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| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION | | {{#Wiki_filter:August 25, 2011 |
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| ==REGION III== | | ==SUBJECT:== |
| 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 August 25, 2011 EA-1 1-1 48 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: FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING WITH ASSESSMENT FOLLOWUP AND NOTICE OF VIOLATION
| | FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING WITH ASSESSMENT FOLLOWUP AND NOTICE OF VIOLATION; NRC INSPECTION REPORT NO. 05000440/2011014 PERRY NUCLEAR POWER PLANT |
| ; NRC INSPECTION REPORT NO. 05000440/201101 4 PERRY NUCLEAR POWER PLANT | |
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| ==Dear Mr. Bezilla:== | | ==Dear Mr. Bezilla:== |
| This letter provides you the final significance determination of the preliminary White finding as discussed in our previous communication dated June 30 , 2011, which included U.S. Nuclear Regulatory Commission (NRC) Inspection Report No. 05000440/2 01101 3. The finding involved your staff's radiological performance associated with the retraction of a stuck source range monitor from the reactor vessel | | This letter provides you the final significance determination of the preliminary White finding as discussed in our previous communication dated June 30, 2011, which included U.S. Nuclear Regulatory Commission (NRC) Inspection Report No. 05000440/2011013. The finding involved your staffs radiological performance associated with the retraction of a stuck source range monitor from the reactor vessel. |
| . In a letter dated August 1, 2011 , you provided a response to the NRC staff preliminary determination regarding the finding. Your response indicated that FirstEnergy Nuclear Operating Company did not contest the facts and assumptions used by the NRC to arrive at the finding and its significance.
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| Your letter further described the corrective actions being taken in response to the finding. | | In a letter dated August 1, 2011, you provided a response to the NRC staff preliminary determination regarding the finding. Your response indicated that FirstEnergy Nuclear Operating Company did not contest the facts and assumptions used by the NRC to arrive at the finding and its significance. Your letter further described the corrective actions being taken in response to the finding. |
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| After considering the information developed during the inspection and based on the absence of any new or additional information in your August 1, 2011, letter regarding the basis for the finding, the NRC has concluded that the finding is appropriately characterized as White, a finding of low to moderate risk significance. According to NRC Inspection Manual Chapter (IMC) 0609, appeal rights only apply to those licensees that have either attended a Regulatory Conference or submitted a written response to the preliminary determination letter. | | After considering the information developed during the inspection and based on the absence of any new or additional information in your August 1, 2011, letter regarding the basis for the finding, the NRC has concluded that the finding is appropriately characterized as White, a finding of low to moderate risk significance. According to NRC Inspection Manual Chapter (IMC) 0609, appeal rights only apply to those licensees that have either attended a Regulatory Conference or submitted a written response to the preliminary determination letter. |
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| The NRC has also determined that violations were associated with the White finding, as cited in the enclosed Notice of Violation (Notice). The circumstances surrounding the violation s were described in detail in NRC Inspection Report No. 05000 440/2 01101 3. In accordance with the NRC Enforcement Policy, the Notice is considered escalated enforcement action because it is associated with a White finding. The NRC has concluded that information regarding the reason for the violation s, the corrective actions taken and planned to be taken to correct the violation s and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. | | The NRC has also determined that violations were associated with the White finding, as cited in the enclosed Notice of Violation (Notice). The circumstances surrounding the violations were described in detail in NRC Inspection Report No. 05000440/2011013. In accordance with the NRC Enforcement Policy, the Notice is considered escalated enforcement action because it is associated with a White finding. The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to be taken to correct the violations and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. 05000440/2011013 and in your letter dated August 1, 2011. |
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| 05000 440/2 011013 and in your letter dated August 1, 2011
| | Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. |
| . Therefore, you are not required to respond to this letter unless the description therein does not accuratel y reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. As a result of our review of Perry's performance, including this White finding and the existing White performance indicator in the Occupational Radiation Safety Cornerstone, we have assessed Perry to be in the Degraded Cornerstone column (Column 3) of the NRC's Action Matrix. Therefore, we plan to conduct a supplemental inspection using Inspection Procedure 95002 , "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," when your staff has notified us of your readiness for this inspection. This inspection procedure is conducted to provide assurance that the root cause and contributing causes of risk significant performance issues are understood, to independently assess and provide assurance that the extent of condition and the extent of cause are identified, to independently determine if safety culture components caused or significantly contributed the performance issues, and to provide assurance that your corrective actions are sufficient to address the root and contributing causes and prevent recurrence.
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| In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC=s Agencywide Document s Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. The NRC also includes significant enforcement actions on its Web site at http://www.nrc.gov/reading-rm/doc-collections/ enforcement/actions | | As a result of our review of Perrys performance, including this White finding and the existing White performance indicator in the Occupational Radiation Safety Cornerstone, we have assessed Perry to be in the Degraded Cornerstone column (Column 3) of the NRCs Action Matrix. Therefore, we plan to conduct a supplemental inspection using Inspection Procedure 95002, Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area, when your staff has notified us of your readiness for this inspection. This inspection procedure is conducted to provide assurance that the root cause and contributing causes of risk significant performance issues are understood, to independently assess and provide assurance that the extent of condition and the extent of cause are identified, to independently determine if safety culture components caused or significantly contributed the performance issues, and to provide assurance that your corrective actions are sufficient to address the root and contributing causes and prevent recurrence. |
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| | In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC=s Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. The NRC also includes significant enforcement actions on its Web site at http://www.nrc.gov/reading-rm/doc-collections/ |
| | enforcement/actions. |
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| Sincerely, | | Sincerely, |
| /RA/ Mark A. Satorius Regional Administrator Docket No. | | /RA/ |
| | | Mark A. Satorius Regional Administrator Docket No. 050-00440 License No. NPF-58 Enclosure: |
| 0 5 0-0 0 440 License No. NPF-58 Enclosure:
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| Notice of Violation cc w/encl: Distribution via ListServ | | Notice of Violation cc w/encl: Distribution via ListServ |
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| ENCLOSURE NOTICE OF VIOLATION FirstEnergy Nuclear Operating Company Docket No. 0 5 0-00 440 Perry Nuclear Power Plant License No. NPF-58 EA-1 1-1 48 During a U.S. Nuclear Regulatory Commission (NRC) special inspection conducted from April 25 to May 2 5 , 201 1 , violation s of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violation s are listed below:
| | NOTICE OF VIOLATION FirstEnergy Nuclear Operating Company Docket No. 050-00440 Perry Nuclear Power Plant License No. NPF-58 EA-11-148 During a U.S. Nuclear Regulatory Commission (NRC) special inspection conducted from April 25 to May 25, 2011, violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below: |
| | A. Title 10 of the Code of Federal Regulations (10 CFR) Part 20 Subpart F - Surveys and Monitoring Section 20.1501 requires, in part, that licensees make surveys that may be necessary to comply with the regulations in Part 20 and are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels and the potential radiological hazards. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal or presence of radioactive material or other sources of radiation. |
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| A. Title 10 of the Code of Federal Regulations (10 CFR) Part 20 Subpart F
| | Contrary to the above, as of April 21, 2011, the licensee failed to make surveys to evaluate the potential radiological hazards incident to work activity to assure compliance with 10 CFR 20.1201, which limits the occupational dose to individual adults. |
| - Surveys and Monitoring Section 20.1501 requires, in part, that licensees make surveys that may be necessary to comply with the regulations in Part 20 and are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels and the potential radiological hazards. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use
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| , transfer, release, disposal or presence of radioactive material or other sources of radiation.
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| Contrary to the above, as of April 21, 2011, the licensee failed to make surveys to evaluate the potential radiological hazards incident to work activity to assure compliance with 10 CFR 20.1201, which limits the occupational dose to individual adults. Specifically, the licensee did not perform an evaluation of the potential radiological hazards associated with the work activity prior to authorizing removal of an irradiated i n-core source range monitor (SRM).
| | Specifically, the licensee did not perform an evaluation of the potential radiological hazards associated with the work activity prior to authorizing removal of an irradiated in-core source range monitor (SRM). |
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| B. Technical Specification 5.7.1.b states, in part, that entry into high and locked high radiation areas be made after the dose rate levels in the area have been established and personnel are made aware of them. | | B. Technical Specification 5.7.1.b states, in part, that entry into high and locked high radiation areas be made after the dose rate levels in the area have been established and personnel are made aware of them. |
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| Contrary to the above, on April 21, 2011, the licensee permitted entry into a high radiation area without establishing the dose rate levels in the area and without personnel being made aware of the dose rates. Specifically, the licensee did not perform a complete radiological characterization of the SRM (a radiological source of unknown magnitude), which was being pulled toward the work area and toward the workers' escape path. Consequently, the licensee did not inform the workers of the potential dose rate levels associated with their entry into the high radiation area | | Contrary to the above, on April 21, 2011, the licensee permitted entry into a high radiation area without establishing the dose rate levels in the area and without personnel being made aware of the dose rates. Specifically, the licensee did not perform a complete radiological characterization of the SRM (a radiological source of unknown magnitude), which was being pulled toward the work area and toward the workers escape path. Consequently, the licensee did not inform the workers of the potential dose rate levels associated with their entry into the high radiation area. |
| . C. Technical Specification 5.4.1 requires that written procedures be established, implemented, and maintained covering the activities in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.
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| Regulatory Guide 1.33, Revision 2, Appendix A Section 7 addresses, in part, procedures for control of radioactivity for limiting personnel exposure. Section 7.e(1) addresses procedures for access control to radiation areas including a radiation work permits system and Section 7.e(9) addresses procedures for implementation of an a s low a s is reasonably achievable (ALARA) | | C. Technical Specification 5.4.1 requires that written procedures be established, implemented, and maintained covering the activities in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. |
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| Notice of Violation-2- ENCLOSURE The licensee established Procedure HPI-C0015 , Revision 00
| | Regulatory Guide 1.33, Revision 2, Appendix A Section 7 addresses, in part, procedures for control of radioactivity for limiting personnel exposure. Section 7.e(1) addresses procedures for access control to radiation areas including a radiation work permits system and Section 7.e(9) addresses procedures for implementation of an as low as is reasonably achievable (ALARA) program. |
| , "Radiological Controls for Highly Radioactive and Irradiated Components or Materials | |
| ," to control highly radioactive objects and materials removed from the reactor vessel.
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| The licensee established Procedure NOP-OP-4107, Revision 05, "Radiation Work Permit ," in part, for implementation of an ALARA program. Step 4.3.2.3 of this procedure states, in part, that ALARA plans are developed with sufficient detail on what requirements, considerations and actions are to be ALARA for the work activity.
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| Contrary to the above, as o f April 21, 2011, the licensee:
| | Notice of Violation -2-The licensee established Procedure HPI-C0015, Revision 00, Radiological Controls for Highly Radioactive and Irradiated Components or Materials, to control highly radioactive objects and materials removed from the reactor vessel. |
| a. Failed to establish a procedure that addressed access control to all radiation areas. Specifically, Procedure HPI-C0015 only addressed work activities on the refueling floor and did not address access control to the undervessel radiation area or control of highly radioactive objects and materials removed from the reactor vessel through the undervessel area.
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| b. Failed to implement Procedure NOP-OP-4107, in that the ALARA plan for work on the SRM lacked sufficient detail about the requirements, consideration, and actions to ensure that the work activity was performed in an ALARA manner. Specifically, the ALARA plan did not ensure that the work activity to retract the irradiated SRM-C contained steps to ensure that the ambient radiation field in the work area in the carousel and sub-pile room areas was being controlled and that the worker actions were in accordance with ALARA considerations.
| | The licensee established Procedure NOP-OP-4107, Revision 05, Radiation Work Permit, in part, for implementation of an ALARA program. Step 4.3.2.3 of this procedure states, in part, that ALARA plans are developed with sufficient detail on what requirements, considerations and actions are to be ALARA for the work activity. |
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| Th e s e violation s are associated with a White Significance Determination Process finding (VIO 0500 440/20110 1 4-01). The NRC has concluded that information regarding the reason for the violation s, the corrective actions taken and planned to be taken to correct the violation s and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. 05000 440/2 01101 3 and in your letter dated August 1, 2011.
| | Contrary to the above, as of April 21, 2011, the licensee: |
| | a. Failed to establish a procedure that addressed access control to all radiation areas. Specifically, Procedure HPI-C0015 only addressed work activities on the refueling floor and did not address access control to the undervessel radiation area or control of highly radioactive objects and materials removed from the reactor vessel through the undervessel area. |
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| However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.
| | b. Failed to implement Procedure NOP-OP-4107, in that the ALARA plan for work on the SRM lacked sufficient detail about the requirements, consideration, and actions to ensure that the work activity was performed in an ALARA manner. |
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| In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation, EA-1 1-1 48," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 , with a copy to the Regional Administrator and the Enforcement Officer, Region III, 2443 Warrenville Road, Suite 210
| | Specifically, the ALARA plan did not ensure that the work activity to retract the irradiated SRM-C contained steps to ensure that the ambient radiation field in the work area in the carousel and sub-pile room areas was being controlled and that the worker actions were in accordance with ALARA considerations. |
| , Lisle, IL 60532, and a copy to the NRC Resident Inspector at the Perry facility within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
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| If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
| | These violations are associated with a White Significance Determination Process finding (VIO 0500440/2011014-01). |
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| Notice of Violation-3- ENCLOSURE If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
| | The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to be taken to correct the violations and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. 05000440/2011013 and in your letter dated August 1, 2011. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. |
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| In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt. Dated this 25 th day of August 201 1 The NRC has concluded that information regarding the reason for the violation s, the corrective actions taken and planned to be taken to correct the violation s and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. | | In that case, or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation, EA-11-148, and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator and the Enforcement Officer, Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532, and a copy to the NRC Resident Inspector at the Perry facility within 30 days of the date of the letter transmitting this Notice of Violation (Notice). |
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| 05000 440/2011013 and in your letter dated August 1, 2011.
| | If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. |
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| Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. As a result of our review of Perry's performance, including this White finding and the existing White performance indicator in the Occupational Radiation Safety Cornerstone, we have assessed Perry to be in the Degraded Cornerstone column (Column 3) of the NRC's Action Matrix. Therefore, we plan to conduct a supplemental inspection using Inspection Procedure 95002 , "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area," when your staff has notified us of your readiness for this inspection. This inspection procedure is conducted to provide assurance that the root cause and contributing causes of risk significant performance issues are understood, to independently assess and provide assurance that the extent of condition and the extent of cause are identified, to independently determine if safety culture components caused or significantly contributed the performance issues, and to provide assurance that your corrective actions are sufficient to address the root and contributing causes and prevent recurrence.
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| In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC
| | ENCLOSURE |
| =s Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. The NRC also includes significant enforcement actions on its Web site at http://www.nrc.gov/reading-rm/doc-collections/enforcement/actions
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| Sincerely,
| | Notice of Violation -3-If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. |
| /RA/ Mark A. Satorius Regional Administrator Docket No. 050-00 440 License No. NPF-58 Enclosure:
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| Notice of Violation cc w/encl: Distribution via ListServ DISTRIBUTION | |
| : See next page FILE NAME:
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| G:\ORAIII\EICS\ENFORCEMENT
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| \Enforcement Cases 2011
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| \EA-11-148 Perry RP
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| \EA-11-148 Perry Final Action (REV 25Aug11).docx Publicly Available, non-sensitive OFFICE RIII RIII RIII OE RIII RIII NAME Orth for Lougheed O'Brien for Dickson O'Brien for Reynolds Coleman for Zimmerman 1Orth Satorius DATE 08/25/11 08/25/11 08/25/11 08/09/11 08/25/11 08/25/11 OFFICIAL RECORD COP Y
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| 1 OE concurrence received via e-mail from N. Coleman on August 9, 201 1.
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| Letter to Mark Bezilla from Mark Satorius , dated August 25, 201 1 SUBJECT: FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING WITH ASSESSMENT FOLLOWUP AND NOTICE OF VIOLATION; NRC INSPECTION REPORT NO. 05000440/201101 4 PERRY NUCLEAR POWER PLANT DISTRIBUTION
| | In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt. |
| : RidsSecyMailCenter.Resource OCADistribution Bill Borchardt Martin Virgilio Roy Zimmerman Nick Hilton Nicole Coleman Mark Satorius Cynthia Pederson Marvin Itzkowitz Catherine Scott Eric Leeds Bruce Boger Mary Ann Ashley Daniel Holody Scott Sparks Heather Gepford Holly Harrington Hubert Bell Cheryl McCrary Mona Williams Steven West Gary Shear
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| Steven Orth Jared Heck Allan Barker Viktoria Mitlyng Prema Chandrathil Patricia Lougheed Paul Pelke Magdalena Gryglak Sarah Bakhsh Daniel Merzke RidsNrrPMPerry Resource RidsNrrDorlLpI3-2 Resource RidsNrrDirsIrib Resource Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource OEMAIL OEWEB
| | Dated this 25th day of August 2011 ENCLOSURE |
| }} | | }} |
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Reactor Water Clean Up Leak Detection Loss of Safety Function
L-24-036, Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2024-06-27027 June 2024
Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models
05000440/LER-2024-001, Operation of the Residual Heat Removal Loops B and C Alternate Keep Fill Configuration Was Prohibited by Technical Specifications and Resulted in an Unanalyzed Condition2024-06-20020 June 2024
Operation of the Residual Heat Removal Loops B and C Alternate Keep Fill Configuration Was Prohibited by Technical Specifications and Resulted in an Unanalyzed Condition
IR 05000440/20240112024-06-17017 June 2024
Fire Protection Team Inspection Report 05000440/2024011
ML24157A3782024-06-0606 June 2024
– Revised Request for Information for NRC License Renewal Inspection: Inspection Report 05000440/2024010
ML24141A1632024-05-20020 May 2024
Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection
L-24-116, Response to License Renewal Environmental Report Severe Accident Mitigation Alternatives Requests for Additional Information and Request for Clarification2024-05-16016 May 2024
Response to License Renewal Environmental Report Severe Accident Mitigation Alternatives Requests for Additional Information and Request for Clarification
L-24-085, Nudear Power Plant, Submittal of Emergency Plan, Revision 622024-05-0606 May 2024
Nudear Power Plant, Submittal of Emergency Plan, Revision 62
L-24-103, Response to NRC Regulatory Issue Summary 2024-01, Preparation & Scheduling of Operator Licensing Exams2024-05-0202 May 2024
Response to NRC Regulatory Issue Summary 2024-01, Preparation & Scheduling of Operator Licensing Exams
ML24117A1222024-04-26026 April 2024
Confirmation of Initial License Examination
IR 05000440/20240012024-04-24024 April 2024
Integrated Inspection Report 05000440/2024001
L-24-096, Submittal of Annual Radiological Environmental Operating Report2024-04-22022 April 2024
Submittal of Annual Radiological Environmental Operating Report
L-24-097, Submittal of 2023 Annual Radiological Effluent Release Report2024-04-22022 April 2024
Submittal of 2023 Annual Radiological Effluent Release Report
ML24095A3282024-04-19019 April 2024
License Renewal Revised Schedule Letter
L-24-083, Response to License Renewal Environmental Report Requests for Additional Information and Request for Clarification2024-04-15015 April 2024
Response to License Renewal Environmental Report Requests for Additional Information and Request for Clarification
L-24-066, Response to Request for Additional Information Regarding 10 CFR 50.55a Request Number VR-9, Feedwater Check Valve Exercising Test Frequency2024-04-15015 April 2024
Response to Request for Additional Information Regarding 10 CFR 50.55a Request Number VR-9, Feedwater Check Valve Exercising Test Frequency
2024-09-09
[Table view]
Category:Notice of Violation
MONTHYEARIR 05000440/20170102017-08-24024 August 2017
EA-17-043 Perry Nuclear Power Plant - Final Significance Determination of a White Finding and Notice of Violation; NRC Inspection Report 05000440/2017010 and Assessment Follow-Up Letter
ML15341A0992015-12-0404 December 2015
IR 05000440/2015010, August 27, 2015 Through November 23, 2015, Perry Nuclear Power Plant Routine Baseline Inspection
IR 05000440/20110142011-08-25025 August 2011
EA-11-148, Perry Nuclear Power Plant, Final Significance Determination of White Finding with Assessment Followup and Notice of Violation, NRC Inspection Report No. 05000440-11-014
IR 05000440/20100082010-07-30030 July 2010
IR 05000440-10-008 and Notice of Violation on 07/16/10 for Perry Nuclear Power Plant, Unit 1
IR 05000440/20050072005-03-29029 March 2005
EA-04-214, Perry Nuclear Power Plant, Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report No. 05000440-05-007(DRS))
ML0505600262005-02-24024 February 2005
EA-01-082; EA-04-172, Williams Power, Notice of Violation
ML0409701602004-04-0101 April 2004
EA-03-208, Perry, Notice of Violation
IR 05000440/20040062004-03-12012 March 2004
EA-04-020, Perry Nuclear Power Plant, Notice of Violation for IR 05000440-04-006
IR 05000440/20040052004-01-28028 January 2004
Final Significance Determination for a White Finding - NRC IR 05000440-04-005)
IR 05000440/20040032004-01-23023 January 2004
Re Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report No. 05000440-04-03)
IR 05000440/20020082003-03-0404 March 2003
Final Significance Determination for a White Finding and Notice of Violation (IR 05000440-02-008)
ML0233706952002-11-27027 November 2002
IA-02-052, Mcgrath, Notice of Violation Perry, Unit 1 Fire Alarm on 04/16/2002
2017-08-24
[Table view]
Category:Enforcement Action
MONTHYEARIA-22-029, Results of NRC Investigation Report No. 3-2021-0072022-09-0202 September 2022
Results of NRC Investigation Report No. 3-2021-007
IR 05000440/20170092017-06-0505 June 2017
NRC Inspection Report 05000440/2017009 and Preliminary White Finding
IR 05000440/20124072012-10-25025 October 2012
IR 05000440-12-407; 09/10/2012 - 09/14/2012, Perry Nuclear Power Plant; Supplemental Inspection - Inspection Procedure 95001 - Cover Letter Only
IR 05000440/20110142011-08-25025 August 2011
EA-11-148, Perry Nuclear Power Plant, Final Significance Determination of White Finding with Assessment Followup and Notice of Violation, NRC Inspection Report No. 05000440-11-014
ML11230A0562011-08-18018 August 2011
EN-11-027, Perry Nuclear Power Plant, Issuance of Final Significance Determination and Notice of Violation, (EA-11-148)
IR 05000440/20050072005-03-29029 March 2005
EA-04-214, Perry Nuclear Power Plant, Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report No. 05000440-05-007(DRS))
2022-09-02
[Table view] |
Inspection Report - Perry - 2011014 |
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Text
August 25, 2011
SUBJECT:
FINAL SIGNIFICANCE DETERMINATION OF WHITE FINDING WITH ASSESSMENT FOLLOWUP AND NOTICE OF VIOLATION; NRC INSPECTION REPORT NO. 05000440/2011014 PERRY NUCLEAR POWER PLANT
Dear Mr. Bezilla:
This letter provides you the final significance determination of the preliminary White finding as discussed in our previous communication dated June 30, 2011, which included U.S. Nuclear Regulatory Commission (NRC) Inspection Report No. 05000440/2011013. The finding involved your staffs radiological performance associated with the retraction of a stuck source range monitor from the reactor vessel.
In a letter dated August 1, 2011, you provided a response to the NRC staff preliminary determination regarding the finding. Your response indicated that FirstEnergy Nuclear Operating Company did not contest the facts and assumptions used by the NRC to arrive at the finding and its significance. Your letter further described the corrective actions being taken in response to the finding.
After considering the information developed during the inspection and based on the absence of any new or additional information in your August 1, 2011, letter regarding the basis for the finding, the NRC has concluded that the finding is appropriately characterized as White, a finding of low to moderate risk significance. According to NRC Inspection Manual Chapter (IMC) 0609, appeal rights only apply to those licensees that have either attended a Regulatory Conference or submitted a written response to the preliminary determination letter.
The NRC has also determined that violations were associated with the White finding, as cited in the enclosed Notice of Violation (Notice). The circumstances surrounding the violations were described in detail in NRC Inspection Report No. 05000440/2011013. In accordance with the NRC Enforcement Policy, the Notice is considered escalated enforcement action because it is associated with a White finding. The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to be taken to correct the violations and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. 05000440/2011013 and in your letter dated August 1, 2011.
Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
As a result of our review of Perrys performance, including this White finding and the existing White performance indicator in the Occupational Radiation Safety Cornerstone, we have assessed Perry to be in the Degraded Cornerstone column (Column 3) of the NRCs Action Matrix. Therefore, we plan to conduct a supplemental inspection using Inspection Procedure 95002, Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic Performance Area, when your staff has notified us of your readiness for this inspection. This inspection procedure is conducted to provide assurance that the root cause and contributing causes of risk significant performance issues are understood, to independently assess and provide assurance that the extent of condition and the extent of cause are identified, to independently determine if safety culture components caused or significantly contributed the performance issues, and to provide assurance that your corrective actions are sufficient to address the root and contributing causes and prevent recurrence.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC=s Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. The NRC also includes significant enforcement actions on its Web site at http://www.nrc.gov/reading-rm/doc-collections/
enforcement/actions.
Sincerely,
/RA/
Mark A. Satorius Regional Administrator Docket No. 050-00440 License No. NPF-58 Enclosure:
Notice of Violation cc w/encl: Distribution via ListServ
NOTICE OF VIOLATION FirstEnergy Nuclear Operating Company Docket No. 050-00440 Perry Nuclear Power Plant License No. NPF-58 EA-11-148 During a U.S. Nuclear Regulatory Commission (NRC) special inspection conducted from April 25 to May 25, 2011, violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below:
A. Title 10 of the Code of Federal Regulations (10 CFR) Part 20 Subpart F - Surveys and Monitoring Section 20.1501 requires, in part, that licensees make surveys that may be necessary to comply with the regulations in Part 20 and are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels and the potential radiological hazards. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal or presence of radioactive material or other sources of radiation.
Contrary to the above, as of April 21, 2011, the licensee failed to make surveys to evaluate the potential radiological hazards incident to work activity to assure compliance with 10 CFR 20.1201, which limits the occupational dose to individual adults.
Specifically, the licensee did not perform an evaluation of the potential radiological hazards associated with the work activity prior to authorizing removal of an irradiated in-core source range monitor (SRM).
B. Technical Specification 5.7.1.b states, in part, that entry into high and locked high radiation areas be made after the dose rate levels in the area have been established and personnel are made aware of them.
Contrary to the above, on April 21, 2011, the licensee permitted entry into a high radiation area without establishing the dose rate levels in the area and without personnel being made aware of the dose rates. Specifically, the licensee did not perform a complete radiological characterization of the SRM (a radiological source of unknown magnitude), which was being pulled toward the work area and toward the workers escape path. Consequently, the licensee did not inform the workers of the potential dose rate levels associated with their entry into the high radiation area.
C. Technical Specification 5.4.1 requires that written procedures be established, implemented, and maintained covering the activities in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A Section 7 addresses, in part, procedures for control of radioactivity for limiting personnel exposure. Section 7.e(1) addresses procedures for access control to radiation areas including a radiation work permits system and Section 7.e(9) addresses procedures for implementation of an as low as is reasonably achievable (ALARA) program.
ENCLOSURE
Notice of Violation -2-The licensee established Procedure HPI-C0015, Revision 00, Radiological Controls for Highly Radioactive and Irradiated Components or Materials, to control highly radioactive objects and materials removed from the reactor vessel.
The licensee established Procedure NOP-OP-4107, Revision 05, Radiation Work Permit, in part, for implementation of an ALARA program. Step 4.3.2.3 of this procedure states, in part, that ALARA plans are developed with sufficient detail on what requirements, considerations and actions are to be ALARA for the work activity.
Contrary to the above, as of April 21, 2011, the licensee:
a. Failed to establish a procedure that addressed access control to all radiation areas. Specifically, Procedure HPI-C0015 only addressed work activities on the refueling floor and did not address access control to the undervessel radiation area or control of highly radioactive objects and materials removed from the reactor vessel through the undervessel area.
b. Failed to implement Procedure NOP-OP-4107, in that the ALARA plan for work on the SRM lacked sufficient detail about the requirements, consideration, and actions to ensure that the work activity was performed in an ALARA manner.
Specifically, the ALARA plan did not ensure that the work activity to retract the irradiated SRM-C contained steps to ensure that the ambient radiation field in the work area in the carousel and sub-pile room areas was being controlled and that the worker actions were in accordance with ALARA considerations.
These violations are associated with a White Significance Determination Process finding (VIO 0500440/2011014-01).
The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to be taken to correct the violations and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. 05000440/2011013 and in your letter dated August 1, 2011. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position.
In that case, or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation, EA-11-148, and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator and the Enforcement Officer, Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532, and a copy to the NRC Resident Inspector at the Perry facility within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
ENCLOSURE
Notice of Violation -3-If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.
Dated this 25th day of August 2011 ENCLOSURE
