IR 05000440/2014502
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Text
October 14, 2014
Mr. Ernest Harkness Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-290 Perry, OH 44081-0097
SUBJECT: PERRY NUCLEAR POWER PLANT BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000440/2014502
Dear Mr. Harkness:
On September 26, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Perry Nuclear Power Plant. The enclosed report documents the results of this inspection, which were discussed on September 26, 2014, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and 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), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Richard A. Skokowski, Chief Plant Support Branch Division of Reactor Safety Docket No. 50-440 License No. NPF-58
Enclosure:
Inspection Report 05000440/2014502
w/Attachment:
Supplemental Information cc w/encl: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-440 License No: NPF-58 Report No: 05000440/2014502 Licensee: FirstEnergy Nuclear Operating Company (FENOC) Facility: Perry Nuclear Power Plant, Unit 1 Location: North Perry, Ohio Dates: September 22 - 26, 2014 Inspectors: R. Jickling, Senior Emergency Preparedness Inspector B. Kemker, Senior Resident Inspector J. Beavers, Emergency Preparedness Inspector G. Hansen, Physical Security Inspector T. Smith, Emergency Preparedness Specialist Approved by: R. Skokowski, Chief Plant Support Branch Division of Reactor Safety 2
SUMMARY OF FINDINGS
IR 05000440/2014502; 09/22/2014 - 09/26/2014; Perry Nuclear Power Plant; Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event; Exercise Evaluation Scenario Review; and Performance Indicator Verification. This report covers a one-week period of announced baseline inspection by three regional inspectors, one resident inspector, and one emergency preparedness specialist. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red) using Inspection Manual Chapter 0609, "Significance Determination Process (SDP)." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, dated February 2014.
A. NRC-Identified
and Self-Revealed Findings
Cornerstone: Emergency Preparedness No findings were identified.
B. Licensee-Identified Violations
None
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REPORT DETAILS
REACTOR SAFETY
Cornerstone:
1EP7 Exercise Evaluation - Hostile Action Event
.1 Exercise Evaluation
a. Inspection Scope
Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E,Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) event directed at the plant site. Perry Nuclear Power Plant designed the September 23, 2014 exercise to satisfy this requirement, and the NRC inspected the Perry Nuclear Power Plant HA event exercise to assess the licensee's ability to effectively implement their Emergency Plan during a HA event and adequately protect public health and safety.
The exercise evaluation consisted of the following reviews and assessments: The adequacy of the licensee's performance in the biennial exercise conducted on September 23, 2014, regarding the implementation of the Risk-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PARs), respectively. The overall adequacy of the licensee's emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities," and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Alternative Emergency Response Facility, Incident Command Post, Central Alarm Station, and the Emergency Operations Facility. A review of other performance areas such as the licensee ERO's recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures. Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14). The adequacy of the licensee's post-exercise critiques, to evaluate Perry Nuclear Power Plant's self-assessment of its ERO performance during the September 23, 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.
4 The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis. This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.
b. Findings
No findings were identified.
1EP8 Exercise Evaluation - Scenario Review
a. Inspection Scope
Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the NRC using IP 71114.08, "Exercise Evaluation - Scenario Review," to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle. The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis. This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstone:
4OA1 Performance Indicator Verification
.1 Drill/Exercise Performance
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP) Performance Indicator (PI) for the period from the third quarter 2013 through the second quarter 2014. To determine the accuracy of the DEP data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) document NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control 5 room simulator training sessions, and performance during other drills. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one DEP sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Emergency Response Organization Drill Participation
a. Inspection Scope
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the third quarter 2013 through the second quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, performance during the 2013 and 2014 drills, and revisions of the roster of personnel assigned to key ERO positions. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Alert and Notification System
a. Inspection Scope
The inspectors sampled licensee submittals for the Alert and Notification System (ANS) PI for the period from the third quarter 2013 through the second quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one ANS sample as defined in IP 71151-05.
b. Findings
No findings were identified.
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4OA6 Management Meetings
.1 Exit Meeting Summary On September 26, 2014, the inspectors presented the biennial exercise inspection results to Mr. E. Harkness 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 Public and Media Briefing On September 26, 2014, the inspector summarized the NRC's preliminary exercise inspection conclusions at a public and media briefing hosted by Department of Homeland Security/Federal Emergency Management Agency Region V Field Office staff at the Lake County Emergency Operations Center in Kirtland, Ohio. ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- E. Harkness, Site Vice President
- D. Hamilton, Plant General Manager
- T. Brown, Performance Improvement Director
- J. Ellis, Maintenance Director
- D. Reeves, Site Engineering Director
- J. Veglia, Maintenance Director
- S. Turrin, Operations Superintendent
- B. Baumgardner, Special Projects Manager
- B. Blair, Maintenance Manager
- P. Boissoneault, Program & Technical Services Manager
- R. Collings, Fleet Emergency Preparedness Supervisor
- N. Conicella, Regulatory Compliance Manager
- R. Dame, Fleet Oversight Supervisor
- D. Frey, Emergency Preparedness Specialist
- B. Huck, Design Manger
- R. Killing, Chemistry Supervisor
- M. Koberling, Work Management Manger
- D. Lockwood, Regulatory Compliance Engineer
- B. Luthanen, Emergency Preparedness Specialist
- G. McKee, Fleet Emergency Preparedness Manager
- N. McKenney, Radiation Protection Manager
- K. Nelson, Plant & Equipment Reliability Manager
- S. Richardson, Supply Chain Manager
- M. Roberts, Security Supervisor
- L. Schlauch, Emergency Preparedness Specialist
- D. Skerness, Human Resources Manager
- R. Smith, Emergency Preparedness Manager
- R. Strohl, Training Manager
- S. Trent, Radiation Protection Supervisor
- L. VanDerhorst, Emergency Preparedness Specialist
- L. Zerr, Regulatory Compliance Supervisor Nuclear Regulatory Commission
- M. Marshfield, Senior Resident Inspector
- J. Nance, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed, and Discussed None
LIST OF DOCUMENTS REVIEWED
The following is a partial list of documents reviewed during the inspection.
- Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overall inspection effort.
- Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
- 1EP7 Exercise Evaluation (71114.07) Perry Emergency Plan; Revision 43
- EPI-A1; Emergency Action Levels; Revision 26
- EPI-A2; Emergency Actions Based on Event Classification; Revision 18 Two Years of Drill and Exercise Corrective Action Program Items; May 2012 - April 2014 Two Years of Scenario Timelines; May 2012 - April 2014
- EPI-B1; Emergency Notification System; Revision 25
- EPI-B4; First Aid and Medical Care; Revision 16
- EPI-B5; Personnel Accountability/Site Evacuation; Revision 15
- EPI-B8; Protective Actions and Guides; Revision 16 PNPP No. 8364; Operations Night Orders; Hostile Action EALs; September 24, 2014
- CR 2014-14878; Exercise-TSC/OSC Repair Team Failed to Adhere to Movement Restrictions From Security and ICP; September 25, 2014
- CR 2014-14876; Exercise-TSC-Repair Team Dispatched to Wrong Location; September 25, 2014
- CR 2014-14853; Exercise-ERDS Transmission Issues From the Simulator; September 25, 2014
- CR 2014-14852; Exercise-Simulator-NRC Alert Notification Objective Was Not Met; September 25, 2014
- CR 2014-14851; Exercise-Simulator-General Emergency Was Declared Prior to Meeting Entry Criteria; October 25, 2014
- CR 2014-14855; Exercise-EOF-Dose Assessment Initially Used Actual MET Data; September 25, 2014
- CR 2014-02281; Drill-OSC Teams Initially Not Controlled and Tracked and Dispatched Without Briefing/Debriefing Sheet; February 6, 2014 1EP8 Exercise Evaluation - Scenario Review (71114.08) Perry HAB Exercise 60 Day Scenario Submittal; July 24, 2014
- 4OA1 Performance Indicator Verification (71151)
- NOBP-LP-4012-11; Emergency Preparedness Drill/Exercise Performance Records; July 2013 - June 2014
- NOBP-LP-4012-12; Emergency Response Organization Drill Participation Records; September 2013 - June 2014
- NOBP-LP-4012-13; Alert and Notification System Reliability Records; July 2013 - June 2014
LIST OF ACRONYMS
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PI Performance Indicator SDP Significance Determination Process
Mr. Ernest Harkness Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant
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- REPORT 05000440/2014502 Dear Mr. Harkness: On September 26, 2014, the U.S. Nuclear Regulatory Commission (
NRC) completed an inspection at your Perry Nuclear Power Plant. The enclosed report documents the results of this inspection, which were discussed on September 26, 2014, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. In accordance with
- NRC 's "Rules of Practice," a copy of this letter and its enclosure, and your response, if any, will be available electronically for public inspection in the
- NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /
- NPF -58 Enclosure: Inspection Report 05000440/2014502 w/Attachment: Supplemental Information cc w/encl: Distribution via
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- PERR 2014 502 (RDJ).docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
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