IR 05000440/2016502

Baseline Emergency Preparedness Biennial Exercise Inspection Report 05000440/2016502

ML16265A048
Person / Time
Site:	Perry
Issue date:	09/20/2016
From:	Orth S K Plant Support Branch II
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
IR 2016502
Download: ML16265A048 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUIT E 210 LISLE, IL 60532

-4352 September 20, 2016 Mr. David Hamilton Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A

-PY-A 290 Perry, OH 44081

-0097

SUBJECT: PERRY NUCLEAR POWER PLANT, UNIT 1 - BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000 440/201 6 502

Dear Mr. Hamilton:

On September 15, 201 6, the U.S. Nuclear Regulatory Commission (NRC) completed a n inspection at your Perry Nuclear Power Plant, Unit 1. The enclosed report documents the results of this inspection

, which were discussed on September 15, 201 6, with you and other members of your staff.

No findings were identified during this inspection.

In accordance with Title 10 of the Code of Federal Regulations (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's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Acce ss and Management System (ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Steven K. Orth, Chief Plant Support Branch

Division of Reactor Safety Docket No. 50

-440 License No. NPF

-58 Enclosure:

I R 05000 440/20 16 502 cc: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-440 License N o: NPF-58 Report No:

05000440/20165 0 2 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Perry Nuclear Power Plant, Unit 1 Location: North Perry, Ohio Dates: September 12 through 1 5, 2016 Inspectors:

G. Hansen, Senior Emergency Preparedness Inspector M. Garza, Emergency Preparedness Inspector B. Kemker, Senior Resident Inspector J. Rutkowski , Project Engineer Approved by:

S. Orth, Chief Plant Support Branch Division of Reactor Safety 2

SUMMARY

I R 05000 440/2016502; 0 9/12/201 6 - 0 9/1 5/201 6; Perry Nuclear

Power Plant, Unit 1; Baseline Emergency Preparedness Exercise Evaluation; Exercise Evaluation Scenario Review; and Performance Indicator Verification

. This report covers a 1-w eek period of announced baseline inspection by four Region III inspectors. The U.S. Nuclear Regulatory Commission's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," dated July 2016.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

No findings were identified.

=

Licensee-Identified Violations===

None 3

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP1 Exercise Evaluation (71114.01)

.1 Exercise Evaluation

a. Inspection Scope

The inspectors reviewed the September 13, 2016, biennial emergency preparedness exercise objectives and scenario to ensure that the exercise would acceptably test major elements of the licensee's emergency plan and to verify that the exercise's simulated problems provided an acceptable framework to support demonstration of the licensee's capability to implement its plan.

The inspectors also reviewed records of other drills and exercises conducted in 2014, 2015

, and 2016, to verify that those drills' scenarios were sufficiently different from the scenario used in the September 13, 2016 , exercise. The inspectors observed and evaluated the licensee's exercise performance, focusing on the risk-significant activities of emergency classification, notification, and protective action decision-making, implementation of accident mitigation strategies, and correction of past exercise weaknesses, in the following emergency response facilities:

Control Room Simulator (CRS);

Technical Support Center (TSC); Operation al Support Center (OSC); and Emergency Operations Facility (EOF). The inspectors also assessed the licensee's recognition of abnormal plant conditions, transfer of responsibilities between facilities, internal communications, interfaces with offsite officials, readiness of emergency facilities and related equipment, and overall implementation of the licensee's emergency plan. The inspectors attended post

-exercise critiques in the CRS, TSC, OSC, and EOF to evaluate the licensee's initial self-assessment of its exercise performance.

The inspectors later met with the licensee's lead exercise evaluators and managers to obtain the licensee's findings and assessments of its exercise participants' performances.

These self

-assessments were then compared with the inspectors' independent observations and assessments to assess the licensee's ability to adequately critique its exercise performance.

Documents reviewed are listed in the Attachment to this report.

This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.01.

b. Findings

No findings were identified.

1EP 8 Exercise Evaluation

- Scenario Review (71114.08)

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in

-office review of the exercise objectives and scenario s submitted to the NRC using IP 71114.08, "Exercise Evaluation

- Scenario Review," to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14).

Documents reviewed are listed in the Attachment to this repor t. This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

(71151)

.1 Drill/Exercise Performance

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP) Performance Indicator (PI) for the period from the second quarter of 201 5 through the second quarter of 201 6. To determine the accuracy of the PI data reported during this period, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, were used.

The inspectors reviewed the licensee's records associated with the performance indicator to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre

-designated control room simulator training sessions, and performance during other drills.

Documents reviewed are listed in the Attachment to this report. This inspection constituted one DEP sample as defined in IP 71151.

b. Findings

No findings were identified.

.2 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspectors sampled licensee submittals for the Emergency Response Organization (ERO) Drill Participation PI for the period from the second quarter of 201 5 through the 5 second quarter of 201 6. To determine the accuracy of the PI data reported during this period, PI definitions and guidance contained in NEI 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, were used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, performance during the 2015 and 2016 drill, and revisions of the roster of personnel assigned to key emergency response organization positions.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one ERO Drill Participation sample as defined in IP 71151.

b. Findings

No findings were identified.

.3 Alert and Notification System

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System (ANS)

PI for the period from the second quarter of 201 5 through the second quarter of 201 6. To determine the accuracy of the PI data reported during this period, PI definitions and guidance contained in NEI 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, were used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one ANS sample as defined in IP 71151.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On September 15, 201 6, the inspectors presented the biennial exercise inspection results to Mr. D. Hamilton

, and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC

T Licensee

D. Hamilton, Site Vice President

F. Payne, Plant General Manager

T. Brown, Performance Improvement Director

D. Reeves, Site Engineering Director

B. Blair, Operations Manager

R. O'Connor, Emergency Preparedness Manager

C. Elliot, Radiation Protection Manager

J. Pry, Work Management

Manager

J. Tufts, Outage Management Manager

P. Boissoneault, Training Manager

S. Gorski, Programs & Technical Services Manager

M. Fox, Security Manager

S. Zalesny, Fleet Emergency Preparedness

L. Zerr, Regulatory Compliance Supervisor

T. Kledzik, Regulatory Compliance

L. Vanderhourst, Emergency Preparedness

B. Luthanen, Emergency Preparedness

P. Harkins, Emergency Preparedness

U.S. Nuclear Regulatory Commission

J. Nance, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUS

SED Opened, Closed, and Discussed

None

LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspector

s reviewed the documents in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

1EP 1 Exercise Evaluation

(71114.0 1) Perry Nuclear Power Plant Emergency Plan; Revision 4

EPI-A1; Emergency Action Levels; Revision 26

EPI-A2; Emergency Actions Based on Event Classification; Revision 1

EPI-A6; Technical Support Center Activation; Revision

EPI-A 7; Operations Support Center Activation; Revision

EPI-A 8; Emergency Operations Facility

Activation; Revision

Two Years of Drill and Exercise Corrective Action Program Items; September 2014

-September 2016

Two Years of Scenario Timelines; September 2014

-September 2016

EPI-B1; Emergency Notification System; Revision 25

EPI-B4; First Aid and Medical Care; Revision 16

EPI-B5; Personnel Accountability/Site Evacuation; Revision 16

EPI-B8; Protective

Actions and Guides; Revision 18

EPI-B10; Emergency Radiological Environmental Monitoring Program; Revision 7

EPI-B11; Emergency Dosimetry Issue; Revision 10

EP-B13; Determination of Core Damage Under Accident Conditions; Revision 10

NOP-LP-2001; Corrective Action Program; Revision 38

NOP-LP-5007; Perry MIDAS Dose Assessment; Revision 2

CR 2014-1 3881; 8/27/14 ERO Drill Controller Performance Issues;

Dated September 3

, 2014 CR 2014-14 364; PA-PY-14-02 , Repeat procedure use and adherence issues with ERO dose assessment

Dated September 15, 2014

CR 201 5-04097; Perry ANS Siren Performance Trend Identified

Dated March 2 6, 201 5 CR 201 6-0 4 271; Declining trend in pager test responses

Dated March 31, 2016

CR 201 6-11070; Evaluated Exercise

- Transfer of Emergency Coordinator Duties

Dated September 19, 201 6 CR 201 6-1 0863; ERO Drill critique, monitoring

of subcriticality during an ATWS, EOP-1A; Dated September 13, 2016

CR 201 6-10923; 2016 Evaluated Exercise

- Release source term not communicated; Dated September 15, 201 6 CR 2016-1092 5; 2016 Evaluated Exercise

- NOP-LP-5007 MIDAS Logic Flowchart Deficiencies

Dated September 15, 2016

CR 2016-109 32; 2016 Evaluated Exercise

- Perry and State Protective Action Recommendations to the Counties were not in Agreement

Dated September 15, 2016

CR 2016-10938; 2016 Evaluated Exercise

- Objective K.7 Not Met

- Site Area Emergency News Statement Timeliness

Dated September 15, 2016

CR 2016-109 41; 2016 Evaluated Exercise

- Objective F.6 Not Met

- Source of Release

Dated September 15, 2016

1EP8 Exercise Evaluation

- Scenario Review (71114.08)

Perry Nuclear Plant Emergency Preparedness Exercise 60-Day Scenario Submittal; Dated July 11, 201 6 4OA1 Performance Indicator Verification

(71151) NOBP-LP-4012-11; Emergency Preparedness Drill/Exercise Performance Records

April 2015 - June 2016 NOBP-LP-4012-12; Emergency Response Organization Drill Participation Records; April 2015 - June 2016 NOBP-LP-4012-13; Alert and Notification System Reliability Records;

April 2015

- June 2016 LIST OF ACRONYMS USE

D ADAMS Agencywide Documents Access and Management System

ANS Alert and Notification System

CFR Code of Federal Regulations

CRS Control Room Simulator

DEP Drill and Exercise Performance

EOF Emergency Operations Facility

ERO Emergency Response Organization

IP Inspection Procedure

NEI Nuclear Energy Institute

NRC U.S. Nuclear Regulatory Commission

OSC Operational Support Center

PARS Publicly Available Records System

PI Performance Indicator

TSC Technical Support Center

Mr. David Hamilton

Site Vice President FirstEnergy Nuclear Operating Company

Perry Nuclear Power Plant

P. O. Box 97, 10 Center Road, A

-PY-A 290 Perry, OH 44081

-0097 SUBJECT: PERRY NUCLEAR POWER PLANT, UNIT 1 - BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000440/201

502 Dear Mr. Hamilton: On September 15, 2016, the

U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Perry Nuclear Power Plant, Unit 1. The enclosed report documents the results of this inspection, which were discussed on September 15, 2016, with you and other members of

your staff.

No findings were identified during this inspection.

In accordance with Title 10 of the Code of Federal Regulations

(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's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide

Documents Access and Management System (ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html

(the Public Electronic Reading Room).

Sincerely, /RA/ Steven

K. Orth, Chief Plant Support Branch

Division of Reactor Safety

Docket No. 50

-440 License No. NPF

-58 Enclosure:

IR 05000440/2016502

cc: Distribution via LISTSERV