Text

IR 05000440-13-004, on 07/01/2013 - 09/30/2013; Perry Nuclear Power Plant. Annual Fire Protection Drill Observation; Occupational Radiation Safety; and Public Radiation Safety
	ML13318A249
Person / Time
Site:	Perry
Issue date:	11/14/2013
From:	Michael Kunowski; NRC/RGN-III/DRP/B5
To:	Harkness E; FirstEnergy Nuclear Operating Co
References
	IR-13-004
	Download: ML13318A249 (59)
	v • d • e

November 14, 2013

SUBJECT:

PERRY NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000440/2013004

Dear Mr. Harkness:

On September 30, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a routine inspection at your Perry Nuclear Power Plant. The enclosed report documents the results of this inspection, which were discussed on October 18, 2013, with Mr. D. Hamilton and other members of your staff.

Based on the results of this inspection, two NRC-identified and two self-revealed findings of very low safety significance were identified. Three of the findings involved violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your corrective action program, the NRC is treating the issues as non-cited violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

Further, the inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Perry Nuclear Power Plant.

If you disagree with the cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Regional Administrator, Region III, and the NRC Resident Inspector at the Perry Nuclear Power Plant. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agencywide Documents Access and Management 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/

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects

Docket No. 05000440 License No. NPF-58

Enclosure:

Inspection Report 05000440/2013004 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-440 License No:

NPF-58 Report No:

05000440/2013004 Licensee:

FirstEnergy Nuclear Operating Company (FENOC)

Facility:

Perry Nuclear Power Plant, Unit 1 Location:

Perry, Ohio Dates:

July 1, 2013, through September 30, 2013 Inspectors:

M. Marshfield, Senior Resident Inspector

J. Nance, Resident Inspector

J. Jandovitz, Project Engineer

R. Jickling, Senior Emergency Preparedness Inspector

M. Phalen, Senior Health Physicist

S. Bell, Health Physicist

Observer:

R. Leidy, Ohio Department of Health,

Bureau of Radiation Protection

Approved by:

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000440/2013004, 07/01/2013 - 09/30/2013; Perry Nuclear Power

Plant. Annual Fire Protection Drill Observation; Occupational Radiation Safety; and Public Radiation Safety.

This report covers a 3-month period of inspection by resident inspectors and announced baseline inspections by regional inspectors. Four Green findings were identified by the inspectors. Three of the findings were considered non-cited violations (NCVs) of NRC regulations. The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within the Cross Cutting Areas, dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance and associated non-cited violation (NCV) of License Condition 2.C(6) for failure to ensure that an individual met the fire drill participation requirements for fire brigade members and fire brigade leaders. Specifically, certified fire brigade members and fire brigade leaders are required to participate in at least two drills per year and in one case the licensee failed to conduct proper drills as required by the license condition. The issue was entered into the licensees corrective action program as Condition Report 2013-12964, and the licensee initiated immediate action to ensure that all current fire brigade members/leaders met drill participation requirements prior to fulfilling those roles.

The inspectors determined that the failure to conduct proper drills was a performance deficiency and was more than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because the finding was associated with the Mitigating Systems Cornerstone attribute of Protection Against External Factors for Fire and adversely affected the associated cornerstone objective of ensuring the reliability and capability of the fire brigade to respond to initiating events to prevent undesirable consequences.

Because the licensee failed to ensure that fire brigade members and fire brigade leaders met the licensees qualification requirements of participating in at least two fire drills per year, the mitigating systems cornerstone attribute to ensure the availability and reliability of the fire brigade to respond to initiating events was impacted. The finding was evaluated using IMC 0609, Significance Determination Process (SDP), Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012. Because the finding involved the Fire Brigade, Table 3, SDP Appendix Router, Section E.1, Fire Protection, directed NRC staff to use IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012. Exhibit 2 of IMC 0609, the Mitigating Systems Screening Questions, Section D.1.a., Fire Brigade, was checked yes because the finding involved the Fire Brigade training and qualification requirements. The first condition under D.1.a.,

The fire brigade demonstrated the ability to meet the required times for fire extinguishment for drill scenarios, was applicable and the finding did not significantly affect the ability of the fire brigade to respond to a fire, so the finding was determined to be of very low safety significance. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component, in that the licensee did not take corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, the licensee failed to identify that all drill requirements for fire brigade personnel as required in Branch Technical Position APCSB 9.5-1, Appendix A, which requires specific factors that qualify a drill for training purposes, was not used to plan and execute drills for personnel re-qualifying for this watch position during 2012 and 2013 (P.1(d)). (Section 1R05.2)

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

Green.

A finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification 5.4.1 was self-revealed through an electronic dosimeter alarm when, on August 6, 2013, a licensee worker inappropriately entered a high radiation area in the overhead of Auxiliary Building 574. The inspectors concluded that the worker failed to comply with the requirements of his radiation work permit that prohibited work 6 feet above floor level until a radiological survey is performed and radiation protection verifies that the area met the requirements of the radiation work permit. This issue was entered into the licensees corrective action program as Condition Report 2013-12077. Corrective actions focused on performance management of the individual involved.

The inspectors reviewed Inspection Manual Chapter (IMC) 0612, Appendix E,

"Examples of Minor Issues," dated August 11, 2009, and determined that the issue was more than minor because it was similar to Example 6(h). The inspectors also determined that the finding was of very low safety significance in accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008. The inspectors identified no cross-cutting issues associated with this finding. (Section 2RS1.1)

Green.

The inspectors reviewed a self-revealed finding (FIN) of very low safety significance involving an unauthorized activity inside a radiologically contaminated locked high radiation area. Specifically, on April 30, 2013, licensee contract personnel inappropriately placed a plastic container of goldfish inside the Turbine Building 620 auxiliary steam tunnel. This issue was entered into the licensees corrective action program as Condition Report 2013-06758. Corrective actions included performance management of the individuals involved.

The inspectors determined that the finding was more than minor, in accordance with Inspection Manual Chapter (IMC) 0612 because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process of radiological exposure and contamination control and adversely affected the associated cornerstone objective to ensure adequate protection of worker health and safety from exposure to radioactive materials during routine civilian nuclear reactor operation. The inspectors also determined that the finding was of very low safety significance in accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated November 28, 2011. Additionally, the inspectors determined that the primary cause of this finding was related to the cross-cutting aspect in the area of human performance in work practices. Specifically, the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety was supported (H.4(c)). (Section 2RS1.2)

Green.

The inspectors identified a finding of very low safety significance and an associated non-cited violation (NCV) of Technical Specification 5.5.1, Offsite Dose Calculation Manual (ODCM). Specifically, the licensee failed to follow the Fish and Invertebrates sampling requirements specified in the ODCM. Corrective actions were being developed in the corrective action program (Condition Report 2013-14987) and senior plant management expressed the understanding that sampling was important and the condition would be corrected.

The finding was more than minor because it was associated with the Public Radiation Safety Cornerstone attribute of program and process of projected offsite dose and adversely affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding was assessed using Inspection Manual Chapter (IMC) 0609,

Attachment D, dated February 12, 2008, for the Public Radiation Safety Significance Determination Process and determined to be of very low safety significance because it involved the Environmental Monitoring Program. Additionally, the inspectors determined that the primary cause of this finding was related to the cross-cutting aspect in the area of human performance in work practices. Specifically, the licensee did not effectively communicate expectations regarding procedural compliance and personnel following procedures (H.4(b)). (Section 2RS7)

B.

Licensee-Identified Violation

A violation of very low safety significance (Green) that was identified by the licensee has been reviewed by the inspectors. Corrective actions planned or taken by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

The plant began the inspection period at 100 percent power. On September 6, 2013, at 12:01 a.m., plant power was reduced for a planned forced outage to replace the V1A 125-volt alternating current (AC) bus regulating transformer control module. At 1:01 p.m. the plant disconnected from the grid and was shutdown. The reactor returned to criticality on September 8 at 9:09 a.m. The plant synchronized to the grid on September 9 at 3:33 a.m. and reached 100 percent power on September 13 and remained at full power for the remainder of the inspection period with the exception of small periods of slightly reduced power to support surveillance testing requirements and minor power reductions for seasonal variations.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant systems:

reactor core isolation cooling;

B annulus exhaust gas treatment system;

Division 2 emergency diesel generator (EDG); and

A emergency closed cooling system.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, Updated Safety Analysis Report (USAR), Technical Specification (TS)requirements, outstanding work orders, condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions.

The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable.

The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies.

The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

These activities constituted four partial system walkdown samples as defined in Inspection Procedure (IP) 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05Q

.1 Routine Resident Inspector Tours

Main article: IP 71111.05Q

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

Fire Zone; 1AB-3B (Auxiliary Building 620' Elevation);

Fire Zone; 0CC-2A, 2B, 2C (Control Complex 599' Elevation);

Fire Zone; 1CC-3B, 3D (Control Complex 620 Elevation) and 1DG-1B (Diesel Generator Building 620 Elevation);

Fire Zone; 0IB-1 (Intermediate Building 574 and Pipe Chase 585 Elevation); and

Fire Zone; 0EW-1A,1B (Emergency Service Water Pump House).

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.

Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.

Documents reviewed are listed in the Attachment to this report.

These activities constituted five quarterly fire protection inspection samples as defined in IP 71111.05-05.

b. Findings

No findings were identified.

.2 Annual Fire Protection Drill Observation

Main article: IP 71111.05A

a. Inspection Scope

On September 18, 2013, the inspectors observed a fire brigade activation for a simulated fire on the junction box for the 480-volt power supply for the nuclear closed cooling pump A motor. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee staff identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

proper wearing of turnout gear and self-contained breathing apparatus;

proper use and layout of fire hoses;

employment of appropriate firefighting techniques;

sufficient firefighting equipment brought to the scene;

effectiveness of fire brigade leader communications, command, and control;

search for victims and propagation of the fire into other plant areas;

smoke removal operations;

utilization of pre-planned strategies;

adherence to the pre-planned drill scenario; and

drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

b. Findings

Introduction:

The inspectors identified a finding of very low safety significance (Green)and associated non-cited-violation of License Condition 2.C(6) for failure to ensure that individuals met requalification fire drill participation requirements for fire brigade members and fire brigade leaders. Specifically, certified fire brigade members and fire brigade leaders are required to participate in at least two drills per year.

Description:

The licensees oversight program conducted a multi-site Fire Protection Audit, MS-C-13-05-31, from May 17, 2013, through July 11, 2013. During that audit several issues were identified at Perry by the audit team. One violation of very low significance (Green), was identified by the licensee, which was documented in NRC IR 05000440/2013003 (ML13219A056), dated August 7, 2013. The finding documented that the licensee took credit, inappropriately, for numerous fire drills in 2011 and 2012.

This finding was documented in the licensees CAP as CR 2013-09402. A peer review was conducted by the licensee of the closure summary for CR 2013-09402. The peer reviewer asked the following question, By not giving credit for some drills, did we still meet the minimum qualification/certification requirements? This was the first opportunity for the licensee to recognize that individuals may not be qualified to fulfill fire brigade member or fire brigade leader positions because they had not completed two fire drills in the past year that conform to the license condition. The response given to the peer review question stated that, FPI-A-B02, Fire Brigade Drills, Rev. 7, Section 6.4.1.2 states Credit for actual Fire Brigade response may be taken by completing the following:

a. Fire Drill Critique Form b. FENOC Attendance Sheet c. Fire Report

The Drill credit that was given did not always include a minimum of the drill objectives as stated in Appendix R and the Branch Technical Position. The procedure does not define that the criteria spelled out in Appendix R and the Branch Technical Position needs to be met for drill credit to be given. This is a deficiency in FPI-A-B02.

Although the minimum objectives for a drill were not always met, the procedure allowed for this drill credit. Because the procedure allowed for credit, no drills were missed by any personnel during the time frame mentioned.

The inspectors reviewed the licensees CR 2013-09402, MS-C-13-05-31: Inappropriate Credit Given for Fire Brigade Drills, dated June 18, 2013, which identified numerous instances where the licensee claimed credit for fire drills which did not meet the license condition requirements. The inspectors identified one instance, involving an individual who fulfilled the role of fire brigade member/leader for an operating crew during June, July, and August 2013, who had not participated in a fire drill that met the license condition in over 18 months.

The inspectors, in August 2013, met with the fire marshal on two different occasions to determine if the licensee had evaluated the continuing qualifications of the fire brigade member/leader based upon participation in fire drills that did not meet the license condition. In both meetings the fire marshal reiterated that although the minimum objectives for a drill were not always met, the procedure allowed for this drill credit and because the procedure allowed for credit, no drills were missed by any personnel during the time frame mentioned, and that all fire brigade personnel were qualified to fulfill those positions. After the second meeting between the fire marshal and the inspectors, the licensee documented the NRCs concerns in CR 2013-12964 on August 21, 2013.

The Immediate Actions Taken section of this CR states, in part, that Currently all fire brigade members have performed fire drills as documented and approved per FPI-A-B02. The current status of all qualified brigade members is documented in the FITS Qual Matrix. The NRC determined fire drills that did not meet requirements imposed by license conditions and licensee procedures should not have been credited, as asserted by the licensee in CR 2013-09402 and in the Immediate Actions Taken section of CR 2013-12964, for fire brigade member/leader qualification/certification requirements.

The inspectors met with the operations manager on August 27, 2013, and discussed their continuing concerns with the qualifications of one fire brigade member/leader that was currently fulfilling those roles in an operating crew despite not having participated in a fire drill that met the license condition in more than 18 months. Following that meeting the licensee took immediate action to ensure that all fire brigade members/leaders met drill participation requirements prior to fulfilling those roles on operating crews.

Analysis:

The inspectors determined that the failure to implement and maintain in effect all provisions of the approved fire protection program was a performance deficiency.

Specifically, the licensee failed to ensure that fire brigade members and fire brigade leaders met the license requirements by participating in at least two fire drills per year, which was within the licensees ability to foresee and correct.

The finding was determined to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because the finding was associated with the Mitigating Systems Cornerstone attribute of Protection Against External Factors for Fire and adversely affected the cornerstone objective of ensuring the reliability and capability of the fire brigade to respond to initiating events to prevent undesirable consequences.

The finding was evaluated using IMC 0609, Significance Determination Process (SDP),0609.04, Initial Characterization of Findings, dated June 19, 2012.

Because the finding involved the fire brigade, Table 3, SDP Appendix Router, Section E.1, Fire Protection, directed NRC staff to use IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012. Exhibit 2 of IMC 0609, the Mitigating Systems Screening Questions, Section D.1.a., Fire Brigade, was checked yes because the finding involved the fire brigade training and qualification requirements. The first condition under D.1.a., The fire brigade demonstrated the ability to meet the required times for fire extinguishment for drill scenarios, was applicable and the finding did not significantly affect the ability of the fire brigade to respond to a fire, so the finding was determined to be of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the CAP component, in that the licensee did not take corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, the licensee failed to identify that all drill requirements for fire brigade personnel as required in Branch Technical Position APCSB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, Appendix A, which requires specific factors that qualify a drill for training purposes, was not used to plan and execute drills for personnel re-qualifying for this watch position during 2012 and 2013 (P.1(d)).

Enforcement:

License Condition 2.C(6) requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR), as amended, and as approved through Safety Evaluation Report NUREG-0887, dated May 1982, and supplement numbers 1 through 10. Section 9A of the USAR described the approved fire protection program.

Section 9A.6. Item 3.III.I describes compliance with Appendix R requirement III.I, Fire Brigade Training and states FENOC will comply as documented in CEI [Cleveland Electric Illuminating] letter dated April 29, 1982, and March 25, 1985. CEI letter dated March 25, 1985, states, in part, that The fire brigade training program will meet criteria stipulated in 10 CFR Part 50, Appendix R, Section III.I which states, in part, that each fire brigade member should participate in each drill, but must participate in at least two drills per year. Section 9.A.5 describes compliance with NRC Branch Technical Position APCSB 9.5-1, Appendix A. Item B.5 states that Training for the Fire Brigade is described in procedures and instructions which are sub-tier to PAP [Perry Administrative Procedure]-1910. Item B.5(b) states, in part, that Drills will be conducted according to procedures and instructions sub-tier to PAP-1910.

Fire Protection Instruction (FPI)-A-B02, Fire Brigade Drills, Revision 7, a procedure incorporated into the licensees Fire Protection Program, PAP-1910, Section 6.2.1 states, in part, that Certified Fire Brigade Members and Fire Brigade Leaders are required to participate in at least two fire drills within their re-qualification year. Contrary to the above, from June 18, 2013, through August 10, 2013, an individual who was listed as a certified fire brigade member and a fire brigade leader had not participated in two fire drills within his requalification year and performed duties as a fire brigade member and fire brigade leader. Because this violation was of very low safety significance and it was entered into the licensees CAP as CR-2013-12964, and the licensee initiated immediate action to ensure that all current fire brigade members/leaders met drill participation requirements prior to fulfilling those roles, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000440/2013004-01, Failure to Meet Fire Brigade Drill Training Requirements).

1R06 Flood Protection Measures

Main article: IP 71111.06

.1 Underground Vaults

a. Inspection Scope

The inspectors selected underground bunkers/manholes subject to flooding that contained cables whose failure could disable risk-significant equipment. The inspectors determined that the cables were not submerged, that splices were intact, and that appropriate cable support structures were in place. In those areas where dewatering devices were used, such as a sump pump, the device was operable and level alarm circuits were set appropriately to ensure that the cables would not be submerged. In those areas without dewatering devices, the inspectors verified that drainage of the area was available, or that the cables were qualified for submergence conditions. The inspectors also reviewed the licensees corrective action documents with respect to past submerged cable issues identified in the CAP to verify the adequacy of the corrective actions. The inspectors performed a walkdown of the following underground bunkers/manholes subject to flooding:

Electrical Safety Manhole #1, Division 2 and Division 3 Safety-Related Circuits;

Electrical Safety Manhole #2, Division 2 and Division 3 Safety-Related Circuits;

Electrical Safety Manhole #3, Division 1 Unit 1 and Division 1 Unit 2 Safety Related-Circuits; and

Electrical Safety Manhole #4, Division 1 Unit 1 and Division 1 Unit 2 Safety-Related Circuits.

Documents reviewed are listed in the Attachment to this report. This inspection constituted one underground vault sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R07 Annual Heat Sink Performance

Main article: IP 71111.07

a. Inspection Scope

The inspectors reviewed the licensees testing of emergency closed cooling A heat exchanger and the residual heat removal A heat exchanger to verify that potential deficiencies did not mask the licensees ability to detect degraded performance, to identify any common cause issues that had the potential to increase risk, and to ensure that the licensee was adequately addressing problems that could result in initiating events that would cause an increase in risk. The inspectors reviewed the licensees observations as compared against acceptance criteria, the correlation of scheduled testing and the frequency of testing, and the impact of instrument inaccuracies on test results. Inspectors also verified that test acceptance criteria considered differences between test conditions, design conditions, and testing conditions. Documents reviewed are listed in the Attachment to this report.

This annual heat sink performance inspection constituted one sample as defined in IP 71111.07-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11Q

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

On July 29, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

licensed operator performance;

crews clarity and formality of communications;

ability to take timely actions in the conservative direction;

prioritization, interpretation, and verification of annunciator alarms;

correct use and implementation of abnormal and emergency procedures;

control board manipulations;

oversight and direction from supervisors; and

ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

Main article: IP 71111.11Q

a. Inspection Scope

On July 16 and July 18, the inspectors observed the operating crew adjust plant equipment to maintain conditions within the design limits of the plant as a result of extended hot weather conditions. The plant remained in a continuous Transmission System Emergency - Hot Weather Alert from Monday, July 15, through Friday, July 19, and had to de-rate several times to maintain condensate and circulation water temperatures within design operating limits. This was an activity that required heightened awareness. The inspectors evaluated licensed operator performance in the following areas:

crews clarity and formality of communications;

ability to take timely conservative actions;

prioritization, interpretation, and verification of annunciator trends/alarms;

correct use and implementation of procedures;

control board/component manipulations;

oversight and direction from supervisors;

documentation of activities; and

pre-activity and post-activity briefs and use of human error prevention techniques.

The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity/risk sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following risk-significant systems:

R14, 125-volt AC current vital distribution system;

B33, reactor recirculation system; and

C22, redundant reactivity control system.

The inspectors reviewed events, such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems, and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

implementing appropriate work practices;

identifying and addressing common cause failures;

scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

characterizing system reliability issues for performance;

charging unavailability for performance;

trending key parameters for condition monitoring;

ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted three quarterly maintenance effectiveness samples as defined in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

upgrade auxiliary building ventilation radiation monitor D-17;

high-pressure core spray inoperability with Unit 1 and Unit 2 air compressor equipment lineup;

scram discharge vent valve failed closed too fast and required troubleshooting and repair;

heating ventilation and air conditioning 'A' trains out of service for maintenance;

uninterruptable power supplies system 125-volt AC V1A regulating transformer control box replacement; and

residual heat removal A and low-pressure core spray water leg pump replacement.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Documents reviewed are listed in the Attachment to this report.

These maintenance risk assessments and emergent work control activities constituted six samples as defined in IP 71111.13-05.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed the following issues:

alternate decay heat removal Cycle 15 operability determination;

Divisions 1, 2, and 3 EDG operability determination;

control complex chiller A leaking chill water isolation check valve;

motor feed pump and support system functionality determination;

A End-of-cycle Recirculation Pump Trip (EOC-RPT) and reactor protection system Channel 'A' operability determination; and

125-volt AC vital bus - V1A operability determination.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS and USAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.

These operability inspections constituted six samples as defined in IP 71111.15-05.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

a. Inspection Scope

The inspectors reviewed the modification for the radioactive waste control system upgrade The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the USAR, and the TS, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; the modification operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modification did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one permanent plant modification sample as defined in IP 71111.18-05.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

M23/M24 motor control center switchgear and battery rooms' recirculation fan 'A' maintenance and repair;

motor-driven fire pump shaft repair and retest;

scram discharge vent and drain valve air regulator repaired and retested;

annulus exhaust gas treatment system general maintenance retest;

125-volt AC vital bus - V1A repair and retest; and

turbine control valve number 3 repair and retest.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted six post-maintenance testing sample as defined in IP 71111.19-05.

b. Findings

No findings were identified.

1R20 Forced Outage Activities

Main article: IP 71111.20

a. Inspection Scope

The inspectors evaluated outage activities for a forced outage that began on September 6 and continued through September 9, 2013. The inspectors reviewed activities to ensure that the licensee considered risk in developing, planning, and implementing the outage schedule.

The inspectors observed or reviewed the reactor shutdown and cooldown, outage equipment configuration and risk management, electrical lineups, selected clearances, control and monitoring of decay heat removal, control of containment activities, personnel fatigue management, startup and heatup activities, and identification and resolution of problems associated with the outage. The outage was the result of the failure of the R14 125-volt AC V1A regulating transformer control box to control voltage on the V1A bus. Although this bus was not a safety-related bus, the plant would not be able to remain at power if the bus became de-energized. The licensee was concerned with continued operations with higher-than-normal voltage on V1A degrading equipment powered off the bus over an extended period of time. The control unit was replaced and tested satisfactorily. Additional work items were also completed while the reactor was shut down to minimize dose to maintenance workers.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one other outage sample as defined in IP 71111.20-05.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

SVI-E12-T2001; RHR A Pump and Valve Operability Test (routine testing);

SVI-E22-T2001; HPCS Pump and Valve Operability Test (in-service testing);

SVI-E22-T1319; Diesel Generator Start and Load Division 3 (routine testing);

SVI-P45-T2003; HPCS ESW Pump and Valve Operability Test (routine testing);

SVI-R43-T1348; Division 2 Standby Diesel Generator 24 Hour Run and Hot Restart (routine testing); and

SVI-E12-T1196B; LPCI Pump B Discharge Flow-Low (Bypass) Channel Functional for 1E12-N652B (routine testing).

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

did preconditioning occur;

the effects of the testing were adequately addressed by control room personnel or engineers prior to the commencement of the testing;

acceptance criteria were clearly stated, demonstrated operational readiness, and consistent with the system design basis;

plant equipment calibration was correct, accurate, and properly documented;

as-left setpoints were within required ranges; and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;

measuring and test equipment calibration was current;

test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

test data and results were accurate, complete, within limits, and valid;

test equipment was removed after testing;

where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

equipment was returned to a position or status required to support the performance of its safety functions; and

all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted five routine surveillance testing samples and one in-service testing sample as defined in IP 71111.22, Sections -02 and -05.

b. Findings

No findings were identified.

1EP2 Alert and Notification System Evaluation

Main article: IP 71114.02

a. Inspection Scope

The inspectors held discussions with the emergency preparedness (EP) staff regarding the operation, maintenance, and periodic testing of the primary and backup Alert and Notification System (ANS) in the plume pathway Emergency Planning Zone. The inspectors reviewed monthly trend reports and siren test failure records from July 2012 through July 2013. Information gathered during document reviews and interviews was used to determine whether the ANS equipment was maintained and tested in accordance with Emergency Plan commitments and procedures. The inspectors also observed a weekly test of the ANS system. Documents reviewed are listed in the to this report.

This ANS evaluation inspection constituted one sample as defined in IP 71114.02-06.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

Main article: IP 71114.03

a. Inspection Scope

The inspectors reviewed and discussed with plant EP staff the Emergency Plan commitments and procedures for Emergency Response Organization (ERO) on-shift and augmentation staffing levels. A sample of approximately 50 ERO training records was reviewed to evaluate ERO key and support positional training. The inspectors reviewed the ERO augmentation system and activation process, the primary and alternate methods of initiating ERO activation, unannounced off-hour augmentation tests from August 2011 through August 2013, and the provisions for maintaining the plants ERO roster.

The inspectors reviewed a sample of corrective actions related to the facilitys ERO staffing and augmentation system program and activities from September 2011 through August 2013 to determine whether corrective actions were completed in accordance with the site's CAP. Documents reviewed are listed in the Attachment to this report.

This ERO staffing and augmentation system inspection constituted one sample as defined in IP 71114.03-06.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

Main article: IP 71114.05

a. Inspection Scope

The inspectors reviewed a sample of nuclear oversight staffs audits of the EP program to determine whether these independent assessments met the requirements of 10 CFR 50.54(t). The inspectors also reviewed critique reports and samples of CAP records associated with the 2012 biennial exercise, as well as various EP drills conducted, in order to determine if the licensee fulfilled its drill commitments, and to evaluate the licensees efforts to identify, track, and resolve concerns identified during these activities. The inspectors reviewed a sample of EP items and corrective actions related to the facilitys EP program and activities from September 2011 through August 2013 to determine whether corrective actions were completed in accordance with the site's CAP. Documents reviewed are listed in the Attachment to this report.

This correction of EP weaknesses and deficiencies inspection constituted one sample as defined in IP 71114.05-06.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on July 10, 2013, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Simulator Control Room and Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the licensee drill critique to compare any inspector-observed weakness with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b. Findings

No findings were identified.

.2 Training Observation

a. Inspection Scope

The inspector observed a simulator training evolution for licensed operators on July 29, 2013, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the CAP. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.

This inspection of the licensees training evolution with EP drill aspects constituted one sample as defined in IP 71114.06-06.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

Main article: IP 71124.01

.1 Instructions to Workers (02.03)

a. Inspection Scope

The inspectors reviewed the following radiation work permits (RWPs) used to access high radiation areas and evaluated the specified work control instructions or control barriers:

RWP 130102, 1G61C0012A; Auxiliary Building Floor Drain Sump Pump Replacement;

RWP 136009, Containment/Drywell General Maintenance Activities; and

RWP 126021; Reactor Reassembly.

For these RWPs, the inspectors assessed whether allowable stay times or permissible dose (including from the intake of radioactive material) for radiologically significant work under each RWP were clearly identified.

The inspection activities supplement those documented in NRC IR 05000440/2013003.

b. Findings

Introduction:

A finding of very low safety significance and an NCV of TS 5.4.1 was self-revealed when a licensee worker inappropriately entered a high radiation area in the overhead of Auxiliary Building elevation 574.

Description:

On August 6, 2013, two licensee maintenance workers were performing a walkdown in the Auxiliary Building elevation 574 of the floor drain sump pump area.

The walk down was to support demobilization of the work zone after work on the sump pumps. Area demobilization included removing a chain-fall that was suspended in the area at about 30 feet in the overhead. From floor level, the workers could not get a clear view of how the chain-fall was secured in the overhead. Consequently, one of the workers proceeded to climb on plant equipment and scale an area wall such that the worker was positioned a nominal 20 feet into the overhead. At that point, the worker had an unobstructed view of how the chain-fall was secured and the efforts that it would take to demobilize the work zone.

Climbing above 6 feet off floor level is prohibited at Perry Nuclear Power Plant (NOP-OP-1002, Conduct of Operations) without specific radiation protection approval.

These areas of the plant are not routinely surveyed. The licensees normal course of operation is to survey these areas as needed when workers need access to the overhead. Plant workers are trained to contact radiation protection for an updated survey as a part of radiation worker training. This requirement is included in each station RWP, and is a part of each workers briefing upon entering the radiologically controlled area (RCA) of the plant. Additionally, safe work practices at the Perry Nuclear Power Plant require that a job safety analysis is performed to determine the safest way to access overhead work locations.

Through interviews, the licensee determined that the workers were focused on the task at hand and failed to notify radiation protection of the need to survey the overhead area.

Dose rates in the overhead were a nominal 130 milliRem/hour (mRem/hr) at 30 centimeters

(cm) from the overhead piping. The 130 mRem/hr dose rate in the overhead was in excess of the RWP electronic dosimeter (ED) dose rate alarm setpoint of 95 mRem/hr. The ED of the worker that climbed into the overhead alarmed when he entered the elevated dose rate area of the overhead. The worker immediately left the area and notified radiation protection of the ED alarm and of his actions. Licensee records indicate that the second maintenance worker that was in the work area did not intervene to stop the first worker from climbing. Licensee corrective actions for this issue focused on performance management of the individuals involved.

Analysis:

The inspectors determined that the failure of the licensee worker to comply with his RWP, radiation worker training, and RCA entry briefing requirements was a performance deficiency. The inspectors determined that the cause of the performance deficiency was reasonably within the licensees ability to foresee and correct and should have been prevented. The finding was not subject to traditional enforcement since the incident did not have a significant safety consequence, did not impact the NRCs ability to perform its regulatory function, and was not willful.

The inspectors reviewed IMC 0612, Appendix E, "Examples of Minor Issues," dated August 11, 2009, and determined that the issue was more than minor because it was similar to Example 6(h). The finding was assessed using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, and was determined to be of very low safety significance. Specifically, the finding was not an as-low-as-is-reasonably achievable (ALARA) planning issue, there was no overexposure, nor substantial potential for an overexposure, and the licensees ability to assess dose was not compromised.

The inspectors reviewed this finding and determined that no cross-cutting aspect was applicable in accordance with IMC 0305 Operating Reactor Assessment Program, dated June 13, 2012, and IMC 0310, Components Within the Cross-Cutting Areas, dated October 28, 2011.

Enforcement:

Technical Specification 5.4.1 requires that written procedures be established, implemented, and maintained covering the activities in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, dated February 1978. Procedures specified in RG 1.33 include radiation protection procedures for an RWP. Radiation Work Permit 130102 prohibited work 6 feet above floor level until a radiological survey was performed and radiation protection verified that the area met the requirements of the RWP.

Contrary to the above, on August 6, 2013, a licensee worker who was signed-in on RWP 130102 climbed a nominal 20 feet into the overhead of the Auxiliary Building elevation 574 near the floor drain sump pump to assess removing a chain-fall while demobilizing the floor drain sump pump work area. Since the issue was of very low safety significance, corrective actions were taken as described above, and the issue was entered into the licensees CAP (as CR 2013-12077), the violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000440/2013004-02, Worker Access Into a High Radiation Area Contrary to the Requirements of the Radiation Work Permit).

.2 Radiation Worker Performance (02.07)

a. Inspection Scope

The inspectors observed radiation worker performance with respect to stated radiation protection work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the radiation work permit controls/limits in place, and whether their performance reflected the level of radiological hazards present.

The inspectors reviewed radiological problem reports since the last inspection that found the cause of the event to be human performance errors. The inspectors evaluated whether there was an observable pattern traceable to a similar cause. The inspectors assessed whether this perspective matched the corrective action approach taken by the licensee to resolve the reported problems. The inspectors discussed with the radiation protection manager any problems with the corrective actions planned or taken.

The inspection activities supplement those documented in NRC IR 05000440/2013003 and constitute one complete sample as defined in IP 71124.01-05.

b. Findings

Introduction:

The inspectors reviewed a self-revealed finding of very low safety significance involving an unauthorized activity inside a radiologically contaminated locked high radiation area contrary to the requirements of licensee procedure NOBP-OP-4009, Radworker Expectations. This procedure requires workers to use work practices that minimize the potential for unnecessary dose or personnel contamination events. Specifically, licensee contract personnel inappropriately placed a container of goldfish inside the Turbine Building 620 elevation in the auxiliary steam tunnel.

Description:

Turbine Building 620 elevation auxiliary steam tunnel is in a radiologically controlled area of the plant controlled as a contaminated locked high radiation area.

Radiological conditions upon entering the room were a nominal 1000 dpm per 100 cm2 for loose surface contamination and radiation area dose rates were a nominal 30 mRem/hr in open, accessible areas. Once inside the auxiliary steam tunnel, workers had unencumbered access to a valve/piping pit area that had loose surface contamination of a nominal 45,000 dpm per 100 cm2 and radiation area dose rates to a nominal 1600 mRem/hr at 30 cm from plant piping/equipment. At the time of the event, the area was being physically guarded by a locked high radiation area access control guard in order to prevent inadvertent entry.

On April 30, 2013, during refueling outage 14 (1RFO14), two goldfish were found in the auxiliary steam tunnel 620 elevation inside a 2-quart plastic container. The plastic container was located on top of a black catch basin, which was used for containing feedwater flow venturi leakage during the previous operating cycle. The individual that discovered the goldfish was in the process of picking up trash and equipment. This individual noticed the plastic container sitting in a black catch basin and observed that there were two goldfish inside the plastic container. The plastic container held approximately 3 inches of water. The individual removed the plastic container from the black catch basin and informed a radiation protection technician. The radiation protection technician transported the plastic container to the contaminated area boundary step-off pad and asked the access control guard if he knew how the fish were brought into the area. The access control guard responded that he did not know when or how the goldfish had been brought into the auxiliary steam tunnel.

Upon exiting the auxiliary steam tunnel, the radiation protection technician transported the plastic container with the goldfish to the chemistry laboratory and turned custody of the goldfish over to the chemistry supervisor. Chemistry personnel then transferred the goldfish into a separate container with demineralized water and performed an isotopic analysis on the goldfish. The goldfish were found to be radioactively contaminated with trace amounts of activated corrosion products.

Upon notification, plant management initiated an extensive investigation that included a contracted team of security specialists, to determine how and why the goldfish were brought into the plant. Ultimately, it was determined that the goldfish were brought into the plant and into the auxiliary steam tunnel locked high radiation area as part of a prank, unrelated to any legitimate work activity or process. The investigation included extent-of-condition reviews that assessed the extent of condition of the prank; and assessed the professional integrity and trustworthiness of the individuals involved. Six contract personnel were determined to be involved to more or lesser extents, resulting in the licensee implementing its Security and Radiological Safety Performance Management Programs.

The inspectors determined that individual radiation exposures related to this issue, including extent-of-condition walkdowns by licensee personnel in the auxiliary steam tunnel, resulted in unintended and unnecessary radiation exposures to those involved.

Additionally, the inspectors determined that the actual exposures received were low.

Specifically, the goldfish were placed in a relatively lower dose rate area of the auxiliary steam tunnel and not in the elevated dose rate areas of the valve/piping pit.

Analysis:

The inspectors determined that bringing the goldfish into a radiologically contaminated locked high radiation area of the plant as part of a prank, unrelated to any legitimate work activity or process, was a performance deficiency in not meeting the requirements of licensee procedure NOBP-OP-4009, Radworker Expectations, that require workers to use work practices that minimize the potential for unnecessary dose or personnel contamination events.

The inspectors reviewed the guidance in IMC 0612, Appendix E, Examples of Minor Issues, dated August 11, 2009, but did not identify any examples similar to the performance deficiency. However, in accordance with IMC 0612, the inspectors determined that the finding was more than minor because it affected the Occupational Radiation Safety Cornerstone objective to ensure adequate protection of worker health and safety from exposure to radioactive materials during routine civilian nuclear reactor operation. The conditions affected the attribute of program and process of radiological exposure and contamination control. Specifically, the placing of the goldfish in the auxiliary steam tunnel (a contaminated locked high radiation area) resulted in unintended exposure to personnel, had the potential to result in more significant unnecessary radiological exposures to personnel, and resulted in the generation of unnecessary radiologically contaminated biological waste. Consequently, the inspectors determined that the performance deficiency was a finding of more than minor safety significance.

In accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined that the finding had very low safety significance because the finding was not an as-low-as-reasonably-achievable planning issue, there was no overexposure or potential for overexposure, and the licensees ability to assess dose was not compromised.

Corrective actions included performance management of the individuals involved.

The inspectors identified that the most significant contributor to the finding was a cross-cutting aspect in the area of human performance in work practices. Specifically, the licensee ensures supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported (H.4(c)).

Enforcement:

Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory requirement. The issue was entered into the licensees CAP as CR 2013-06758 and corrective actions were implemented to address the issue (FIN 05000440/2013004-03, Unprofessional Worker Conduct Inside a Locked High Radiation Area in the Turbine Building 620 Auxiliary Steam Tunnel).

2RS2 Occupational As-Low-As-Is-Reasonably-Achievable Planning and Controls

Main article: IP 71124.02

The inspection activities supplement those documented in NRC IRs 05000440/2012003 and 05000440/2013003, and constitute one complete sample as defined in IP 71124.02-

05.

.1 Radiological Work Planning (02.02)

The inspectors reviewed the annual radiological environmental operating reports and the results of any licensee assessments since the last inspection to assess whether the Radiological Environmental Monitoring Program (REMP) was implemented in accordance with the TSs and Offsite Dose Calculation Manual (ODCM). This review included reported changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, Inter-Laboratory Comparison Program, and analysis of data.

The inspectors reviewed the ODCM to identify locations of environmental monitoring stations.

The inspectors reviewed the USAR for information regarding the Environmental Monitoring Program and meteorological monitoring instrumentation.

The inspectors reviewed quality assurance audit results of the program to assist in choosing inspection smart samples. The inspectors also reviewed audits and technical evaluations performed on the vendor laboratory if used.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, report to determine if the licensee was sampling, as appropriate, for the predominant and dose-causing radionuclides likely to be released in effluents.

b. Findings

No findings were identified.

.2 Site Inspection (02.02)

a. Inspection Scope

The inspectors walked down selected air sampling stations and thermoluminescent dosimeter monitoring stations to determine whether they were located as described in the ODCM and to determine the equipment material condition. Consistent with smart sampling, the air sampling stations were selected based on the locations with the highest X/Q, D/Q wind sectors, and thermoluminescent dosimeters were selected based on the most risk-significant locations (e.g., those that have the highest potential for public dose impact).

For the air samplers and thermoluminescent dosimeters selected, the inspectors reviewed the calibration and maintenance records to evaluate whether they demonstrated adequate operability of these components. Additionally, the review included the calibration and maintenance records of select composite water samplers.

The inspectors assessed whether the licensee had initiated sampling of other appropriate media upon loss of a required sampling station.

The inspectors observed the collection and preparation of environmental samples from different environmental media (e.g., ground and surface water, milk, vegetation, sediment, and soil) as available to determine if environmental sampling was representative of the release pathways as specified in the ODCM and if sampling techniques were in accordance with procedures.

Based on direct observation and review of records, the inspectors assessed whether the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the USAR, NRC RG 1.23, Meteorological Monitoring Programs for Nuclear Power Plants, and licensee procedures. The inspectors assessed whether the meteorological data readout and recording instruments in the control room and, if applicable, at the tower were operable.

The inspectors evaluated whether missed and/or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, inoperable sampler, lost thermoluminescent dosimeter, or anomalous measurement to determine if the licensee identified the cause and implemented corrective actions. The inspectors reviewed the licensees assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection) and reviewed the associated radioactive effluent release data that was the source of the released material.

The inspectors selected structures, systems, or components that involve or could reasonably involve licensed material for which there is a credible mechanism for licensed material to reach ground water, and assessed whether the licensee implemented a Sampling and Monitoring Program sufficient to detect leakage of these structures, systems, or components to ground water.

The inspectors evaluated whether records, as required by 10 CFR 50.75(g), of leaks, spills, and remediation since the previous inspection were retained in a retrievable manner.

The inspectors reviewed any significant changes made by the licensee to the ODCM as the result of changes to the land census, long-term meteorological conditions (3-year average), or modifications to the sampler stations since the last inspection. They reviewed technical justifications for any changed sampling locations to evaluate whether the licensee performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The licensee uses a vendor laboratory to analyze the REMP samples so the inspectors reviewed the results of the vendors Quality Control Program, including the inter-laboratory comparison, to assess the adequacy of the vendors program.

The inspectors reviewed the results of the licensees Inter-Laboratory Comparison Program to evaluate the adequacy of environmental sample analyses performed by the licensee. The inspectors assessed whether the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility. If applicable, the inspectors reviewed the licensees determination of any bias to the data and the overall effect on the REMP.

b. Findings

Introduction:

The inspectors identified a finding of very low safety significance and an associated NCV of TS 5.5.1, Offsite Dose Calculation Manual (ODCM). Specifically, the licensee failed to follow the Fish and Invertebrates sampling requirements specified in the ODCM.

Description:

In April 2002, the licensee revised its ODCM and reduced its scope of radioactive sampling of fish from multiple samples from a nominal 32 species to one species of fish being analyzed. The technical bases for the reduced scope of fish sample was primarily based on a nominal 15-year history of sampling and radiochemical analyses of various species of fish and finding no radioactivity attributable to plant operations. In May 2008, the NRC identified a minor violation of regulatory requirements, in that, the technical bases for the 2002 changes to the ODCM were inadequate. Specifically, the NRC detailed to the licensee that an Environmental Sampling and Monitoring Program of fish near the Perry Nuclear Power Plant should detect minimal radioactive material, based upon the minimal radioactive material that was released in plant effluents. Additionally, the NRC detailed to the licensee that a proper technical evaluation should address the basis technical guidance provided in NUREG-1302. Specifically, that a REMP include the sampling and analysis of each commercially and recreationally important species of fish and invertebrates in the vicinity of plant discharges and a sample of the same species in areas not influenced by plant discharges. In 2008, the licensee initiated a CAP document (CR 2008-40760) and increased its environmental fish sampling population from one sample species to two sample species. Although the fish species that were to be sampled (walleye and yellow perch) were indicative of the majority of the consumed species of fish near the station, the inspectors identified that the increased sampling was not effectively implemented.

Specifically, licensee fish sampling conducted in 2010, 2011, and 2012 was limited to one species of fish and in 2012 the licensee failed to collect any control fish samples as required by the licensees ODCM. Compliance to the ODCM maintains the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, in order to not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

Analysis:

The failure to perform representative sampling of fish in order to accurately assess ingestion radiation as required by the ODCM is a performance deficiency, because the licensee failed to meet the requirement and the cause of this issue was reasonably within its ability to foresee and correct, and should have been prevented.

The finding was not subject to traditional enforcement since the incident did not have a significant safety consequence, did not impact the NRCs ability to perform its regulatory function, and was not willful.

The inspectors reviewed the guidance in IMC 0612, Appendix E, Examples of Minor Issues, dated August 11, 2009, but did not identify any examples similar to the performance deficiency. However, in accordance with IMC 0612, the inspectors determined that the finding was more than minor because it was associated with the Public Radiation Safety Cornerstone attribute of program and process of projected offsite dose and adversely affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain. The finding was assessed using IMC 0609, D for the Public Radiation Safety SDP and determined to be of very low safety significance (Green) because it involved the Environmental Monitoring Program.

Corrective actions were being developed and senior plant management expressed the understanding that sampling was important and the condition would be corrected. The inspectors also determined that the primary cause of this finding was related to the cross-cutting aspect in the area of human performance in work practices. Specifically, the licensee did not effectively communicate expectations regarding procedural compliance and personnel following procedures (H.4(b)).

Enforcement:

Technical Specification 5.5.1.a states that the ODCM shall contain the methodology and parameters used in the conduct of the REMP. Section 5.1 of the ODCM states that environmental samples shall be collected and analyzed in accordance with Table 5.1-1, RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM.

Section 4.b of Table 5.1-1 requires two or more commercially and/or recreationally important species in vicinity of the plant discharge area to be collected during fishing season.

Contrary to the above, as of September 27, 2013, the licensee failed to perform representative sampling of fish in accordance with the ODCM. This was a violation.

Since the licensee documented this issue in its CAP (CR-2013-14987) and because the violation is of very low safety significance, it is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 0500440/2013004-04, Failure to Perform Representative Sampling of Fish in Order to Accurately Assess Ingestion Radiation as Required by the ODCM).

.3 Identification and Resolution of Problems (02.03)

a. Inspection Scope

The inspectors assessed whether problems associated with the REMP were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees CAP. Additionally, they assessed the appropriateness of the corrective actions for a selected sample of problems documented by the licensee that involved the REMP.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08) This inspection constituted one complete sample as defined in IP 71124.08-05.

.1 Inspection Planning (02.01)

a. Inspection Scope

The inspectors reviewed the solid radioactive waste system description in the USAR, the Process Control Program (PCP), and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste disposed.

The inspectors reviewed the scope of any quality assurance audits in this area since the last inspection to gain insights into the licensees performance and inform the smart sampling inspection planning.

b. Findings

No findings were identified.

.2 Radioactive Material Storage (02.02)

a. Inspection Scope

The inspectors selected areas where containers of radioactive waste are stored and evaluated whether the containers were labeled in accordance with 10 CFR 20.1904, Labeling Containers, or controlled in accordance with 10 CFR 20.1905, Exemptions to Labeling Requirements, as appropriate.

The inspectors assessed whether the radioactive material storage areas were controlled and posted in accordance with the requirements of 10 CFR Part 20, Standards for Protection Against Radiation. For materials stored or used in the controlled or unrestricted areas, the inspectors evaluated whether they were secured against unauthorized removal and controlled in accordance with 10 CFR 20.1801, Security of Stored Material, and 10 CFR 20.1802, Control of Material Not in Storage, as appropriate.

The inspectors evaluated whether the licensee established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water) that was sufficient to identify potential unmonitored, unplanned releases or nonconformance with waste disposal requirements.

The inspectors selected containers of stored radioactive material and assessed them for signs of swelling, leakage, and deformation.

b. Findings

No findings were identified.

.3 Radioactive Waste System Walkdown (02.03)

a. Inspection Scope

The inspectors walked down accessible portions of select radioactive waste processing systems to assess whether the current system configuration and operation agreed with the descriptions in the USAR, ODCM, and PCP.

The inspectors reviewed administrative and/or physical controls (i.e., drainage and isolation of the system from other systems) to assess whether the equipment which is not in service or abandoned in place would not contribute to an unmonitored release path and/or affect operating systems or be a source of unnecessary personnel exposure.

The inspectors assessed whether the licensee reviewed the safety significance of systems and equipment abandoned in place in accordance with 10 CFR 50.59, Changes, Tests, and Experiments.

The inspectors reviewed the adequacy of changes made to the radioactive waste processing systems since the last inspection. The inspectors evaluated whether changes from what is described in the USAR were reviewed and documented in accordance with 10 CFR 50.59, as appropriate, and to assess the impact on radiation doses to members of the public.

The inspectors selected processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers and assessed whether the waste stream mixing, sampling procedures, and methodology for waste concentration averaging were consistent with the PCP, and provided representative samples of the waste product for the purposes of waste classification as described in 10 CFR 61.55, Waste Classification.

For those systems that provide tank recirculation, the inspectors evaluated whether the tank recirculation procedures provided sufficient mixing.

The inspectors assessed whether the licensees PCP correctly described the current methods and procedures for dewatering and waste stabilization (e.g., removal of freestanding liquid).

b. Findings

No findings were identified.

.4 Waste Characterization and Classification (02.04)

a. Inspection Scope

The inspectors selected the following radioactive waste streams for review:

bead resin;

dry active waste; and

reactor water clean-up resin.

For the waste streams listed above, the inspectors assessed whether the licensees radiochemical sample analysis results (i.e., 10 CFR Part 61 analysis) were sufficient to support radioactive waste characterization as required by 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste. The inspectors evaluated whether the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current 10 CFR Part 61 analysis for the selected radioactive waste streams.

The inspectors evaluated whether changes to plant operational parameters were taken into account to:

(1) maintain the validity of the waste stream composition data between the annual or biennial sample analysis update; and

(2) assure that waste shipments continued to meet the requirements of 10 CFR Part 61 for the waste streams selected above.

The inspectors evaluated whether the licensee established and maintained an adequate Quality Assurance Program to ensure compliance with the waste classification and characterization requirements of 10 CFR 61.55 and 10 CFR 61.56, Waste Characteristics.

b. Findings

No findings were identified.

.5 Shipment Preparation (02.05)

a. Inspection Scope

The inspectors observed shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. The inspectors assessed whether the requirements of applicable transport cask certificate of compliance had been met. The inspectors evaluated whether the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated whether the licensees procedures for cask loading and closure procedures were consistent with the vendors current approved procedures.

The inspectors observed radiation workers during the conduct of radioactive waste processing and radioactive material shipment preparation and receipt activities. The inspectors assessed whether the shippers were knowledgeable of the shipping regulations and whether shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport with respect to:

the licensees response to NRC Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, dated August 10, 1979; and

Title 49 CFR Part 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans, Subpart H, Training.

Additionally, the inspectors assessed whether the licensees training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.

b. Findings

No findings were identified.

.6 Shipping Records (02.06)

a. Inspection Scope

The inspectors evaluated whether the shipping documents indicated the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and United Nations number for the following radioactive shipments:

12-3003; Radioactive Material Shipment Irradiated Coupon;

13-1003; Radioactive Waste Shipment Bead Resin;

13-1002; Radioactive Waste Shipment Bead Resin;

13-3080; Radioactive Material Shipment Irradiated Coupon; and

13-1015; Radioactive Waste Shipment Powered Resin.

Additionally, the inspectors assessed whether the shipment placarding was consistent with the information in the shipping documentation.

b. Findings

No findings were identified.

.7 Identification and Resolution of Problems (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with radioactive waste processing, handling, storage, and transportation were being identified by the licensee at an appropriate threshold, were properly characterized, and were properly addressed for resolution in the licensees CAP. Additionally, the inspectors evaluated whether the corrective actions were appropriate for a selected sample of problems documented by the licensee that involve radioactive waste processing, handling, storage, and transportation.

The inspectors reviewed results of selected audits performed since the last inspection of this program and evaluated the adequacy of the licensees corrective actions for issues identified during those audits.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems

Main article: IP 71152

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

To assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily condition report packages.

These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. Findings

No findings were identified.

.3 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of January 1, 2013, through June 30, 2013, although some examples expanded beyond those dates where the scope of the trend warranted.

The review also included issues documented outside of the normal CAP in major equipment problem lists, repetitive and/or reworks maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and maintenance rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 R14 System - 125-Volt AC Vital Transformer High Voltage

a. Inspection Scope

The inspectors reviewed the plants response to high voltage on the 125-volt AC V1A bus. The high voltage was caused by a failed aluminum electrolytic capacitor in the regulating transformer control module. Upon discovery of the high voltage condition on August 30, 2013, the licensee created an Operational Decision-Making Issue for operating the plant in a degraded condition for a short period of time while preparations were made to take the plant off-line on September 6 in an orderly fashion to repair the V1A regulating transformer. The licensee replaced the regulating transformer control module and completed additional forced outage planned activities prior to restarting the plant on September 8. Documents reviewed are listed in the Attachment to this report.

This event follow-up review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

.2 (Closed) Licensee Event Report (LER) 05000440/2013-003-00:

Shutdown Required by Technical Specifications Due to RCS Pressure Boundary Leakage This event, which occurred on June 15, 2013, was identified by licensee inspections inside the drywell while the reactor was in Mode 1, at approximately 8 percent rated thermal power. A planned down power had been commenced on June 14, to inspect the drywell for sources of unidentified leakage. During those inspections, two sources of leakage were identified and one was later classified as through-wall leakage from the reactor coolant system. A plant shutdown was performed in accordance with TS 3.4.5, RCS Operational Leakage, and the plant entered into cold shutdown on June 16 at 1:58 p.m. Repairs were made and the licensee completed its extent-of-condition investigation and root cause analysis under CR 2013-09255. The inspectors reviewed the LER submittal and root cause. The inspectors determined that no additional deficiencies were identified by the licensee. Documents reviewed are listed in the to this report. This LER is closed.

This event follow-up review constituted one sample as defined in IP 71153-05.

4OA5 Other Activities

.1 Follow-up Reviews in Accordance with IP 71151, for URI 05000440/2012005-07

The inspectors performed follow-up reviews in accordance with IP 71151, for URI 05000440/2012005-07, for Follow-up to Occupational Radiation Safety Performance Indicator Verification. Results of the inspectors reviews are documented in section 4OA1.5. This URI is closed.

.2 Correction to Input for Temporary Instructions (TI)-2515/182 - Review of the Industry

Initiative to Control Degradation of Underground Piping and Tanks The TI-2515/182 inspection completion, documented in NRC IR 2013002 (ML13130A326), contained a link to the specific questions the inspection focused on.

The link provided in the report was incorrect; the following is the correct link:

http://www.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf

4OA6 Meetings

.1

Exit Meeting Summary

On October 18, 2013, the inspectors presented the inspection results to Mr. D. Hamilton and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

.2 Interim Exit Meetings

Interim exits were conducted for:

The inspection results for the areas of radiological hazard assessment and exposure controls; occupational ALARA planning and controls; radioactive solid waste processing and radioactive material handling, storage, and transportation; and RCS specific activity and occupational exposure control effectiveness performance indicator verification with Mr. D. Hamilton, Director of Site Operations, on August 16, 2013.

Follow-up conference call for the areas of radiological hazard assessment and exposure controls with Mr. T. Veitch, Manager of Regulatory Compliance, on August 23, 2013.

The inspection results for the areas of radiological hazard assessment and exposure controls; and radiological environmental monitoring with Mr. D. Hamilton, Director of Site Operations, on September 27, 2013.

Teleconference update with Mr. T. Veitch, Regulatory Compliance Manager, and other members of the licensees staff on October 2, 2013.

The results of the EP program inspection were discussed with Mr. D. Reeves on September 19, 2013.

The inspectors confirmed none of the potential report inputs discussed were considered proprietary.

4OA7 Licensee-Identified Violations

The following violation of very low significance (Green) or Severity Level IV was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

Title 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). The Perry Nuclear Power Plant Emergency Plan, Section 4.0 states, in part, a 15-minute goal has been established for assessing and classifying an emergency once indications are available to control room operators that an emergency action level (EAL) has been exceeded. Contrary to the above, on November 17, 2010, the licensee failed to follow its EP during an actual emergency, which resulted in a failure to implement. Specifically, an extent-of-condition review (CR-2013-04165) of past radiological events identified vagueness and lack of specificity in EAL GU1 entry criteria resulted in the failure to classify the 2010 notification of unusual event.

Using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated February 24, 2012, Section 4.0, Actual Event Implementation Issue (Failure to Implement), the inspectors determined that the violation was not greater than very low safety significance (Green) because no public official protective actions were implemented as a result of this event missed classification. The issue was documented in the licensees CAP as CAP 2013-05332. Corrective actions included making revisions to provide clarity to EALs GU1 and GA1 and revision of the EALs entry criteria.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

E. Harkness, Site Vice-President

D. Hamilton, Site Operations Director

J. Ellis, Recovery Director

T. Brown, Performance Improvement Director

D. Reeves, Site Engineering Director

J. Veglia, Maintenance Director

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened and Closed

05000440/2013004-01 NCV Failure To Meet Fire Brigade Drill Training Requirements (Section 1R05.2)

05000440/2013004-02 NCV Worker Access Into A High Radiation Area Contrary To The Requirements Of The Radiation Work Permit (Section 2RS1.1)

05000440/2013004-03 FIN Unprofessional Worker Conduct Inside A Locked High Radiation Area In The Turbine Building 620 Auxiliary Steam Tunnel (Section 2RS1.2)

05000440/2013004-04 NCV Failure To Perform Representative Sampling of Fish In Order to Accurately Assess Ingestion Radiation As Required By The ODCM (Section 2RS7.2)

Closed

05000440/2013-03-00 LER Shutdown Required By Technical Specifications Due to RCS Pressure Boundary Leakage (Section 4OA3.2)

05000440/2012005-07 URI

Follow-Up to 2012 Occupational Radiation Safety Performance Indicator Verification (Section 4OA1.5)

Discussed

2515/182 TI Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks (Section 4OA5)

LIST OF DOCUMENTS REVIEWED

IR 05000440/2013004

Text

SUBJECT:

Dear Mr. Harkness:

Enclosure:

SUMMARY OF FINDINGS

NRC-Identified

Cornerstone: Mitigating Systems

REPORT DETAILS

Summary of Plant Status

REACTOR SAFETY

1R04 Equipment Alignment

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

b. Findings

1R05 Fire Protection

.1 Routine Resident Inspector Tours

a. Inspection Scope

b. Findings

.2 Annual Fire Protection Drill Observation

a. Inspection Scope

b. Findings

Introduction:

Description:

Analysis:

Enforcement:

1R06 Flood Protection Measures

.1 Underground Vaults

a. Inspection Scope

b. Findings

1R07 Annual Heat Sink Performance

a. Inspection Scope

b. Findings

1R11 Licensed Operator Requalification Program

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification

a. Inspection Scope

b. Findings

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a. Inspection Scope

b. Findings

1R12 Maintenance Effectiveness

a. Inspection Scope

b. Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

b. Findings

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

b. Findings

1R18 Plant Modifications

a. Inspection Scope

b. Findings

1R19 Post-Maintenance Testing

a. Inspection Scope

b. Findings

1R20 Forced Outage Activities

a. Inspection Scope

b. Findings

1R22 Surveillance Testing

a. Inspection Scope

b. Findings

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

b. Findings

1EP3 Emergency Response Organization Staffing and Augmentation System

a. Inspection Scope

b. Findings

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

b. Findings

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

b. Findings

.2 Training Observation

a. Inspection Scope

b. Findings

RADIATION SAFETY

2RS1 Radiological Hazard Assessment and Exposure Controls

.1 Instructions to Workers (02.03)