ML12065A157

Annual Assessment Letter for Perry Nuclear Power Plant (Report 05000440/2011007)

ML12065A157
Person / Time
Site:	Perry
Issue date:	03/05/2012
From:	Pederson C Region 3 Administrator
To:	Emily Larson FirstEnergy Nuclear Operating Co
References
IR-11-007
Download: ML12065A157 (7)

See also: IR 05000440/2011007

Text

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

March 5, 2012

Mr. Eric Larson Acting 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: ANNUAL ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT (REPORT 05000440/2011007) Dear Mr. Larson: On February 15, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff completed its end-of-cycle performance review of Perry Nuclear Power Plant. The NRC reviewed the most recent quarterly performance indicators (PIs) in addition to inspection results and enforcement actions for the period from January 1, 2011, through December 31, 2011. This letter informs

you of the NRC's assessment of your facility during this period and its plans for future

inspections at your facility. This performance review and enclosed inspection plan does not

include security information. A separate letter will include the NRC's assessment of your performance in the Security Cornerstone and its security-related inspection plan.

The NRC determined that the performance at the Perry Nuclear Power Plant during the most

recent quarter was within the Degraded Cornerstone Column of the NRC's Reactor Oversight

Process (ROP) Action Matrix because of one finding having a low-to-moderate safety significance (i.e., White) from the second quarter of 2011 and a White Occupational Exposure Control Effectiveness Performance Indicator (PI) with four occurrences (the threshold for Green-to-White is more than 2 occurrences) during the second and third

quarters of 2011. The finding and the performance indicator were both in the Occupational

Radiation Safety Cornerstone. One of the PI occurrences was in November 2010 and,

therefore, no longer counted in the fourth quarter 2011. Additionally, one of the remaining three

PI occurrences from the second quarter of 2011 had the same underlying cause as the White finding (a situation which could result in double counting the PI and the finding as White). Therefore, for the fourth quarter of 2011, in accordance with the guidance in Section 11.03 of

Inspection Manual Chapter 0305, "Operating Reactor Assessment Program," the White PI is not

considered an Action Matrix input. Despite having only the single White finding as an input to

the Action Matrix, Perry will remain in the Degraded Cornerstone Column of the ROP until a supplemental inspection in accordance with Inspection Procedure (IP) 95002, "Supplemental Inspection for One Degraded Cornerstone or Any Three White Inputs in a Strategic

Performance Area" is completed. We will schedule and conduct the inspection after you have

completed your investigation on the reasons for the White performance indicator and White

E. Larson - 2 -

finding in the same cornerstone, and after you have advised us, in writing, that you are ready for the inspection. This supplemental inspection is in addition to ROP baseline inspections at your

facility.

Performance at the Perry Nuclear Power Plant during the assessment period continued to

exhibit weaknesses in the area of human performance (HP) with 12 findings identified. This assessment period is the ninth consecutive assessment period identifying a substantive cross-cutting issue in the HP cross-cutting area. In our mid-cycle assessment letter

[ADAMS ML112440084] dated September 1, 2011, we advised you of substantive cross-cutting issues (SCCIs) in the HP area with cross-cutting themes in Work Planning, H.3(a), and

Documentation/Procedures, H.2(c). In addition, we advised you that the HP SCCIs would remain open until the number of findings in the H.3(a) and H.2(c) aspects were reduced and you demonstrated the implementation of effective corrective actions that resulted in sustained performance improvement in the HP area.

Regarding H.3 (a), at the time of the mid-cycle assessment, this SCCI was open for eight consecutive assessment periods. We performed an inspection [ADAMS ML120190153] in December 2011, and determined your corrective actions on this SCCI had been successful in

reducing the findings and addressing the underlying causes. There were no findings in this

aspect during this assessment cycle and there has been sustained performance improvement. For this reason, the SCCI in Work Planning, H.3(a), is closed.

During the same inspection performed in December 2011, regarding the SCCI in H.2(c), evaluations and actions had not been completed to

allow NRC review. Your staff informed us that your facility was ready for the inspection in December; however, we determined while

onsite that several key evaluations were not completed. We concluded the site was not ready

for us to inspect your actions in regards to this SCCI. To date, the actions implemented by your staff have not resulted in sustained performance improvement in this aspect. Specifically, three inspection findings were identified with this aspect as the most significant contributing cause.

As a result, the H.2(c) SCCI will remain open.

During this assessment period, the NRC staff identified a new SCCI in the HP area in the

aspect of Conservative Assumptions, H.1(b). There were four findings during this assessment cycle which identified this aspect as the most significant contributing cause. At the close of

2011, your staff was performing a cause evaluation and the actions taken had not yet proven you were effective at mitigating the theme.

Therefore, the NRC is opening an SCCI in

Conservative Assumptions, H.1(b).

The SCCIs in H.1(b) and H2(c) will remain open until the number of findings in the H.1(b) and H.2(c) aspects are reduced and you demonstrate the implementation of effective corrective actions that result in sustained performance improvement in each of these aspects of HP. Although we noted some improvement in specific areas of HP during this assessment cycle, concerns with the SCCIs identified by this letter continue to exist. Because we were not able to

inspect these SCCIs at the end of 2011 [since you had not completed your actions], we are asking you to provide to us within 30 days of this letter, in writing, the causes and corrective action planned and completed for the two SCCIs addressed in this letter. The plan should

provide projected dates for actions, and you s

hould provide any metrics you are using to determine whether sustained improvement has been achieved. In addition, you should be

E. Larson - 3 -

prepared to discuss these actions at the end-of-cycle assessment meeting. Based on the level of progress demonstrated at the end-of-cycle meeting, we will determine if additional meetings

are needed.

The enclosed inspection plan lists the inspections scheduled through June 30, 2013.

Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last 9 months of the inspection plan are tentative and may be revised at the mid-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.

In addition to the ROP baseline and IP 95002 inspections, inspections are planned for

Temporary Instruction (TI) 2515/177, "Managing Gas Accumulation in Emergency Core Cooling,

Decay Heat Removal, and Containment Spray Systems"; TI 2515/182, "Buried Piping and

Tanks"; TI 2515/185, "Follow-up of NEI Groundwater Protection Initiative"; and Independent Spent Fuel Storage Installation (ISFSI) inspections: IP 60854.1, "Preoperational Testing of ISFSIs at Operating Plants"; IP 60855.1, "Operation of an ISFSI at Operating Plants"; and

IP 60856.1, "Review of 10 CFR 72.212(b) Evaluations at Operating Plants."

In accordance with 10 CFR 2.390 of the NRC

=s A Rules of Practice,@ a copy of this letter will be

available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Please contact John B. Giessner at 630-829-9619 with any questions you have regarding this

letter.

Sincerely, /RA/

Cynthia D. Pederson

Acting Regional Administrator

Docket No. 50-440

License No. NPF-58

Enclosure: Perry Nuclear Power Plant Inspection/Activity Plan

cc w/encl: Distribution via ListServ

E. Larson - 3 -

prepared to discuss these actions at the end-of-cycle assessment meeting. Based on the level of progress demonstrated at the end-of-cycle meeting, we will determine if additional meetings

are needed.

The enclosed inspection plan lists the inspections scheduled through June 30, 2013.

Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last 9 months of the inspection plan are tentative and may be revised at the mid-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.

In addition to the ROP baseline and IP 95002 inspections, inspections are planned for

Temporary Instruction (TI) 2515/177, "Managing Gas Accumulation in Emergency Core Cooling,

Decay Heat Removal, and Containment Spray Systems"; TI 2515/182, "Buried Piping and

Tanks"; TI 2515/185, "Follow-up of NEI Groundwater Protection Initiative"; and Independent Spent Fuel Storage Installation (ISFSI) inspections: IP 60854.1, "Preoperational Testing of ISFSIs at Operating Plants"; IP 60855.1, "Operation of an ISFSI at Operating Plants"; and

IP 60856.1, "Review of 10 CFR 72.212(b) Evaluations at Operating Plants."

In accordance with 10 CFR 2.390 of the NRC

=s A Rules of Practice,@ a copy of this letter will be

available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Please contact John B. Giessner at 630-829-9619 with any questions you have regarding this

letter.

Sincerely, /RA/ Cynthia D. Pederson

Acting Regional Administrator

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

Enclosure: Perry Nuclear Power Plant Inspection/Activity Plan

cc w/encl: Distribution via ListServ DOCUMENT NAME: G:\DRPIII\1-Secy\1-Work In Progress\2012 EOC Letters\Perry 2011 EOC Letter.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in th

e concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII RIII

NAME JGiessner:dtp

GShear for SWest CPederson

DATE 02/27/12 03/02/12 03/0212

OFFICIAL RECORD COPY

Letter to E. Larson from C. Pederson dated March 5, 2012.

SUBJECT: ANNUAL ASSESSMENT LETTER FOR PERRY NUCLEAR POWER PLANT 05000440/2011007 DISTRIBUTION

Breeda Reilly

RidsNrrPMPerry Resource

RidsNrrDorlLpI3-2 Resource

RidsNrrDirsIrib Resource

Charles Casto Cynthia Pederson

Jennifer Uhle

Steven Orth

Jared Heck

Allan Barker

Carole Ariano Linda Linn

DRPIII

DRSIII

Patricia Buckley Tammy Tomczak ROPassessment.Resource@nrc.gov

Page 1 of 2

Planned Dates

Start End

Inspection Activity

Title No. of Staff

on Site Perry Inspection / Activity Plan

01/01/2012

-06/30/2013

ISFSI-ISFSI INSPECTION - SCHEDULE DEPENDENT

2 IP Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants

60854.1 01/01/2012

05/31/2012

BI PI&R-BIENNIAL PI&R INSPECTION

4 IP Problem Identification and Resolution

71152B 01/09/2012

01/27/2012

BI HS-TRIENNIAL HEAT SINK INSPECTION

2 IP Heat Sink Performance

7111107T 02/27/2012

03/02/2012

BI FIRE-FIRE PROTECTION INSPECTION & BAG TRIP

3 IP Fire Protection [Triennial]

7111105T 03/12/2012

04/13/2012

BI RP-RADIATION PROTECTION BASELINE INSPECTION

2 IP Occupational ALARA Planning and Controls

71124.02 03/26/2012

03/30/2012

IP Radiation Monitoring Instrumentation

71124.05 03/26/2012

03/30/2012

IP Occupational Exposure Control Effectiveness

71151-OR01

03/26/2012

03/30/2012

BI RP-RADIATION PROTECTION BASELINE INSPECTION

1 IP Occupational Dose Assessment

71124.04 05/07/2012

05/11/2012

IP Reactor Coolant System Activity

71151-BI01

05/07/2012

05/11/2012

IP RETS/ODCM Radiological Effluent

71151-PR01

05/07/2012

05/11/2012

ISFSI-ISFSI INSPECTION - SCHEDULE DEPENDENT

2 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants

60855.1 06/01/2012

11/30/2012

TI-182-TI-2515/182 PHASE I - BURIED PIPING

1 IP Review of the Implementation of the Industry Initiative to Control Degradation of Underground Piping

2515/182 06/11/2012

06/15/2012

BI RP-RADIATION PROTECTION BASELINE INSPECTION

2 IP Radiological Hazard Assessment and Exposure Controls

71124.01 08/20/2012

08/24/2012

IP Radiation Monitoring Instrumentation

71124.05 08/20/2012

08/24/2012

BI RP-RADIATION PROTECTION BASELINE INSPECTION

1 IP Follow-up on the Industry's Ground Water Protection Initiative

2515/185 09/17/2012

09/21/2012

IP Radioactive Gaseous and Liquid Effluent Treatment

71124.06 09/17/2012

09/21/2012

TI-177-TEMPORARY INSTRUCTION 2515/177

1 IP Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal & Containment Spray System

2515/177 09/17/2012

10/05/2012

BI EPX-EP EXERCISE INSPECTION / PI VERIFICATION

2 IP Exercise Evaluation

7111401 10/01/2012

10/05/2012

IP Performance Indicator Verification

71151 10/01/2012

10/05/2012

BI OLRQ-BIENNIAL REQUAL PROGRAM INSPECTION

2 IP Licensed Operator Requalification Program

7111111B 12/10/2012

12/14/2012

Page 2 of 2

Planned Dates

Start End

Inspection Activity

Title No. of Staff

on Site Perry Inspection / Activity Plan

01/01/2012

-06/30/2013

OL PREP-PERRY INIT PREP 02/2013

3 OL - INITIAL EXAM - 2013 FEB-MAR - PERRY

W90290 02/04/2013

02/08/2013

BI ISI-INSERVICE INSPECTION

1 IP Inservice Inspection Activities - BWR

7111108G 02/18/2013

03/31/2013

BI RP-RADIATION PROTECTION BASELINE INSPECTION

1 IP Radiological Hazard Assessment and Exposure Controls

71124.01 02/25/2013

03/01/2013

OL EXAM-PERRY INIT EXAM 02/2013

3 OL - INITIAL EXAM - 2013 FEB-MAR - PERRY

W90290 02/25/2013

03/08/2013

BI RP-RADIATION PROTECTION BASELINE INSPECTION

1 IP In-Plant Airborne Radioactivity Control and Mitigation

71124.03 04/15/2013

04/19/2013