IR 05000440/2013007: Difference between revisions

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{{Adams
{{Adams
| number = ML14003A186
| number = ML14246A151
| issue date = 01/03/2014
| issue date = 09/03/2014
| title = IR 05000440-13-007; 11/04/2013 - 11/22/2013; Perry Nuclear Power Plant; Biennial PI&R Inspection
| title = Perry Nuclear Power Plant - Revised Non-Cited Violation 05000440/2013007-01 in NRC PI&R Inspection Report 05000440/2013007
| author name = Kunowski M A
| author name = Boland A T
| author affiliation = NRC/RGN-III/DRP/B5
| author affiliation = NRC/RGN-III/DRP
| addressee name = Harkness E
| addressee name = Harkness E
| addressee affiliation = FirstEnergy Nuclear Operating Co
| addressee affiliation = FirstEnergy Nuclear Operating Co
Line 10: Line 10:
| license number = NPF-058
| license number = NPF-058
| contact person =  
| contact person =  
| case reference number = EA-14-143
| document report number = IR-13-007
| document report number = IR-13-007
| document type = Inspection Report, Letter
| document type = Letter
| page count = 27
| page count = 4
}}
}}


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=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 September 3, 2014  
[[Issue date::January 3, 2014]]


Mr. Ernest Harkness Site Vice President
EA-14-143


FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-A290 Perry, OH 44081-0097
Mr. Ernest Harkness Site Vice-President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-290 Perry, OH 44081-0097


SUBJECT: PERRY NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2013007
SUBJECT: PERRY NUCLEAR POWER PLANT - REVISED NON-CITED VIOLATION 05000440/2013007-01 IN NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2013007


==Dear Mr. Harkness:==
==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. 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.
On January 3, 2014, the U.S. Nuclear Regulatory Commission (NRC) issued the subject inspection report following completion of a baseline problem identification and resolution (PI&R) team inspection. In this report, the NRC inspectors documented a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 3.4.11, "RCS Pressure and Temperature (P/T) Limits," for the failure to comply with reactor vessel pressure/minimum temperature limits (NCV 05000440/2013007-01). Specifically, from June 2011 through July 2013, reactor operators operated the plant with a vacuum in the reactor vessel during 5 cold startups and 1 cooldown. Vessel pressures at a vacuum, i.e., less than 0 pounds per square inch gauge, are not indicated on the graphs (the pressure/temperature limit curves) associated with TS 3.4.11. The purposes of specifying the minimum temperatures at a bounding range of vessel pressures are to prevent brittle fracture (nonductile) failure of the vessel and to maintain adequate shutdown margin to criticality. As discussed in the inspection report, the NRC concluded, at the time, that the operation of the reactor in those 6 instances represented a violation of the TS. However, after further review, the NRC has concluded that a violation of TS 3.4.11 did not occur. The intent of the curves was to show the minimum temperatures which must be maintained at the pressures shown on the curves. These pressures range from 0 to 1400 pounds per square inch gauge. Because pressures less than 0 pounds per square inch gauge, i.e., a vacuum, are not shown, operation of the reactor in a vacuum on the 6 instances discussed in the inspection report did not represent a violation of the TS. However, those instances did represent operation outside of the parameters used in the analysis by your vendor (General Electric) to generate the pressure/temperature limit curves. This analysis is incorporated into the Facility Operating License No. NPF-58 by Amendment 127 issued by the NRC to Perry on April 29, 2003, and the curves are incorporated into TS 3.4.11. The analysis assumed reactor pressure of 0 pounds per square inch gauge or greater for startups, cooldowns, and power operation. Although we have now concluded that a violation of TS 3.4.11 did not occur during the 5 reactor cold startups and 1 cooldown discussed in the inspection report, we have concluded that the operation of the reactor outside of the parameters of the analysis involved a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings." Criterion V requires, in part, that activities affecting quality be prescribed by procedures appropriate to the circumstances. Startup and cooldown of the reactor are activities affecting quality and the instructions and procedures used by the operators for these activities, IOI-1, "Cold Startup"; IOI-4, "Shutdown"; and Surveillance Instruction (SVI-)B21-T1176, "RCS Heatup and Cooldown Surveillance," were not appropriate to the circumstances. Specifically, they allowed reactor vessel pressure during the 5 cold startups and 1 cooldown from June 2011 through July 2013 to be less than 0 pounds per square inch gauge, outside of the pressure parameter inputs to the analysis that is the basis for the pressure/temperature limit curves of TS 3.4.11.


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.
As part of the corrective action for the original TS NCV (in your corrective action program as


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).
Condition Report 2013-18689), you submitted a license amendment request, dated June 23, 2014, to revise the pressure/temperature curves to show pressures less than 0 pounds


Sincerely,/RA/ Michael A. Kunowski, Chief Branch 5 Division of Reactor Projects Docket No. 50-440 License No. NPF-58
per square inch gauge and the associated minimum temperatures. The NRC is treating the Criterion V violation as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. The cross-cutting aspect identified in NRC Inspection Report 05000440/2013007 for the previously documented NCV of TS 3.4.11 is appropriate to the Criterion V violation, as is our previous determination of very low safety significance (Green). In our letter dated August 5, 2014, we notified you that we have accepted your License Amendment Request for review. Further correspondence on this request will be through the established process for licensee amendment requests.


===Enclosure:===
If you contest the violation or significance of this revised NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the U.S. 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
Inspection Report 05000440/2013007


===w/Attachment:===
Inspector Office at Perry Nuclear Power Plant.
Supplemental Information


cc w/encl: Distribution via ListServ TM Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-440
If you disagree with the cross-cutting aspect assigned to this finding, you should provide a response within 30 days of the date of this letter, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Perry Nuclear Power Plant.


License No: NPF-58
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 and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Report No: 05000440/2013007
Sincerely,/RA/ Anne T. Boland, Director Division of Reactor Projects


Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Docket No. 50-440 License No. NPF-58


Facility: Perry Nuclear Power Plant
cc w/encl: Distribution via LISTSERV Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Location: Perry, OH
Sincerely,/RA/
Anne T. Boland, Director Division of Reactor Projects


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


Division of Reactor Projects
cc w/encl: Distribution via LISTSERV DISTRIBUTION w/encl
: John Jandovitz RidsNrrPMPerry Resource


1 Enclosure
RidsNrrDorlLpl3-2 Resource RidsNrrDirsIrib Resource Cynthia Pederson


=SUMMARY OF FINDINGS=
Darrell Roberts Steven Orth
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.
Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley


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.
Carmen Olteanu ROPassessment.Resource@nrc.gov


===NRC-Identified===
DOCUMENT NAME: Perry IR 2013007 Letter Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII NRR OE NAME MKunowski:rj SOrth ABoland DDorman 1 PHolahan 2 DATE 08/19/14 08/19/14 08/19/14 08/26/14 08/27/14 OFFICIAL RECORD COPY
and Self-Revealed Findings
______________________
 
1 NRR concurrene provided via email from L. Casey on August 26, 2014 2 OE concurrence provided via email from K. Hanley on August 27, 2014
===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 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)
 
=REPORT DETAILS=
 
==OTHER ACTIVITIES==
{{a|4OA2}}
==4OA2 Problem Identification and Resolution==
{{IP sample|IP=IP 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, in cluding 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, incl uding 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 whet her 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 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. Review ing 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 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 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) fo r 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 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 hours; on October 18, 2011, for more than 8 hours; on March 3, 2012, for more than 2 hours; on June 17, 2012, for more than 4 hours; 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 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.
 
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 instru ment 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 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 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
* 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.
 
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.
{{a|4OA6}}
==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=
 
==KEY POINTS OF CONTACT==
 
===Licensee Personnel===
: [[contact::E. Gordon]], Supervisor, Performance Improvement
: [[contact::B. Blair]], Manager - Maintenance
: [[contact::E. Harkness]], Site Vice President
: [[contact::D. Hamilton]], Director - Site Operations
: [[contact::N. Conicella]], Manager - Regulatory Compliance
: [[contact::L. Zerr]], Supervisor - Regulatory Compliance
: [[contact::J. Ellis]], Director - Recovery
: [[contact::V. Veglia]], Director - Maintenance
: [[contact::T. Veitch]], Manager - Regulatory Compliance
: [[contact::R. Coad]], Supervisor, Design Engineering
: [[contact::K. Coggins]], Maintenance
 
===NRC Personnel===
: [[contact::M. Kunowski]], Chief, Branch 5, Division of Reactor Projects
: [[contact::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
 
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
: NOP-OP-1012 Material Readiness And Housekeeping Inspection 
===Procedure===
: 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 
: 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 3 rd 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 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 1
st 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 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 1
st 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 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 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 
: 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-13-0 1 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
th Quarter 2011 Safety Culture Monitoring Panel May 8, 2012 May 8, 2012
: SN-SA-2012-0149 1
st 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 
: Attachment
: OE 2011-0986
: IN 2010-01 Pipe Support Anchors
: OE 2011-1187 Failures Of Moore 535 Digital Singl
e 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
: Attachment
==LIST OF ACRONYMS==
: [[USED]] [[]]
ACE  Apparent Cause Evaluation ADAMS Agencywide Documents A
ccess 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]]
: [[NCV]] [[, 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 ListServ
: [[TM]] [[]]
: [[DISTRI]] [[BUTION]]
: 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
: [[PL]] [[ougheed for MKunowski]]
: [[DATE]] [[01/02/14 01/02/14 01/03/14]]
: [[OFFICI]] [[AL]]
: [[RECORD]] [[]]
COPY  
 
Letter to Ernest Harkness from Michael Kunowski dated January 3, 2014
: [[SUBJEC]] [[T:]]
: [[PERRY]] [[]]
: [[NUCLEA]] [[R]]
: [[POWER]] [[]]
: [[STATIO]] [[N -]]
: [[NRC]] [[]]
: [[PROBLE]] [[M IDENTIFICATION]]
: [[AND]] [[]]
: [[RESOLU]] [[TION INSPECTION]]
: [[REPORT]] [[05000346/2013007]]
: [[DISTRI]] [[BUTION]]
: Brett Rini
RidsNrrPMPerry Resource
 
RidsNrrDorlLpl3-2 Resource
RidsNrrDirsIrib Resource Cynthia Pederson
 
Anne Boland
Steven Orth
 
Allan Barker
Carole Ariano Linda Linn
: [[DRPIII]] [[]]
: [[DRSIII]] [[Patricia Buckley Tammy Tomczak ROPreports.Resource@nrc.gov]]
}}
}}

Revision as of 20:45, 19 October 2018

Perry Nuclear Power Plant - Revised Non-Cited Violation 05000440/2013007-01 in NRC PI&R Inspection Report 05000440/2013007
ML14246A151
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 09/03/2014
From: Boland A T
Division Reactor Projects III
To: Harkness E
FirstEnergy Nuclear Operating Co
References
EA-14-143 IR-13-007
Download: ML14246A151 (4)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 September 3, 2014

EA-14-143

Mr. Ernest Harkness Site Vice-President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-290 Perry, OH 44081-0097

SUBJECT: PERRY NUCLEAR POWER PLANT - REVISED NON-CITED VIOLATION 05000440/2013007-01 IN NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2013007

Dear Mr. Harkness:

On January 3, 2014, the U.S. Nuclear Regulatory Commission (NRC) issued the subject inspection report following completion of a baseline problem identification and resolution (PI&R) team inspection. In this report, the NRC inspectors documented a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 3.4.11, "RCS Pressure and Temperature (P/T) Limits," for the failure to comply with reactor vessel pressure/minimum temperature limits (NCV 05000440/2013007-01). Specifically, from June 2011 through July 2013, reactor operators operated the plant with a vacuum in the reactor vessel during 5 cold startups and 1 cooldown. Vessel pressures at a vacuum, i.e., less than 0 pounds per square inch gauge, are not indicated on the graphs (the pressure/temperature limit curves) associated with TS 3.4.11. The purposes of specifying the minimum temperatures at a bounding range of vessel pressures are to prevent brittle fracture (nonductile) failure of the vessel and to maintain adequate shutdown margin to criticality. As discussed in the inspection report, the NRC concluded, at the time, that the operation of the reactor in those 6 instances represented a violation of the TS. However, after further review, the NRC has concluded that a violation of TS 3.4.11 did not occur. The intent of the curves was to show the minimum temperatures which must be maintained at the pressures shown on the curves. These pressures range from 0 to 1400 pounds per square inch gauge. Because pressures less than 0 pounds per square inch gauge, i.e., a vacuum, are not shown, operation of the reactor in a vacuum on the 6 instances discussed in the inspection report did not represent a violation of the TS. However, those instances did represent operation outside of the parameters used in the analysis by your vendor (General Electric) to generate the pressure/temperature limit curves. This analysis is incorporated into the Facility Operating License No. NPF-58 by Amendment 127 issued by the NRC to Perry on April 29, 2003, and the curves are incorporated into TS 3.4.11. The analysis assumed reactor pressure of 0 pounds per square inch gauge or greater for startups, cooldowns, and power operation. Although we have now concluded that a violation of TS 3.4.11 did not occur during the 5 reactor cold startups and 1 cooldown discussed in the inspection report, we have concluded that the operation of the reactor outside of the parameters of the analysis involved a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings." Criterion V requires, in part, that activities affecting quality be prescribed by procedures appropriate to the circumstances. Startup and cooldown of the reactor are activities affecting quality and the instructions and procedures used by the operators for these activities, IOI-1, "Cold Startup"; IOI-4, "Shutdown"; and Surveillance Instruction (SVI-)B21-T1176, "RCS Heatup and Cooldown Surveillance," were not appropriate to the circumstances. Specifically, they allowed reactor vessel pressure during the 5 cold startups and 1 cooldown from June 2011 through July 2013 to be less than 0 pounds per square inch gauge, outside of the pressure parameter inputs to the analysis that is the basis for the pressure/temperature limit curves of TS 3.4.11.

As part of the corrective action for the original TS NCV (in your corrective action program as

Condition Report 2013-18689), you submitted a license amendment request, dated June 23, 2014, to revise the pressure/temperature curves to show pressures less than 0 pounds

per square inch gauge and the associated minimum temperatures. The NRC is treating the Criterion V violation as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. The cross-cutting aspect identified in NRC Inspection Report 05000440/2013007 for the previously documented NCV of TS 3.4.11 is appropriate to the Criterion V violation, as is our previous determination of very low safety significance (Green). In our letter dated August 5, 2014, we notified you that we have accepted your License Amendment Request for review. Further correspondence on this request will be through the established process for licensee amendment requests.

If you contest the violation or significance of this revised NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the U.S. 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 Office at Perry Nuclear Power Plant.

If you disagree with the cross-cutting aspect assigned to this finding, you should provide a response within 30 days of the date of this letter, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at 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 and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Anne T. Boland, Director Division of Reactor Projects

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

cc w/encl: Distribution via LISTSERV Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Anne T. Boland, Director Division of Reactor Projects

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

cc w/encl: Distribution via LISTSERV DISTRIBUTION w/encl

John Jandovitz RidsNrrPMPerry Resource

RidsNrrDorlLpl3-2 Resource RidsNrrDirsIrib Resource Cynthia Pederson

Darrell Roberts Steven Orth

Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley

Carmen Olteanu ROPassessment.Resource@nrc.gov

DOCUMENT NAME: Perry IR 2013007 Letter Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII NRR OE NAME MKunowski:rj SOrth ABoland DDorman 1 PHolahan 2 DATE 08/19/14 08/19/14 08/19/14 08/26/14 08/27/14 OFFICIAL RECORD COPY

______________________

1 NRR concurrene provided via email from L. Casey on August 26, 2014 2 OE concurrence provided via email from K. Hanley on August 27, 2014

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