IR 05000440/2004009

IR 05000440-04-009; 05/24/2004 - 05/28/2004; Perry Nuclear Power Plant; Supplemental Inspection; IP 95001, Inspection for One or Two White Inputs in a Strategic Performance Area

ML041750028
Person / Time
Site:	Perry
Issue date:	06/22/2004
From:	Pederson C Division of Reactor Safety III
To:	Kanda W FirstEnergy Nuclear Operating Co
References
IP 95001 IR-04-009
Download: ML041750028 (17)

Text

June 22, 2004

SUBJECT:

PERRY NUCLEAR POWER PLANT NRC SUPPLEMENTAL INSPECTION REPORT 05000440/2004009

Dear Mr. Kanda:

On May 28, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at your Perry Nuclear Power Plant. The enclosed report documents the inspection results which were discussed on May 28, 2004, with you and members of your staff.

The NRC performed this supplemental inspection to assess your evaluation of a White finding, which was also a violation of 10 CFR 50.47(b)(4), in the Emergency Preparedness area of the Reactor Safety cornerstone. This inspection was conducted in accordance with Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area, and examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

Based on the results of this inspection, we concluded that you have adequately completed a root cause analysis of the issue, which was an untimely actual emergency declaration on April 24, 2003, and have identified appropriate corrective actions to prevent recurrence of the issue. No findings of significance were identified concerning the root cause evaluation and corrective actions. As a result, the violation is considered closed.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA by Roy Caniano Acting for/

Cynthia D. Pederson, Director Division of Reactor Safety Docket No. 50-440 License No. NPF-58 Enclosure:

Inspection Report 05000440/2004009 w/Attachment: Supplemental Information cc w/encl:

G. Leidich, President - FENOC L. Myers, Chief Operating Officer, FENOC J. Hagan, Senior Vice President Engineering and Services, FENOC W. OMalley, Director, Maintenance Department V. Higaki, Manager, Regulatory Affairs J. Messina, Director, Nuclear Services Department T. Lentz, Director, Nuclear Engineering Department T. Rausch, Plant Manager, Nuclear Power Plant Department M. OReilly, Attorney, First Energy Public Utilities Commission of Ohio Ohio State Liaison Officer R. Owen, Ohio Department of Health

SUMMARY OF FINDINGS

IR 05000440/2004009; 05/24/2004 - 05/28/2004; Perry Nuclear Power Plant; Supplemental

Inspection; IP 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area.

This supplemental inspection was performed by regional inspectors. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Cornerstone: Reactor Safety

The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental inspection to assess the licensees evaluation of a White finding in the Emergency Preparedness area of the Reactor Safety cornerstone. The issue that resulted in a White finding was also a violation of 10 CFR 50.47(b)(4). This supplemental inspection was performed in accordance with Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area. The inspectors concluded that the licensee performed an adequate evaluation of the root causes of the issue (an untimely actual Alert declaration on April 24, 2003) and had identified appropriate corrective actions. As a result, the violation is considered closed.

The licensees evaluation of the issue identified two root causes. First, managements expectations were not clearly established regarding the roles and responsibilities of reactor engineers in their oversight of the contractor personnel performing the spent fuel inspection activities, including communications expectations with Control Room personnel. Second, the Shift Managers supervisory methods were ineffective in maintaining command and control of the emergency event.

Given this acceptable performance in addressing the condition associated with the White finding, this performance issue will not be held open beyond the normal four quarters provided in NRC Manual Chapter 0305, Operating Reactor Assessment Program.

REPORT DETAILS

INSPECTION SCOPE

The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental inspection to assess the licensees evaluation of a White finding in the Emergency Preparedness area of the Reactor Safety cornerstone. The White finding, which was also a violation of 10 CFR 50.47(b)(4), was due to inadequate use of the standard emergency classification scheme, which resulted in an untimely actual Alert declaration on April 24, 2003.

On April 24, 2003, while the Perry Plant was in a refueling outage, licensee and contractor personnel were performing spent fuel inspection activities in the Fuel Handling Building (FHB).

At about 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, spent fuel inspection and engineering personnel noted that the end plug had separated from its spent fuel rod and they observed gas bubbles coming from the spent fuel rod.

Soon after the release of gas bubbles from the damaged spent fuel rod entered the FHBs atmosphere, the FHB ventilation exhaust systems gaseous radiation monitor alarmed in the Control Room. The high alarm also caused an evacuation alarm to sound in the FHB and tripped the FHBs ventilation supply fan. Control Room personnel responded to the high alarm in accordance with Off-Normal Instructions (ONI), and the Unit Supervisor (US) ordered an evacuation of the affected area. However, having received no reports of damaged fuel, the Shift Manager (SM) concluded that an emergency declaration was not warranted based on his understanding of the Emergency Action Levels (EAL) in the Perry Plants emergency plan and the plans implementing procedures.

Between about 1120 and 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, separate evaluations of whether an emergency declaration was warranted took place within and outside of the Control Room. At 1127 hour0.013 days <br />0.313 hours <br />0.00186 weeks <br />4.288235e-4 months <br />, FHB radiation alarms cleared and relevant radiation level readings were returning to pre-event levels. However, the SM did not declare an Alert until 1150 hour0.0133 days <br />0.319 hours <br />0.0019 weeks <br />4.37575e-4 months <br />, which was untimely.

EVALUATION OF INSPECTION REQUIREMENTS 02.01 Problem Identification a.

Determine that the root cause evaluation identifies who (i.e., licensee, self-revealing, or NRC) identified the issue and under what conditions.

The licensee identified that the Alert declaration was untimely and initiated Condition Report (CR) 03-02408 on April 24, 2003. This CR documented the following: the relevant EAL; the determination that the Alert declaration was untimely; and that a Cause Analysis (CA) would be done to address the untimely Alert declaration. The inspectors concluded that the issue (untimely emergency declaration) was licensee-identified.

b.

Determine that the root cause evaluation identifies how long the issue existed and prior opportunities for identification.

Besides the CA resulting from CR 03-02408, the licensee completed an April 24, 2003 Alert Classification NRC 95001 Inspection Readiness Review (Readiness Review Report), which adequately addressed the aspects of pre-existence of the issue and prior opportunities for identification of the issue.

The Readiness Review Report indicated that no prior untimely emergency declarations had occurred at the Perry Plant involving actual plant operations, or during emergency preparedness drills or exercises in recent years. Specifically, the readiness review team reviewed records of all seven actual emergency declarations made at the Perry Plant between February 1996 and May 14, 2004. The only actual emergency event that was not declared in a timely manner was the Alert declaration on April 24, 2003. The team also reviewed records of those emergency preparedness drills and exercises, whose emergency classification, offsite notification, and offsite protective action recommendation actions were evaluated and counted as Drill and Exercise Performance (DEP) Performance Indicator (PI) opportunities, for the period January 2002 through March 2004. Over 60 of these PI opportunities were emergency classification opportunities. The team determined that none of the unsuccessful DEP indicator opportunities were due to untimely emergency classification decisions. Instead, the unsuccessful opportunities were either due to errors in accurately completing the notification form, which would be used to transmit emergency event information to State and county officials, or to errors in choosing the relevant EAL.

The inspectors performed an independent review of the licensees records of DEP indicator opportunities for the period April 2003 through April 2004 and did not identify any instances of untimely emergency classification decisions. Reviews of the actual emergency events that occurred between February 1996 and August 2003 were evaluated during prior NRC inspections. The inspectors agreed with the Readiness Review Reports conclusion that there were no prior instances in recent years at the Perry Plant of difficulties in making timely emergency classification decisions.

c.

Determine that the root cause evaluation documents the plant-specific risk consequences (as applicable) and compliance concerns associated with the issue.

The Readiness Review Report summarized plant-specific risk consequences associated with the emergency event on April 24, 2003. For example, Control Room personnel did not delay in initiating appropriate onsite protective actions for personnel even though the causes of the FHBs ventilation exhaust systems radiation monitor alarm was unknown at the time that these onsite protective action decisions were made. Also, onsite protective actions continued because the cause of the high alarm, which lasted roughly 45 seconds. There was no adverse impact on public health and safety.

With respect to compliance concerns, the licensees evaluation acknowledged that the SMs emergency declaration decision was untimely and that the SM failed to adequately implement one of the risk significant emergency planning standards in NRCs regulations. The Readiness Review Report also recognized that emergency classification decisions are important triggers that cause onsite and offsite emergency responders to become ready should it become necessary to implement actions to protect public health and safety. The report also correctly noted that offsite officials were notified in a timely manner after the SM eventually made the Alert declaration.

Based on the above information, the inspectors concluded that the licensees evaluations of the risk consequences and compliance concerns associated with the untimely Alert declaration were adequate.

02.02 Root Cause and Extent of Condition a.

Determine that the issue was evaluated using systematic method(s) to identify root cause(s) and contributing cause(s).

The licensees initial CA, which was documented as CA 03-02408, utilized Event and Causal Factors Charting. The subsequent Readiness Review Report resulting from CR 04-02025 included the following evaluation techniques: Event and Causal Factors Charting; and Barrier

Analysis.

The Readiness Review Reports root cause evaluations verified that both root causes identified in the earlier CA 03-02408 were adequate.

Specifically, the aforementioned reports identified two root causes. First, managements expectations were not clearly established regarding the roles and responsibilities of reactor engineers in their oversight of contractor personnel performing the spent fuel inspection activities, including communications expectations with Control Room personnel. Second, the SMs supervisory methods were ineffective in maintaining command and control of the event. For example, the SM became involved in performing some actions that were the USs responsibility, which detracted from the SMs ability to perform a SMs oversight and event classification responsibilities.

The inspectors reviewed the root cause analysis methods employed by the licensee and concluded that an adequate, formal, structured approach was utilized to identify the root causes.

b.

Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the issue.

The licensee categorized the CA associated with CR 03-02408 as an apparent cause evaluation. The inspectors concluded that the subsequent Readiness Review Report was a significant expansion of the scope of this CA and that the report also exhibited an improved understanding of NRC Supplemental Inspection Procedure 95001. The inspectors concluded that the combination of the CA and the Readiness Review Report constituted the licensees root cause evaluation of the issue. The inspectors determined that the root cause evaluation was conducted to a sufficient level of detail for an issue that did not warrant offsite protective actions and did result in adequate onsite protective actions. The inspectors also concluded that the licensee utilized acceptable methods to evaluate the issue and adequately identified the root causes of the untimely Alert declaration.

c.

Determine that the root cause evaluation included consideration of prior occurrences of the problem and knowledge of prior operating experience.

The Readiness Review Report evaluated industry operating experience, as well as internal records to determine if similar spent fuel damage events had occurred previously. This report summarized interviews with contractor personnel that indicated that fuel pin end cap failures occur in about 10 percent of the fuel pins during disassembly. However, the contractors could not recall another instance when an end cap failure resulted in a building ventilation systems radiation monitor alarming and a building evacuation alarm sounding.

Based on a records review of past CRs, the readiness review team did not identify prior instances of a non-spurious, unplanned high radiation alarm in the FHB. The team interviewed reactor engineering personnel and did not uncover any fuel damage events that were not documented in the Perry Plants corrective action program.

The Readiness Review Report included an analysis of drill and actual emergency events at other operating power reactor sites during 2002 and 2003 that were categorized as NRC inspection findings either because these events were not classified as emergency events, or because they were not classified as emergency events in a timely manner.

No such events at other sites involved fuel handling activities.

Based upon the reviews summarized in Subsections 02.01.b and 02.02.c of this Inspection Report, the inspectors concluded that the licensee had adequately searched for prior occurrences of the issue.

d.

Determine that the root cause evaluation addresses the extent of condition and the extent of cause of the issue.

The Readiness Review Report included extent of condition evaluations of the issue. As summarized previously in this Inspection Report, the licensees extent of condition evaluation adequately encompassed the following topics:

(1) timeliness of emergency declarations at the Perry Plant associated with actual emergencies and emergency classification opportunities during drills and exercises counted as PI opportunities;

(2) NRC inspection findings associated with emergency classification decision making problems at other licensees facilities during recent years actual emergency situations and drills;

(3) previous instances at Perry Plant and other licensees facilities of damage to fuel pin end caps during fuel inspection activities; and a search for other instances of valid FHB radiation monitor alarms at the Perry Plant and other licenses facilities resulting from damage during fuel handling activities. None of these evaluations resulted in the identification of prior occurrences of the issue at the Perry Plant, or a similar issue at another operating power reactor site.

The Readiness Review Report also included extent of cause evaluations of several areas for symptoms similar to those associated with the issue. With respect to command and control of Control Room activities, the timeliness of those required, non-emergency event reports to NRC, which were due in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, were evaluated for the period January 2002 through March 2004. The last untimely, non-emergency event report was in late December 2002. Roughly half of these reports were subsequent to the untimely Alert declaration in March 2003.

The readiness review team also evaluated Nuclear Quality Assurance (NQA) staffs reports since January 2002 for observations of a SMs or USs command and control of Control Room activities during actual plant operations and training sessions. A sample of these NQA reports were independently reviewed by the inspectors. None of these NQA reports documented command and control concerns.

The initial CA associated with CR 03-02408 identified the need for revisions to several procedures related to fuel handling activities to address the issues root causes. The Readiness Review Reports extent of cause evaluation expanded upon these procedure reassessments to encompass all ONI procedures and Fuel Technical (Engineering)

Instructions (FTI-series). In addition, all EALs were evaluated to identify those that required information not available within the Control Room to allow the SM to make an informed emergency classification decision.

The inspectors included that the licensees extent of condition and extent of cause evaluations were adequate.

02.03 Corrective Actions a.

Determine that appropriate corrective actions are specified for each root cause, or that there is an evaluation that no actions are necessary.

The initial CA associated with CR 03-02408 resulted in four corrective actions that were relevant to one or both root causes. The relatively extensive Readiness Review Report included 11 additional corrective actions associated with the root causes, which the readiness review team determined to be unchanged from the root causes identified in the initial CA.

One of the 11 corrective actions resulting from the Readiness Review Report was completed during this NRC Supplemental Inspection. This corrective action involved reassessment of all ONI procedures to determine if existing references to the emergency plan or to the plans EALs were adequately highlighted. As was done following its analogous reassessment of FTI-series procedures, the licensee then generated an additional CR for each of the seven FTI procedures for which enhancement of references to the emergency plan or EALs was deemed appropriate, plus an eighth CR to track the need to revise a relevant procedure writers guide.

The inspectors concluded that all of the aforementioned corrective actions were appropriate and should be adequate to prevent recurrence of the issue.

The inspectors also reviewed revised procedures and training materials that were associated with a sample of the corrective actions that were listed as being completed in the corrective action programs records. The inspectors concluded that these corrective actions had been adequately completed.

b.

Determine that the corrective actions have been prioritized with consideration of the risk significance and regulatory compliance.

The inspectors determined that the corrective action programs records contained accurate information regarding what corrective actions were completed and what other actions were ongoing. Uncompleted corrective actions, which were associated with fuel handling and inspection activities, were prioritized with consideration of risk significance in the sense that they were to be completed prior to the next refueling outage.

Corrective actions involving references in some ONI and FTI procedures to the emergency plan or EALs were reasonably prioritized, since these corrective actions involved enhancing existing references, rather than adding such emergency planning references for the first time to these procedures.

The inspectors discussed corrective actions associated with planned changes to several EALs with the licensees emergency planning staff. The inspectors were satisfied that the licensee adequately understood the need to avoid making EAL changes that could be perceived as decreasing the emergency plans effectiveness without prior NRC approval, and that the licensee adequately understood the need to obtain relevant offsite officials agreement to planned EAL changes.

c.

Determine that a schedule has been established for implementing and completing the corrective actions.

The inspectors determined that corrective actions had been completed on schedule, as documented in corrective action program records. The inspectors discussed the status of ongoing corrective actions with the licensee and did not identify concerns that planned corrective actions would not be completed by their currently scheduled due dates. The inspectors concluded that the overall schedule for completion of corrective actions was reasonable.

d.

Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence.

The CA associated with CR 03-02408 included limited provisions for an effectiveness review of its corrective actions. Only Condition Report Corrective Action (CRCA) 03-02408-01 included an effectiveness review of one revised FTI-series procedure that addressed inspection of spent fuel bundles. As a result, the subsequent Readiness Review Report included expanded provisions for an effectiveness review of all corrective actions associated with that reports extent of condition and extent of cause evaluations. The licensee indicated that this effectiveness review was scheduled in Spring 2005.

The Readiness Review Report also documented the review teams conclusion that the effectiveness of several completed corrective actions was demonstrated by successful performance in several areas. For example, the report accurately noted that both actual emergency declarations that occurred subsequent to April 2003, as well as the associated notifications to offsite officials, were made in a timely manner. The report also noted that no non-emergency event reports, which were made since late December 2002 and had notification deadlines of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, were untimely.

The inspectors concluded that the Readiness Review Report included adequate provisions for an effectiveness review. The timing of this review was reasonable, since the next refueling outage was currently planned to occur in early 2005.

MANAGEMENT MEETINGS

Exit Meeting Summary

The inspectors presented the inspection results to Mr. W. Kanda and other members of licensee management and staff at the conclusion of the inspection on May 28, 2004.

The licensee acknowledged the information presented. No proprietary information was discussed.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

L. Burgwalt, On-site Emergency Planner

D. Cleavenger, Senior Emergency Planner

V. Higaki, Regulatory Affairs Manager

W. Kanda, Vice President - Perry Plant

T. Lentz, Engineering Director

M. McFarland, Staff Superintendent

K. Russell, Compliance Engineer

LIST OF ITEMS

Opened

None.

Closed

05000440/2004003-01 VIO Untimely Actual Alert Declaration on April 24, 2003, Due to Inadequate Use of the Emergency Classification Scheme

Discussed

None.