IR 05000440/2006001

(Eco) Annual Assessment Letter (Report 05000440/2006001)

ML060610400
Person / Time
Site:	Perry
Issue date:	03/02/2006
From:	Caldwell J NRC/RGN-III
To:	Pearce L FirstEnergy Nuclear Operating Co
References
IR-06-001
Download: ML060610400 (8)

Text

rch 2, 2006

SUBJECT:

ANNUAL ASSESSMENT LETTER - PERRY NUCLEAR POWER PLANT (REPORT 05000440/2006001)

Dear Mr. Pearce:

On February 8, 2006, the NRC staff completed its performance review of the Perry Nuclear Power Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2005. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include physical protection information. A separate letter designated and marked as Exempt from Public Disclosure in accordance with 10 CFR 2.390 will include the physical protection review and resultant inspection plan.

Overall, Perry operated in a manner that preserved public health and safety. While Perry met all cornerstone objectives, it remained within the Multiple/Repetitive Degraded Cornerstone column of the Action Matrix with longstanding issues or significant degradation in safety performance. The degraded cornerstones were based on two open White findings in the Mitigating Systems cornerstone and continuing performance deficiencies in Human Performance and Problem Identification and Resolution. FirstEnergy Nuclear Operating Company (FENOC) was initially notified that Perry had entered the Multiple/Repetitive Degraded Cornerstone column in our August 12, 2004, letter.

In response to Perrys transition to the Multiple/Repetitive Degraded Cornerstone column, the NRC conducted an Inspection Procedure (IP) 95003 supplemental inspection from January to May 2005. You responded to the IP 95003 inspection report by letters dated August 8 and August 17, 2005. These letters provided actions that FENOC committed to perform to address issues in the Corrective Action Program, Human Performance, IP 95002 Issue Followup, and Emergency Preparedness areas. The letter also provided information concerning your revised Performance Improvement Initiative (PII). To confirm the agencys understanding of these and other specific actions that FENOC planned to take to improve and sustain performance at Perry, the NRC issued a Confirmatory Action Letter (CAL) on September 28, 2005. The NRC is in the process of conducting CAL followup inspections, in addition to the normal baseline inspection program, to assess the status and confirm the effectiveness of FENOCs commitments and action items outlined in the CAL and the IP 95003 response letters; primarily in the areas of Problem Identification and Resolution, and Human Performance.

Additionally, the staff has identified substantive cross-cutting issues in the areas of Problem Identification and Resolution, and Human Performance. Perry was first informed of these substantive cross-cutting issues in our mid-cycle assessment letter dated August 30, 2004, and our annual assessment letter dated March 2, 2005, respectively, and again in our mid-cycle assessment letter dated August 30, 2005. The two substantive cross-cutting issues were also reflected in the IP 95003 inspection report as well as the 2005 quarterly inspection reports, where examples of continuing problems in the areas of Problem Identification and Resolution, and Human Performance, were documented.

In the area of Problem Identification and Resolution, there continued to be numerous findings identified associated with weaknesses in the causal factor areas of corrective action, identification, and evaluation. These include the failure to quarantine equipment, the failure to identify and correct emergency diesel generator lube oil cooler packing leakage, and the failure to promptly correct an improperly placed thermocouple in a reactor water cleanup system valve room that led to an engineered safety feature (ESF) actuation.

In the area of Human Performance, there were numerous findings related to personnel performance associated with weaknesses in the causal factor areas of personnel and organization. Examples include the failure to develop appropriate procedures for the fill and vent of the engine driven fuel oil pump suction and discharge lines, personnel errors during the calibration of the containment/drywell purge exhaust radiation monitor that resulted in an ESF actuation, and an operator error that resulted in the draining of 8500 gallons of suppression pool water to a floor drain.

We note that Corrective Action Program implementation and overall Human Performance have been, and continue to be, focal points of your Performance Improvement Initiative; yet issues continue to be identified. Therefore, the substantive cross-cutting issues in Human Performance and Problem Identification and Resolution will remain open. We request that you discuss your actions planned and/or implemented to address these substantive cross-cutting issues at the end-of-cycle public meeting.

We will continue to assess your performance in these areas through the implementation of the baseline inspection program, which will include a Problem Identification and Resolution inspection, and the Confirmatory Action Letter followup inspection activities, which will be conducted as CAL action items are completed by your staff. Additionally, on February 24, 2005, the staff issued a Severity Level III Notice of Violation in accordance with the NRCs Enforcement Policy to FENOC for employment discrimination by one of its contractors; Williams Industrial Services Group, LLC, formerly known as Williams Power Corporation. This action addressed a condition that occurred in March 2000. The NRC action also included two Severity Level III Notices of Violation issued to Williams Industrial Services Group for employee protection and deliberate misconduct, and an Order to the former Contract Site Superintendent prohibiting involvement in NRC-licensed activities for 3 years.

In accordance with IMC 0305, Operating Reactor Assessment Program, your plant will be discussed at the upcoming Agency Action Review Meeting. We will notify you via separate correspondence if any agency actions change as an outcome of the meeting.

This letter advises you of our planned inspection effort resulting from the Perry end-of-cycle review. The enclosed inspection plan details the inspections, less those related to physical protection, through September 30, 2007. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspection activities are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs 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).

If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Eric Duncan at (630) 829-9628 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

James L. Caldwell Regional Administrator Docket No. 50-440 License No. NPF-58 Enclosure: Perry Inspection/ Activity Plan See Attached Distribution