IR 05000440/2017007

NRC Problem Identification and Resolution Inspection Report 05000440/2017007

ML17356A018
Person / Time
Site:	Perry
Issue date:	12/21/2017
From:	Billy Dickson NRC/RGN-III/DRP/B5
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
IR 2017007
Download: ML17356A018 (27)

Text

December 21, 2017

SUBJECT:

PERRY NUCLEAR POWER PLANT, UNIT 1 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2017007

Dear Mr. Hamilton:

On November 17, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) inspection at your Perry Nuclear Power Plant, Unit 1 (Perry). The enclosed inspection report documents the inspection results, which were discussed at an exit meeting on November 17, 2017 with with Mr. F. Payne and other members of your staff.

The inspectors examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Perry Nuclear Power Plant, Unit 1, was generally effective in identifying, evaluating and correcting issues. Your program had a low threshold for identifying issues and entering them into the CAP. A risk based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to procedure.

The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments based on the documents the team reviewed. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Perry Nuclear Power Plant. Your staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that your stations performance in each of these areas supported nuclear safety. Based on the results of this inspection, the NRC has identified an issue that was evaluated under the security significance determination process as having very low security significance (Green). The NRC has also determined that a violation is associated with this issue. Because you have initiated corrective actions to address the issue, this violation is being treated as a Non-Cited Violation (NCV), consistent with Section 2.3.2a of the Enforcement Policy. Since this issue is security-related, the NCV is described in a separate Official-Use-Only inspection report (05000440/2017410).

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Billy Dickson, Chief Branch 5 Division of Reactor Projects Docket No. 50-440 License No. NPF-58

Enclosure:

Inspection Report 05000440/2017007 cc: Distribution via LISTSERV

SUMMARY OF FINDINGS

Inspection Report 05000440/2017007; 10/30/2017-11/17/2017; Perry Nuclear Power Plant,

Unit 1; Identification and Resolution of Problems.

This report covers a 3-week period of announced routine baseline inspection. This inspection was performed by three region-based inspectors and the resident inspector at Perry. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," dated July 2016.

Identification and Resolution of Problems On the basis of the samples selected for review, the team concluded that the Corrective Action Program (CAP) at Perry Nuclear Power Plant, Unit 1, was generally effective in identifying, evaluating and correcting issues. The program had a low threshold for identifying issues and entering them into the CAP. A risk based approach was used to determine the significance of the issues and priority for issue evaluation and resolution. Corrective actions were generally implemented in a timely manner, commensurate with their safety significance. Operating experience was entered into the CAP when appropriate and evaluated according to procedure.

The use of operating experience was integrated into daily activities and found to be effective in preventing similar issues at the plant. In addition, self-assessments and audits were conducted at appropriate frequencies with sufficient depth for all departments based on the documents the team reviewed. The assessments were thorough and effective in identifying site performance deficiencies, programmatic concerns, and improvement opportunities. On the basis of the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Perry Nuclear Power Plant. Your staff was aware of and generally familiar with the CAP and other station processes, including the Employee Concerns Program, through which concerns could be raised. The team determined that your stations performance in each of these areas supported nuclear safety.

Although implementation of the CAP was determined to be effective overall, the inspectors identified several issues that represented potential weakness of the program.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of Problem Identification and Resolution (PI&R) inspection as defined by Inspection Procedure 71152, Problem Identification and Resolution. Documents reviewed are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures and processes that described the CAP at Perry to ensure, in part, that the requirements of Title 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XVI, Corrective Action, were met. The inspectors observed and evaluated the effectiveness of meetings related to the CAP, such as the Management Review Committee meetings, the Corrective Action Review Board and the Maintenance Notification Screening meetings. Selected licensee personnel were interviewed to assess their understanding of and their involvement in the CAP.

The inspectors reviewed selected condition reports (CR) across all seven Reactor Oversight Process cornerstones to determine if problems were being properly identified and entered into the licensees CAP. The majority of the risk-informed samples of CRs reviewed were issued since the last NRC biennial PI&R inspection completed in August of 2015. The inspectors also reviewed selected issues that were more than five years old.

The inspectors assessed the licensees characterization and evaluation of the issues and examined the assigned corrective actions. This review encompassed the full range of safety significance and evaluation classes, including root cause evaluations, apparent cause evaluations, common cause evaluations and trending analysis. The inspectors assessed the scope and depth of the licensees evaluations. For issues that were characterized as significant conditions adverse to quality, the inspectors evaluated the licensees corrective actions to prevent recurrence and for issues that were less significant, the inspectors reviewed the corrective actions to determine if they were implemented in a timely manner commensurate with their safety significance.

The inspectors performed a 5-year review of the safety-related 125-volt direct current (DC) system based on input from the resident staff. Two divisions of the DC system provides required DC power to associated loads needed for safe shutdown of the plant. Its batteries and chargers are sized to provide DC power under Loss of Cooling Accident conditions in the operating unit coincident with the continuous load of the other unit (not built). A third division of DC power provides a continuous and independent 125-volt DC source of control and motive power for high pressure core spray (HPCS) system logic, HPCS diesel generator control and protection and all Division 3 related 125-volt DC control. The primary purpose of this review was to determine whether the licensee was monitoring and addressing performance issues of the 125-Volt DC system. The inspectors performed walkdowns, as needed, to verify the resolution of selected issues.

A 5-year review of the HPCS system was also undertaken to assess the licensee staffs efforts in monitoring system performance. This system is part of the emergency core cooling system and its failure could adversely affect plans ability to mitigate an accident.

The inspectors review was to determine whether the licensee staff was properly monitoring and evaluating the performance of the system through effective implementation of station monitoring program, such as the system health report. The inspectors performed walkdowns, as needed, to verify the resolution of selected issues.

The inspectors examined the results of self-assessments of the CAP completed during the review period. The results of the self-assessments were compared to self-revealed and NRC-identified findings. The inspectors also reviewed the corrective actions associated with previously identified NCVs and findings to determine whether the station properly evaluated and resolved those issues. The inspectors also performed walkdowns, as necessary, to verify the resolution of the selected issues.

b.

Assessment

(1) Identification of Issues Based on the results of the inspection, the inspectors concluded that Perry was generally effective in identifying issues at a low threshold and entering them into the CAP. The inspectors determined that problems were normally identified and captured in a complete and accurate manner in the CAP. The station was appropriately screening issues from both NRC and industry operating experience at an appropriate level and entering them into the CAP when applicable to the station. The inspectors also noted that deficiencies were identified by external organizations (including the NRC) that had not been previously identified by licensee personnel. These deficiencies were subsequently entered into the CAP for resolution.

The inspectors determined that the licensee was generally effective at trending low level issues to prevent larger issues from developing. The licensee used the CAP to document instances where previous corrective actions were ineffective or were inappropriately closed.

The inspectors conducted a 5-year review of the HPCS system through documentation reviews, system walkdown, and interviews. The inspectors walked down the Division III HPCS diesel room and discussed various CRs like over-torqued studs for mounted rectifier on the diesel generator, diesel overspeed trips, and high vibrations of the diesel alternating current soakback pump with the associated system engineer. The inspectors observed HPCS diesel room equipment condition and verified HPCS system performance relative to documented Maintenance Rule status and actions. The inspectors confirmed that known issues were documented in the corrective action program and the licensee had taken or planned corrective actions to address the issues.

The inspectors did not observe any licensee performance deficiencies in this area.

i)

Observations

Change in Condition Report Generation

During this biennial problem identification and resolution inspection, the team identified a decline in CR generation in 2016. Prior to 2016, the number of CR generated was in the order of about 5700 per year. In 2016, the total number of CR generated was `

about 3800. This represented a 33 percent drop from 2015.

The licensee utilizes the Notification system through which deficient conditions are reported and work is requested. The team also noticed a corresponding change in the number of notification the licensee generated. Notifications are generally divided into two categories: Nuclear Maintenance Notification and General Activity Tracking Notification. A Nuclear Maintenance Notification is used to report deficient conditions and request work in the field, whereas a General Activity Tracking Notification is used to request other actions, such as engineering evaluation request or document change request. The issues identified in the Notification system are prioritized according to the level of urgency and significance of component/work. The Notification system is not completely part of the CAP but is utilized as a driving force to accomplish actions to support resolution of issues identified through the CAP. Any deficient condition that is a condition adverse to quality should have a CR written and linked to the notification.

The licensee had recognized this change and written a number of CRs for this issue in 2016 and early 2017. The licensee attributed the cause of the decline partially to CAP process changes that resulted in a new baseline plateau as well as improvement in plant operation. Although the licensees evaluation was inconclusive to the root cause of the decline, a number of actions were taken by the licensee to educate its staff on the new CAP process. The licensee continued to monitor the generation rates and would interfere when necessary.

Based on the samples we reviewed during this inspection, both low and high safety significance issues were in the CAP. No issue was identified in the Notification system.

Through interviews with the licensees staff, the inspectors concluded that the staff were willing to bring up safety issue and write CRs. Therefore, the inspectors concluded that this declining trend had not affected plant operations but the licensee needs to be cognizant of this trend before it affects the problem identification process.

ii) Findings No findings were identified.

(2) Prioritization and Evaluation of Issues

Based on the results of the inspection, the inspectors concluded that the licensee was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified issue, including an appropriate consideration of risk. In particular, the inspectors observed that while the majority of issues identified were at a low level of significance, those issues and issues of more significance were assigned a review and action level appropriate for the identified condition and in accordance with governing procedures. Issues were being appropriately screened by the originating departments, the Management Review Board, and Operations Shift Management for items potentially impacting equipment operability. Evaluations in apparent cause and root cause reports reviewed by the inspectors were effective in resolving the underlying issues.

The inspectors determined that the Management Review Committee meetings, the Corrective Action Review Board and the Maintenance Notification Screening meetings were generally thorough and maintained a high standard for evaluation quality.

Members of the committees were engaged and discussed selected issues in sufficient detail as well as challenged each other regarding their conclusions and recommendations.

The inspectors determined that the licensee evaluated equipment functionality requirements adequately after a degraded or non-conforming condition was identified.

In general, appropriate actions were assigned to correct the degraded or non-conforming condition.

i)

Observations Failure to Perform Independent Spent Fuel Storage Installation Pad Radiation Surveys During the review of the radiation protection related CRs, the inspectors noted instances of missing independent spent fuel storage installation pad (ISFSI) radiation survey. The missing surveys were previously identified by an audit performed by Fleet Oversight in March 2017. This issue was entered into their CAP and the CR documented that the site could not locate a number of quarterly survey records. Specifically, two records in 2015 and two in 2016 could not be located. Corrective actions included evaluating the use of the work order process to track the periodic survey activity. However, the licensee determined that tracking via the work order process was not needed and the current method was adequate. The CR was subsequently closed with no change implemented for tracking the performance of ISFSI pad survey.

As a result, the inspectors requested the survey results for 2017 and identified that the licensee failed to perform the survey for the second quarter. The inspectors determined that this issue was of minor significance because the subsequent survey performed in July 2017 during the third quarter showed that there were no adverse changes in radiological conditions in the area and that there were no indications to suggest that the dose limits as required by the NRC regulation were exceeded. The inspectors determined that this was a minor violation of Technical Specification 5.4.1 for the licensees failure to perform ISFSI Pad radiation survey in accordance with established procedure for control of radioactivity. Because of its minor safety significance, this issue was not subject to enforcement action in accordance with the NRCs Enforcement Policy.

The licensee entered this issue into their CAP as CR 2017-11375, 2017 NRC PI&R Inspection: RP Did Not Perform the 2017 Second Quarter Survey for ISFSI Pad In Accordance With HPI-D0006, Independent Spent Fuel Storage Installation Radiation Survey, dated November 13, 2017, and initiated corrective actions to address the issue.

ii) Findings No findings were identified.

(3) Effectiveness of Corrective Actions Based on the results of the inspection, the inspectors concluded that the licensee was generally effective in addressing identified issues and the assigned corrective actions were generally appropriate. The licensee implemented corrective actions in a timely manner, commensurate with their safety significance, including an appropriate consideration of risk.

Problems identified using root or apparent cause methodologies were resolved in accordance with the CAP procedural and regulatory requirements. Corrective actions designed to prevent recurrence were generally comprehensive, thorough, and timely.

The inspectors sampled corrective action assignments for selected NRC documented violations and determined that actions assigned were generally effective and timely.

The inspectors reviewed open corrective work orders, open corrective action items, and recent system health reports for the DC system. The Unit 1 Division 1 and 2 Battery Rooms and Division 2 Battery Charger Room were walked down with the DC system engineer. The inspectors found the system to be in overall good health with a reasonable number of open corrective work orders and corrective action items. A sample of issues identified in the system health reports were reviewed and found to have interim compensatory measures and corrective actions to address them. The inspectors did not find any discrepancies between the conditions represented by the open work orders, corrective action documents, and system health reports and the actual conditions. The inspectors concluded that the licensee staff were properly monitoring the performance of the system and taking actions necessary for improvements as well as deficiencies.

i)

Observations None.

ii) Findings A security related finding and an associated non-cited violation was identified by the inspectors. The finding is documented in the NRC Inspection Report 05000440/2017410.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed the OE program implementing procedures, attended CAP meetings to observe the use of OE information, reviewed licensee evaluations of OE issues and events and reviewed selected assessment of the OE performance indicators. The objective of the review was to determine whether the licensee was effectively integrating OE into the performance of daily activities, whether evaluations of issues were appropriate, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE, were identified and implemented in an effective and timely manner.

b.

Assessment Overall, the inspectors determined that the licensee was effective at evaluating industry OE for relevance to the facility. The inspectors observed that operating experience was discussed as part of the daily and pre-job briefings. Industry operating experience was disseminated across plant departments for their review and use, if needed. Specific equipment related issues were distributed to appropriate engineers for evaluating and screening into the CAP. The inspectors also verified that the use of OE in formal CAP products such as root cause evaluations and apparent cause evaluations was appropriate and adequately considered.

Operating experience that was applicable to the facility was appropriately evaluated and actions were implemented or are being implemented to address any issues that resulted from the evaluations. These operating experience evaluations included NRC generic communications, significant industry issues, Part 21s, and General Electric Services Information Letters. Generally, OE that was applicable to Perry was thoroughly evaluated and actions were implemented in a timely manner to address any issues that resulted from the evaluations.

Based on the results of the inspection, the inspectors concluded that operating experience was effectively utilized at the station. No significant issues were identified during the inspectors review of selected licensee operating experience evaluations.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed selected self-assessments and Fleet Oversight audits, as well as the schedule of past and future assessments. The inspectors evaluated whether these audits and self-assessments were effectively managed, adequately covered the subject areas, and properly captured identified issues in the CAP. In addition, the inspectors interviewed licensee personnel regarding the implementation of the audit and self-assessment programs.

b.

Assessment Based on the results of the inspection, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and self-critical. They were effective at identifying issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. Selected licensee programs audited by Fleet Oversight were found to be satisfactorily implemented, with a few isolated examples of deficiencies that have been appropriately prioritized and addressed through their CAP process. In many cases, these self-assessments and audits had identified numerous issues that were not previously recognized by the station. The inspectors also determined that findings from the CAP self-assessment were consistent with the inspectors assessment.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment (SCWE)through the reviews of the facilitys Employee Concerns Program (ECP) implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of CRs. The inspectors also reviewed the results from the safety culture assessment and safety conscious work environment survey conducted in 2016.

The inspectors held scheduled interviews with 20 onsite staff members. They included individual contributors and supervisors from both licensee and contractor organization.

During the interview, the inspectors assessed their willingness to raise nuclear safety issues. Additionally, the inspectors interviewed other personnel informally to ascertain their views on the effectiveness of the CAP and their willingness and freedom to raise issues.

The individuals in the scheduled interviews were randomly selected to provide a distribution across various departments at the site. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also included discussion on any changes in the plant environment over the last 12 months. Items discussed included:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP;

• willingness to use the CAP; and

• knowledge and understanding of ECP.

The inspectors also discussed the functioning of the ECP with the program coordinator; reviewed program logs from 2015 through 2017; and reviewed selected case files to identify any emergent issues or potential trends.

b.

Assessment The inspectors did not identify any issues of concern regarding the licensees SCWE.

Information obtained during the interviews indicated that an environment was established where licensee personnel felt free to raise nuclear safety issues without fear of retaliation. Licensee personnel were generally aware of and familiar with the CAP and other processes, including the ECP and the NRCs allegation process, through which concerns could be raised. In addition, a review of the types of issues in the ECP indicated that the licensee staff members were appropriately using the CAP and ECP to identify issues. The inspectors did not observe and were not provided any examples where there was retaliation for the raising of nuclear safety issues. Documents provided to the inspectors regarding surveys and monitoring of the safety culture and SCWE generally supported the conclusions from the interviews.

c. Findings

No findings were identified.

4OA6 Management Meetings

Exit Meeting On November 17, 2017, the inspectors presented the inspection results to Mr. F. Payne 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.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

F. Payne, Plant General Manager

J. Archer, Manager - Security

B. Blair, Manager - Operations

S. Benedict, Manager - Chemistry

P. Boissoneault, Manager - Training

K. Clark, Manager - Maintenance

M. DeStefano, Manager - Fleet Oversight

B. Huck, Manager - Outage Management

D. Mauck, Manager - Work Management

G. Mizenko, Manager - Supply Chain

R. OConnor, Manager - Emergency Preparedness

J. Oelbracht, Manager - Radiation Protection

D. Reeves, Director - Site Engineering

D. Saltz, Director - Performance Improvement

NRC

B. Dickson, Branch Chief

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Open None

Closed

None

Discussed

None