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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 1, 2010  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 1, 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
 
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:==
==SUBJECT:==
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - PERRY NUCLEAR POWER PLANT
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -
PERRY NUCLEAR POWER PLANT


==Dear Mr. Bezilla:==
==Dear Mr. Bezilla:==


On August 4, 2010, the NRC staff completed its mid-cycle performance review of the Perry Nuclear Power Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2009, through June 30, 2010.
On August 4, 2010, the NRC staff completed its mid-cycle performance review of the Perry Nuclear Power Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2009, through June 30, 2010.
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.  
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.
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 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.
 
In our 2009 annual assessment letter, dated March 3, 2010 [ADAMS Ref. ML100610281],
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 was within the Licensee Response column of the NRC
we advised you of a substantive cross-cutting issue in the area of Human Performance with cross-cutting themes in the areas of work planning (H.3(a)), human error prevention techniques (H.4(a)), and work oversight (H.4(c)).
=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. In our 2009 annual assessment letter, dated March 3, 2010 [ADAMS Ref. ML100610281], we advised you of a substantive cross-cutting issue in the area of Human Performance with cross-cutting themes in the areas of work planning (H.3(a)), human error prevention techniques (H.4(a)), and work oversight (H.4(c)). Although the total number of findings with documented cross-cutting aspects in human performance decreased from 19 to 14, a cross-cutting theme in the human performance area was once again identified, based on four findings with a cross-cutting aspect of work planning (H.3(a)). We remain concerned about whether the development of causal evaluations and implementation of corrective actions can be effective in demonstrating sustainable performance in this area. The NRC has a continuing concern with your scope of efforts and progress in addressing this cross-cutting area. Based on the identification of a human performance cross-cutting theme, and because of continued NRC concerns with your performance issues in M. Bezilla   
Although the total number of findings with documented cross-cutting aspects in human performance decreased from 19 to 14, a cross-cutting theme in the human performance area was once again identified, based on four findings with a cross-cutting aspect of work planning (H.3(a)). We remain concerned about whether the development of causal evaluations and implementation of corrective actions can be effective in demonstrating sustainable performance in this area. The NRC has a continuing concern with your scope of efforts and progress in addressing this cross-cutting area. Based on the identification of a human performance cross-cutting theme, and because of continued NRC concerns with your performance issues in
 
the human performance area, the human performance substantive cross-cutting issue will remain open. It will remain open until your co rrective actions have demonstrated positive, sustainable improvements in the area and have resulted in a reduction in the number of findings in the area. As part of our continuing review of this issue, a Problem Identification & 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. During this assessment period, the number of findings with cross-cutting aspects of human error prevention techniques (H.4(a)) and work oversight (H.4(c)) were reduced to below the threshold for a cross-cutting theme. We have reviewed your corrective actions to address these cross-cutting themes and believe that they have resulted in positive improvement and, if properly implemented, can provide sustained, improved performance. While we will continue to monitor the human performance area as a whole, the H.4(a) and H.4(c) cross-cutting themes are closed.


M. Bezilla                                    the human performance area, the human performance substantive cross-cutting issue will remain open. It will remain open until your corrective actions have demonstrated positive, sustainable improvements in the area and have resulted in a reduction in the number of findings in the area. As part of our continuing review of this issue, a Problem Identification & 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.
During this assessment period, the number of findings with cross-cutting aspects of human error prevention techniques (H.4(a)) and work oversight (H.4(c)) were reduced to below the threshold for a cross-cutting theme. We have reviewed your corrective actions to address these cross-cutting themes and believe that they have resulted in positive improvement and, if properly implemented, can provide sustained, improved performance. While we will continue to monitor the human performance area as a whole, the H.4(a) and H.4(c) cross-cutting themes are closed.
This mid-cycle assessment letter is the sixth consecutive assessment letter identifying a substantive cross-cutting issue in the human performance area, which was initially opened in our March 3, 2008, end-of-cycle assessment letter [ADAMS Ref. ML080600303]. Based on the results of the most recent assessment period, the actions taken in response to continued human performance errors have not demonstrated sufficient progress in addressing the issue.
This mid-cycle assessment letter is the sixth consecutive assessment letter identifying a substantive cross-cutting issue in the human performance area, which was initially opened in our March 3, 2008, end-of-cycle assessment letter [ADAMS Ref. ML080600303]. Based on the results of the most recent assessment period, the actions taken in response to continued human performance errors have not demonstrated sufficient progress in addressing the issue.
Your effectiveness at implementing sustainable corrective actions to address this substantive cross-cutting issue will be reviewed during our biennial PI&R inspection in November 2010. We will await the outcome of our inspection in November to determine whether additional actions not covered by the Action Matrix, as prescribed in Inspection Manual Chapter 0305, are necessary. Our 2009 annual assessment letter also advised you of our request that you have an independent assessment of safety culture performed at your site. This assessment was intended to 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. We requested that this assessment be completed in time to be reviewed during the NRC biennial PI&R inspection scheduled for November 2010. We understand that the assessment was completed in May 2010; however, we have not yet reviewed this safety culture assessment.
Your effectiveness at implementing sustainable corrective actions to address this substantive cross-cutting issue will be reviewed during our biennial PI&R inspection in November 2010. We will await the outcome of our inspection in November to determine whether additional actions not covered by the Action Matrix, as prescribed in Inspection Manual Chapter 0305, are necessary.
Further progress in this area will be evaluated in accordance with our schedule for the biennial  
Our 2009 annual assessment letter also advised you of our request that you have an independent assessment of safety culture performed at your site. This assessment was intended to 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. We requested that this assessment be completed in time to be reviewed during the NRC biennial PI&R inspection scheduled for November 2010. We understand that the assessment was completed in May 2010; however, we have not yet reviewed this safety culture assessment.
 
Further progress in this area will be evaluated in accordance with our schedule for the biennial PI&R Inspection.
PI&R Inspection.
In our 2009 annual assessment letter we also advised you of a substantive cross-cutting issue in the area of PI&R with a cross-cutting theme in the area of corrective action program evaluation/extent of condition (P.1(c)). Our mid-cycle assessment noted positive sustainable improvement in the PI&R area. For this assessment period, we identified one finding with a cross-cutting aspect in the PI&R area and no findings with a cross-cutting aspect of P.1(c).
In our 2009 annual assessment letter we also advised you of a substantive cross-cutting issue in the area of PI&R with a cross-cutting theme in the area of corrective action program evaluation/extent of condition (P.1(c)). Our mid-cycle assessment noted positive sustainable improvement in the PI&R area. For this assessment period, we identified one finding with a cross-cutting aspect in the PI&R area and no findings with a cross-cutting aspect of P.1(c). Based on the actions you have taken to decrease the number of findings in the P.1(c) aspect, and because no cross-cutting theme was identified in the PI&R cross-cutting area, the PI&R substantive cross-cutting issue is closed.
Based on the actions you have taken to decrease the number of findings in the P.1(c) aspect, and because no cross-cutting theme was identified in the PI&R cross-cutting area, the PI&R substantive cross-cutting issue is closed.
 
M. Bezilla The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 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 end-of-cycle review.  


M. Bezilla                                      The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 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 end-of-cycle review.
In accordance with 10 CFR 2.390 of the NRC's "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 (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with 10 CFR 2.390 of the NRC's "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 (PARS) component of NRC's document system (ADAMS), 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.  
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 by Gary L. Shear for/
Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58


Sincerely, 
==Enclosure:==
      /RA by Gary L. Shear for/
Perry Inspection/Activity Plan cc w/encl:      Distribution via ListServ
Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58


==Enclosure:==
Perry Inspection / Activity Plan 09/01/2010 - 12/31/2011 Planned Dates                                                                                                                                No. of Staff Start      End      Inspection Activity                                                          Title                                        on Site ISFSI        - ISFSI INSPECTION                                                                                                  2 7/01/2010  09/30/2010  IP 60854.1            Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 9/01/2010  12/31/2010  IP 60855.1            Operation of an Independent Spent Fuel Storage Installation at Operating Plants BI EP        - EP EXERCISE INSPECTION / PI VERIFICATION                                                                          3 9/27/2010  10/01/2010  IP 7111401            Exercise Evaluation 9/27/2010  10/01/2010  IP 71151-EP01        Drill/Exercise Performance 9/27/2010  10/01/2010  IP 71151-EP02        ERO Drill Participation 9/27/2010  10/01/2010  IP 71151-EP03        Alert & Notification System BI PI&R      - BIENNIAL PI&R INSPECTION                                                                                          4 1/01/2010  11/19/2010  IP 71152B            Identification and Resolution of Problems BI OL        - BIENNIAL REQUAL PROGRAM INSPECTION                                                                                2 1/29/2010  12/03/2010  IP 7111111B          Licensed Operator Requalification Program BI RP        - RADIATION PROTECTION BASELINE INSPECTION                                                                          1 1/24/2011  01/28/2011  IP 71124.05          Radiation Monitoring Instrumentation 1/24/2011  01/28/2011  IP 71151-BI01        Reactor Coolant System Activity 1/24/2011  01/28/2011  IP 71151-OR01        Occupational Exposure Control Effectiveness 1/24/2011  01/28/2011  IP 71151-PR01        RETS/ODCM Radiological Effluent STRIKE        - STRIKE CONTINGENCY-OPS/MAINT/RP/CHEM/I&C                                                                          2 4/01/2011  05/15/2011  IP 92709              Licensee Strike Contingency Plans BI ENG        - INSERVICE INSPECTION                                                                                              1 4/18/2011  05/22/2011  IP 7111108G          Inservice Inspection Activities - BWR BI RP        - RADIATION PROTECTION BASELINE INSPECTION                                                                          1 5/02/2011  05/06/2011  IP 2515/179          Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 5/02/2011  05/06/2011  IP 71124.02          Occupational ALARA Planning and Controls ISFSI        - ISFSI INSPECTION - SCHEDULE DEPENDENT                                                                              2 6/01/2011  06/30/2011  IP 60856              Review of 10 CFR 72.212(b) Evaluations BI RP        - RADIATION PROTECTION BASELINE INSPECTION                                                                          1 6/27/2011  07/01/2011  IP 71124.06          Radioactive Gaseous and Liquid Effluent Treatment BI EP        - EP ROUTINE INSPECTION / PI VERIFICATION                                                                            2 9/12/2011  09/16/2011  IP 7111402            Alert and Notification System Testing 9/12/2011  09/16/2011  IP 7111403            Emergency Preparedness Organization Staffing and Augmentation System 9/12/2011  09/16/2011  IP 7111405            Correction of Emergency Preparedness Weaknesses and Deficiencies 9/12/2011  09/16/2011  IP 71151-EP01        Drill/Exercise Performance 9/12/2011  09/16/2011  IP 71151-EP02        ERO Drill Participation
Perry Inspection/Activity Plan cc w/encl: Distribution via ListServ


Inspection / Activity Plan Page 1 of 2 08/26/2010 Report 22 09/01/2010
Perry Inspection / Activity Plan 09/01/2010 - 12/31/2011 Planned Dates                                                                                                                               No. of Staff Start     End     Inspection Activity                                                       Title                                           on Site BI EP         - EP ROUTINE INSPECTION / PI VERIFICATION                                                                         2 09/12/2011  09/16/2011  IP 71151-EP03      Alert & Notification System BI RP         - RADIATION PROTECTION BASELINE INSPECTION                                                                         1 09/12/2011   09/16/2011   IP 71124.02         Occupational ALARA Planning and Controls 09/12/2011   09/16/2011   IP 71124.07        Radiological Environmental Monitoring Program BI RP         - RADIATION PROTECTION BASELINE INSPECTION                                                                         1 10/17/2011   10/21/2011   IP 71124.08        Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation BI ENG       - COMPONENT DESIGN BASIS INSPECTION                                                                               5 10/31/2011  12/02/2011  IP 2515/177        Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal & Containment Spray System 10/31/2011   12/02/2011   IP 7111121          Component Design Bases Inspection OL PREP       - PERRY INIT EXAM - 01/2011                                                                                       3 12/19/2011   12/23/2011     W90232          OL - INITIAL EXAM - JAN 2011 - PERR
-12/31/2011 Unit Number Planned Dates Start           End Inspection Activity Title No. of Staff on Site Perry 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 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 PI&R-BIENNIAL PI&R INSPECTION 4 1    IP Identification and Resolution of Problems 71152B 11/01/2010 11/19/2010 BI OL-BIENNIAL REQUAL PROGRAM INSPECTION 2 1    IP Licensed Operator Requalification Program 7111111B 11/29/2010 12/03/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1    IP Radiation Monitoring Instrumentation 71124.05 01/24/2011 01/28/2011 1    IP Reactor Coolant System Activity 71151-BI01 01/24/2011 01/28/2011 1    IP Occupational Exposure Control Effectiveness 71151-OR01 01/24/2011 01/28/2011 1    IP RETS/ODCM Radiological Effluent 71151-PR01 01/24/2011 01/28/2011 STRIKE-STRIKE CONTINGENCY-OPS/MAINT/RP/CHEM/I&C 2 1    IP Licensee Strike Contingency Plans 92709 04/01/2011 05/15/2011 BI ENG-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 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 2515/179 05/02/2011 05/06/2011 1    IP Occupational ALARA Planning and Controls 71124.02 05/02/2011 05/06/2011 ISFSI-ISFSI INSPECTION - SCHEDULE DEPENDENT 2 1    IP Review of 10 CFR 72.212(b) Evaluations 60856 06/01/2011 06/30/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1    IP Radioactive Gaseous and Liquid Effluent Treatment 71124.06 06/27/2011 07/01/2011 BI EP-EP ROUTINE INSPECTION / PI VERIFICATION 2 1    IP A lert and Notification System Testing 7111402 09/12/2011 09/16/2011 1    IP Emergency Preparedness Organization Staffing and Augmentation System 7111403 09/12/2011 09/16/2011 1    IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 09/12/2011 09/16/2011 1    IP Drill/Exercise Performance 71151-EP01 09/12/2011 09/16/2011 1    IP ERO Drill Participation 71151-EP02 09/12/2011 09/16/2011 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
Inspection / Activity Plan Page 2 of 2 08/26/2010 Report 22 09/01/2010
-12/31/2011 Unit Number Planned Dates Start          End Inspection Activity Title No. of Staff on Site Perry BI EP-EP ROUTINE INSPECTION / PI VERIFICATION 2 1    IP A lert & Notification System 71151-EP03 09/12/2011 09/16/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1    IP Occupational ALARA Planning and Controls 71124.02 09/12/2011 09/16/2011 1    IP Radiological Environmental Monitoring Program 71124.07 09/12/2011 09/16/2011 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1    IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71124.08 10/17/2011 10/21/2011 BI ENG-COMPONENT DESIGN BASIS INSPECTION 5 1    IP Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal & Containment Spray System 2515/177 10/31/2011 12/02/2011 1    IP Component Design Bases Inspection 7111121 10/31/2011 12/02/2011 OL PREP-PERRY INIT EXAM - 01/2011 3 1    OL - INITIAL EXAM - JAN 2011 - PERR W90232 12/19/2011 12/23/2011 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
M. Bezilla The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 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 end-of-cycle review.


M. Bezilla                                                                The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 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 end-of-cycle review.
In accordance with 10 CFR 2.390 of the NRC's "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 (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with 10 CFR 2.390 of the NRC's "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 (PARS) component of NRC's document system (ADAMS), 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.  
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,
Sincerely,
                                                                          /RA by Gary L. Shear for/
      /RA by Gary L. Shear for/
Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58
Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58  


==Enclosure:==
==Enclosure:==
Perry Inspection/Activity Plan cc w/encl: Distribution via ListServ  
Perry Inspection/Activity Plan cc w/encl:               Distribution via ListServ DOCUMENT NAME: G:\Branch TSS\ALL MOC\midcycle 2010 to 2011\midcycle letters\Perry 2010 MOC Letter.docx                                                                  See Previous Concurrences 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 NAME                AGarmoe:dtp*                        JCameron*                        SWest*GLS for DATE                08/18/10                            08/19/10                        08/23/10 OFFICIAL RECORD COPY


DOCUMENT NAME:  G:\Branch TSS\ALL MOC\midcycle 2010 to 2011\midcycle letters\Perry 2010 MOC Letter.docx  See Previous Concurrences 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 NAME  AGarmoe:dtp*
Letter to M. Bezilla from S. West dated September 1, 2010.
JCameron* SWest*GLS for DATE  08/18/10  08/19/10 08/23/10 OFFICIAL RECORD COPY
 
Letter to M. Bezilla from S. West dated September 1, 2010.  


==SUBJECT:==
==SUBJECT:==
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - PERRY NUCLEAR PLANT DISTRIBUTION
MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -
: Susan Bagley  
PERRY NUCLEAR PLANT DISTRIBUTION:
 
Susan Bagley RidsNrrPMPerry RidsNrrDorlLpI3-2 RidsNrrDirsIpab Resource Steven Reynolds Jared Heck Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource}}
RidsNrrPMPerry RidsNrrDorlLpI3-2 RidsNrrDirsIpab Resource Steven Reynolds Jared Heck Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource}}

Latest revision as of 13:55, 13 November 2019

Mid-Cycle Performance Review and Inspection Plan - Perry Nuclear Power Plant
ML102440084
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 09/01/2010
From: Khadijah West
Division Reactor Projects III
To: Bezilla M
FirstEnergy Nuclear Operating Co
References
Download: ML102440084 (7)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 September 1, 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:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PERRY NUCLEAR POWER PLANT

Dear Mr. Bezilla:

On August 4, 2010, the NRC staff completed its mid-cycle performance review of the Perry Nuclear Power Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2009, through June 30, 2010.

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 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.

In our 2009 annual assessment letter, dated March 3, 2010 [ADAMS Ref. ML100610281],

we advised you of a substantive cross-cutting issue in the area of Human Performance with cross-cutting themes in the areas of work planning (H.3(a)), human error prevention techniques (H.4(a)), and work oversight (H.4(c)).

Although the total number of findings with documented cross-cutting aspects in human performance decreased from 19 to 14, a cross-cutting theme in the human performance area was once again identified, based on four findings with a cross-cutting aspect of work planning (H.3(a)). We remain concerned about whether the development of causal evaluations and implementation of corrective actions can be effective in demonstrating sustainable performance in this area. The NRC has a continuing concern with your scope of efforts and progress in addressing this cross-cutting area. Based on the identification of a human performance cross-cutting theme, and because of continued NRC concerns with your performance issues in

M. Bezilla the human performance area, the human performance substantive cross-cutting issue will remain open. It will remain open until your corrective actions have demonstrated positive, sustainable improvements in the area and have resulted in a reduction in the number of findings in the area. As part of our continuing review of this issue, a Problem Identification & 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.

During this assessment period, the number of findings with cross-cutting aspects of human error prevention techniques (H.4(a)) and work oversight (H.4(c)) were reduced to below the threshold for a cross-cutting theme. We have reviewed your corrective actions to address these cross-cutting themes and believe that they have resulted in positive improvement and, if properly implemented, can provide sustained, improved performance. While we will continue to monitor the human performance area as a whole, the H.4(a) and H.4(c) cross-cutting themes are closed.

This mid-cycle assessment letter is the sixth consecutive assessment letter identifying a substantive cross-cutting issue in the human performance area, which was initially opened in our March 3, 2008, end-of-cycle assessment letter [ADAMS Ref. ML080600303]. Based on the results of the most recent assessment period, the actions taken in response to continued human performance errors have not demonstrated sufficient progress in addressing the issue.

Your effectiveness at implementing sustainable corrective actions to address this substantive cross-cutting issue will be reviewed during our biennial PI&R inspection in November 2010. We will await the outcome of our inspection in November to determine whether additional actions not covered by the Action Matrix, as prescribed in Inspection Manual Chapter 0305, are necessary.

Our 2009 annual assessment letter also advised you of our request that you have an independent assessment of safety culture performed at your site. This assessment was intended to 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. We requested that this assessment be completed in time to be reviewed during the NRC biennial PI&R inspection scheduled for November 2010. We understand that the assessment was completed in May 2010; however, we have not yet reviewed this safety culture assessment.

Further progress in this area will be evaluated in accordance with our schedule for the biennial PI&R Inspection.

In our 2009 annual assessment letter we also advised you of a substantive cross-cutting issue in the area of PI&R with a cross-cutting theme in the area of corrective action program evaluation/extent of condition (P.1(c)). Our mid-cycle assessment noted positive sustainable improvement in the PI&R area. For this assessment period, we identified one finding with a cross-cutting aspect in the PI&R area and no findings with a cross-cutting aspect of P.1(c).

Based on the actions you have taken to decrease the number of findings in the P.1(c) aspect, and because no cross-cutting theme was identified in the PI&R cross-cutting area, the PI&R substantive cross-cutting issue is closed.

M. Bezilla The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 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 end-of-cycle review.

In accordance with 10 CFR 2.390 of the NRC's "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 (PARS) component of NRC's document system (ADAMS), 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 by Gary L. Shear for/

Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58

Enclosure:

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

Perry Inspection / Activity Plan 09/01/2010 - 12/31/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site ISFSI - ISFSI INSPECTION 2 7/01/2010 09/30/2010 IP 60854.1 Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 9/01/2010 12/31/2010 IP 60855.1 Operation of an Independent Spent Fuel Storage Installation at Operating Plants BI EP - EP EXERCISE INSPECTION / PI VERIFICATION 3 9/27/2010 10/01/2010 IP 7111401 Exercise Evaluation 9/27/2010 10/01/2010 IP 71151-EP01 Drill/Exercise Performance 9/27/2010 10/01/2010 IP 71151-EP02 ERO Drill Participation 9/27/2010 10/01/2010 IP 71151-EP03 Alert & Notification System BI PI&R - BIENNIAL PI&R INSPECTION 4 1/01/2010 11/19/2010 IP 71152B Identification and Resolution of Problems BI OL - BIENNIAL REQUAL PROGRAM INSPECTION 2 1/29/2010 12/03/2010 IP 7111111B Licensed Operator Requalification Program BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 1/24/2011 01/28/2011 IP 71124.05 Radiation Monitoring Instrumentation 1/24/2011 01/28/2011 IP 71151-BI01 Reactor Coolant System Activity 1/24/2011 01/28/2011 IP 71151-OR01 Occupational Exposure Control Effectiveness 1/24/2011 01/28/2011 IP 71151-PR01 RETS/ODCM Radiological Effluent STRIKE - STRIKE CONTINGENCY-OPS/MAINT/RP/CHEM/I&C 2 4/01/2011 05/15/2011 IP 92709 Licensee Strike Contingency Plans BI ENG - INSERVICE INSPECTION 1 4/18/2011 05/22/2011 IP 7111108G Inservice Inspection Activities - BWR BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 5/02/2011 05/06/2011 IP 2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in NSTS 5/02/2011 05/06/2011 IP 71124.02 Occupational ALARA Planning and Controls ISFSI - ISFSI INSPECTION - SCHEDULE DEPENDENT 2 6/01/2011 06/30/2011 IP 60856 Review of 10 CFR 72.212(b) Evaluations BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 6/27/2011 07/01/2011 IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 2 9/12/2011 09/16/2011 IP 7111402 Alert and Notification System Testing 9/12/2011 09/16/2011 IP 7111403 Emergency Preparedness Organization Staffing and Augmentation System 9/12/2011 09/16/2011 IP 7111405 Correction of Emergency Preparedness Weaknesses and Deficiencies 9/12/2011 09/16/2011 IP 71151-EP01 Drill/Exercise Performance 9/12/2011 09/16/2011 IP 71151-EP02 ERO Drill Participation

Perry Inspection / Activity Plan 09/01/2010 - 12/31/2011 Planned Dates No. of Staff Start End Inspection Activity Title on Site BI EP - EP ROUTINE INSPECTION / PI VERIFICATION 2 09/12/2011 09/16/2011 IP 71151-EP03 Alert & Notification System BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 09/12/2011 09/16/2011 IP 71124.02 Occupational ALARA Planning and Controls 09/12/2011 09/16/2011 IP 71124.07 Radiological Environmental Monitoring Program BI RP - RADIATION PROTECTION BASELINE INSPECTION 1 10/17/2011 10/21/2011 IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation BI ENG - COMPONENT DESIGN BASIS INSPECTION 5 10/31/2011 12/02/2011 IP 2515/177 Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal & Containment Spray System 10/31/2011 12/02/2011 IP 7111121 Component Design Bases Inspection OL PREP - PERRY INIT EXAM - 01/2011 3 12/19/2011 12/23/2011 W90232 OL - INITIAL EXAM - JAN 2011 - PERR

M. Bezilla The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 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 end-of-cycle review.

In accordance with 10 CFR 2.390 of the NRC's "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 (PARS) component of NRC's document system (ADAMS), 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 by Gary L. Shear for/

Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58

Enclosure:

Perry Inspection/Activity Plan cc w/encl: Distribution via ListServ DOCUMENT NAME: G:\Branch TSS\ALL MOC\midcycle 2010 to 2011\midcycle letters\Perry 2010 MOC Letter.docx See Previous Concurrences 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 NAME AGarmoe:dtp* JCameron* SWest*GLS for DATE 08/18/10 08/19/10 08/23/10 OFFICIAL RECORD COPY

Letter to M. Bezilla from S. West dated September 1, 2010.

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN -

PERRY NUCLEAR PLANT DISTRIBUTION:

Susan Bagley RidsNrrPMPerry RidsNrrDorlLpI3-2 RidsNrrDirsIpab Resource Steven Reynolds Jared Heck Steven Orth Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

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