ML100610281

EOC Assessment Letter, Inspection/Activity Plan

ML100610281
Person / Time
Site:	Perry
Issue date:	03/03/2010
From:	Stephanie West Division Reactor Projects III
To:	Bezilla M FirstEnergy Nuclear Operating Co
References
FOIA/PA-2010-0209
Download: ML100610281 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 March 3, 2010 Mr. Mark Bezilla

Site Vice President

FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-A290 Perry, OH 44081-0097

SUBJECT:

ANNUAL ASSESSMENT LETTER - PERRY NUCLEAR PLANT (05000440/2010001)

Dear Mr. Bezilla:

On February 11, 2010, the NRC staff completed its performance review of the Perry Nuclear Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from January 1 through December 31, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

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

Overall, Perry Nuclear Power Plant operated in a manner that preserved public health and safety and fully met all cornerstone objectives. Plant performance for the most recent quarter, as well as for the first three quarters of the assessment cycle, was within the Licensee Response column of the NRC

=s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Therefore, we plan to conduct reactor oversight process (ROP) baseline inspections at your facility. We also plan on conducting several special and infrequently performed Inspection Procedures (IPs) which include: IP 60854.1, "Preoperational testing of Independent Spent Fuel Storage Installations at Operating Plants;" and IP 60855.1, "Operation of an Independent Spent Fuel Storage Installation at Operating

Plants."

In our mid-cycle assessment letter dated September 1, 2009, we advised you of a substantive cross-cutting issue in the cross-cutting area of human performance. During this most recent assessment period, Perry has continued to exhibit weaknesses in the area of human performance. The total number of findings with documented cross-cutting aspects in human performance remained relatively constant, changing from 20 during the last assessment period to 19 during the most recent one. Our assessment of the findings identified

M. Bezilla

three cross-cutting themes in the human performance area: work control - planning (H.3(a)), five findings; work practices - human error prevention techniques (H.4(a)), four findings; and work control - oversight (H.4(c)), four findings. However, during the past assessment period, the number of findings with the same cross-cutting aspect of resources-documentation/procedures (H.2(c)) was reduced to below the threshold for substantive cross-cutting issue themes. While we will continue to monitor the human performance area as a whole in addition to the current cross-cutting themes, based on the actions you have taken to decrease the number of findings in the H.2(c) aspect, the theme in this aspect is being closed.

This assessment period is the fifth consecutive assessment period identifying a substantive cross-cutting issue in the human performance area first opened in our March 3, 2008, end-of-cycle assessment letter [ADAMS Ref. ML080600303]. It is

apparent that the development of causal evaluations and implementation of corrective actions has not been effective in demonstrating sustainable performance in the human performance arena. Therefore, the NRC has a continuing concern with the scope of your efforts and progress in addressing this cross-cutting area and has concluded that the substantive cross-cutting issue in human performance will remain open. The human performance substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of human performance. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme. As part of our continuing review of this issue, a Problem Identification and Resolution (PI&R) follow-up inspection item will be performed in accordance with IP 71152, "Identification and Resolution of Problems,"

Section 03.02, "Selected Issue Follow-up Inspection," during the upcoming assessment period.

On November 12, 2009, at a public meeting to address the ongoing human performance substantive cross-cutting issue, you discussed the progress of the corrective actions you have taken as well as the reasons you believed thes e actions would be more effective than actions previously undertaken. We recognize your attempts to refocus site personnel on their human performance commitments using stand-downs and by placing emphasis on the use of human performance tools. However, the number of human performance findings remains high, and we believe that it is important for you to demonstrate progress in these areas as well as a clear understanding of how overall safety culture improvements can assist in your recovery. Therefore, because your efforts to effect improvements in the human performance area have not been sufficiently effective, we request that you have an independent assessment of safety culture performed at your site. This assessment will help improve your understanding of how the overall safety culture at your site may be impacting your ability to achieve sustained results in the human performance area. This assessment should be completed in time to be reviewed during the NRC biennial PI&R inspection scheduled for November 2010.

Additionally, in our mid-cycle letter dated Sept ember 1, 2009, we advised you of a substantive cross-cutting issue in the cross-cutting area of PI&R. For this assessment period, we identified four findings in the PI&R area with the same aspect of the corrective action program - thorough evaluation (P.1(c)). Because your corrective actions have been unsuccessful in addressing this M. Bezilla

issue, you have failed to demonstrate an improving trend in this aspect. Additionally, we remain concerned that a weakness in the aspect of thorough evaluation may be a significant contributor to your inability to correct your human performance issues. Because of the continued difficulties with PI&R, the NRC has a concern with the scope of your efforts and progress in addressing the cross-cutting area performance deficiencies and has concluded that a substantive cross-cutting issue exists in this area. This substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of PI&R. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme. We request that you address your progress and plans regarding this substantive cross-cutting issue during our upcoming end-of-cycle meeting. We will contact you separately to schedule this meeting.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through June 30, 2011. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at

the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRC

=s A Rules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (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).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at 630-829-9833 with any questions you may have regarding this letter or the inspection plan.

Sincerely, /RA/ Steven West, Director Division of Reactor Projects

Docket No. 50-440 License No. NPF-58

Enclosure:

Perry Inspection/Activity Plan cc w/encl: Distribution via ListServ

Inspection / Activity Plan Page 1 of 2 02/24/2010 Report 22 03/01/2010

-06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Perry BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 2515/173 03/08/2010 03/12/2010 1 IP Reactor Coolant System Activity 71151-BI01 03/08/2010 03/12/2010 ISFSI-ISFSI INSPECTION 2 1 IP Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 60854.1 07/01/2010 09/30/2010 1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 09/01/2010 12/31/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 2 1 IP Radiological Hazard Assessment and Exposure Controls 71124.01 04/19/2010 04/23/2010 1 IP Occupational ALARA Planning and Controls 71124.02 04/19/2010 04/23/2010 1 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 04/19/2010 04/23/2010 1 IP Occupational Dose Assessment 71124.04 04/19/2010 04/23/2010 1 IP Occupational Exposure Control Effectiveness 71151-OR01 04/19/2010 04/23/2010 BI ENG-TRIENNIEL ENGINEERING PERM MODS/50.59 3 1 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 06/14/2010 07/02/2010 OL PREP-PERRY INIT PREP - APRIL 2010 3 1 OL - INITIAL EXAM - MAY 2010 - PERR W90223 05/24/2010 05/28/2010 OL EXAM-PERRY INIT EXAM - JUNE 2010 3 1 OL - INITIAL EXAM - MAY 2010 - PERR W90223 06/14/2010 06/25/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 2 1 IP Radiological Hazard Assessment and Exposure Controls 71124.01 07/19/2010 07/23/2010 1 IP In-Plant Airborne Radioactivity Control and Mitigation 71124.03 07/19/2010 07/23/2010 1 IP Occupational Dose Assessment 71124.04 07/19/2010 07/23/2010 1 IP Public Radiation Safety 71124.07 07/19/2010 07/23/2010 1 IP RETS/ODCM Radiological Effluent 71151-PR01 07/19/2010 07/23/2010 BI EP-EP EXERCISE INSPECTION / PI VERIFICATION 3 1 IP Exercise Evaluation 7111401 09/27/2010 10/01/2010 1 IP Drill/Exercise Performance 71151-EP01 09/27/2010 10/01/2010 1 IP ERO Drill Participation 71151-EP02 09/27/2010 10/01/2010 1 IP A lert & Notification System 71151-EP03 09/27/2010 10/01/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 10/04/2010 10/08/2010 BI PI&R-BIENNIAL PI&R INSPECTION 3 1 IP Identification and Resolution of Problems 71152B 11/01/2010 11/19/2010 This report does not include INPO and OUTAGE activities.

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

Inspection / Activity Plan 02/24/2010 Report 22 03/01/2010

-06/30/2011 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Perry BI OL-BIENNIAL REQUAL PROGRAM INSPECTION 2 1 IP Licensed Operator Requalification Program 7111111B 12/13/2010 12/17/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radiation Monitoring Instrumentation 71124.05 01/24/2011 01/28/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 2515/179 04/18/2011 04/22/2011 1 IP Radiological Hazard Assessment and Exposure Controls 71124.01 04/18/2011 04/22/2011 1 IP Occupational ALARA Planning and Controls 71124.02 04/18/2011 04/22/2011 1 IP Occupational Exposure Control Effectiveness 71151-OR01 04/18/2011 04/22/2011 BI ENG-ENGINEERING INSERVICE INSPECTION 1 1 IP Inservice Inspection Activities - BWR 7111108G 04/18/2011 05/22/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radioactive Gaseous and Liquid Effluent Treatment 71124.06 06/27/2011 07/01/2011 1 IP RETS/ODCM Radiological Effluent 71151-PR01 06/27/2011 07/01/2011 This report does not include INPO and OUTAGE activities.

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

M. Bezilla

issue, you have failed to demonstrate an improving trend in this aspect. Additionally, we remain concerned that a weakness in the aspect of thorough evaluation may be a significant contributor to your inability to correct your human performance issues. Because of the continued difficulties with PI&R, the NRC has a concern with the scope of your efforts and progress in addressing the cross-cutting area performance deficiencies and has concluded that a substantive cross-cutting issue exists in this area. This substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of PI&R. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme. We request that you address your progress and plans regarding this substantive cross-cutting issue during our upcoming end-of-cycle meeting. We will contact you separately to schedule this meeting.

The enclosed inspection plan details the inspections, less those related to physical protection, scheduled through June 30, 2011. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at

the mid-cycle review.

In accordance with 10 CFR 2.390 of the NRC

=s A Rules of Practice,@ a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (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).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at 630-829-9833 with any questions you may have regarding this letter or the inspection plan.

Sincerely, /RA/ Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. NPF-58

Enclosure:

Perry Inspection/Activity Plan cc w/encl: Distribution via ListServ DOCUMENT NAME: G:\1-Secy\1-Work in Progress\2009 EOC Letters\Perry EOC 2009 Letter.doc See Previous Concurrences G Publicly Available G Non-Publicly Available G Sensitive G Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII NAME PVoss:dtp*

JCameron*

SWest DATE 02/23/10 02/23/10 03/03/10 OFFICIAL RECORD COPY

Letter to M. Bezilla from S. West dated March 3, 2010.

SUBJECT:

ANNUAL ASSESSMENT LETTER - PERRY NUCLEAR PLANT (05000440/2010001) DISTRIBUTION

Susan Bagley

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