ML14003A186

IR 05000440-13-007; 11/04/2013 - 11/22/2013; Perry Nuclear Power Plant; Biennial PI&R Inspection

ML14003A186
Person / Time
Site:	Perry
Issue date:	01/03/2014
From:	Kunowski M A NRC/RGN-III/DRP/B5
To:	Harkness E FirstEnergy Nuclear Operating Co
References
IR-13-007
Download: ML14003A186 (27)

See also: IR 05000440/2013007

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 January 3, 2014

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: PERRY NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2013007 Dear Mr. Harkness: On November 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Perry Nuclear Power Plant. The enclosed inspection report documents the inspection results, which were discussed on

November 22, 2013, with you and other members of your staff. Based on the inspection sample, the inspection team determined that your staff's implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the team assessed how well your staff identified problems at a low threshold, your staff's implementation of the station's process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the team determined that your staff's performance was adequate to support nuclear safety. The team also evaluated other processes your staff used to identify issues for resolution. These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs,

processes, and procedures. The team determined that your station's performance in each of

these areas supported nuclear safety Finally, the team determined that your station's management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the team's observations, your employees are willing to raise concerns related to nuclear safety using at least one of the

several means available. Two NRC-identified findings of very low safety significance (Green) were identified, both of which involved violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your Corrective Action Program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy.

E. Harkness -2- If you contest a violation or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement,

U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Perry Nuclear Power Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Perry Nuclear Power Plant.

In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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 System (PARS) component of the 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). Sincerely,

/RA/ Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket No. 50-440

License No. NPF-58

Enclosure: Inspection Report 05000440/2013007 w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServTM

Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-440

License No: NPF-58

Report No: 05000440/2013007

Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Perry Nuclear Power Plant

Location: Perry, OH

Dates: November 4 through November 22, 2013 Inspectors: J. Jandovitz, Project Engineer, Team Lead C. Brown, Senior Reactor Inspector

J. Gilliam, Reactor Engineer

J. Nance, Resident Inspector Approved by: Michael Kunowski, Chief Branch 5

Division of Reactor Projects

1 Enclosure SUMMARY OF FINDINGS Inspection Report (IR) 05000440/2013007; 11/04/2013 - 11/22/2013; Perry Nuclear Power Plant; Biennial Problem Identification and Resolution (PI&R) Inspection. This inspection was performed by three regional-based inspectors and the Perry Nuclear Power Plant resident inspector. Two (Green) findings were identified by the inspectors, both with

associated Non-Cited Violations (NCVs) of NRC regulations. The significance of inspection

findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and

determined using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process,"

dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, "Components Within the Cross Cutting Areas," dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated January 28, 2013. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, "Reactor Oversight Process," Revision 4. Problem Identification and Resolution Based on the samples selected for review, the team concluded that implementation of the corrective action program (CAP) at the Perry Nuclear Power Plant was effective. The licensee

had a low stated threshold for identifying problems and entering them in the CAP. Items

entered into the CAP were generally screened and prioritized in a timely manner using

established criteria, although the team identified timeliness issues for a small percentage of issues. With a few exceptions documented by the team, issues in the CAP were evaluated and corrective actions were generally implemented in a timely manner. The team noted that the licensee reviewed operating experience (OE) for applicability to station activities. Audits and self-assessments were performed at an appropriate level to identify deficiencies. Based on interviews conducted during the inspection, licensee staff expressed freedom to raise nuclear

safety concerns and to enter nuclear safety concerns into the CAP. NRC-Identified and Self-Revealed Findings Cornerstone: Barrier Integrity Green. The inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of Technical Specification 3.4.11, "RCS Pressure and

Temperature (P/T) Limits," for failure to comply with reactor pressure vessel pressure/temperature limits. Specifically, in 2011 the inspectors identified the pressure/temperature limits in Technical Specification 3.4.11 only contained values for reactor

pressure vessel pressures greater than 0 pounds per square inch gauge. However, between

June 2011 and July 2013, the licensee operated the plant with a vacuum in the reactor pressure

vessel during 5 cold startups and 1 cooldown. The licensee entered the finding into its

corrective action program as Condition Report CR 2013-18689. The performance deficiency was determined to be more than minor because the finding was associated with the area of Routine Operations Performance within the Human Performance

attribute of the Barrier Integrity Cornerstone and had the potential to adversely affect the

associated cornerstone objective of providing reasonable assurance that a physical design

barrier (reactor coolant system) protects the public from radionuclide releases caused by accidents or events. The finding screened as very low safety significance because it was determined that there was no change in risk due to the performance deficiency. This finding

2 Enclosure has a cross-cutting aspect in the area of human performance, resources. Specifically, complete, accurate, and up-to-date procedures were not available to operators to ensure

operations within the requirements of Technical Specification 3.4.11, (H.2(c)). (Section 4OA2.1b.(2).1) Green. The inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective

Action," for failure to promptly correct a non-conservative Technical Specification. Specifically,

the inspectors identified on November 14, 2013, that the licensee failed to promptly correct the

non-conservative Technical Specification 3.4.11 by not submitting a license amendment request in accordance with NRC Administrative Letter 98-10, which required submittal within 1 year or 1 operating cycle. The licensee had determined Technical Specification 3.4.11, "RCS

Pressure and Temperature (P/T) Limits," to be non-conservative on October 16, 2009, and

implemented administrative controls as allowed by the Administrative Letter. As of November 14, 2013, the licensee had not submitted the license amendment request, over 4 years and 2 operating cycles after determining the Technical Specification was non-conservative. The licensee entered the finding into the corrective action program as Condition

Report CR 2013-18983. The performance deficiency was determined to be more than minor because the finding was associated with the area of Routine Operations Procedures within the Procedure Quality attribute of the Barrier Integrity Cornerstone and had the potential to adversely affect the associated cornerstone objective of providing reasonable assurance that physical design

barriers (fuel cladding, reactor coolant system, and containment) protect the public from

radionuclide releases caused by accidents or events. The finding was screened as very low

safety significance because it was determined that operators followed the appropriate reactor

coolant system P/T curves even though the Technical Specification was non-conservative. The finding has a cross-cutting aspect in the area of human performance, decision-making, where licensee decisions demonstrate that nuclear safety is an overriding priority. Specifically, from the time of discovery of the non-conservative technical specification until now, various

decisions had been made by the licensee that have delayed the timely submittal of the license

amendment request (H.1(c)). (Section 4OA2.1b.(3).1)

3 Enclosure REPORT DETAILS 4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution (71152B) This inspection constituted one biennial sample of Problem Identification and Resolution (PI&R) as defined in Inspection Procedure (IP) 71152, "Problem Identification and Resolution." Documents reviewed are listed in the Attachment to this report. .1 Corrective Action Program Effectiveness a. Inspection Scope The inspectors reviewed the licensee's Corrective Action Program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by licensee staff. The inspectors also interviewed licensee staff about their use of the CAP. The inspectors reviewed risk and safety significant issues in the licensee's CAP since the last NRC PI&R inspection in January 2012. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee

audits, OE reports, and NRC documented findings. The inspectors reviewed Condition

Reports (CRs) that were generated and a selection of completed investigations from the

licensee's various investigation methods, including root cause evaluations (RCEs), full apparent cause evaluations (ACEs), limited apparent cause evaluations (LACEs), and common cause analyses (CCAs). The inspectors selected the station large transformers to review in detail because the system had numerous operational problems, including replacements, in recent years. The intent of the review was to determine whether the licensee staff were properly

monitoring and evaluating the performance of this system through effective implementation of station monitoring programs. A five-year review of the Unit 1 main

transformer, 1-PY-T, the Unit 1 auxiliary transformer, 110-PY-B, and the Unit 2 start-up transformer, 200-PY-B, was performed. A review of the use of the station maintenance rule program to help identify equipment issues was also conducted. On September 3, 2013, the NRC issued the Mid-Cycle Assessment Letter for the Perry Nuclear Plant (ADAMS Accession Number ML13246A237). That assessment discussed

that continued management attention and focus was needed to address lower level, less

risk significant issues involving procedure use and adherence and procedure quality.

To further evaluate these issues, this inspection implemented the NRC plan to specifically review the licensee's corrective actions for the extent of cause evaluations completed in response to the 2011 and 2012 White findings in the radiation protection area. During the reviews, the inspectors determined whether the licensee's actions were in compliance with the licensee's CAP and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors determined whether licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the station's CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate

4 Enclosure investigational method to ensure the correct determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of

corrective actions for selected issue reports, completed investigations, and NRC

previously identified findings that included principally non-cited violations. b. Assessment (1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of CRs and interviews, the inspectors concluded that the licensee has an appropriate low threshold for initiating

CRs. The number of CAP items generated were distributed across the various

departments. The inspectors did not identify any safety significant items that were not entered into the CAP, but noted that various licensee assessments found instances that did not meet licensee expectations for entering issues into the CAP. The inspectors

assessed the effectiveness of problem identification as adequate, partially due to the continued expectation that the licensee will continue to perform assessments of the same quality and resulting corrective actions improving the CAP process. Observations Since 2012, the inspectors noted that licensee assessments of the CAP, including fleet and oversight assessments, have been self-critical and rated the CAP as marginally

effective but with an improving trend. Corrective actions have been developed to improve CAP implementation, but the assessments continue to reveal areas for improvement as late as the 2013 second trimester assessment. The 2012 NRC Problem Identification and Resolution (PI&R) Inspection Report, 05000440/2012007 (ADAMS Accession Number ML12066A195), noted that issues with

the use of work order Work-In-Progress (WIP) logs where the logs included information

that should have been included in the CAP, provided technical direction, and that either

initiated or stopped work. The inspectors noted improvement during this inspection with one similar WIP log issue that was identified by the licensee. Review of the CAP performance indicators showed that the number of CRs generated has increased over the last year. Reviewing the six-month averages, the site had a low of 566 in March 2013, and a high of 709 in September of 2013. As expected, the

number increased significantly during the spring outage period, a high of 952 CRs

initiated in May 2013. Findings No findings were identified. (2) Prioritization and Evaluation of Issues The inspectors reviewed the classification of CRs and attended licensee meetings that categorized and prioritized CRs and determined that, in general, CRs were assigned appropriate prioritization and evaluation levels. Evaluations in RCEs and ACEs

reviewed by the inspectors were adequate. The licensee completed about 12 RCEs

since November 2012. The inspectors considered the quality of the selected RCEs to

have improved since the last inspection. A contributing factor may be that licensee

5 Enclosure review groups had previously identified issues with the quality of the evaluations resulting in corrective actions. The inspectors determined that the licensee's

prioritization and evaluation of issues were sufficient to ensure that established corrective actions would be effective and that there was appropriate consideration of risk in prioritizing issues. Several CR evaluations were found to lack sufficient depth to fully evaluate and correct the issue. In most of these cases, the CRs were processed to trend and when a trend or

more CRs with the same issue were identified, it was more fully evaluated by the

licensee. None of these evaluations were considered by the inspectors to be of more-than-minor significance. Observations CR 2013-09086 was reviewed. It discussed material near the transformers that could become missiles in high winds, impacting the transformers. The CR stated previous communications had been unsuccessful in addressing this issue. The CR provided

minimal evaluation and was closed to the action to remove the material. There was no

consideration of procedure and process deficiencies that should have prevented the

condition. After questions by the inspectors, the licensee staff conducted a walkdown

of the area identified in the CR. Additional material was found in the area and CR 2013-17984 was generated. That CR evaluation identified existing procedures which controlled material in these areas to protect the transformers and found the

licensee personnel were not familiar with those procedures. Specifically, the procedures

were PAP-0204, "Housekeeping/Cleanliness Control Program," and NOP-O-1012,

"Material Readiness and Housekeeping Inspection Program." These procedures contained directions for inspections in or around the switchyard and for the removal or restraint of material or debris that had the potential to become airborne with high winds

and cause the loss of offsite power. This was determined to be a performance

deficiency but not considered more-than-minor and it was entered into the CAP.

A notice was issued to all site personnel by the licensee to highlight these procedures and requirements. CR 2011-03864 was reviewed. It identified an NRC question on operating with a vacuum in the reactor pressure vessel when it appeared that Technical Specifications

(TSs) only contained criteria that allowed operation with reactor vessel pressure greater

than 0 pounds per square inch gauge (psig). The inspectors found the evaluation of the

condition to address only the technical aspects of the question and not compliance with the TSs. No further action was taken or planned by the licensee. As a result, the NRC determined operating with a vacuum in the reactor pressure vessel was not in

compliance with the TSs and documented a finding. Findings .1 Failure To Comply With TS 3.4.11 Introduction: The inspectors identified a finding of very low safety significance (Green) and associated NCV of TS 3.4.11 for failure to comply with the reactor coolant system (RCS) pressure and temperature (P/T) limits, a condition adverse to quality. Specifically, although the TS P/T limits only contain values for operating with pressures greater than

0 psig in the reactor pressure vessel (RPV), between May 2011 and July 2013, the

6 Enclosure licensee operated the plant with a vacuum in the RPV during 5 cold startups and 1 cooldown.

Description: In October 2011, the inspectors identified a concern with the P/T limits for TS 3.4.11, "RCS Pressure and Temperature (P/T) Limits." The pressure limits for non-

nuclear heatup only existed for values greater than or equal to 0 psig and the licensee

was actually operating with a vacuum (below 0 psig) in the RPV. The licensee initiated

CR 2011-03864, "NRC Question on Tech Spec 3.4.11 RCS Pressure and Temperature

Curves/Drawing a Vacuum during Non-Nuclear Heatup," and evaluated the concern to determine if any potential deficiency existed for not operating within the curve limits. The resulting engineering evaluation stated that "The Reactor Vessel is designed

following the rules of ASME Section III Subsection NB Class 1 components. From the

Chicago Bridge and Iron, ASME Code Design Report, D-1, page 35, the vessel head

is 4 19/32 inch thick with an inner radius of 119 inches and the vessel wall below the flange is 6 inches thick with an inner radius of 120 inches. The dimensions of these components are identified to provide indication of the robustness of the design. Due to

the size and thicknesses of these components the stresses produced by vacuum are

judged to be relatively insignificant." The licensee, however, did not evaluate implication for TS compliance. In January 2013, during a cold startup following an automatic scram, the inspectors

again questioned operating with the RPV in a vacuum during the startup. The licensee

referred to the 2011 CR. The licensee had not committed to update the curves and

submit a license amendment request (LAR) for approval of new P/T limits to reflect operation with a vacuum in the RPV during cold startups and during cooldowns. On November 5, 2013, during a phone call with various branches in the Office of Nuclear Reactor Regulation, including the Technical Specification branch, it was decided that

the current TS does not address operating the RPV in a vacuum and doing so violated

TS 3.4.11.

Analysis: The inspectors determined that the failure to comply with the RCS P/T limits of TS 3.4.11 was a performance deficiency. The performance deficiency was determined

to be more than minor, and thus a finding, using Inspection Manual Chapter (IMC) 0612,

Appendix B, "Issue Screening," dated September 7, 2012, because it was associated

with the Human Performance attribute area of Routine Operations Performance of the

Barrier Integrity Cornerstone and had the potential to adversely affect the associated cornerstone objective of providing reasonable assurance that a physical design barrier (reactor coolant system) protects the public from radionuclide releases caused by accidents or events. Specifically, without NRC evaluation and approval of revised P/T limits that include operating the RPV in a vacuum, the inspectors did not have

reasonable assurance the RPV was not adversely affected. The finding was evaluated using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), Attachment 0609.04, "Initial Characterization of Findings," dated June 19, 2012,

and IMC 0609, Appendix A, Exhibit 3 - Barrier Integrity Screening Questions, dated

June 19, 2012. Because the finding involved the RCS boundary (e.g., pressurized

thermal shock issues), the SDP directs the inspectors to stop and go to the detailed risk

evaluation section. The regional Senior Reactor Analyst (SRA) reviewed the finding and determined that a detailed risk evaluation was not required based on the licensee engineering evaluation. As a result, the SRA concluded that there was no change in risk

due to the performance deficiency. This finding has a cross-cutting aspect in the area of

human performance, resources. Specifically, complete, accurate and up-to-date

7 Enclosure procedures were not available to operators to ensure operations within the requirements of TS 3.4.11, (H.2(c)).

Enforcement: Technical Specification 3.4.11 requires that RPV pressures and temperatures be maintained within limits at all times. Contrary to this requirement, between June 2011 and July 2013, the licensee operated the plant with a pressure in the

RPV less than the TS 3.4.11 limit of greater than or equal to 0 psig. Specifically, the

licensee operated the RPV in a vacuum during cold startups on June 4, 2011, for more

than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />; on October 18, 2011, for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; on March 3, 2012, for more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; on June 17, 2012, for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; and on May 11, 2013, for more than 30 minutes; and twice during a cooldown on June 16, 2013, for 15 and 30 minutes.

Because the violation was of a very low safety significance and was documented in the

licensee's corrective action program (as Condition Report CR 2013-18689), it is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy

(NCV 05000440/2013007-01, Failure To Comply With Technical Specification 3.4.11). (3) Corrective Actions In general, the inspectors concluded that the corrective actions were appropriate for the identified issues. The corrective actions in 2011 and 2012 in response to the NRC White

radiation protection issues were found to be ineffective to improve procedure use and

adherence. For other selected NRC documented violations, corrective actions were

determined to be effective and timely. The inspectors' review of the previous 5 years of

the licensee's efforts to address issues with the station large transformers did not identify any negative trends or inability by the licensee to address long-term issues.

Observations

The inspectors reviewed various corrective actions from the RCEs for the 2011 and 2012 NRC White issues. The inspector noted that licensee assessments and plant events have continued to demonstrate weakness in procedure compliance indicating the

corrective actions developed from the RCEs were not effective. The inspectors also noted that on August 8, 2013, licensee senior managers conducted site standdowns to

provide clear site expectations and standards, including procedure use and adherence. Also in August 2013, the licensee rolled out a new site action plan, the Perry Strategic Improvement Plan, to improve procedure use and adherence as well as the use of performance improvement tools, teamwork, and accountability. The inspectors reviewed portions of the Strategic Improvement Plan and noted it included required field

observations by supervisors and management specifically observing and documenting

procedure use behaviors. A review by the inspectors of the documented observations indicated procedure use and adherence was improving but the plan and actions have not been implemented long enough for the inspectors to conclude that notable and

sustained improvement in this area had yet occurred.

In CR 2013-09637, the licensee identified that Plant Data Book I0004, "Instrumentation

Channels," was approved and made effective before the NRC approved the associated LAR. After discussions with the licensee and review of the CR, the inspectors determined that the premature change was made because of a failure to follow

procedure NOP-SS-3001, "Procedure Review and Approval." The corrective action

assigned by the licensee was to send out a lessons-learned notice to all of the

8 Enclosure procedure writers. However, the notice did not address the failure to follow procedure. In addition, there was no verification that all of the procedure writers reviewed the

information. The licensee initiated CR 2013-18661, "NRC Questions the Thoroughness of CR 213-09637, License Amendment Implementation Completed Prior to Amendment Approval," to address this concern. Findings .1 Failure to Promptly Correct a Non-Conservative TS Introduction: The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action,"

for failure to promptly correct a condition adverse to quality, a non-conservative TS.

Specifically, in November 2013, the inspectors identified that the licensee implemented

an administrative TS change when the licensee identified in October 2009 that TS 3.4.11, "RCS Pressure and Temperature (P/T) Limits," was non-conservative, but did not promptly submit the required LAR. Description: In October 2009, the licensee documented in Condition Report CR 2009-64465 that TS 3.4.11, "RCS Pressure and Temperature (P/T) Limits," was non-

conservative. These limits protect the reactor vessel material from pressurized thermal

shock. The corrective action by the licensee was an administrative TS change in accordance with NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient To Ensure Plant Safety." The change shifted a

portion of the reactor pressure vessel P/T limits so that it required operation at a higher

RPV temperature than previously specified at certain pressures. The licensee correctly invoked Administrative Letter 98-10 and took an action to issue a non-conservative TS tracking form, prepared in accordance with procedure NOP-LP-4009, for the purpose of alerting all TS holders of the changes to the P/T limit curves. The licensee also initiated

a corrective action to formally update the calculations from which the curves were

developed and, when the calculations were approved, to initiate the appropriate change

mechanism, a license amendment request, to formally update the TS P/T curves. However, as of the November 2013 start of the current inspection, that calculation had not been performed. The inspectors also noted that the procedure did not specify a time

requirement for the LAR submittal and did not clearly identify the organization

responsible to initiate a LAR for non-conservative TSs. A timeline of this issue is

presented below. Timeline of Licensee Actions 09/11/2009 GE Hitachi (GEH) Nuclear Energy letter to FirstEnergy identified non-conservative TS values through an Impact Assessment for Water Level Instrumentation Nozzle Penetration on P/T curves provided to BWR Owners Group (BWROG) members. 09/15/2009 CR 2009-64465 was initiated based on GEH letter; corrective action CA-001 was initiated to seek revision to calculation EA-0246 to include

level instrument analyses. 10/02/2009 GEH letter File 0000-0106-1616 Rev. 1 to FirstEnergy identified level instrument nozzle impact on P/T curves. 10/16/2009 Non-conservative TS tracking forms issued and placed into all controlled copies of licensee's TS manuals per NOP-LP-4009-04.

9 Enclosure 02/09/2010 CA-001, due February 10, 2010, extended to June 11, 2010, and provided estimated schedule with GEH as primary contractor. 05/06/2010 CA-001, due June 11, 2010, was extended to February 28, 2011, based on unacceptable proposal costs. The alternate BWROG revision

to the P/T limits topical report was chosen. No definitive schedule was

identified other than financial approval by the FENOC BWROG

representative in April 2010. Justification was based on low safety significance. 02/14/2011 CA-001 due on February 28, 2011, was extended to August 12, 2011, based on receipt of draft calculation from the BWROG contractor. 08/10/2011 Calculation EA 0272 was initiated on August 10, 2011, and was approved on September 2. It used preliminary BWROG results to

incorporate the level instrument curve. 09/16/2011 CA-001, due August 12, 2011, was closed to CA-004 which added the tracking of this item to the Design Basis Assessment Report which is

output quarterly. 03/15/2013 A proposal was received to update P/T curves for License Renewal by incorporating the results of the capsule pulled in the recent refueling

outage, with inclusion of instrument line impact, and an additional note to the curves for startup under a vacuum. 11/26/2013 CR 2013-18983, "2013 NRC PI&R: Timeliness Concern with Non-Conservative Technical Specification 3.4.11," was initiated to address the timeliness issue raised by the NRC. Administrative Letter 98-10 contained two examples of untimely corrective action to

correct a non-conservative TS. The first example was a licensee that waited until after a

refueling outage to submit a license amendment. The second example a licensee that

waited over one year to submit an LAR. As of November 14, 2013, Perry had not

submitted an LAR license amendment after implementing administrative controls, over four years and two operating cycles. Based on the two examples in 98-10, the inspectors determined that Perry's corrective action to submit the LAR was not timely and a violation of 10 CFR Part 50, Appendix B, Criterion XVI.

Analysis: The licensee's failure to promptly correct a condition adverse to quality was a performance deficiency and was more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated September 12, 2012, because the finding was associated with the area of Routine Operations Procedures

within the Procedure Quality attribute of the Barrier Integrity Cornerstone, and had the

potential to adversely affect the associated cornerstone objective of providing

reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, without NRC approval of the revised P/T limits, the inspectors did not have reasonable assurance the reactor vessel was not adversely

affected. The finding was evaluated using IMC 0609, Significance Determination

Process (SDP), Attachment 0609.04, "Initial Characterization of Findings," dated

June 19, 2012, and IMC 0609, Appendix A, Exhibit 3 - Barrier Integrity Screening Questions, dated June 19, 2012. Because the finding involved the RCS boundary (e.g., pressurized thermal shock issues), the SDP directs the inspectors to stop and go

to the detailed risk evaluation section. The regional SRA determined that a detailed risk evaluation was not required because operators followed the appropriate TS P/T curves

10 Enclosure which were supported with approved licensee calculations. Therefore, there was no impact to the RCS boundary as a result of this finding and the analyst concluded that

this issue was of very low safety significance. The finding has a cross-cutting aspect in the area of human performance, decision-making, where licensee decisions demonstrate that nuclear safety is an overriding priority. Specifically, from the time of discovery of the non-conservative technical specification until now, various decisions

had been made by the licensee that have delayed the timely submittal of the license amendment request (H.1(c)).

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that conditions adverse to quality be promptly identified and corrected.

Contrary to the above, the licensee failed to promptly correct a non-conservative

Technical Specification, a condition adverse to quality. Specifically, the inspectors

identified on November 14, 2013, that the licensee failed to promptly correct the non-conservative TS 3.4.11 by not submitting the LAR in accordance with NRC Administrative Letter 98-10, which specified submittal within one year or one operating

cycle. The licensee had determined TS 3.4.11, "RCS Pressure and Temperature (P/T)

Limits," to be non-conservative on October 16, 2009, and implemented administrative

controls as allowed by the Administrative Letter. However, as of November 14, 2013, the licensee had not submitted the LAR, over four years and two operating cycles after determining TS 3.4.11 was non-conservative. Because the violation was of very low

safety significance and was documented in the licensee's corrective action program (as Condition Report CR 2013-18983), it is being treated as a Non-Cited Violation,

consistent with Section 2.3.2 of the Enforcement Policy (NCV 05000440/2013007-02, Failure To Promptly Correct a Non-Conservative Technical Specification). .2 Use of Operating Experience a. Inspection Scope The inspectors reviewed the licensee's implementation of the facility's Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, reviewed completed evaluations of OE issues and events, interviewed the OE

coordinator, and attended a weekly OE meeting which included representatives from

various departments. The intent of the review was to: (1) determine whether the

licensee was effectively integrating OE experience into the performance of daily

activities; (2) determine whether evaluations of issues were appropriate and conducted by qualified individuals; (3) determine whether the licensee's program was sufficient to prevent future occurrences of previous industry events; and (4) determine whether the

licensee effectively used the information in developing departmental assessments and

facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and implemented effectively and timely. b. Assessment Overall, the inspectors determined that the licensee was adequately evaluating industry OE for relevance to the facility. The licensee had entered all applicable items in the CAP in accordance with the licensee's procedures. Both internal and external OE was being

incorporated into lessons learned for training and pre-job briefs. The inspectors

11 Enclosure concluded that the licensee was evaluating industry OE when performing root cause and apparent cause evaluations. Observations The inspectors identified a potential weakness in the licensee's documenting of the basis for OE not requiring an evaluation. Specifically, once an OE was sent to the responsible

department as "Information Only," the expectation was that if it were determined to need

an evaluation, then Corrective Action (CA) would be documented. Currently, however, there was no documentation of the justification of why an evaluation was not required, even if the OE were discussed in the weekly OE meeting. The licensee initiated

CR 2012-17901, "Potential Improvement Item was Identified Regarding "Information

Only" OE Justification." The inspectors did not identify any OE for which an evaluation

had not been performed if required. Findings No findings were identified. .3 Self-Assessments and Audits a. Inspection Scope The inspectors assessed the licensee staff's ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions, through

efforts from departmental assessments and audits. The inspectors reviewed audit reports and completed assessments. The inspectors reviewed fleet assessments, site Quality Assurance audits, and departmental self-assessments. b. Assessment Based on the self-assessments and audits reviewed, the inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at

identifying issues and enhancement opportunities at an appropriate threshold. The audits and self-assessments were completed by personnel knowledgeable in the subject area, and the audits were thorough and critical. The inspectors observed that CAP

items had been initiated for issues identified through audits and self-assessments. The

inspectors reviewed the self-assessment performed on the CAP and found no issues

and generally agreed with the overall results and conclusions drawn. Observations The inspectors reviewed fleet oversight assessment reports since the third trimester of 2012. The assessments were found to be critical of site performance. For instance, the 2013 second trimester report concluded two of the site organizations ineffective and four

marginally effective (of 9 total organizations). Repeat comments and deficiencies noted in these assessments included: * Workmanship issues due to procedure use, * Procedure compliance issues, * Lapses in accountability, * Issues with management intrusiveness, and

12 Enclosure * Concerns and issues over CAP implementation. The relatively longstanding and repetitive nature of the issues identified support the inspector conclusions that corrective actions to improve procedure use and adherence were ineffective. The licensee was relying on the recently issued Strategic Improvement Plant to improve and sustain a higher standard of human performance. Findings No findings were identified. .4 Safety Conscious Work Environment (SCWE) a. Inspection Scope The inspectors assessed the licensee's SCWE through the review of the licensee's employee concerns program (ECP), implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. An extensive SCWE review was conducted with multiple focus groups during the 2013 Inspection Procedure 95002 inspection that the NRC conducted in June. The results of that review are contained in NRC Inspection Report 05000440/2013009 (ADAMS

Accession Number ML13224A382) and concluded the SCWE environment at Perry was

adequate. Therefore, for the current inspection, the inspectors conducted impromptu interviews with plant personnel to verify the results of the 95002 inspection. Approximately 20 people were involved in questions and discussions involving SCWE. In addition to assessing individuals' willingness to raise nuclear safety issues, the

interviews also addressed changes in the CAP and plant environment and management over the past 2 years. Other items discussed included: * knowledge and understanding of the CAP, * effectiveness and efficiency of the CAP, and * willingness to use the CAP. b. Assessment The interviews and discussions reinforced the conclusion from the 95002 inspection that the licensee has an environment where people are free to raise nuclear safety issues without fear of retaliation. All of the individuals interviewed knew that in addition to the CAP, they could raise issues to their immediate supervisor, the ECP, or the NRC. The

number of issues raised to the ECP and the subsequent investigations conducted by the

ECP personnel support the responses that personnel are knowledgeable and willing to use this program. Observations A number of the people interviewed identified that one of the organizational issues was staffing. This had also been identified as one of the major concerns during the 95002 inspection and continued to be an issue for employees although no nexus was drawn to a SCWE issue. The licensee was aware of the staff's beliefs related to staffing.

13 Enclosure Several comments indicated that there was an improvement with the communication of the leadership at Perry. Both the Site Vice-President and the Plant Manager were newly

assigned to Perry since the 95002 inspection. Personnel commented that both individuals appear to spend more time in the field communicating directly with them, and appear to listen to their concerns. Continuing this behavior by the senior leadership

would likely result in an improvement to the SCWE. Findings No findings were identified. 4OA6 Management Meeting .1 Exit Meeting Summary On November 22, 2013, the inspectors presented the inspection results to Mr. Harkness, the Site Vice-President, and members of his staff. The licensee

acknowledged the issues presented. The inspectors confirmed that proprietary documents were appropriately returned or will be destroyed. ATTACHMENT: SUPPLEMENTAL INFORMATION

1 Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel

E. Gordon, Supervisor, Performance Improvement

B. Blair, Manager - Maintenance

E. Harkness, Site Vice President D. Hamilton, Director - Site Operations N. Conicella, Manager - Regulatory Compliance

L. Zerr, Supervisor - Regulatory Compliance

J. Ellis, Director - Recovery

V. Veglia, Director - Maintenance T. Veitch, Manager - Regulatory Compliance R. Coad, Supervisor, Design Engineering

K. Coggins, Maintenance

NRC Personnel M. Kunowski, Chief, Branch 5, Division of Reactor Projects

M. Marshfield, Senior Resident Inspector

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened and Closed 05000440/2013007-01 NCV Failure To Comply With Technical Specification 3.4.11 (Section 4OA2.1b.(2).1)05000440/2013007-02 NCV Failure To Promptly Correct a Non-conservative Technical Specification (Section 4OA2.1b.(3).1) Discussed

None

2 Attachment LIST OF DOCUMENTS REVIEWED The following is a list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of 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. CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED OPERABILITY EVALUATIONS Number Description or Title Date or Revision 2012-03521 DG Ventilation Fans Cracking May 10, 2012 2013-07483-01 Condensate Transfer System Elevated Temperatures May 13, 2013 2013-13136 Turbine Stop Valve Testing August 25, 2013 PLANT PROCEDURES Number Description or Title Date or Revision GEI-0007-A Instructions For Cable And Wire Terminations 11 IOI-1 Cold Startup 37

IOI-4 Shutdown 19 NOBP-LP-2001 FENOC Self-Assessment And Benchmarking 19 NOBP-LP-2008 FENOC Corrective Action Review Board 14 NOBP-LP-2011 FENOC Cause Analysis 16 NOBP-WM-4003 FENOC Refurbishment Process 00 NOBP-WM-4300 Order Execute Process 12 NOPB-LP-2022 Compliance Auditing 11 NOPB-LP-2023 Conduct Of Fleet Oversight 12 NOP-ER-3004 FENOC Maintenance Rule Program 2 NOP-LP-2020 Quality Control Receipt Inspection 14 NOP-LP-4009 Requests For NRC Licensing Action 2 NOP-LP-4009-04 TS Tracking Form; RCS P/T Limits 3.4.11 October 16, 2009 NOP-OP-1009 Operability Determinations And Functionality Assessments 3 NOP-OP-1012 Material Readiness And Housekeeping Inspection Procedure 7 NOP-SS-3001 Procedure Review And Approval 19 NORM-LP-2003 Analytical Methods Guidebook 4 PAP-0204 Housekeeping/Cleanliness Control Program 26 PYBP-PNMD-005 Maintenance Mentoring Process 00 PYBP-POS-5-11 Operations Work Control Unit (WCU) Guide 11 SOI-G33 Reactor Water Cleanup System 38 SVI-B21-T1176 RCS Heatup Data, Table 1 June 4, 2011 SVI-B21-T1176 RCS Heatup Data, Table 1 October 18, 2011 SVI-B21-T1176 RCS Heatup Data, Table 1 March 3, 2012 SVI-B21-T1176 RCS Heatup Data, Table 1 June 17, 2012 SVI-B21-T1176 RCS Heatup Data, Table 1 May 11, 2013 SVI-B21-T1176 RCS Cooldown Data, Table 1 June 16, 2013

3 Attachment Number Description or Title 2008-48338 High Water Content In U2 Startup XFMR Oil 2010-82586 Unit 2 Startup XFMR Oil Sample Results Indicate High Moisture Content 2011-06031 2011 AFI MA. 1-1 Maintenance Consistent Use Of Procedures And Work Orders As Written 2011-06137 Declining Ownership With CAP And OE Due Dates 2011-06714 Focused Self-Assessment Recommendation Four Actions From Industry Peers To Be Tracked In CAP 2011-07124 Lack Of Work Preparation/Execution Not Limited To, But Including Div-1 AOT 2012-00212 Historical Review Of Oil Analysis On Aux Transformer Reviewed IEEE Condition 1 Limits Exceeded 2012-00386 Work Could Not Be Performed As Scheduled During Div 2 EDG Outage 2012-00400 SLC Pump 'A' Unavailable In Narrative Log But Not In A Timely Manner 2012-00406 Voltage Found During Live Dead Live Check 2012-00615 SN-SA-2012-006: Deficiencies Found With OE Reviews During FP Self-Assessment 2012-00658 Activity To Perform "Line Kill" Of RFPT B Casing Drain Line Was Unsuccessful 2012-00798 Adverse Trend - Declining Performance In Maintenance Training Programs (IP-SA-2012-0001) 2012-01073 TSC UPS B Abnormal DC Voltage Alarm 2012-02767 Unexpected Trip Of S-621 And S-620 2012-03809 Rigging Issue During Removal Of A Beam In Dry Cask Storage Project 2012-06153 Loss Of Control For The Seismic Restraint For The Dry Cask Storage Project 2012-11886 RWCU Isolation Pump Trip During SVI Restoration 2012-01516 PY-PA-12-01 The CAP Performance Was Rated Marginally Effective For The 3rd Trimester Of 2011 2012-01908 Review Of All Site Condition Reports From January Identified A Trend Of Repeat Issues 2012-02678 MS-C-12-01-13, Issues Identified Pertaining To GL-89-13 Program 2012-02794 MS-C-12-01-13, Test Equipment Uncertainties Not Accounted In Valve Testing 2012-02911 CNRB Recommendation: Capture Feedback From NRC PI&R Inspection Debrief 2012-03231 Manual Reactor SCRAM 1-12-01 Occurred at 02:24 March 1, 2012 2012-03720 Unexpected Breaker Trip During Uncoupled Run 2012-03840 Miscommunication Of Emergency Diesel Generator Ventilation Fan Air Flow Compensation Requirements 2012-06167 Actions Taken In Response To CR11-89188 Are Outside The Corrective Action Program 2012-06485 Procedure Adherence Issues During Unit 1 Division 2 Battery Charge 2012-06660 Feedwater Heater 5A Leak As Reported Is Above An ODMI Trigger Point

4 Attachment 2012-06973 NRC NCV, Inadequate Risk Evaluation For Main Generator Stator Water Cooling System Maintenance Resulted In A Manual Reactor Scram 2012-07882 NRC NCV, Inadequate Procedure Resulted In Loss Of High-Pressure Core Spray Function 2012-09931 Supplemental Personnel Injured During Scaffold Modification 2012-10293 PA-PY-2012-02, Maintenance CAP Implementation Issues 2012-11148 PYSP IPAT 1st Half of 2012- Emerging Trend Identified Related To An Increase In Human Performance Events Within the Section (IP-SA-2012-0119) 2012-11369 Belt Installed On TB Supply Fan B, Unsafe Act 2012-12152 Declining CAP Health Indicators 2012-12349 July CAP Performance Indicator Shows A Declining Trend In Cause Evaluation Quality 2012-12674 Missed SVI Unit 1 Division 1 Battery

2012-13408 FO-SA-2012-0013: Activities Are Being Inappropriately Designated A Different Color Of Risk Than What Is Assessed Per NOP-OP-1007 2012-13758 Ineffective Communications During Pre-Job Brief Resulted In Drilling Through Rebar Without Prior Engineering Approval 2012-15950 SN-SA-0220 Perry Nuclear Safety Culture Review Self-Assessment- Principle 7 2012-16671 The 3rd Quarter Safety Culture Monitoring Meeting Held On October 19, 2012 Determined That Safety Culture Attribute If Needs

Further Review And Attention 2012-16828 Work Group Unprepared to Start Task For Hot Short Modification Causes Un-necessary Unavailability Time For Division 1 Diesel 2012-18618 Chemistry Section Was Rated RED For The 2012 SCWE Survey Pillar 2012-19535 XCAP Precursor Issues In Cross-Cutting Aspect H.4(a) 2013-00013 Data Suggests That The Importance Placed On The Corrective Action Program Is Not Where It Needs To Be For The Station 2013-00511 TB West Crane Deficiencies Not Entered Into CAP And Resolution Not Documented In WO 200493418 2013-00826 FO-SA-2011-0017, Based On The Number Of Issues Of Issues Identified Similar In Nature To Previously Identified Issues. The Corrective Actions Taken Have Been Less Than Fully Effective 2013-00753 Clearance Not Adequate For Work To Be Performed 2013-01011 Inverter 1R14S0004 Found On Alternate Source With The Fila Light On Following Reactor Scram 2013-01476 PY-C--13-01-01, Clearance Revision Process Described In NOP-OP-1001 Is Not Being Followed 2013-01965 CARB Identified Line Ownership Of The CAP Is Inconsistent And Is Delaying Improvement Of The Implementation Of CAP At Perry 2013-03005 Snapshot Self-Assessment SN-SA-2012-0079, Found Project Section That Had One LACE CR That Required Cause Code(s) 2013-03016 MS-C-13-02-22, CR 2012-13758 Interim Effectiveness Review Not Adequately Reviewed Or Issues Identified In CAP 2013-03223 Corrective Actions Assigned In CR 2013-00478 Do Not Address Apparent Cause Identified 2013-04435 Valve Found Out-of-Position

5 Attachment 2013-05236 Resolution Of A Condition Adverse To Quality (Non-Conservative Technical Specification) Is Not Being Tracked In The Corrective Action Program 2013-05741 NRC Cross-Cutting Theme In Human Performance Aspect H.4(a)

2013-05809 Potential Trend: There Have Been Nine Overdue CAP Products Between March 31, 2013 And April 14, 2013 2013-05993 MS-C-13-02-22: Perry Corrective Action Program Implementation Rated Marginally Effective 2013-06207 Auto Start Of 1M15C0001A During SVI-R43-T7000A. On April 15, 2013, Was Not Documented In CAP 2013-06479 P-1925 Could Inappropriately Credit RHR Availability For Decay Heat Removal In Defense-In-Depth When ADHR Is In Service 2013-07473 Level Transient During Performance Of PTI-N27-P0012 2013-07582 Conditional Release Of 1P11-F0545 2013-07585 Valve Refurbishment Did Not Follow NOBP-WM-4003 2013-07665 Field Wiring Did Not Match Drawing 209-0158-00003 For The AT Junction Box In The Generator Alterex Cabinet 2013-07881 NRC FIN, Failure To Perform Vendor Recommended Preventative Maintenance 2013-07883 NRC NCV, Valve Mis-Position Causes SDV Level Detector Inoperability 2013-07884 NRC NCV, Failure To Follow Procedures For Conducting A Standby Liquid Control System Surveillance 2013-08962 PA-PY-13-01 Organizational Effectiveness Rated Marginally Effective For 1st Trimester 2013 2013-09086 Potential Debris/Missile Material Stored Outside Of MB-100 2013-09461 Cross Cutting Aspect H(3).b For NCV 05000440/2013002-01 Not Evaluated In CR2013-03863 Or CR2013-03781 2013-09486 SN-SA-2013-0144, CA 2011-97640-001 Not Implemented As Stated In Corrective Action Closure Comments 2013-09601 Safety Concern Roof Top Workers 2013-09637 License Amendment Implementation Completed Prior To Amendment Approval 2013-10222 Changes In Procedure's Effect On MSPI Not Evaluated 2013-11771 Five Rosemount Trip Units Have Demonstrated Drifts That Warrants Accelerated Replacement In Accordance With POD 2012-10238 2013-13040 MN-ID: Adverse Trend In Material Handling 2013-13272 NRC 95002 NCV, RWCU Valve Misposition, Elevated Temperatures In Condenser Transfer Piping 2013-13274 NRC 95002 NCV, Unexpected RPV Level Transient During Performance Of PTI-N27-P0012, Procedure Was Not Appropriate To

The Circumstances 2013-13420 RP Root Cause CR 2013-09891 Was Rejected By CARB On August 26, 2013 Due To Numerous Changes And Low Grading Score 2013-13992 FO-SA-2012-0025, PI&R: Review of CR-2011-06037, Maintenance Corrective Action Implementation Issues 2013-16086 Unit 1 Start-up Transformer Oil Quality Exceeded Established Trend Plan Limits 2013-18180 2013 NRC PI&R: Potential Improvement Item Was Identified Regarding Justification For No Maintenance Rule Evaluation

6 Attachment 2013-18689 2013 NRC PI&R: TS 3.4.11 RCS P/T Limits Comprehension 2013-18696 2013 NRC PI&R: Deficiency Found In Execution Of Work Order 20056349, Replacement Of 1P11F0545 2013-18704 2013 NRC PI&R: Planning Deficiency In Work Order 200563495, Replacement Of P11F0545 CR-G202-2009-56349 Loss Of Non-Essential 480 V BUS F-1-C And F-1-D.

CR-G202-2009-66058 Recirculation Pump A Trip On Failure To Transfer To Slow Speed CR-G202-2010-76727 Reactor Scram OTHER DOCUMENTS Number Description or Title Date or Revision CNRB - Work Management Sub-Committee Meeting (Handout) September 2013 Maintenance Standards Implementation 0 Green News Flash- Awareness Of Housekeeping Standards For Switchyard And

Transformer Areas November 17, 2013 Maintenance Superintendent And Supervisor Weekly Meeting Agenda November 7, 2013 Message From Site Leadership Team On Site Expectations And Standards August 8, 2013 Perry Station Safety & Human Performance Recovery Plan For NPS September 18, 2012 Perry Nuclear Power Plant Performance Indicator 01 November 19, 2013 Revise Organizational Effectiveness Plan October 31, 2013 200487879 Perform Line KiII On RFPT B Per ECP 08-0712-003 January 13, 2012 GAT 6008631128 Management Alignment And Ownership Meeting Agendas November 5, 2013 November 6, 2013

November 7, 2013 November 8, 2013 MEC-201203-PY-04 Electrical Maintenance Continuous Training 2012 Third Cycle, Phase Rotation Meters October 3, 2012 PY Plant Status Email Perry Plant Status For Friday, November 8, 2013; E-Mail From Dave Hamilton November 8, 2013 System Health Report 2013-1 System--S11-Power Transformers August 22, 2013 System Health Report 2012-2 System--S11-Power Transformers August 10, 2012 TEEW IC-12-01 I&C Radworker H.I.T. March 14, 2012 TEEW IC-13-01 Human Performance Tools, Verification Techniques July 1, 2013 TEEW ME-13-01 Human Performance Tools, Lifting And Landing Of Electrical Wires/Cables July 1, 2013

7 Attachment OPERATING EXPERIENCE Number Description or Title OE 2011-0554 Preliminary-Failed Agastat E7012PB Model Timing Relay OE 2011-0780 Preliminary-Emergency Diesel Generator Field and Output Voltage Fluctuation AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS Number Description or Title Date or Revision FENOC Oversight Fleet Summary, Third Trimester 2012 September 1, 2012 through

December 31, 2012 FO-SA-2012-0011 CAP Process / Database February 8, 2013 FO-SA-2012-0025 Preparation For The Corrective Action Program NRC Problem And Identification Inspection September 4, 2013 FO-SA-2013-0121 Compare Revision Changes of "INPO 97-011 Guidelines For The Use of Operating Experience" June 24, 2013 MS-C-13-02-22 Fleet Oversight Audit Report April 15, 2013 PA-PY-13-01 Perry Nuclear Power Plant Fleet Oversight Trimester Report, 1st Trimester 2013 May 29, 2013 PA-PY-13-02 Perry Nuclear Power Plant Fleet Oversight Trimester Report, 2nd Trimester 2013 September 26, 2013 PY-PA-12-01 Review Of All Site Condition Reports From January Identified A Trend Of Repeat Issues July 31, 2012 SN-SA-2012 0041 Submittal Of OE To The Industry July 20, 2012 SN-SA-2012 0166 Snapshot Of Timeliness Of PJB For Significant CRs, CR Report Closure Timeliness And

Evaluator Attendance At CARB. August 6, 2012 SN-SA-2012 0254 Per CA-2012-01912-2, Perform A Snapshot 3 Months After Implementation Of New Performance

Indicators To Determine Effectiveness Of Reducing Timeliness Issues In CAP January 13, 2013 SN-SA-2012-0079 Perform A Review Of All Limited, Full, Root Cause Evaluations That Do Not Have A Cause Code In

Devonway May 8, 2012 SN-SA-2012-0095 4th Quarter 2011 Safety Culture Monitoring Panel May 8, 2012 May 8, 2012 SN-SA-2012-0149 1st Q 2012 Management Oversight And Awareness Of Conservative Decisions August 6, 2012 SN-SA-2012-0181 Management Oversight And Awareness Of Conservative Decisions March 5, 2013 SN-SA-2012-0246 Switchyard Component Control Assessment November 8, 2012 SN-SA-2012-02-77-001 Plant Engineering Backlog August 12, 2013 SN-SA-2013-004 NRC Inspection 71113004 Equipment Performance, Testing, And Maintenance July 22, 2013 SN-SA-2013-0342 2013 Perry INPO Organizational Effectiveness Survey Analysis October 31, 2013

8 Attachment OE 2011-0986 IN 2010-01 Pipe Support Anchors OE 2011-1187 Failures Of Moore 535 Digital Single Loop Controllers Causing Problems In Multiple System OE 2011-1307 Declining Trend In Operability Determination Led To An Inadequate Evaluation OE 2011-1372 Preliminary- During 125 Volt DC Electrical Maintenance A Short Circuit Caused A Reactor Trip OE 2012-0277 IN 12-01 Seismic Considerations- Principally Involving Tanks

OE 2012-0965 Environmental Qualification (EQ) Program Challenged By Inconsistent Scheduling Of Required Maintenance OE 2013-1217 Unit 2 Turbine Trip On Main Generator Lockout

OE 2013-1225 Counterfeit Batteries Identified During Receipt Inspection CONDITION REPORTS GENERATED DURING INSPECTION Number Description or Title 2013-17900 2013 NRC PI&R: Enhance Tracking Of Maintenance Rule (a)(1) System Work Orders 2013-17901 2013 NRC PI&R: Potential Improvement Item Was Identified Regarding "Information Only" OE Justification 2013-17984 2013 NRC PI&R: Potential Transformer Yard Debris/Missile Hazards Stored Outside Of MB-100 2013-18176 2013 NRC PI&R: No Final Effectiveness Review Exist For Root Cause CR 2009-66058 2013-18180 2013 NRC PI&R: Potential Improvement Item Was Identified Regarding Justification For No Maintenance Rule Evaluation 2013-18387 2013 NRC PI&R: NRC Questions Perry Response To CR 2013-00511 2013-18579 2013 NRC PI&R: Documentation Of Corrective Action Implementation Does Not Meet Expectation 2013-18661 2013 NRC PI&R: NRC Questions The Thoroughness Of The Response To CR 2013-09637, License Amendment Implementation Completed Prior To Amendment Approval ROOT CAUSES AND APPARENT CAUSES Number Description or Title 2011-02542 Unit 1 Start-up Transformer Failure 2012-07454 IRM D Indicating Failure During Power Ascension

2013-01011 Inverter 1R14S004 Was Found On Its Alternate Source And With The Fail Light On Following A Reactor Scram 2013-05234 Root Cause For Fuel Defect Found During 1R14

2013-07454 IRM D Not Responding Properly

2013-09737 Maintenance And Technical Training Station Identified Finding

9 Attachment LIST OF ACRONYMS USED ACE Apparent Cause Evaluation ADAMS Agencywide Documents Access and Management System BWROG Boiling Water Reactor Owners Group CA Corrective Action

CAP Corrective Action Program

CARB Corrective Action Review Board

CCA Common Cause Analysis

CFR Code of Federal Regulations CR Condition Report ECP Employee Concerns Program

FENOC FirstEnergy Nuclear Operating Company

GEH General Electric-Hitachi

IMC Inspection Manual Chapter IP Inspection Procedure IR Inspection Report

LACE Limited Apparent Cause Evaluation

LAR License Amendment Request

NCV Non-Cited Violation NRC Nuclear Regulatory Commission OE Operating Experience

P/T Pressure/Temperature

PARS Publicly Available Records System

PI&R Problem Identification and Resolution

PSIG Pounds per Square Inch Gauge RCE Root Cause Evaluation RCS Reactor Coolant System

RPV Reactor Pressure Vessel

SCWE Safety Conscious Work Environment

SDP Significance Determination Process SRA Senior Reactor Analyst TS Technical Specification

WIP Work-In-Progress

E. Harkness -2- If you contest a violation or significance of these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement,

U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector at the Perry Nuclear Power Plant.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Perry Nuclear Power Plant.

In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," 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 System (PARS) component of the 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). Sincerely,

/RA/ Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket No. 50-440

License No. NPF-58

Enclosure: Inspection Report 05000440/2013007 w/Attachment: Supplemental Information

cc w/encl: Distribution via ListServTM

DISTRIBUTION: See next page

DOCUMENT NAME: Perry IR 2013007 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-DRP RIII RIII RIII NAME JJandovtiz:rj SOrth PLougheed for MKunowski DATE 01/02/14 01/02/14 01/03/14 OFFICIAL RECORD COPY

Letter to Ernest Harkness from Michael Kunowski dated January 3, 2014

SUBJECT: PERRY NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000346/2013007

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