IR 05000440/2012004

IR 05000440-12-004 and 07200069-12-001, 07/01/2012 - 09/30/2012, Perry Nuclear Power Plant, Unit 1, Routine Integrated Inspection Report

ML12299A305
Person / Time
Site:	Perry, 07200069
Issue date:	10/25/2012
From:	Michael Kunowski NRC/RGN-III/DRP/B5
To:	Kaminskas V FirstEnergy Nuclear Operating Co
References
IR-12-004
Download: ML12299A305 (37)

Text

October 25, 2012

SUBJECT:

PERRY NUCLEAR POWER PLANT NRC INTEGRATED INSPECTION REPORT 05000440/2012004 AND 07200069/2012001

Dear Mr. Kaminskas:

On September 30, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated baseline inspection and an inspection of the Independent Spent Fuel Storage Installation at your Perry Nuclear Power Plant Unit 1. The enclosed inspection report documents the inspection results which were discussed on October 10, 2012, 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 Commissions 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, 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 Document Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael A. Kunowski, Branch Chief Branch 5 Division of Reactor Projects

Docket Nos.: 05000440; 07200069 License No.: NPF-58

Enclosure:

Inspection Report 05000440/2012004;

07200069/2012001 w/Attachment: Supplemental Information

REGION III==

Docket Nos:

50-440;72-069 License No:

NPF-58 Report Nos:

05000440/2012004; 07200069/2012001 Licensee:

FirstEnergy Nuclear Operating Company (FENOC)

Facility:

Perry Nuclear Power Plant, Unit 1 Location:

Perry, Ohio Dates:

July 1, 2012 through September 30, 2012 Inspectors:

M. Marshfield, Senior Resident Inspector

J. Nance, Resident Inspector

E. Bonney, Resident Inspector, Beaver Valley

R. Edwards, Reactor Inspector, DNMS

M. Learn, Reactor Engineer, DNMS

C. Morell, Safety Inspector, NMSS

R. Temps, Senior Safety Inspector, NMSS

Approved by:

Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000440/2012004 and 07200069/2012001; 07/01/2012 - 09/30/2012;

Perry Nuclear Power Plant, Unit 1; Routine Integrated Report.

This report covers a 3-month period of inspection by resident, regional, and headquarters inspectors. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

No findings were identified.

B.

No findings were identified.

REPORT DETAILS

The plant began the inspection period at 100 percent power. On August 3 and 4, plant power was reduced to 60 percent to support further diagnostic testing for an additional fuel leak indicated by plant chemistry results. The results showed that there was still only one leaking pin in the core. On September 21, plant power was reduced to 67 percent to support a rod pattern adjustment and removal of 3A feedwater heater for repairs to a leaking relief valve. The repairs were unsuccessful and the plant returned to full power at completion of the rod pattern adjustment. Throughout the rest of the inspection period, the plant remained at full power with the exception of small periods of slightly reduced power to support surveillance testing requirements.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

==1R01 a.

Adverse Weather Protection-External Flooding (71111.01)==

The inspectors evaluated the design, material condition, and procedures for coping with the design basis probable maximum flood. The evaluation included a review to check for deviations from the descriptions provided in the Updated Safety Analysis Report (USAR) for features intended to mitigate the potential for flooding from external factors.

As part of this evaluation, the inspectors checked for obstructions that could prevent draining, checked that the roofs did not contain obvious loose items that could clog drains in the event of heavy precipitation, and determined that barriers required to mitigate the flood were in place and operable. Additionally, the inspectors performed a walkdown of the protected area to identify any modification to the site which would inhibit site drainage during a probable maximum precipitation event or allow water ingress past a barrier. The inspectors also reviewed the off-normal instruction for mitigating the design basis flood to ensure it could be implemented as written.

Inspection Scope This inspection constituted one external flooding sample as defined in Inspection Procedure (IP) 71111.01-05.

b.

No findings were identified.

Findings

==1R04 a.

Equipment Alignment - Quarterly Partial System Walkdowns (71111.04)==

The inspectors performed partial system walkdowns of the following risk-significant systems:

Inspection Scope

• standby liquid control system 'B';

• emergency closed cooling system 'A';

• control room ventilation and control room emergency recirculating 'B'; and

• annulus exhaust gas treatment system 'B'.

The inspectors selected these systems based on their risk significance relative to the Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could impact the function of the system and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, USAR, Technical Specification (TS) requirements, outstanding work orders, condition reports (CRs), and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also walked down accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of mitigating systems or barriers and entered them into the corrective action program (CAP) with the appropriate significance characterization.

Documents reviewed are listed in the Attachment to this report.

These activities constituted four partial system walkdown samples as defined in IP 71111.04-05.

b.

No findings were identified.

Findings 1R05

.1 Fire Protection (71111.05Q and A)

Quarterly Fire Protection Walkdowns a.

The inspectors conducted fire protection walkdowns which were focused on availability, accessibility, and the condition of firefighting equipment in the following risk-significant plant areas:

Inspection Scope

• Fire Zones 1A and 1B (Emergency Service Water Pump House and Diesel Fire Pump Room);

• Fire Zones 3B (Division 3 Switchgear Room) and Fire Zone 1C (Division 3 Emergency Diesel Generator Room);

• Fire Zones 2A, B, C (Control Complex 599') and Fire Zone 3D (Control Complex 620');

• Fire Zone 1 (Intermediate Building 574' and Pipe Chase 585'); and

• Fire Zone 1AB-3A, 1AB-3B, and 1AB-1F (Auxiliary Building 620'-6" Elevation).

The inspectors reviewed areas to assess if the licensee had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant, effectively maintained fire detection and suppression capability, maintained passive fire protection features in good material condition, and implemented adequate compensatory measures for out-of-service, degraded or inoperable fire protection equipment, systems, or features in accordance with the licensees fire plan.

The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plants Individual Plant Examination of External Events with later additional insights, their potential to impact equipment which could initiate or mitigate a plant transient, or their impact on the plants ability to respond to a security event.

Using the documents listed in the Attachment to this report, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed; that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensees CAP.

Documents reviewed are listed in the Attachment to this report.

These activities constituted five quarterly fire protection inspection samples as defined in IP 71111.05-05.

b.

No findings were identified.

Findings

.2 Annual Fire Protection Drill Observation

a.

On July 12, 2012, the inspectors observed an activation of the fire brigade because of a simulated duct detector alarm in the control ventilation return header with subsequent smoke on the control complex 679' level. Based on this observation, the inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that the licensee identified deficiencies; openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions. Specific attributes evaluated were:

Inspection Scope

• proper wearing of turnout gear and self-contained breathing apparatus;

• proper use and layout of fire hoses;

• employment of appropriate firefighting techniques;

• sufficient firefighting equipment brought to the scene;

• effectiveness of fire brigade leader communications, command, and control;

• search for victims and propagation of the fire into other plant areas;

• utilization of pre-planned strategies;

• adherence to the pre-planned drill scenario;

• control of plant response by control room personnel; and

• drill objectives.

Documents reviewed are listed in the Attachment to this report.

These activities constituted one annual fire protection inspection sample as defined in IP 71111.05-05.

b.

No findings were identified.

Findings 1R11

.1 Licensed Operator Requalification/Licensed Operator Performance

Resident Inspector Quarterly Review of Licensed Operator Requalification a.

On August 20, 2012, the inspectors observed a crew of licensed operators in the plants simulator during licensed operator requalification training to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

Inspection Scope

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The crews performance in these areas was compared to pre-established operator action expectations and successful critical task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program simulator sample as defined in IP 71111.11-05 b.

No findings were identified.

Findings

.2 Resident Inspector Quarterly Observation of Heightened Activity or Risk

a.

On August 3 and 4, 2012, the inspectors observed a scheduled down-power to 60 percent to support fuel defect power suppression testing in an attempt to identify a possible second fuel defect. This was an activity that required heightened awareness or was related to increased risk. The inspectors evaluated the following areas:

Inspection Scope

• licensed operator performance;

• crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms,

• correct use and implementation of procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• ability to identify and implement appropriate TS actions and Emergency Plan actions and notifications.

The performance in these areas was compared to pre-established operator action expectations, procedural compliance and task completion requirements. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity or risk sample as defined in IP 71111.11-05.

b.

No findings were identified.

Findings

==1R12 a.

Maintenance Effectiveness (71111.12)==

The inspectors evaluated degraded performance issues involving the risk-significant reactor water clean-up filter and demineralizer system.

Inspection Scope The inspectors reviewed events, such as where ineffective equipment maintenance had resulted in valid or invalid automatic actuations of engineered safeguards systems, and independently verified the licensee's actions to address system performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with 10 CFR 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and components/functions classified as (a)(2), or appropriate and adequate goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the inspectors verified maintenance effectiveness issues were entered into the CAP with the appropriate significance characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly maintenance effectiveness sample as defined in IP 71111.12-05.

b.

No findings were identified.

Findings

==1R13 a.

Maintenance Risk Assessments and Emergent Work Control (71111.13)==

The inspectors reviewed the licensee's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk-significant and safety-related equipment listed below to verify that the appropriate risk assessments were performed prior to removing equipment for work:

Inspection Scope

• low-pressure core injection pump 'A' discharge low flow (bypass) channel functional;

• Radwaste 574' recovery;

• steam bypass and pressure regulator 'A' failure;

• average power range monitor 'E' connector cleaning - orange risk; and

• fuel handling building crane and Magnetorque repair.

These activities were selected based on their potential risk significance relative to the Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate and complete. When emergent work was performed, the inspectors verified that the plant risk was promptly reassessed and managed. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed TS requirements and walked down portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Specific documents reviewed during this inspection are listed in the Attachment to this report. These maintenance risk assessments and emergent work control activities constituted five samples as defined in IP 71111.13-05.

b.

No findings were identified.

Findings

==1R15 a.

Operability Determinations and Functionality Assessments (71111.15)==

The inspectors reviewed the following issues:

Inspection Scope

• USAR time-critical operator action validation suppression pool cooling actions not previously validated;

• continued cycle 14 operations with the potential of multiple fuel defects;

• control rod 46-51 indication anomaly;

• fuel handling building crane and Magnetorque evaluation; and

• control rod 34-11 lifetime exposure limit reached.

The inspectors selected these potential operability issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that TS operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TSs and USAR to the licensees evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Documents reviewed are listed in the to this report.

This operability inspection constituted five samples as defined in IP 71111.15-05.

b.

No findings were identified.

Findings

==1R18 a.

Plant Modifications (71111.18)==

The inspectors reviewed the permanent modification for Engineering Change Package 04-0274-003, "Upgrade Unit 1 Plant Vent Radiation Monitor 1D17K0780 From Analog to Digital."

Inspection Scope The inspectors reviewed the configuration changes and associated 10 CFR 50.59 safety evaluation screening against the design basis, the USAR, and the TSs, as applicable, to verify that the modification did not affect the operability or availability of the affected system. The inspectors, as applicable, observed ongoing and completed work activities to ensure that the modification was installed as directed and consistent with the design control documents; the modification operated as expected; post-modification testing adequately demonstrated continued system operability, availability, and reliability; and that operation of the modification did not impact the operability of any interfacing systems. As applicable, the inspectors verified that relevant procedure, design, and licensing documents were properly updated. Lastly, the inspectors discussed the plant modification with operations, engineering, and training personnel to ensure that the individuals were aware of how the operation with the plant modification in place could impact overall plant performance. Documents reviewed in the course of this inspection are listed in the Attachment to this report.

This inspection constituted one permanent plant modification sample as defined in IP 71111.18-05.

b.

No findings were identified.

Findings

==1R19

a. Post-Maintenance Testing

(71111.19)==

The inspectors reviewed the following post-maintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

Inspection Scope

• control rod 30-51, rod settling time;

• average power range monitor 'E' indication anomalies;

• reactor protection system motor generator 'A' power supply replacement;

• fuel handling building crane Magnetorque brake;

• residual heat removal to radwaste isolation valve; and

• residual heat removal 'B' minimum flow valve remote shutdown switch replacement.

These activities were selected based upon the structure, system, or component's ability to impact risk. The inspectors evaluated these activities for the following (as applicable):

the effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed; acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate; tests were performed as written in accordance with properly reviewed and approved procedures; equipment was returned to its operational status following testing (temporary modifications or jumpers required for test performance were properly removed after test completion); and test documentation was properly evaluated. The inspectors evaluated the activities against TSs, the USAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with post-maintenance tests to determine whether the licensee was identifying problems and entering them in the CAP and that the problems were being corrected commensurate with their importance to safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted six post-maintenance testing samples as defined in IP 71111.19-05.

b.

No findings were identified.

Findings

==1R22 a.

Surveillance Testing (71111.22)==

The inspectors reviewed the test results for the following activities to determine whether risk-significant systems and equipment were capable of performing their intended safety function and to verify testing was conducted in accordance with applicable procedural and TS requirements:

Inspection Scope

• low-pressure core injection 'C' discharge flow-low channel routine functional testing;

• Division 2 emergency diesel generator routine monthly testing;

• Division 3 emergency diesel generator routine monthly testing;

• remote shutdown testing for Division 2, 2-year surveillance (containment isolation valve testing);

• main steam isolation valve closure channel routine functional testing;

• turbine stop valve channel 'A' and channel 'E' closure and end of core - recirculation pump trip channel 'A' response time routine test; and

• main turbine control valve testing and turbine stop valve closure and turbine control valve fast closure channel routine functional testing.

The inspectors observed in-plant activities and reviewed procedures and associated records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, demonstrated operational readiness, and consistent with the system design basis;

• plant equipment calibration was correct, accurate, and properly documented;

• as-left setpoints were within required ranges, and the calibration frequency was in accordance with TSs, the USAR, procedures, and applicable commitments;

• measuring and test equipment calibration was current;

• test equipment was used within the required range and accuracy; applicable prerequisites described in the test procedures were satisfied;

• test frequencies met TS requirements to demonstrate operability and reliability; tests were performed in accordance with the test procedures and other applicable procedures; jumpers and lifted leads were controlled and restored where used;

• test data and results were accurate, complete, within limits, and valid;

• test equipment was removed after testing;

• where applicable for inservice testing activities, testing was performed in accordance with the applicable version of Section XI, American Society of Mechanical Engineers code, and reference values were consistent with the system design basis;

• where applicable, test results not meeting acceptance criteria were addressed with an adequate operability evaluation or the system or component was declared inoperable;

• where applicable for safety-related instrument control surveillance tests, reference setting data were accurately incorporated in the test procedure;

• where applicable, actual conditions encountering high resistance electrical contacts were such that the intended safety function could still be accomplished;

• prior procedure changes had not provided an opportunity to identify problems encountered during the performance of the surveillance or calibration test;

• equipment was returned to a position or status required to support the performance of its safety functions; and

• all problems identified during the testing were appropriately documented and dispositioned in the CAP.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted six routine surveillance testing samples, and one isolation valve sample as defined in IP 71111.22, Sections -02 and -05.

b.

No findings were identified.

Findings 1EP6

.1 Drill Evaluation

a.

Emergency Preparedness Drill Observation The inspectors evaluated the conduct of a routine licensee emergency drill on August 22, 2012, to identify any weaknesses and deficiencies in classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the Control Room Simulator and Technical Support Center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.

The inspectors also attended the licensee's drill critique to compare any inspector-observed weaknesses with those identified by the licensee staff in order to evaluate the critique and to verify whether the licensee staff was properly identifying weaknesses and entering them into the CAP. As part of the inspection, the inspectors reviewed the drill package and other documents listed in the Attachment to this report.

Inspection Scope This emergency preparedness drill inspection constituted one sample as defined in IP 71114.06-05.

b.

No findings were identified.

Findings

.2 a.

Training Observation The inspector observed a simulator training evolution for licensed operators on August 20, 2012, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that the licensee evaluators noted the same issues and entered them into the CAP. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the Attachment to this report.

Inspection Scope This inspection of the licensees training evolution with emergency preparedness drill aspects constituted one sample as defined in IP 71114.06-05.

b.

No findings were identified.

Findings

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity 4OA1

.1 Performance Indicator Verification

a.

Mitigating Systems Performance Index - Heat Removal System The inspectors sampled licensee submittals for the Mitigating Systems Performance Index (MSPI) Heat Removal System performance indicator (PI) for the third quarter 2011 through the second quarter 2012. To determine the accuracy of the PI data reported, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used.

The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.

The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

Inspection Scope This inspection constituted one MSPI heat removal system sample as defined in IP 71151-05.

b.

No findings were identified.

Findings

.2 a.

Mitigating Systems Performance Index - Residual Heat Removal System The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal System PI for the third quarter 2011 through the second quarter 2012. To determine the accuracy of the PI data reported, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Inspection Scope Revision 6 was used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance. The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the to this report.

This inspection constituted one MSPI residual heat removal system sample as defined in IP 71151-05.

b.

No findings were identified.

Findings

.3 a.

Mitigating Systems Performance Index - Cooling Water Systems The inspectors sampled licensee submittals for the MSPI - Cooling Water Systems PI for the third quarter 2011 through the second quarter 2012. To determine the accuracy of the PI data reported, PI definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, was used. The inspectors reviewed the licensees operator narrative logs, issue reports, MSPI derivation reports, event reports, and NRC Integrated Inspection Reports to validate the accuracy of the submittals. The inspectors reviewed the MSPI component risk coefficient to determine if it had changed by more than 25 percent since the previous inspection, and if so, that the change was in accordance with applicable NEI guidance.

The inspectors also reviewed the licensees issue report database to determine if any problems had been identified with the PI data collected or transmitted for this indicator and none were identified. Documents reviewed are listed in the Attachment to this report.

Inspection Scope This inspection constituted one MSPI cooling water system sample as defined in IP 71151-05.

b.

No findings were identified.

Findings 4OA2

.1 Identification and Resolution of Problems

a.

Routine Review of Items Entered into the Corrective Action Program As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensees CAP at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. Attributes reviewed included: identification of the problem was complete and accurate; timeliness was commensurate with the safety significance; evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent-of-condition reviews, and previous occurrences reviews were proper and adequate; and that the classification, prioritization, focus, and timeliness of corrective actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Inspection Scope Minor issues entered into the licensees CAP as a result of the inspectors observations are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure they were considered an integral part of the inspections performed during the quarter and documented in Section 1 of this report.

b.

No findings were identified.

Findings

.2 a.

Daily Corrective Action Program Reviews In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensees CAP. This review was accomplished through inspection of the stations daily CR packages.

Inspection Scope These daily reviews were performed by procedure as part of the inspectors daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b.

No findings were identified.

Findings

.3 a.

Semi-Annual Trend Review The inspectors performed a review of the licensees CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors review was focused on repetitive equipment issues, but also considered the results of daily inspector CAP item screening discussed in Section 4OA2.2 above, licensee trending efforts, and licensee human performance results. The inspectors review nominally considered the 6-month period of January 1, 2012 through June 30, 2012, although some examples expanded beyond those dates where the scope of the trend warranted.

Inspection Scope The review also included issues documented outside the normal CAP such as major equipment problem lists, repetitive and/or rework maintenance lists, departmental problem/challenges lists, system health reports, quality assurance audit/surveillance reports, self-assessment reports, and Maintenance Rule assessments. The inspectors compared and contrasted their results with the results contained in the licensees CAP trending reports. Corrective actions associated with a sample of the issues identified in the licensees trending reports were reviewed for adequacy.

This review constituted one semi-annual trend inspection sample as defined in IP 71152-05.

b.

No findings were identified.

Findings

.4 a.

Selected Issue Follow-Up Inspection: Radiological Waste Controls and Processing System During a review of items entered in the licensees CAP, the inspectors recognized two corrective action items documenting a floor drain backup in Radwaste Building 646' and a large resin spill in Radwaste Building 574', which occurred on April 19, 2012, and June 2, 2012, respectfully. A follow-up of these two issues formed an in-depth review of the Radiological Waste Controls and Processing System over the last 2 years. The two CRs were:

Inspection Scope

• CR 2012-06121; Radwaste, 646, Floor Drain Backed Up; dated April 19, 2012; and

• CR 2012-09120; Resin Found on Floor of 574' Radwaste; dated June 2, 2012.

The inspectors discussed the evaluation and associated corrective actions with licensee personnel and verified the following attributes during their review of the above apparent and root cause evaluations:

• complete and accurate identification of the problem in a timely manner, commensurate with its safety significance and ease of discovery;

• consideration of the extent of condition, generic implications, common cause and previous occurrences;

• classification and prioritization of the resolution of the problem, commensurate with safety significance;

• identification of the root and contributing causes of the problem; and

• identification of corrective actions, which were appropriately focused to correct the problem.

The inspectors discussed the corrective actions and associated action request evaluations with licensee personnel. Further NRC evaluation of this issue will be documented in IR 05000440/2012009.

This review constituted one in-depth problem identification and resolution sample as defined in IP 71152-05.

b.

No findings were identified.

Findings

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

a.

Licensee Event Report (LER) 05000440/2012-002-00: Inoperable High-Pressure Core Spray System The inspectors reviewed the plants response to the high-pressure core spray system being declared inoperable due to the Division 3 direct current (DC) electrical power subsystem being declared inoperable. Approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> later, the licensee placed the Division 3 reserve charger into service and restored the Division 3 DC electrical power subsystem and the high-pressure core spray system to operable status. The licensee documented the equipment deficiency in CR 2012-09572 and conducted a root cause evaluation to determine appropriate corrective actions. Immediate corrective actions were taken to place the reserve battery charger into service. This LER was reviewed by the inspectors and no additional findings or violations of NRC requirements were identified. The causal analysis and corrective actions associated with this event are listed in the attachment. This LER is closed.

Inspection Scope This event follow-up review constituted one sample as defined in IP 71153-05.

b.

No findings were identified.

Findings 4OA5

.1 Other Activities

Preoperational Testing of an Independent Spent Fuel Storage Facility Installation (ISFSI) at Operating Plants (60854.1)

a. Inspection Scope

(1) The inspectors reviewed training records and qualifications of individuals performing work activities associated with the ISFSI. The inspectors interviewed licensee personnel in various departments to verify that they were knowledgeable in the scope of work that was being performed.

Training

(2) The inspectors reviewed the licensees Quality Assurance Program, as it applied to the ISFSI, and noted that the NRC-approved 10 CFR Part 50, Appendix B, Quality Assurance Program was utilized for dry fuel storage activities as allowed by 10 CFR 72.140(d), Quality Assurance.

Quality Assurance The inspectors reviewed procedures and documentation pertaining to the receipt inspection of the transfer cask (HI-TRAC), multi-purpose canister (MPC),storage cask (HI-STORM), and special lifting devices. The inspectors observed the licensee implement its Materials and Test Equipment program into ISFSI activities and verified that gauges and tools were within their calibration date.

(3) The inspectors reviewed the licensees Emergency Preparedness Plan required by 10 CFR 50.47, Emergency Plans, for conformance with 10 CFR 72.32(c), Emergency Plans. The inspectors verified that the licensee incorporated Emergency Action Levels into the Emergency Plan to address the emergency scenarios, their classification, and recovery actions associated with the ISFSI. The inspectors reviewed the licensees procedure that addressed contingency actions, including a fire at the ISFSI.

Emergency Preparedness and Fire Protection

(4) The inspectors reviewed the licensees calculations associated with fuel characterization and selection for storage. The inspectors reviewed the initial campaign cask fuel selection packages to verify that the licensee planned to load fuel in accordance with the Certificate of Compliance (CoC) approved contents.

Fuel Selection The inspectors reviewed the licensees evaluations that characterize fuel as fuel debris, damaged, or intact. The licensee did not plan to load any damaged fuel assemblies, fuel assemblies with pinhole leaks or hair line cracks, or fuel debris during the initial campaign.

The inspectors reviewed the selected assemblies to identify the maximum burnup and noted that the maximum burnup of any assembly planned for loading during the initial campaign was less than 45,000 megawatt days/metric tons of uranium (MWd/MTU).

Fuel assemblies with burnup greater than 45,000 MWd/MTU limit are considered as high burnup assemblies, and additional requirements exist. As such, the licensee planned to load only moderate burnup assemblies during the 2012 campaign.

The inspectors reviewed the licensees use of NRC Regulatory Guide 3.54, Spent Fuel Heat Generation in an Independent Spent Fuel Storage Installation, to calculate decay heat loads for each assembly. The licensee assessed heat loads for both the total canister as well as individual canister assembly locations. The inspectors verified that the licensee incorporated appropriate cooling times, initial uranium enrichments, and burnup limiting acceptance criteria into its calculations to ensure the radiation dose limits from the ISFSI were in compliance with 10 CFR 72.104, Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS [Monitored Retrievable Storage Installation].

(5) The inspectors evaluated the licensees Radiation Protection Program pertaining to the operation of the ISFSI and maintaining exposures as-low-as-is-reasonably-achievable (ALARA). The inspectors reviewed the licensees procedures describing the methods and techniques used when performing dose rate and surface contamination surveys and verified that they ensured dose rate limits and surveillance requirements of the TSs were met. The inspectors verified that the licensees radiation protection staff considered lessons learned from other utilities spent fuel loading campaigns during development of the radiological controls for the loading, storage, and unloading operations. The inspectors interviewed licensee personnel to verify their knowledge regarding the scope of the work and the radiological hazards associated with the transfer and storage of spent fuel. The inspectors reviewed licensee dose rate calculations to Radiation Protection verify that the licensees ISFSI was in compliance with 10 CFR 72.104, Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS. The inspectors verified that the licensee has a radiation monitoring program in place to ensure compliance with 10 CFR 20.1301, Dose Limits for Individual Members of the Public, and interviewed staff on the implementation of this program in regards to ISFSI storage operations.

(6) The inspectors reviewed the licensees implementation of the control of heavy loads program for ISFSI operations. The inspectors reviewed inspection, testing, and maintenance documentation associated with the Fuel Handling Building crane, HI-TRAC lifting trunnions, lift yoke, and Vertical Cask Transporter to ensure compliance with industry standards, station procedures, and design specifications. The inspectors observed the licensee perform heavy loads movements inside and outside of the Fuel Handling Building.

Control of Heavy Loads

(7) The licensee performed pre-operational dry run activities in order to fulfill the requirements of the CoC. The NRC inspectors were onsite to observe dry run activities.

These activities included MPC welding and processing; heavy loads operations inside and outside of the Fuel Handling Building; reviews of the licensees 10 CFR 72.212, Conditions of General License Issued Under 72.210, report; and other documentation reviews.

Dry Run Activities The inspectors observed the licensee place the HI-TRAC containing the MPC into the spent fuel pool (SFP) and the subsequent loading and unloading of dummy fuel assemblies into the MPC basket. The licensee demonstrated removal of a dummy fuel assembly from the SFP storage rack, placement of the assembly into the MPC, and retrieval of the fuel assembly from the MPC to the SFP rack. The inspectors observed the licensee remove a HI-TRAC containing an MPC from the SFP and subsequent placement of the HI-TRAC in the processing lay-down area.

The inspectors observed the licensee demonstrate all closure welds and non-destructive testing (NDT) required to prepare the MPC for storage. Welding procedures, procedure qualification reports, and welder qualifications were reviewed to ensure compliance with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section IX requirements. The NDT procedures and the qualifications of the technician performing the testing were reviewed by the inspectors to ensure compliance with American Society of Mechanical Engineers Boiler and Pressure Vessel Section V requirements.

The inspectors observed the licensee demonstrate MPC processing activities, including MPC hydrostatic testing, blow-down, vacuum drying, and helium backfilling. The inspectors also observed the licensee demonstrate MPC unloading dry run activities.

The inspectors observed transfer of the MPC from the HI-TRAC transfer cask to the HI-STORM storage cask in a restrained support structure in the Fuel Handling Building and the subsequent movement of the HI-STORM outside of the Fuel Handling Building on a Zero Profile Transporter.

The inspectors observed communications between dry cask personnel, operations, radiation protection, and security staff. The inspectors verified adequate communication and coordination between departments and adherence to procedures.

The inspectors attended licensee briefings during dry run operations including:

infrequently performed test or evolution briefings, pre-job briefs, post-job briefs, ALARA radiation dose briefs, and in-field briefs.

The inspectors reviewed loading and unloading procedures to ensure that they contained commitments and requirements specified in the CoC, TS, Final Safety Analysis Report (FSAR), and 10 CFR Part 72.

b. Findings

No findings were identified.

.2 a.

Review of 10 CFR 72.212(b) Evaluations at Operating Plants (60856.1)

(1) Inspection Scope The inspectors previously reviewed the licensees ISFSI pad evaluations for compliance with the requirements in 10 CFR 72.212(b)(5)(ii) during ISFSI inspections documented in NRC IRs 05000440/2011009 and 07200069/2011001(DNMS).

Review of ISFSI Pad Evaluations

(2) The inspectors evaluated the licensees compliance with the requirements of 10 CFR 72.212 and 10 CFR 72.48, Changes, Tests, and Experiments. The inspection consisted of interviews with cognizant personnel and a review of applicable documentation. The licensee is required, as specified in 10 CFR 72.212(b)(1), to notify the NRC of the intent to store spent fuel at the Perry Nuclear Power Plant ISFSI facility at least 90 days prior to the first storage of spent fuel. The licensee notified the NRC on June 25, 2010, of its intent to store spent fuel using the Holtec HI-STORM 100 Cask System according to CoC No. 72-1014, Amendment 5.

Review of Site Characteristics Against Safety Analysis Report and Safety Evaluation Report A written evaluation is required per 10 CFR 72.212(b)(6), prior to use, to establish that the conditions of the CoC have been met. Perry Nuclear Power Plant Independent Spent Fuel Storage Installation (ISFSI) 10 CFR 72.212 Evaluations Report, Revision 0, dated October 11, 2010, documented the evaluations performed by the licensee prior to use of the 10 CFR Part 72 general license.

The inspector reviewed the technical report together with various supporting documents to assess whether the Perry Nuclear Power Plant had adequately performed the required evaluations. In particular, Calculation No. G58-S-R-M-004, Evaluation of Hydrogen and Oxygen Hazards for ISFSI, and G58-S-R-L-011, Evaluation of Fire and Explosion Hazards for ISFSI, were reviewed in detail. These calculations (reports)contained the results of the fire and explosion hazard analysis for the ISFSI haul path and storage location and prescribed physical and administrative controls required during cask movement on the haul path as well as for ISFSI operations.

Through this review, the inspectors verified that applicable reactor site parameters, such as possible: fires, explosions, tornadoes, wind-generated missile impacts, seismic qualifications, lightning strikes, flooding, and temperature extremes, were evaluated for acceptability with bounding values specified in the Holtec HI-STORM 100 FSAR.

b.

No findings were identified.

Findings 4OA6

.1 Meetings, Including Exit

On October 10, 2012, the inspectors presented the inspection results to the Site Vice-President, Mr. Vito Kaminskas, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

.2 Interim Exit Meetings

The ISFSI preoperational inspection concluded with an exit meeting on August 28, 2012. The inspector presented the inspection results to Mr. V. Kaminskas and other members of the licensee management and staff. Licensee personnel acknowledged the information presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

V. Kaminskas, Site Vice-President

Licensee

J. Grabnar, Site Operations Director

R. Coad, Director, Regulatory Compliance

H. Hanson, Performance Improvement Director

D. Reeves, Site Engineering Director

J. Tufts, Operations Manager

J. Veglia, Maintenance Director

T. Wallender, Holtec Site Manager

LIST OF ITEMS

Opened

None

Closed

05000440/2012002-00 LER Inoperable High-Pressure Core Spray System (4OA3)

Discussed

None