ML12248A312
| ML12248A312 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/04/2012 |
| From: | Casto C Region 3 Administrator |
| To: | Kaminskas V FirstEnergy Nuclear Operating Co |
| References | |
| Download: ML12248A312 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 4, 2012 Mr. Vito Kaminskas 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 ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT
Dear Mr. Kaminskas:
On August 7, 2012, the NRC completed its mid-cycle performance review of the Perry Nuclear Plant. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from July 1, 2011, through June 30, 2012. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility. This assessment reflects the integration of the Security Cornerstone into the assessment program.
The NRC determined the performance at Perry Nuclear Plant during the most recent quarter was within the Degraded Cornerstone Column of the NRCs Reactor Oversight Process (ROP)
Action Matrix because of one White PI in Occupational Exposure Control Effectiveness and one finding, originating in the second quarter of 2011, having a low-to-moderate safety significance (i.e. White) related to the Occupational Radiation Safety Cornerstone. The Occupational Radiation Safety PI was reported with a total of five occurrences (White) in the second quarter of 2012 putting this in the White region. We understand you are evaluating this indicator as some of the occurrences may be associated with a single event. We will review this evaluation as part of our ROP baseline inspection process. Regardless, Perry will remain in the Degraded Cornerstone Column of the ROP until the successful completion of a supplemental inspection in accordance with Inspection Procedure (IP) 95002, Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area. In addition, there is one or more greater-than-green Security Cornerstone input(s) as described in Inspection Report Number 05000440/2012406(DRS) dated June 25, 2012.
On August 9, 2012, your staff notified the NRC of your readiness for us to conduct a supplemental inspection to review the actions you have taken to address the performance issues which caused the degraded cornerstone. Therefore, in addition to ROP baseline inspections, the NRC is conducting a supplemental inspection in accordance with IP 95002, beginning on August 27, 2012. The objectives of the Supplemental IP are to provide assurance that the root and contributing causes of the performance issues are understood, to provide assurance that the extent of condition and the extent of cause are identified, to determine if safety culture components caused or significantly contributed to the individual and collective risk-significant performance issues and to provide assurance that corrective actions are sufficient to address the root and contributing causes and prevent recurrence.
V. Kaminskas Performance at the Perry Nuclear Power Plant during the assessment period continued to exhibit some weaknesses in the area of human performance (HP) with nine findings identified.
Although plant work management performance has improved over the period, we have noted occasional challenges caused by HP. Improved performance has been noted in areas where you have completed thorough cause evaluations and taken aggressive corrective actions. In our end-of-cycle performance letter [ML12065A157] dated March 5, 2012, we advised you of substantive cross-cutting issues (SCCIs) in the area of HP with cross-cutting themes in the components of Decision Making, (H.1(b)), and Documentation/Procedures, (H.2(c)). In addition, we advised you that the HP substantive cross-cutting issues would remain open until the number of findings in the H.1(b) and H.2(c) aspects were reduced and you demonstrated the implementation of effective corrective actions that result in sustained performance improvement in the HP area.
Regarding H.1 (b), this SCCI was open through the last assessment period. We have determined, through our baseline inspection process and observations of the programmatic changes you have made with the corrective actions from the root cause evaluation you completed in February of 2012, that your corrective actions on this SCCI have been successful in reducing the findings and addressing the underlying causes. There were two findings in this aspect during this assessment cycle. In addition, there has been sustained performance improvement including several recent examples of conservative decision making by senior management. For these reasons, the SCCI in Decision Making, H.1(b), is closed.
Regarding H.2(c), this SCCI was open for four consecutive assessment periods at the time of the 2011 end-of-cycle assessment. We have determined, through our baseline inspection process and observations in the field of changes implemented by your corrective actions from the root cause evaluation you completed in May of 2012, that your corrective actions have been effective in addressing performance improvement, improving documentation and procedures, and reducing the number of findings related to H.2(c). There were two findings in this HP component during the current assessment cycle, and your actions to ensure implementation of procedural changes through work planning milestone changes have demonstrated improvement in this component of HP. Therefore, the SCCI in Documentation/Procedures, H.2(c), is closed.
The radiation protection program has not demonstrated sustained performance improvements, as problems in occupational radiation safety continue to occur. Radiation safety issues continue to be identified by inspectors and self-revealed to plant staff. Specifically, issues continue to exist regarding the control and access to high radiation areas at the plant. Following the last assessment period, your staff enforced aggressive actions to stabilize and improve performance in this area. These steps initially showed a prompt improvement in this area. For example, during the most recent refueling outage inspection there were no findings involving individual workers entering unauthorized high dose areas. Additionally, the number of personnel contamination events was significantly reduced. However, recent performance indicates that more work needs to be done to ensure that these types of events are arrested. The NRC notes that the radiation protection program should be a continuing focus area for improvement.
V. Kaminskas The enclosed inspection plan lists the inspections scheduled through December 31, 2013.
Routine inspections performed by resident inspectors are not included in the inspection plan.
The inspections listed during the last 9 months of the inspection plan are tentative and may be revised at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence.
In addition to the ROP baseline and IP 95002 inspections, inspections are planned for Temporary Instruction (TI) 2515/177, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems; TI 2515/182, Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping; TI 2515/187, Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walk downs; TI 2515/188, Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walk downs; Independent Spent Fuel Storage Installation (ISFSI) inspections: IP 60854.1, Preoperational Testing of ISFSIs at Operating Plants; and IP 60855.1, Operation of an ISFSI at Operating Plants.
In accordance with 10 CFR 2.390 of the NRCs ARules of Practice,@ a copy of this letter 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Please contact Mr. John Giessner at 630-829-9619 with any questions you have regarding this letter.
Sincerely,
/RA/
Charles A. Casto Regional Administrator Docket No. 50-440 License No. NPF-58
Enclosure:
Perry Nuclear Power Plant Inspection/Activity Plan cc w/encl:
Distribution via ListServ
V. Kaminskas The enclosed inspection plan lists the inspections scheduled through December 31, 2013.
Routine inspections performed by resident inspectors are not included in the inspection plan.
The inspections listed during the last 9 months of the inspection plan are tentative and may be revised at the end-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. This inspection plan does not include security related inspections, which will be sent via separate, non-publicly available correspondence.
In addition to the ROP baseline and IP 95002 inspections, inspections are planned for Temporary Instruction (TI) 2515/177, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems; TI 2515/182, Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping; TI 2515/187, Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walk downs; TI 2515/188, Inspection of Near-Term Task Force Recommendation 2.3 Seismic Walk downs; Independent Spent Fuel Storage Installation (ISFSI) inspections: IP 60854.1, Preoperational Testing of ISFSIs at Operating Plants; and IP 60855.1, Operation of an ISFSI at Operating Plants.
In accordance with 10 CFR 2.390 of the NRCs ARules of Practice,@ a copy of this letter 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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Please contact Mr. John Giessner at 630-829-9619 with any questions you have regarding this letter.
Sincerely,
/RA/
Charles A. Casto Regional Administrator Docket No. 50-440 License No. NPF-58
Enclosure:
Perry Nuclear Power Plant Inspection/Activity Plan cc w/encl:
Distribution via ListServ DOCUMENT NAME: G:\\DRPIII\\1-Secy\\1-Work In Progress\\2012 MOC Letters\\Perry MOC Letter to Licensee.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 OFFICE RIII RIII RIII RIII NAME SShah:dtp JGiessner GShear CCasto DATE 08/22/12 08/27/12 08/27/12 08/27/12 OFFICIAL RECORD COPY
Letter to V. Kaminskas from C. Casto dated September 4, 2012.
SUBJECT:
MID-CYCLE ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT DISTRIBUTION:
Silas Kennedy RidsNrrPMPerry Resource RidsNrrDorlLpl3-2 Resource RidsNrrDirsIrib Resource C. Casto Cynthia Pederson Steven Orth Jared Heck Allan Barker Christine Lipa Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPassessment.Resource@nrc.gov
Page 1 of 2 Planned Dates Start End Inspection Activity Title No. of Staff on Site Perry Inspection / Activity Plan 09/01/2012 - 12/31/2013 ISFSI
- ISFSI INSPECTION - SCHEDULE DEPENDENT 2
IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 08/01/2012 11/30/2012 TI-187
- TI-187 FLOODING WALKDOWN 2
IP Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns 2515/187 07/01/2012 12/30/2012 TI-188
- TI-188 SEISMIC WALKDOWN 2
IP Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns 2515/187 07/02/2012 12/31/2012 95002
- SUPPLEMENTAL FOR RAD PRO WHITE ISSUE 5
IP Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Perfor 95002 08/27/2012 09/14/2012 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP Follow-up on the Industry's Ground Water Protection Initiative 2515/185 09/24/2012 09/28/2012 IP Radioactive Gaseous and Liquid Effluent Treatment 71124.06 09/24/2012 09/28/2012 TI-177
- TEMPORARY INSTRUCTION 2515/177 1
IP Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal & Containment Spray System 2515/177 09/17/2012 10/05/2012 BI EPX
- EP EXERCISE INSPECTION / PI VERIFICATION 2
IP Exercise Evaluation 7111401 10/01/2012 10/05/2012 IP Performance Indicator Verification 71151 10/01/2012 10/05/2012 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 2
IP Radiological Hazard Assessment and Exposure Controls 71124.01 10/22/2012 10/26/2012 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP Occupational Dose Assessment 71124.04 10/22/2012 10/26/2012 BI OLRQ
- BIENNIAL REQUAL PROGRAM INSPECTION 2
IP Licensed Operator Requalification Program 7111111B 12/03/2012 12/07/2012 OL PREP
- PERRY INIT PREP 02/2013 3
OL - INITIAL EXAM - 2013 FEB-MAR - PERRY W90290 02/04/2013 02/08/2013 TI INSP
- TI 182 BURIED PIPING PHASE 2 1
IP Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping 2515/182 02/04/2013 02/08/2013 OL EXAM
- PERRY INIT EXAM 02/2013 3
OL - INITIAL EXAM - 2013 FEB-MAR - PERRY W90290 02/25/2013 03/08/2013 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP Radiological Hazard Assessment and Exposure Controls 71124.01 03/18/2013 03/22/2013 BI ISI
- INSERVICE INSPECTION 1
IP Inservice Inspection Activities - BWR 7111108G 03/18/2013 05/29/2013
Page 2 of 2 Planned Dates Start End Inspection Activity Title No. of Staff on Site Perry Inspection / Activity Plan 09/01/2012 - 12/31/2013 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 04/15/2013 04/19/2013 BI MODS
- TRIENNIAL PERM MODS/50.59 1
IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 07/08/2013 07/26/2013 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP Radiological Environmental Monitoring Program 71124.07 07/22/2013 07/26/2013 IP Reactor Coolant System Activity 71151-BI01 07/22/2013 07/26/2013 IP Occupational Exposure Control Effectiveness 71151-OR01 07/22/2013 07/26/2013 IP RETS/ODCM Radiological Effluent 71151-PR01 07/22/2013 07/26/2013 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 08/19/2013 08/23/2013 BI EPR
- EP ROUTINE INSPECTION / PI VERIFICATION 2
IP Alert and Notification System Testing 7111402 09/16/2013 09/20/2013 IP Emergency Preparedness Organization Staffing and Augmentation System 7111403 09/16/2013 09/20/2013 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 09/16/2013 09/20/2013 IP Performance Indicator Verification 71151 09/16/2013 09/20/2013 BI PI&R
- BIENNIAL PI&R INSPECTION 2
IP Problem Identification and Resolution 71152B 10/21/2013 11/08/2013 BI RP
- RADIATION PROTECTION BASELINE INSPECTION 1
IP Radiation Monitoring Instrumentation 71124.05 10/28/2013 11/01/2013 BI OLRQ
- REQUALIFICATION PROGRAM INSPECTION 1
IP Licensed Operator Requalification Program - Annual Review 7111111A 12/02/2013 12/06/2013