:
1.
Complete commercial-grade item dedication package including relevant documentation
such as the following, as applicable: description of item/service, identification of safety
functions and safety classifications, like-for-like or equivalency evaluations, credible
failure modes/failure modes and effects analysis, critical characteristics and acceptance
criteria, identification of the suppliers commercial quality assurance program or other
documented controls.
2.
Complete purchase order including relevant documentation such as the following, as
applicable: purchase requisition, catalog specifications, item product data sheets/vendor
manuals, shelf-life information, service/qualified life information, certificates of
conformance/compliance/quality, vendor test and inspection reports, third-party or sub
vendor test and inspection results, vendor dedication or partial dedication information,
material receiving reports, packing list/invoices or other shipping documents, and other
pertinent vendor/licensee correspondence.
3.
Receipt inspection reports and any related test reports, documents noting any deviations
from design, material, and performance characteristics relevant to the safety function
(nonconformance dispositions).
4.
Documents showing objective evidence of special test and inspection procedures used
to verify technical and quality requirements have been met, commercial-grade survey
reports, or source verification reports; any other documents to trace the item from the
time it was dedicated to the time it was installed, tested, and accepted.
5.
Completed installation work orders and stock or material issue forms; completed
post-installation test procedures and results.
6.
Design basis information of the inspection sample such as: normal/accident service
environment, normal/accident performance requirements, design basis
document/system description, calculation/drawing/procedure updates, etc.
7.
10 CFR 50.59 documentation, if required.
2
8.
Historical performance information, including corrective action documents, maintenance
rule performance, failure analysis or root cause analysis for any failed components, and
system health reports related to the installed components.