ML13246A237

2013 Perry Nuclear Power Plant Mid-Cycle Letter Combined

ML13246A237
Person / Time
Site:	Perry
Issue date:	09/03/2013
From:	Pederson C Region 3 Administrator
To:	Harkness E FirstEnergy Nuclear Operating Co
References
IR-13-006
Download: ML13246A237 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532

-4352 September 3, 2013

Mr. Ernest Harkness Site Vice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A

-PY-A290 Perry, OH 44081

-0097

SUBJECT:

MID-CYCLE ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT (REPORT 0500440/2013006

)

Dear Mr. H arkness:

On August 13, 2013, the U.S. Nuclear Regulatory Commission (NR C) completed its mid

-cycle performance review of the Perry Nuclear Power Plant. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions from July 1, 20 12 , through June 30, 20 13. This letter informs you of the NRC's assessment of your facility during this period and its plans for future inspections at your facility.

The NRC determined the performance at Perry during the most recent quarter, ending June 30, 2013, was within the Degraded Cornerstone Column (Column 3) of the NRC's Reactor Oversight Process (ROP) Action Matrix because of a low-to-moderate safety significance (i.e., White) held-open inspection finding and Notice of Violation (NOV), a Yellow Occupational Exposure Control Effectiveness PI, and a parallel White PI inspection finding, all of which affected the Occupational Radiation Safety Cornerstone.

Work management performance at Perry has remained steady over the assessment period with some challenges caused by human performance problems. During the refueling outage in March and April 2013, NRC inspectors identified human performance deficiencies, indicatin g that additional effort is needed to engrain expected behaviors when the organization is conducting infrequently performed tasks or schedule pressure exists. Of note were two valve mispositionings that resulted in NRC findings of very low safety significance (Green). The NRC also noted that your staff ma de a conservative decision to shut down the reactor when E. Harkness leakage increased in the drywell after the refueling outage was completed. Several unexpected maintenance issues and equipment repairs arose during th e shutdown and the performance of your staff in addressing those issues was considered good. On August 12, 2013, the NRC issued 95002 Supplemental Inspection Report and Assessment Follow-up Letter (ML13224A382) that closed the held

-open White inspection finding and NOV, and the parallel White PI inspection finding. Also, the Occupational Exposure Control Effectiveness PI returned from Yellow to Green in the second quarter of 2013. As a result, the NRC assessed the performance at Perry to be in the Licensee Response Column (Column 1) of the ROP Action Matrix as of August 12, 2013.

Our August 12, 2013 inspection report discusses that continued management attention and focus is needed to address lower level, less risk significant issues in the radiation protection area, radiological work coordination among all site departments, and continued emphasis that the issues in the radiation protection area are not restricted to the radiation protection department but apply to radiation workers in the other Perry departments. Included in these lower level issues that affect other departments are procedure use and adherence and procedure quality. In a letter dated January 17, 2013, a deviation from the R OP Action Matrix was approved by the Executive Director for Operations. Because of two White inspection findings in the occupational radiation safety area and one o r more Greater

-than-Green inspection findings in the security area, Perry met the criteria for a Repetitive Degraded Cornerstone (Column 4) of the Action Matrix. However, because the performance issues were well understood and appeared limited to occupational radiation safety, the NRC considered the regulatory actions specified for Column 3 were more appropriate tha n those for Column 4.

With satisfactory completion of the inspection procedure 95002 inspection, documented in the August 12, 2013 , inspection report, this deviation is no longer in effect.

Based on this assessment, we plan to conduct ROP baseline inspections at your facility.

However, the radiation protection baseline inspections will focus on those radiation protection issues identified above and the biennial Problem Identification and Resolution team inspection will review your corrective actions for your extent of cause evaluations completed in response to the White findings. The enclosed inspection plan lists the inspections scheduled through December 31, 20 1 4. Routine inspections performed by resident inspectors are not included in the inspection plan.

The inspections listed during the last nine months of the inspection plan are tentative and may be revised at the end

-of-cycle performance review. The NRC provides the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes.

This inspection plan does not include security related inspections, which will be sent via separate, non

-publicly available correspondence.

E. Harkness In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records 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).

Please contact Mr. Michael Kunowski, Branch 5 Chief, Division of Reactor Projects, at 630-829-9618 , with any questions you may have regarding this letter or the inspection plan.

Sincerely, /RA/

Cynthia D. Pederson Re gional Ad minist r a t o r Docket No. 50

-440 License No. NPF

-58 E nc losu r e: P e rr y N uc l ear P o w er Plant Inspe c t i on/A c t i v i t y Pl a n cc w/enc l: Di s tr i bu t i on v i a L i s t S e r vŽ E. Harkness In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records 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).

Please contact Mr. Michael Kunowski, Branch 5 Chief, Division of Reactor Projects, at 630-829-9618 , with any questions you may have regarding this letter or the inspection plan.

Sincerely, /RA/

Cynthia D. Pederson Re gional Ad minist r a t o r Docket No. 50

-440 License No. NPF

-58 E nc losu r e: P e rr y N uc l ear P o w er Plant Inspe c t i on/A c t i v i t y Pl a n cc w/enc l: Di s tr i bu t i on v i a L i s t S e r vŽ DISTRIBUTION

See next page DOCUMENT NAME: PERRY MOC 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 RIII NAME MKunowski:sb/rj KO'Brien CPederson DATE 08/29/13 08/29/13 08/29/13 OFFICIAL RECORD COPY

Letter to E. Harkness from C. Pederson dated September 3, 2013

SUBJECT:

MID-CYCLE ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT (REPORT 0500440/2013006

) DISTRIBUTION

Vivian Campbell 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 ROPassessment.Resource@nrc.gov

Page 1 of 2 08/26/2013 07:15:01 Report 22 Unit NumberPlanned Dates Start EndInspection ActivityTitle No. of Staff on Site PerryInspection / Activity Plan 09/01/2013

-12/31/2014 BI EPR-EP ROUTINE INSPECTION / PI VERIFICATION 2 1 IP A lert and Notification System Testing7111402 09/16/2013 09/20/2013 1 IP Emergency Preparedness Organization Staffing and Augmentation System7111403 09/16/2013 09/20/2013 1 IP Correction of Emergency Preparedness Weaknesses and Deficiencies7111405 09/16/2013 09/20/2013 1 IP Performance Indicator Verification71151 09/16/2013 09/20/2013 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radiological Environmental Monitoring Program71124.07 09/23/2013 09/27/2013 BI PI&R-BIENNIAL PI&R INSPECTION 5 1 IP Problem Identification and Resolution71152B11/04/201311/22/2013 BI RP-RADIATION PROTECTION BASELINE INSPECTION 2 1 IP Radiation Monitoring Instrumentation71124.05 10/28/201311/01/2013 1 IP Radioactive Gaseous and Liquid Effluent Treatment71124.06 10/28/201311/01/2013 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP In-Plant Airborne Radioactivity Control and Mitigation71124.0311/18/201311/22/2013 1 IP Occupational Dose Assessment71124.0411/18/201311/22/2013 1 IPReactor Coolant System Activity71151-BI0111/18/201311/22/2013 1 IPOccupational Exposure Control Effectiveness71151-OR0111/18/201311/22/2013 1 IPRETS/ODCM Radiological Effluent71151-PR0111/18/201311/22/2013 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP In-Plant Airborne Radioactivity Control and Mitigation71124.03 01/13/2014 01/17/2014 1 IP Occupational Dose Assessment71124.04 01/13/2014 01/17/2014 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radiological Hazard Assessment and Exposure Controls71124.01 02/10/2014 02/14/2014 BI ENG-COMPONENT DESIGN BASIS INSPECTION 6 1 IP Component Design Bases Inspection7111121 03/03/2014 04/04/2014 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radiation Monitoring Instrumentation71124.05 05/05/2014 05/09/2014 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Occupational ALARA Planning and Controls71124.02 06/16/2014 06/20/2014 1 IPReactor Coolant System Activity71151-BI01 06/16/2014 06/20/2014 1 IPOccupational Exposure Control Effectiveness71151-OR01 06/16/2014 06/20/2014 1 IPRETS/ODCM Radiological Effluent71151-PR01 06/16/2014 06/20/2014 This report does not include INPO and OUTAGE activities. This report shows only on-site and announced inspection procedures.

Page 2 of 2 08/26/2013 07:15:01 Report 22 Unit NumberPlanned Dates Start EndInspection ActivityTitle No. of Staff on Site PerryInspection / Activity Plan 09/01/2013

-12/31/2014 BI EPX-EP EXERCISE INSPECTION / PI VERIFICATION 2 1 IP Performance Indicator Verification71151 09/22/2014 09/26/2014 ISFSI-ISFSI OPERATION AT REACTOR SITE 1 1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 10/01/2014 10/31/2014 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation71124.08 10/20/2014 10/24/2014 BI OLRQ-BIENNIAL REQUAL PROGRAM INSPECTION 2 1 IP Licensed Operator Requalification Program7111111B 12/15/2014 12/19/2014 This report does not include INPO and OUTAGE activities. This report shows only on-site and announced inspection procedures.