ML13246A237

2013 Perry Nuclear Power Plant Mid-Cycle Letter Combined

ML13246A237
Person / Time
Site:	Perry
Issue date:	09/03/2013
From:	Pederson C Region 3 Administrator
To:	Harkness E FirstEnergy Nuclear Operating Co
References
IR-13-006
Download: ML13246A237 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 3, 2013 Mr. Ernest Harkness 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 (REPORT 0500440/2013006)

Dear Mr. Harkness:

On August 13, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed its mid-cycle performance review of the Perry Nuclear Power Plant. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from July 1, 2012, through June 30, 2013. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined the performance at Perry during the most recent quarter, ending June 30, 2013, was within the Degraded Cornerstone Column (Column 3) of the NRCs Reactor Oversight Process (ROP) Action Matrix because of a low-to-moderate safety significance (i.e., White) held-open inspection finding and Notice of Violation (NOV), a Yellow Occupational Exposure Control Effectiveness PI, and a parallel White PI inspection finding, all of which affected the Occupational Radiation Safety Cornerstone.

Work management performance at Perry has remained steady over the assessment period with some challenges caused by human performance problems. During the refueling outage in March and April 2013, NRC inspectors identified human performance deficiencies, indicating that additional effort is needed to engrain expected behaviors when the organization is conducting infrequently performed tasks or schedule pressure exists. Of note were two valve mispositionings that resulted in NRC findings of very low safety significance (Green). The NRC also noted that your staff made a conservative decision to shut down the reactor when

E. Harkness leakage increased in the drywell after the refueling outage was completed. Several unexpected maintenance issues and equipment repairs arose during the shutdown and the performance of your staff in addressing those issues was considered good.

On August 12, 2013, the NRC issued 95002 Supplemental Inspection Report and Assessment Follow-up Letter (ML13224A382) that closed the held-open White inspection finding and NOV, and the parallel White PI inspection finding. Also, the Occupational Exposure Control Effectiveness PI returned from Yellow to Green in the second quarter of 2013. As a result, the NRC assessed the performance at Perry to be in the Licensee Response Column (Column 1) of the ROP Action Matrix as of August 12, 2013.

Our August 12, 2013 inspection report discusses that continued management attention and focus is needed to address lower level, less risk significant issues in the radiation protection area, radiological work coordination among all site departments, and continued emphasis that the issues in the radiation protection area are not restricted to the radiation protection department but apply to radiation workers in the other Perry departments. Included in these lower level issues that affect other departments are procedure use and adherence and procedure quality. In a letter dated January 17, 2013, a deviation from the ROP Action Matrix was approved by the Executive Director for Operations. Because of two White inspection findings in the occupational radiation safety area and one or more Greater-than-Green inspection findings in the security area, Perry met the criteria for a Repetitive Degraded Cornerstone (Column 4) of the Action Matrix. However, because the performance issues were well understood and appeared limited to occupational radiation safety, the NRC considered the regulatory actions specified for Column 3 were more appropriate than those for Column 4.

With satisfactory completion of the inspection procedure 95002 inspection, documented in the August 12, 2013, inspection report, this deviation is no longer in effect.

Based on this assessment, we plan to conduct ROP baseline inspections at your facility.

However, the radiation protection baseline inspections will focus on those radiation protection issues identified above and the biennial Problem Identification and Resolution team inspection will review your corrective actions for your extent of cause evaluations completed in response to the White findings. The enclosed inspection plan lists the inspections scheduled through December 31, 2014. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last nine 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.

E. Harkness In accordance with 10 CFR 2.390 of the NRCs 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 System (PARS) component of NRC's Agencywide Documents 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).

Please contact Mr. Michael Kunowski, Branch 5 Chief, Division of Reactor Projects, at 630-829-9618, with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Cynthia D. Pederson Regional Administrator Docket No. 50-440 License No. NPF-58

Enclosure:

Perry Nuclear Power Plant Inspection/Activity Plan cc w/encl: Distribution via ListServ'

E. Harkness In accordance with 10 CFR 2.390 of the NRCs 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 System (PARS) component of NRC's Agencywide Documents 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).

Please contact Mr. Michael Kunowski, Branch 5 Chief, Division of Reactor Projects, at 630-829-9618, with any questions you may have regarding this letter or the inspection plan.

Sincerely,

/RA/

Cynthia D. Pederson Regional Administrator Docket No. 50-440 License No. NPF-58

Enclosure:

Perry Nuclear Power Plant Inspection/Activity Plan cc w/encl: Distribution via ListServ' DISTRIBUTION:

See next page DOCUMENT NAME: PERRY MOC Letter 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 MKunowski:sb/rj KOBrien CPederson DATE 08/29/13 08/29/13 08/29/13 OFFICIAL RECORD COPY

Letter to E. Harkness from C. Pederson dated September 3, 2013

SUBJECT:

MID-CYCLE ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT (REPORT 0500440/2013006)

DISTRIBUTION:

Vivian Campbell RidsNrrPMPerry Resource RidsNrrDorlLpl3-2 Resource RidsNrrDirsIrib Resource Cynthia Pederson Anne Boland Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPassessment.Resource@nrc.gov

Page 1 of 2 Perry 08/26/2013 07:15:01 Inspection / Activity Plan Report 22 09/01/2013 - 12/31/2014 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site BI EPR - EP ROUTINE INSPECTION / PI VERIFICATION 2 1 09/16/2013 09/20/2013 IP 7111402 Alert and Notification System Testing 1 09/16/2013 09/20/2013 IP 7111403 Emergency Preparedness Organization Staffing and Augmentation System 1 09/16/2013 09/20/2013 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 1 09/16/2013 09/20/2013 IP 71151 Performance Indicator Verification BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 09/23/2013 09/27/2013 IP 71124.07 Radiological Environmental Monitoring Program BI PI&R - BIENNIAL PI&R INSPECTION 5 1 11/04/2013 11/22/2013 IP 71152B Problem Identification and Resolution BI RP - RADIATION PROTECTION BASELINE INSPECTION 2 1 10/28/2013 11/01/2013 IP 71124.05 Radiation Monitoring Instrumentation 1 10/28/2013 11/01/2013 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 11/18/2013 11/22/2013 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1 11/18/2013 11/22/2013 IP 71124.04 Occupational Dose Assessment 1 11/18/2013 11/22/2013 IP 71151-BI01 Reactor Coolant System Activity 1 11/18/2013 11/22/2013 IP 71151-OR01 Occupational Exposure Control Effectiveness 1 11/18/2013 11/22/2013 IP 71151-PR01 RETS/ODCM Radiological Effluent BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 01/13/2014 01/17/2014 IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 1 01/13/2014 01/17/2014 IP 71124.04 Occupational Dose Assessment BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 02/10/2014 02/14/2014 IP 71124.01 Radiological Hazard Assessment and Exposure Controls BI ENG - COMPONENT DESIGN BASIS INSPECTION 6 1 03/03/2014 04/04/2014 IP 7111121 Component Design Bases Inspection BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 05/05/2014 05/09/2014 IP 71124.05 Radiation Monitoring Instrumentation BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 06/16/2014 06/20/2014 IP 71124.02 Occupational ALARA Planning and Controls 1 06/16/2014 06/20/2014 IP 71151-BI01 Reactor Coolant System Activity 1 06/16/2014 06/20/2014 IP 71151-OR01 Occupational Exposure Control Effectiveness 1 06/16/2014 06/20/2014 IP 71151-PR01 RETS/ODCM Radiological Effluent This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Page 2 of 2 Perry 08/26/2013 07:15:01 Inspection / Activity Plan Report 22 09/01/2013 - 12/31/2014 Unit Planned Dates No. of Staff Number Start End Inspection Activity Title on Site BI EPX - EP EXERCISE INSPECTION / PI VERIFICATION 2 1 09/22/2014 09/26/2014 IP 71151 Performance Indicator Verification ISFSI - ISFSI OPERATION AT REACTOR SITE 1 1 10/01/2014 10/31/2014 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1 10/20/2014 10/24/2014 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation BI OLRQ - BIENNIAL REQUAL PROGRAM INSPECTION 2 1 12/15/2014 12/19/2014 IP 7111111B Licensed Operator Requalification Program This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.