ML052420709
| ML052420709 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/30/2005 |
| From: | Caldwell J Region 3 Administrator |
| To: | Richard Anderson FirstEnergy Nuclear Operating Co |
| References | |
| Download: ML052420709 (8) | |
Text
August 30, 2005 Mr. R. Anderson Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant 10 Center Road, A290 Perry, OH 44081
SUBJECT:
MID-CYCLE ASSESSMENT LETTER - PERRY NUCLEAR POWER PLANT AND REQUEST FOR RESPONSE
Dear Mr. Anderson:
On August 9, 2005, the NRC staff completed its performance review of Perry Nuclear Power Plant for the first half of the calendar year 2005 assessment cycle. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results over the previous twelve months. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.
This performance review and the enclosed inspection plan do not include physical protection information. A separate letter designated and marked as "Exempt from Public Disclosure in Accordance with 10 CFR 2.390" will include the physical protection review and a resultant inspection plan.
Plant performance for the most recent quarter was within the Multiple/Repetitive Degraded Cornerstone (Column IV) of the NRCs Action Matrix based on continuing performance deficiencies in human performance, and the corrective action program in general and its application to the emergency service water pump failures. These are the same issues addressed in our March 2, 2005, Annual Assessment letter for calendar year 2004. Our March 2, 2005, letter also provided details of the White findings which caused Perry Nuclear Power Plant to enter the Multiple/Repetitive Degraded Cornerstone in the third quarter of 2004.
FirstEnergy Nuclear Operating Company (FENOC) was initially notified that Perry had entered Column IV by our August 12, 2004, letter.
The NRC completed an Inspection Procedure (IP) 95003 inspection earlier this year. Overall, while some limited improvements may have been realized, the NRC concluded that there has been no substantial improvement in human performance or your implementation of the corrective action program since Perry entered the Multiple/Repetitive Degraded Cornerstone of the NRCs Action Matrix in August 2004. You responded to the IP 95003 inspection by letter dated August 8, 2005. Your August 8, 2005, letter provided actions that FENOC committed to perform to address the corrective action program, human performance, IP 95002 inspection, and emergency preparedness issues. The letter also provided information on Phase 2 of your Performance Improvement Initiative. The NRC is currently reviewing your response.
R. Anderson Additionally, the staff has identified substantive cross-cutting issues in the areas of Problem Identification and Resolution, and Human Performance. We informed you of the former area in our August 30, 2004, mid-cycle assessment letter and our March 2, 2005, annual assessment letter, with the latter being identified in the March 2, 2005, assessment letter. The two cross-cutting issues were also reflected in the IP 95003 inspection, where current examples of problems in the areas of human performance and problem identification and resolution were identified.
In the area of Problem Identification and Resolution, there continued to be numerous findings identified during the assessment period. These include, but were not limited to, the failure to identify inadequate thread engagement on a residual heat removal water leg pump discharge flange, to identify and correct containment deck grating that did not meet seismic requirements, to incorporate industry operating experience for the reactor recirculation system, to correct in a timely manner deficiencies in the use of error reduction tools, and acceptance of test results with identified likely erroneous or otherwise unexplainable data.
In the area of Human Performance, there were numerous findings related to personnel performance, with common themes of failure to follow procedures or inattention to detail.
Examples include, but were not limited to, performing procedure steps out of sequence and continuing to perform the procedure without adequate review once the error was identified, installing a jumper in the wrong safety-related breaker cubicle, operator error resulting in draining 8500 gallons of suppression pool water to the floor drain, not quarantining equipment following down-shift of both reactor recirculation pumps, not following modification procedures for emergency diesel generator exhaust system, and failure to ensure room temperature monitoring devices had appropriate accuracy to maintain temperature.
We are concerned with your progress in addressing these cross-cutting deficiencies. The examples continued after we had notified you of these substantive cross-cutting issues in our August 30, 2004, and March 2, 2005, assessment letters, indicating that your efforts to address these areas have not been fully effective. Specifically, we note that addressing problems with your corrective action program has been a focal point of your performance improvement initiative, yet issues continue to be identified. Therefore, we are continuing the substantive cross-cutting issues in problem identification and resolution and human performance. We will continue to assess your performance in this area as part of the IP 95003 follow up inspection activities and the baseline inspection program, which includes a normally scheduled Problem Identification and Resolution Inspection to be performed in November 2005. We request that you inform us, within 30 days of the date of this letter, of any actions in addition to those already described in your August 8, 2005, letter, that are planned to address the two substantive cross-cutting issues. Further, we request that you discuss your views at a public meeting to be scheduled in the fourth quarter of 2005.
In addition to the issues discussed above, on February 24, 2005, the NRC issued a SL III Notice of Violation (NOV) and Proposed Imposition of Civil Penalty - $55,000 to FENOC for employment discrimination by one of its contractors, Williams Power Corp. This action addressed an employment discrimination condition that occurred in March 2000. The NRC action also included SL III NOVs issued to Williams Power Corp. for employee protection and
R. Anderson deliberate misconduct and an Order to the former Contract Site Superintendent prohibiting involvement in NRC-licensed activities for three years.
The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through March 31, 2007. The inspection plan is provided to minimize the resource impact on your staff and to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspection activities are not listed due to their ongoing and continuous nature. The inspection in the last nine months of the inspection plan are tentative and may be revised at the end-of-cycle review meeting.
In addition to the routine inspection activities, we have scheduled an IP 95001 inspection in October 2005. The IP 95001 inspection will address an RHR unavailability PI reporting issue.
Further, an emergency preparedness issue, involving your staffs failure to follow the guidance in an emergency action level, will be open greater than four quarters because your staff has indicated that the facility is not ready to support our inspection activity. We will schedule an IP 95001 inspection once your review is complete and you indicate your readiness for the inspection. In addition, we will be conducting an IP 95003 follow up inspection to review unresolved items from inspection report 05000440/2005003.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
If circumstances arise which cause us to change the inspection plan, we will contact you to discuss the change as soon as possible. Please contact Christine Lipa at (630) 829-9619 with any questions you may have regarding this letter or the inspection plan.
Sincerely,
/RA by G. Grant Acting for/
James L. Caldwell Regional Administrator Docket No. 50-440 License No. NPF-58
Enclosure:
Perry Nuclear Power Plant Inspection/Activity Plan See Attached Distribution
DOCUMENT NAME:G:\\Branch TSS\\ALL MOC\\midcycle 2004 to 2005\\MOC letters\\perr.wpd
- See previous concurrence G Publicly Available G Non-Publicly Available G Sensitive G 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 OFFICE RIII RIII NRR-IIPB RIII RIII RIII NAME GWright/trn*
GWright for CLipa*
GWright for SRichards (email)*
CPederson*
GShear for MSatorius*
GGrant for JCaldwell DATE 08/26/05 08/26/05 08/26/05 08/26/05 08/29/05 08/30/05 OFFICIAL RECORD COPY
R. Anderson cc w/encl:
G. Leidich, President - FENOC J. Hagan, Chief Operating Officer, FENOC D. Pace, Senior Vice President Engineering and Services, FENOC Director, Site Operations Director, Regulatory Affairs M. Wayland, Director, Maintenance Department Manager, Regulatory Compliance T. Lentz, Director, Performance Improvement J. Shaw, Director, Nuclear Engineering Department D. Jenkins, Attorney, First Energy Public Utilities Commission of Ohio Ohio State Liaison Officer R. Owen, Ohio Department of Health President, Geauga County Board Executive Director, Department of Emergency Services Geauga County Sheriff President, Ashtabula County Board of Commissioners Ashtabula County Sheriff Director, Ashtabula County Emergency Management Agency Mayor, Village of Genoa Genoa Village Administrator President, Lake County Board of Commissioners Lake County Sheriff Painesville City Manager Lake County Administrator President, Village of Fairport Harbor Mayor, City of Eastlake Mayor, City of Wickliffe President, Geneva City Council City Manager, Geneva Mayor, City of Kirtland Mayor, City of Mentor City Manager, Mentor Mayor, City of Mentor on the Lake Administrative Director Mayor, City of Willoughby Hills Mayor, City of Willoughby Mayor, City of Willowick Mayor, Village of Madison Village of Madison Chairman, Board of Madison Township Trustees Mayor, Village of Kirtland Hills Mayor, Village of Geneva-on-the-Lake Mayor, Lakeline Village Mayor, Village of Timberlake Mayor, Village of Grand River INPO
R. Anderson ADAMS Distribution:
GYS WAM1 DWW Project Director, NRR RidsNrrDipmlipb JLC1 GEG KGO RML2 SRI Perry DRPIII DRSIII PLB1 JRK1
Perry Inspection / Activity Plan 09/01/2005 - 03/31/2007 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 1 of 2 08/29/2005 11:05:46 Report 22 1
- ALARA AND ACCESS CONTROL Baseline Inspections 09/12/2005 09/16/2005 ALARA Planning and Controls IP 7112102 1
Baseline Inspections 09/12/2005 09/16/2005 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 1
Baseline Inspections 09/12/2005 09/16/2005 Performance Indicator Verification IP 71151 1
3 PI&R
- PROBLEM IDENTIFICATION AND RESOLUTION Baseline Inspections 11/28/2005 12/16/2005 Identification and Resolution of Problems IP 71152B 1
1 71114
- BASELINE EP INSPECTION Baseline Inspections 12/05/2005 12/09/2005 Alert and Notification System Testing IP 7111402 1
Baseline Inspections 12/05/2005 12/09/2005 Emergency Response Organization Augmentation Testing IP 7111403 1
Baseline Inspections 12/05/2005 12/09/2005 Correction of Emergency Preparedness Weaknesses and Deficiencies IP 7111405 1
Baseline Inspections 12/05/2005 12/09/2005 Performance Indicator Verification IP 71151 1
5 SSDPC
- SAFETY SYS DESIGN&PERFORMANCE CAPABILITY Baseline Inspections 01/30/2006 03/03/2006 Safety System Design and Performance Capability IP 7111121 1
2 IP 71122
- EFFLUENTS, ACCESS CONTROL Baseline Inspections 01/09/2006 01/13/2006 Access Control to Radiologically Significant Areas IP 7112101 1
Baseline Inspections 01/09/2006 01/13/2006 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems IP 7112201 1
1 IP 71122
- ACCESS CONTROL, REMP Baseline Inspections 06/05/2006 06/09/2006 Access Control to Radiologically Significant Areas IP 7112101 1
Baseline Inspections 06/05/2006 06/09/2006 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control P IP 7112203 1
1 ROUTINE
- ACCESS CONTL, RADWASTE & TRANSPORTATION Baseline Inspections 08/21/2006 08/25/2006 Access Control to Radiologically Significant Areas IP 7112101 1
Baseline Inspections 08/21/2006 08/25/2006 Radioactive Material Processing and Transportation IP 7112202 1
1 MAINRULE
- MAINTENANCE EFFECTIVENESS INSPECTION Baseline Inspections 09/11/2006 09/15/2006 Maintenance Effectiveness IP 7111112B 1
2 MOD50.59
- MOD/ 50.59 INSPECTION Baseline Inspections 10/02/2006 10/20/2006 Evaluation of Changes, Tests, or Experiments IP 7111102 1
Baseline Inspections 10/02/2006 10/20/2006 Permanent Plant Modifications IP 7111117B 1
2 IP 71114
- EP EXERCISE BASELINE Baseline Inspections 10/23/2006 10/27/2006 Exercise Evaluation IP 7111401 1
Baseline Inspections 10/23/2006 10/27/2006 Performance Indicator Verification IP 71151 1
1 ROUTINE
- ACCESS CONTROL, ALARA Baseline Inspections 11/06/2006 11/10/2006 Access Control to Radiologically Significant Areas IP 7112101 1
Baseline Inspections 11/06/2006 11/10/2006 ALARA Planning and Controls IP 7112102 1
Baseline Inspections 11/06/2006 11/10/2006 Performance Indicator Verification IP 71151 1
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Perry Inspection / Activity Plan 09/01/2005 - 03/31/2007 Inspection Type Inspection Activity Planned Dates Start End No. of Staff on Site Title Unit Number Page 2 of 2 08/29/2005 11:05:46 Report 22 3
FPI
- TRIENNIAL FIRE PROTECTION INSPECTION Baseline Inspections 11/27/2006 12/15/2006 Fire Protection [Triennial]
IP 7111105T 1
2 71111.11
- LIC OPERATOR REQUAL PROGRAM EVALUATION Baseline Inspections 12/11/2006 12/15/2006 Licensed Operator Requalification Program IP 7111111B 1
1 71121.03
- INSTRUMENTATION Baseline Inspections 01/29/2007 02/02/2007 Radiation Monitoring Instrumentation and Protective Equipment IP 7112103 1
This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.