ML092440409

Perry - Mid-Cycle Performance Review and Inspection Plan

ML092440409
Person / Time
Site:	Perry
Issue date:	09/01/2009
From:	Khadijah West Division Reactor Projects III
To:	Bezilla M FirstEnergy Nuclear Operating Co
References
FOIA/PA-2010-0209
Download: ML092440409 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 1, 2009 Mr. Mark Bezilla Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-A290 Perry, OH 44081-0097

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PERRY NUCLEAR PLANT

Dear Mr. Bezilla:

On August 19, 2009, the NRC staff completed its performance review of the Perry Nuclear Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2008 through June 30, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.

Plant performance for the most recent quarter at Perry Nuclear Plant was within the Licensee Response column of the NRC=s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green).

Performance at the Perry Nuclear Power Plant during the assessment period continued to exhibit weaknesses in the area of human performance. The total number of findings with documented cross-cutting aspects in human performance increased from 12 to 20. Our assessment of the findings identified three new cross-cutting themes in the human performance area: work controlplanning (H.3(a)), five findings; work practiceshuman error prevention techniques (H.4(a)), five findings; and work controloversight (H.4(c)), four findings. In addition, while the number of findings with a cross-cutting aspect of resources -

documentation/procedures (H.2(c)) declined, we are leaving this theme open pending a demonstration of sustainable performance in this area.

M. Bezilla 2 This assessment period is the fourth consecutive assessment period identifying a substantive cross-cutting issue in the human performance area first opened in our March 3, 2008, End-of-Cycle assessment letter [Adams Ref. ML080600303]. It is apparent that the development of causal evaluations and implementation of corrective actions has not been effective in demonstrating sustainable performance in the human performance arena. Therefore, the NRC has a continuing concern with the scope of your efforts and progress in addressing this cross-cutting area and has concluded that the substantive cross-cutting issue in human performance will remain open. The human performance substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of human performance. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme. As part of our continuing review of this issue, a problem identification and resolution follow-up inspection item will be performed in accordance with IP 71152, Identification and Resolution of Problems, Section 03.02, Selected Issue Follow-up Inspection, during the upcoming assessment period.

Because your efforts to effect improvements in the human performance area have not been effective as evidenced by the number of significant human performance issues having risen during the assessment period, we would like to discuss the issue with you at a public meeting.

The meeting will afford you the opportunity to present the progress of your actions taken in response to this weakness and why you believe future actions will be more effective than actions previously undertaken to address these longstanding substantive cross-cutting issues.

We will contact you separately to schedule this meeting.

In addition to the negative trend in human performance, we have noted, since July 2008, a declining trend in the PI&R area. For this assessment period, we identified five findings in the PI&R area with the same aspect of corrective action programthorough evaluation (P.1(c)).

Four of the five findings were identified in the last two quarters of the assessment period.

Condition reports generated through your corrective action program have continued to note the adverse trend in thorough evaluation (P.1(c)), but failed to take corrective actions that were effective in addressing that trend. Because of the continued decline in the area of PI&R, the NRC has a concern with the scope of your efforts and progress in addressing the cross-cutting area performance deficiencies and has concluded that a substantive cross-cutting issue exists in this area. This substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of problem identification and resolution. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme.

The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite.

Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the End-of-Cycle review.

M. Bezilla 3 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), 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 this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at 630-829-9833 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

K. Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58

Enclosure:

Perry Inspection/Activity Plan DISTRIBUTION:

See next page

Letter to M. Bezilla from K. Steven West dated September 1, 2009.

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PERRY NUCLEAR PLANT cc w/encl: J. Hagan, President and Chief Nuclear Officer - FENOC J. Lash, Senior Vice President of Operations and Chief Operating Officer - FENOC D. Pace, Senior Vice President, Fleet Engineering - FENOC K. Fili, Vice President, Fleet Oversight - FENOC P. Harden, Vice President, Nuclear Support - FENOC Director, Fleet Regulatory Affairs - FENOC Manager, Fleet Licensing - FENOC Manager, Site Regulatory Compliance - FENOC D. Jenkins, Attorney, FirstEnergy Corp.

Public Utilities Commission of Ohio C. OClaire, State Liaison Officer, Ohio Emergency Management Agency R. Owen, Ohio Department of Health President, Geauga County Board 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 Director, Lake County Emergency Management Agency 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 Administrator, 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 G. Mortensen, INPO

M. Bezilla 3 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), 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 this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at 630-829-9833 with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

K. Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58

Enclosure:

Perry Inspection/Activity Plan DISTRIBUTION:

See next page DOCUMENT NAME: G:\Branch TSS\ALL MOC\midcycle 2008 to 2009\Mid-cycle Letters Perry 2009 MOC Letter.doc 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 RIII NAME GWright:dtp JCameron SWest DATE 08/27/09 08/27/09 08/31/09 OFFICIAL RECORD COPY

Letter to M. Bezilla from K. Steven West dated September 1, 2009.

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PERRY NUCLEAR PLANT DISTRIBUTION:

Susan Bagley RidsNrrPMPerry RidsNrrDorlLpI3-2 RidsNrrDirsIpob Resource Cynthia Pederson Jared Heck Steven Orth Allan Barker DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

Perry Inspection / Activity Plan 09/01/2009 - 12/31/2010 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 2 09/21/2009 09/25/2009 IP 2515/175 Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review 09/21/2009 09/25/2009 IP 7111402 Alert and Notification System Testing 09/21/2009 09/25/2009 IP 7111403 Emergency Response Organization Augmentation Testing 09/21/2009 09/25/2009 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 09/21/2009 09/25/2009 IP 71151-EP01 Drill/Exercise Performance 09/21/2009 09/25/2009 IP 71151-EP02 ERO Drill Participation 09/21/2009 09/25/2009 IP 71151-EP03 Alert & Notification System BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 10/19/2009 10/23/2009 IP 7112201 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 10/19/2009 10/23/2009 IP 71151-BI01 Reactor Coolant System Activity 10/19/2009 10/23/2009 IP 71151-PR01 RETS/ODCM Radiological Effluent BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 11/16/2009 11/20/2009 IP 7112103 Radiation Monitoring Instrumentation and Protective Equipment BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 01/25/2010 01/29/2010 IP 7112101 Access Control to Radiologically Significant Areas 01/25/2010 01/29/2010 IP 7112102 ALARA Planning and Controls 01/25/2010 01/29/2010 IP 71151-OR01 Occupational Exposure Control Effectiveness BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 03/01/2010 03/05/2010 IP 2515/173 Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 03/01/2010 03/05/2010 IP 71151-BI01 Reactor Coolant System Activity 03/01/2010 03/05/2010 IP 71151-PR01 RETS/ODCM Radiological Effluent ISFSI - ISFSI INSPECTION 2 04/01/2010 09/30/2010 IP 60854.1 Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 04/01/2010 09/30/2010 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants OL PREP - PERRY INIT PREP - APRIL 2010 3 04/19/2010 04/23/2010 W90223 OL - INITIAL EXAM - MAY 2010 - PERR OL EXAM - PERRY INIT EXAM - MAY 2010 3 05/10/2010 05/21/2010 W90223 OL - INITIAL EXAM - MAY 2010 - PERR BI ENG - ENGINEERING MODIFICATIONS / 50.59 3 06/14/2010 07/02/2010 IP 7111117T Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 06/14/2010 06/18/2010 IP 7112203 Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 08/23/2010 08/27/2010 IP 7112202 Radioactive Material Processing and Transportation

Perry Inspection / Activity Plan 09/01/2009 - 12/31/2010 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI EP - EP EXERCISE INSPECTION / PI VERIFICATION 3 09/27/2010 10/01/2010 IP 7111401 Exercise Evaluation 09/27/2010 10/01/2010 IP 71151-EP01 Drill/Exercise Performance 09/27/2010 10/01/2010 IP 71151-EP02 ERO Drill Participation 09/27/2010 10/01/2010 IP 71151-EP03 Alert & Notification System BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 11/15/2010 11/19/2010 IP 7112101 Access Control to Radiologically Significant Areas 11/15/2010 11/19/2010 IP 7112102 ALARA Planning and Controls BI OL - LIC. OPERATOR REQUAL. PROGRAM EVALUATION 2 12/06/2010 12/10/2010 IP 7111111B Licensed Operator Requalification Program OL PREP - PERRY INIT PREP - DEC. 2010 3 12/20/2010 12/24/2010 W90232 OL - INITIAL EXAM - JAN 2011 - PERR