ML14003A186
ML14003A186 | |
Person / Time | |
---|---|
Site: | Perry |
Issue date: | 01/03/2014 |
From: | Michael Kunowski NRC/RGN-III/DRP/B5 |
To: | Harkness E FirstEnergy Nuclear Operating Co |
References | |
IR-13-007 | |
Download: ML14003A186 (27) | |
See also: IR 05000440/2013007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
January 3, 2014
Mr. Ernest Harkness
Site Vice President
FirstEnergy Nuclear Operating Company
Perry Nuclear Power Plant
P. O. Box 97, 10 Center Road, A-PY-A290
Perry, OH 44081-0097
SUBJECT: PERRY NUCLEAR POWER PLANT - NRC PROBLEM IDENTIFICATION
AND RESOLUTION INSPECTION REPORT 05000440/2013007
Dear Mr. Harkness:
On November 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a
Problem Identification and Resolution biennial inspection at your Perry Nuclear Power Plant.
The enclosed inspection report documents the inspection results, which were discussed on
November 22, 2013, with you and other members of your staff.
Based on the inspection sample, the inspection team determined that your staffs
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 staffs implementation of the stations 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 staffs 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 stations performance in each of
these areas supported nuclear safety
Finally, the team determined that your stations management maintains a safety-conscious work
environment adequate to support nuclear safety. Based on the teams 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
E. Harkness -2-
If you contest a violation or significance of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with
copies to the Regional Administrator, Region III; the Director, Office of Enforcement,
U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident
Inspector at the Perry Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the
Perry Nuclear Power Plant.
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections,
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any) will be available electronically for public inspection in
the NRCs Public Document Room or from the Publicly Available Records System (PARS)
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
Sincerely,
/RA/
Michael A. Kunowski, Chief
Branch 5
Division of Reactor Projects
Docket No. 50-440
License No. NPF-58
Enclosure: Inspection Report 05000440/2013007
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServTM
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-440
License No: NPF-58
Report No: 05000440/2013007
Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Perry Nuclear Power Plant
Location: Perry, OH
Dates: November 4 through November 22, 2013
Inspectors: J. Jandovitz, Project Engineer, Team Lead
C. Brown, Senior Reactor Inspector
J. Gilliam, Reactor Engineer
J. Nance, Resident Inspector
Approved by: Michael Kunowski, Chief
Branch 5
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
Inspection Report (IR) 05000440/2013007; 11/04/2013 - 11/22/2013; Perry Nuclear Power
Plant; Biennial Problem Identification and Resolution (PI&R) Inspection.
This inspection was performed by three regional-based inspectors and the Perry Nuclear Power
Plant resident inspector. Two (Green) findings were identified by the inspectors, both with
associated Non-Cited Violations (NCVs) of NRC regulations. The significance of inspection
findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and
determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process,
dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within
the Cross Cutting Areas, dated October 28, 2011. All violations of NRC requirements are
dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 4.
Problem Identification and Resolution
Based on the samples selected for review, the team concluded that implementation of the
corrective action program (CAP) at the Perry Nuclear Power Plant was effective. The licensee
had a low stated threshold for identifying problems and entering them in the CAP. Items
entered into the CAP were generally screened and prioritized in a timely manner using
established criteria, although the team identified timeliness issues for a small percentage of
issues. With a few exceptions documented by the team, issues in the CAP were evaluated and
corrective actions were generally implemented in a timely manner. The team noted that the
licensee reviewed operating experience (OE) for applicability to station activities. Audits and
self-assessments were performed at an appropriate level to identify deficiencies. Based on
interviews conducted during the inspection, licensee staff expressed freedom to raise nuclear
safety concerns and to enter nuclear safety concerns into the CAP.
NRC-Identified and Self-Revealed Findings
Cornerstone: Barrier Integrity
Green. The inspectors identified a finding of very low safety significance (Green) and
associated Non-Cited Violation of Technical Specification 3.4.11, RCS Pressure and
Temperature (P/T) Limits, for failure to comply with reactor pressure vessel
pressure/temperature limits. Specifically, in 2011 the inspectors identified the
pressure/temperature limits in Technical Specification 3.4.11 only contained values for reactor
pressure vessel pressures greater than 0 pounds per square inch gauge. However, between
June 2011 and July 2013, the licensee operated the plant with a vacuum in the reactor pressure
vessel during 5 cold startups and 1 cooldown. The licensee entered the finding into its
corrective action program as Condition Report CR 2013-18689.
The performance deficiency was determined to be more than minor because the finding was
associated with the area of Routine Operations Performance within the Human Performance
attribute of the Barrier Integrity Cornerstone and had the potential to adversely affect the
associated cornerstone objective of providing reasonable assurance that a physical design
barrier (reactor coolant system) protects the public from radionuclide releases caused by
accidents or events. The finding screened as very low safety significance because it was
determined that there was no change in risk due to the performance deficiency. This finding
1 Enclosure
has a cross-cutting aspect in the area of human performance, resources. Specifically,
complete, accurate, and up-to-date procedures were not available to operators to ensure
operations within the requirements of Technical Specification 3.4.11, (H.2(c)).
(Section 4OA2.1b.(2).1)
Green. The inspectors identified a finding of very low safety significance (Green) and
associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective
Action, for failure to promptly correct a non-conservative Technical Specification. Specifically,
the inspectors identified on November 14, 2013, that the licensee failed to promptly correct the
non-conservative Technical Specification 3.4.11 by not submitting a license amendment request
in accordance with NRC Administrative Letter 98-10, which required submittal within 1 year
or 1 operating cycle. The licensee had determined Technical Specification 3.4.11, RCS
Pressure and Temperature (P/T) Limits, to be non-conservative on October 16, 2009, and
implemented administrative controls as allowed by the Administrative Letter. As of
November 14, 2013, the licensee had not submitted the license amendment request, over
4 years and 2 operating cycles after determining the Technical Specification was non-
conservative. The licensee entered the finding into the corrective action program as Condition
Report CR 2013-18983.
The performance deficiency was determined to be more than minor because the finding was
associated with the area of Routine Operations Procedures within the Procedure Quality
attribute of the Barrier Integrity Cornerstone and had the potential to adversely affect the
associated cornerstone objective of providing reasonable assurance that physical design
barriers (fuel cladding, reactor coolant system, and containment) protect the public from
radionuclide releases caused by accidents or events. The finding was screened as very low
safety significance because it was determined that operators followed the appropriate reactor
coolant system P/T curves even though the Technical Specification was non-conservative.
The finding has a cross-cutting aspect in the area of human performance, decision-making,
where licensee decisions demonstrate that nuclear safety is an overriding priority. Specifically,
from the time of discovery of the non-conservative technical specification until now, various
decisions had been made by the licensee that have delayed the timely submittal of the license
amendment request (H.1(c)). (Section 4OA2.1b.(3).1)
2 Enclosure
REPORT DETAILS
4. OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (71152B)
This inspection constituted one biennial sample of Problem Identification and Resolution
(PI&R) as defined in Inspection Procedure (IP) 71152, Problem Identification and
Resolution. Documents reviewed are listed in the Attachment to this report.
.1 Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the licensees 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 licensees 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
licensees various investigation methods, including root cause evaluations (RCEs), full
apparent cause evaluations (ACEs), limited apparent cause evaluations (LACEs), and
common cause analyses (CCAs).
The inspectors selected the station large transformers to review in detail because the
system had numerous operational problems, including replacements, in recent years.
The intent of the review was to determine whether the licensee staff were properly
monitoring and evaluating the performance of this system through effective
implementation of station monitoring programs. A five-year review of the Unit 1 main
transformer, 1-PY-T, the Unit 1 auxiliary transformer, 110-PY-B, and the Unit 2 start-up
transformer, 200-PY-B, was performed. A review of the use of the station maintenance
rule program to help identify equipment issues was also conducted.
On September 3, 2013, the NRC issued the Mid-Cycle Assessment Letter for the Perry
Nuclear Plant (ADAMS Accession Number ML13246A237). That assessment discussed
that continued management attention and focus was needed to address lower level, less
risk significant issues involving procedure use and adherence and procedure quality.
To further evaluate these issues, this inspection implemented the NRC plan to
specifically review the licensees 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 licensees actions were in
compliance with the licensees CAP and 10 CFR Part 50, Appendix B requirements.
Specifically, the inspectors determined whether licensee personnel were identifying plant
issues at the proper threshold, entering the plant issues into the stations 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
3 Enclosure
investigational method to ensure the correct determination of root, apparent, and
contributing causes. The inspectors also evaluated the timeliness and effectiveness of
corrective actions for selected issue reports, completed investigations, and NRC
previously identified findings that included principally non-cited violations.
b. Assessment
(1) Effectiveness of Problem Identification
Based on the information reviewed, including initiation rates of CRs and interviews, the
inspectors concluded that the licensee has an appropriate low threshold for initiating
CRs. The number of CAP items generated were distributed across the various
departments. The inspectors did not identify any safety significant items that were not
entered into the CAP, but noted that various licensee assessments found instances that
did not meet licensee expectations for entering issues into the CAP. The inspectors
assessed the effectiveness of problem identification as adequate, partially due to the
continued expectation that the licensee will continue to perform assessments of the
same quality and resulting corrective actions improving the CAP process.
Observations
Since 2012, the inspectors noted that licensee assessments of the CAP, including fleet
and oversight assessments, have been self-critical and rated the CAP as marginally
effective but with an improving trend. Corrective actions have been developed to
improve CAP implementation, but the assessments continue to reveal areas for
improvement as late as the 2013 second trimester assessment.
The 2012 NRC Problem Identification and Resolution (PI&R) Inspection Report,
05000440/2012007 (ADAMS Accession Number ML12066A195), noted that issues with
the use of work order Work-In-Progress (WIP) logs where the logs included information
that should have been included in the CAP, provided technical direction, and that either
initiated or stopped work. The inspectors noted improvement during this inspection with
one similar WIP log issue that was identified by the licensee.
Review of the CAP performance indicators showed that the number of CRs generated
has increased over the last year. Reviewing the six-month averages, the site had a low
of 566 in March 2013, and a high of 709 in September of 2013. As expected, the
number increased significantly during the spring outage period, a high of 952 CRs
initiated in May 2013.
Findings
No findings were identified.
(2) Prioritization and Evaluation of Issues
The inspectors reviewed the classification of CRs and attended licensee meetings that
categorized and prioritized CRs and determined that, in general, CRs were assigned
appropriate prioritization and evaluation levels. Evaluations in RCEs and ACEs
reviewed by the inspectors were adequate. The licensee completed about 12 RCEs
since November 2012. The inspectors considered the quality of the selected RCEs to
have improved since the last inspection. A contributing factor may be that licensee
4 Enclosure
review groups had previously identified issues with the quality of the evaluations
resulting in corrective actions. The inspectors determined that the licensees
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
5 Enclosure
licensee operated the plant with a vacuum in the RPV during 5 cold startups and 1
cooldown.
Description: In October 2011, the inspectors identified a concern with the P/T limits for
TS 3.4.11, RCS Pressure and Temperature (P/T) Limits. The pressure limits for non-
nuclear heatup only existed for values greater than or equal to 0 psig and the licensee
was actually operating with a vacuum (below 0 psig) in the RPV. The licensee initiated
CR 2011-03864, NRC Question on Tech Spec 3.4.11 RCS Pressure and Temperature
Curves/Drawing a Vacuum during Non-Nuclear Heatup, and evaluated the concern to
determine if any potential deficiency existed for not operating within the curve limits.
The resulting engineering evaluation stated that The Reactor Vessel is designed
following the rules of ASME Section III Subsection NB Class 1 components. From the
Chicago Bridge and Iron, ASME Code Design Report, D-1, page 35, the vessel head
is 4 19/32 inch thick with an inner radius of 119 inches and the vessel wall below the
flange is 6 inches thick with an inner radius of 120 inches. The dimensions of these
components are identified to provide indication of the robustness of the design. Due to
the size and thicknesses of these components the stresses produced by vacuum are
judged to be relatively insignificant. The licensee, however, did not evaluate implication
for TS compliance.
In January 2013, during a cold startup following an automatic scram, the inspectors
again questioned operating with the RPV in a vacuum during the startup. The licensee
referred to the 2011 CR. The licensee had not committed to update the curves and
submit a license amendment request (LAR) for approval of new P/T limits to reflect
operation with a vacuum in the RPV during cold startups and during cooldowns. On
November 5, 2013, during a phone call with various branches in the Office of Nuclear
Reactor Regulation, including the Technical Specification branch, it was decided that
the current TS does not address operating the RPV in a vacuum and doing so violated
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
6 Enclosure
procedures were not available to operators to ensure operations within the requirements
Enforcement: Technical Specification 3.4.11 requires that RPV pressures and
temperatures be maintained within limits at all times. Contrary to this requirement,
between June 2011 and July 2013, the licensee operated the plant with a pressure in the
RPV less than the TS 3.4.11 limit of greater than or equal to 0 psig. Specifically, the
licensee operated the RPV in a vacuum during cold startups on June 4, 2011, for more
than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />; on October 18, 2011, for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; on March 3, 2012, for more
than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; on June 17, 2012, for more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; and on May 11, 2013, for more
than 30 minutes; and twice during a cooldown on June 16, 2013, for 15 and 30 minutes.
Because the violation was of a very low safety significance and was documented in the
licensees 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 licensees 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
7 Enclosure
procedure writers. However, the notice did not address the failure to follow procedure.
In addition, there was no verification that all of the procedure writers reviewed the
information. The licensee initiated CR 2013-18661, NRC Questions the Thoroughness
of CR 213-09637, License Amendment Implementation Completed Prior to Amendment
Approval, to address this concern.
Findings
.1 Failure to Promptly Correct a Non-Conservative TS
Introduction: The inspectors identified a finding of very low safety significance (Green)
and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
for failure to promptly correct a condition adverse to quality, a non-conservative TS.
Specifically, in November 2013, the inspectors identified that the licensee implemented
an administrative TS change when the licensee identified in October 2009 that
TS 3.4.11, RCS Pressure and Temperature (P/T) Limits, was non-conservative, but
did not promptly submit the required LAR.
Description: In October 2009, the licensee documented in Condition Report CR 2009-
64465 that TS 3.4.11, RCS Pressure and Temperature (P/T) Limits, was non-
conservative. These limits protect the reactor vessel material from pressurized thermal
shock. The corrective action by the licensee was an administrative TS change in
accordance with NRC Administrative Letter 98-10, Dispositioning of Technical
Specifications That Are Insufficient To Ensure Plant Safety. The change shifted a
portion of the reactor pressure vessel P/T limits so that it required operation at a higher
RPV temperature than previously specified at certain pressures. The licensee correctly
invoked Administrative Letter 98-10 and took an action to issue a non-conservative TS
tracking form, prepared in accordance with procedure NOP-LP-4009, for the purpose of
alerting all TS holders of the changes to the P/T limit curves. The licensee also initiated
a corrective action to formally update the calculations from which the curves were
developed and, when the calculations were approved, to initiate the appropriate change
mechanism, a license amendment request, to formally update the TS P/T curves.
However, as of the November 2013 start of the current inspection, that calculation had
not been performed. The inspectors also noted that the procedure did not specify a time
requirement for the LAR submittal and did not clearly identify the organization
responsible to initiate a LAR for non-conservative TSs. A timeline of this issue is
presented below.
Timeline of Licensee Actions
09/11/2009 GE Hitachi (GEH) Nuclear Energy letter to FirstEnergy identified non-
conservative TS values through an Impact Assessment for Water Level
Instrumentation Nozzle Penetration on P/T curves provided to BWR
Owners Group (BWROG) members.
09/15/2009 CR 2009-64465 was initiated based on GEH letter; corrective action
CA-001 was initiated to seek revision to calculation EA-0246 to include
level instrument analyses.
10/02/2009 GEH letter File 0000-0106-1616 Rev. 1 to FirstEnergy identified level
instrument nozzle impact on P/T curves.
10/16/2009 Non-conservative TS tracking forms issued and placed into all
controlled copies of licensees TS manuals per NOP-LP-4009-04.
8 Enclosure
02/09/2010 CA-001, due February 10, 2010, extended to June 11, 2010, and
provided estimated schedule with GEH as primary contractor.
05/06/2010 CA-001, due June 11, 2010, was extended to February 28, 2011,
based on unacceptable proposal costs. The alternate BWROG revision
to the P/T limits topical report was chosen. No definitive schedule was
identified other than financial approval by the FENOC BWROG
representative in April 2010. Justification was based on low safety
significance.
02/14/2011 CA-001 due on February 28, 2011, was extended to August 12, 2011,
based on receipt of draft calculation from the BWROG contractor.
08/10/2011 Calculation EA 0272 was initiated on August 10, 2011, and was
approved on September 2. It used preliminary BWROG results to
incorporate the level instrument curve.
09/16/2011 CA-001, due August 12, 2011, was closed to CA-004 which added the
tracking of this item to the Design Basis Assessment Report which is
output quarterly.
03/15/2013 A proposal was received to update P/T curves for License Renewal by
incorporating the results of the capsule pulled in the recent refueling
outage, with inclusion of instrument line impact, and an additional note
to the curves for startup under a vacuum.
11/26/2013 CR 2013-18983, 2013 NRC PI&R: Timeliness Concern with Non-
Conservative Technical Specification 3.4.11, was initiated to address
the timeliness issue raised by the NRC.
Administrative Letter 98-10 contained two examples of untimely corrective action to
correct a non-conservative TS. The first example was a licensee that waited until after a
refueling outage to submit a license amendment. The second example a licensee that
waited over one year to submit an LAR. As of November 14, 2013, Perry had not
submitted an LAR license amendment after implementing administrative controls, over
four years and two operating cycles. Based on the two examples in 98-10, the
inspectors determined that Perrys corrective action to submit the LAR was not timely
and a violation of 10 CFR Part 50, Appendix B, Criterion XVI.
Analysis: The licensees 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
9 Enclosure
which were supported with approved licensee calculations. Therefore, there was no
impact to the RCS boundary as a result of this finding and the analyst concluded that
this issue was of very low safety significance. The finding has a cross-cutting aspect in
the area of human performance, decision-making, where licensee decisions
demonstrate that nuclear safety is an overriding priority. Specifically, from the time of
discovery of the non-conservative technical specification until now, various decisions
had been made by the licensee that have delayed the timely submittal of the license
amendment request (H.1(c)).
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,
requires, in part, that conditions adverse to quality be promptly identified and corrected.
Contrary to the above, the licensee failed to promptly correct a non-conservative
Technical Specification, a condition adverse to quality. Specifically, the inspectors
identified on November 14, 2013, that the licensee failed to promptly correct the non-
conservative TS 3.4.11 by not submitting the LAR in accordance with NRC
Administrative Letter 98-10, which specified submittal within one year or one operating
cycle. The licensee had determined TS 3.4.11, RCS Pressure and Temperature (P/T)
Limits, to be non-conservative on October 16, 2009, and implemented administrative
controls as allowed by the Administrative Letter. However, as of November 14, 2013,
the licensee had not submitted the LAR, over four years and two operating cycles after
determining TS 3.4.11 was non-conservative. Because the violation was of very low
safety significance and was documented in the licensees 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 licensees implementation of the facilitys 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 licensees 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 licensees procedures. Both internal and external OE was being
incorporated into lessons learned for training and pre-job briefs. The inspectors
10 Enclosure
concluded that the licensee was evaluating industry OE when performing root cause and
apparent cause evaluations.
Observations
The inspectors identified a potential weakness in the licensees 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 staffs 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
11 Enclosure
- Concerns and issues over CAP implementation.
The relatively longstanding and repetitive nature of the issues identified support the
inspector conclusions that corrective actions to improve procedure use and adherence
were ineffective. The licensee was relying on the recently issued Strategic Improvement
Plant to improve and sustain a higher standard of human performance.
Findings
No findings were identified.
.4 Safety Conscious Work Environment (SCWE)
a. Inspection Scope
The inspectors assessed the licensees SCWE through the review of the licensees
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 staffs beliefs related to staffing.
12 Enclosure
Several comments indicated that there was an improvement with the communication of
the leadership at Perry. Both the Site Vice-President and the Plant Manager were newly
assigned to Perry since the 95002 inspection. Personnel commented that both
individuals appear to spend more time in the field communicating directly with them, and
appear to listen to their concerns. Continuing this behavior by the senior leadership
would likely result in an improvement to the SCWE.
Findings
No findings were identified.
4OA6 Management Meeting
.1 Exit Meeting Summary
On November 22, 2013, the inspectors presented the inspection results to
Mr. Harkness, the Site Vice-President, and members of his staff. The licensee
acknowledged the issues presented. The inspectors confirmed that proprietary
documents were appropriately returned or will be destroyed.
ATTACHMENT: SUPPLEMENTAL INFORMATION
13 Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
E. Gordon, Supervisor, Performance Improvement
B. Blair, Manager - Maintenance
E. Harkness, Site Vice President
D. Hamilton, Director - Site Operations
N. Conicella, Manager - Regulatory Compliance
L. Zerr, Supervisor - Regulatory Compliance
J. Ellis, Director - Recovery
V. Veglia, Director - Maintenance
T. Veitch, Manager - Regulatory Compliance
R. Coad, Supervisor, Design Engineering
K. Coggins, Maintenance
NRC Personnel
M. Kunowski, Chief, Branch 5, Division of Reactor Projects
M. Marshfield, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened and Closed
05000440/2013007-01 NCV Failure To Comply With Technical Specification 3.4.11
(Section 4OA2.1b.(2).1)05000440/2013007-02 NCV Failure To Promptly Correct a Non-conservative
Technical Specification (Section 4OA2.1b.(3).1)
Discussed
None
1 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 3
Assessments
NOP-OP-1012 Material Readiness And Housekeeping Inspection 7
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
2 Attachment
Number Description or Title
2008-48338 High Water Content In U2 Startup XFMR Oil
2010-82586 Unit 2 Startup XFMR Oil Sample Results Indicate High Moisture
Content
2011-06031 2011 AFI MA. 1-1 Maintenance Consistent Use Of Procedures And
Work Orders As Written
2011-06137 Declining Ownership With CAP And OE Due Dates
2011-06714 Focused Self-Assessment Recommendation Four Actions From
Industry Peers To Be Tracked In CAP
2011-07124 Lack Of Work Preparation/Execution Not Limited To, But Including
Div-1 AOT
2012-00212 Historical Review Of Oil Analysis On Aux Transformer Reviewed
IEEE Condition 1 Limits Exceeded
2012-00386 Work Could Not Be Performed As Scheduled During Div 2 EDG
Outage
2012-00400 SLC Pump A Unavailable In Narrative Log But Not In A Timely
Manner
2012-00406 Voltage Found During Live Dead Live Check
2012-00615 SN-SA-2012-006: Deficiencies Found With OE Reviews During FP
Self-Assessment
2012-00658 Activity To Perform Line Kill Of RFPT B Casing Drain Line Was
Unsuccessful
2012-00798 Adverse Trend - Declining Performance In Maintenance Training
Programs (IP-SA-2012-0001)
2012-01073 TSC UPS B Abnormal DC Voltage Alarm
2012-02767 Unexpected Trip Of S-621 And S-620
2012-03809 Rigging Issue During Removal Of A Beam In Dry Cask Storage
Project
2012-06153 Loss Of Control For The Seismic Restraint For The Dry Cask
Storage Project
2012-11886 RWCU Isolation Pump Trip During SVI Restoration
2012-01516 PY-PA-12-01 The CAP Performance Was Rated Marginally Effective
For The 3rd Trimester Of 2011
2012-01908 Review Of All Site Condition Reports From January Identified A
Trend Of Repeat Issues
2012-02678 MS-C-12-01-13, Issues Identified Pertaining To GL-89-13 Program
2012-02794 MS-C-12-01-13, Test Equipment Uncertainties Not Accounted In
Valve Testing
2012-02911 CNRB Recommendation: Capture Feedback From NRC PI&R
Inspection Debrief
2012-03231 Manual Reactor SCRAM 1-12-01 Occurred at 02:24 March 1, 2012
2012-03720 Unexpected Breaker Trip During Uncoupled Run
2012-03840 Miscommunication Of Emergency Diesel Generator Ventilation Fan
Air Flow Compensation Requirements
2012-06167 Actions Taken In Response To CR11-89188 Are Outside The
Corrective Action Program
2012-06485 Procedure Adherence Issues During Unit 1 Division 2 Battery
Charge
2012-06660 Feedwater Heater 5A Leak As Reported Is Above An ODMI Trigger
Point
3 Attachment
2012-06973 NRC NCV, Inadequate Risk Evaluation For Main Generator Stator
Water Cooling System Maintenance Resulted In A Manual Reactor Scram
2012-07882 NRC NCV, Inadequate Procedure Resulted In Loss Of High-
Pressure Core Spray Function
2012-09931 Supplemental Personnel Injured During Scaffold Modification
2012-10293 PA-PY-2012-02, Maintenance CAP Implementation Issues
2012-11148 PYSP IPAT 1st Half of 2012- Emerging Trend Identified Related To
An Increase In Human Performance Events Within the Section
(IP-SA-2012-0119)
2012-11369 Belt Installed On TB Supply Fan B, Unsafe Act
2012-12152 Declining CAP Health Indicators
2012-12349 July CAP Performance Indicator Shows A Declining Trend In Cause
Evaluation Quality
2012-12674 Missed SVI Unit 1 Division 1 Battery
2012-13408 FO-SA-2012-0013: Activities Are Being Inappropriately Designated
A Different Color Of Risk Than What Is Assessed Per NOP-OP-1007
2012-13758 Ineffective Communications During Pre-Job Brief Resulted In Drilling
Through Rebar Without Prior Engineering Approval
2012-15950 SN-SA-0220 Perry Nuclear Safety Culture Review Self-Assessment-
Principle 7
2012-16671 The 3rd Quarter Safety Culture Monitoring Meeting Held On
October 19, 2012 Determined That Safety Culture Attribute If Needs
Further Review And Attention
2012-16828 Work Group Unprepared to Start Task For Hot Short Modification
Causes Un-necessary Unavailability Time For Division 1 Diesel
2012-18618 Chemistry Section Was Rated RED For The 2012 SCWE Survey
Pillar
2012-19535 XCAP Precursor Issues In Cross-Cutting Aspect H.4(a)
2013-00013 Data Suggests That The Importance Placed On The Corrective
Action Program Is Not Where It Needs To Be For The Station
2013-00511 TB West Crane Deficiencies Not Entered Into CAP And Resolution
Not Documented In WO 200493418
2013-00826 FO-SA-2011-0017, Based On The Number Of Issues Of Issues
Identified Similar In Nature To Previously Identified Issues. The
Corrective Actions Taken Have Been Less Than Fully Effective
2013-00753 Clearance Not Adequate For Work To Be Performed
2013-01011 Inverter 1R14S0004 Found On Alternate Source With The Fila Light
On Following Reactor Scram
2013-01476 PY-C--13-01-01, Clearance Revision Process Described In NOP-
OP-1001 Is Not Being Followed
2013-01965 CARB Identified Line Ownership Of The CAP Is Inconsistent And Is
Delaying Improvement Of The Implementation Of CAP At Perry
2013-03005 Snapshot Self-Assessment SN-SA-2012-0079, Found Project
Section That Had One LACE CR That Required Cause Code(s)
2013-03016 MS-C-13-02-22, CR 2012-13758 Interim Effectiveness Review Not
Adequately Reviewed Or Issues Identified In CAP
2013-03223 Corrective Actions Assigned In CR 2013-00478 Do Not Address
Apparent Cause Identified
2013-04435 Valve Found Out-of-Position
4 Attachment
2013-05236 Resolution Of A Condition Adverse To Quality (Non-Conservative
Technical Specification) Is Not Being Tracked In The Corrective
Action Program
2013-05741 NRC Cross-Cutting Theme In Human Performance Aspect H.4(a)
2013-05809 Potential Trend: There Have Been Nine Overdue CAP Products
Between March 31, 2013 And April 14, 2013
2013-05993 MS-C-13-02-22: Perry Corrective Action Program Implementation
Rated Marginally Effective
2013-06207 Auto Start Of 1M15C0001A During SVI-R43-T7000A. On April 15,
2013, Was Not Documented In CAP
2013-06479 P-1925 Could Inappropriately Credit RHR Availability For Decay
Heat Removal In Defense-In-Depth When ADHR Is In Service
2013-07473 Level Transient During Performance Of PTI-N27-P0012
2013-07582 Conditional Release Of 1P11-F0545
2013-07585 Valve Refurbishment Did Not Follow NOBP-WM-4003
2013-07665 Field Wiring Did Not Match Drawing 209-0158-00003 For The AT
Junction Box In The Generator Alterex Cabinet
2013-07881 NRC FIN, Failure To Perform Vendor Recommended Preventative
Maintenance
2013-07883 NRC NCV, Valve Mis-Position Causes SDV Level Detector
Inoperability
2013-07884 NRC NCV, Failure To Follow Procedures For Conducting A Standby
Liquid Control System Surveillance
2013-08962 PA-PY-13-01 Organizational Effectiveness Rated Marginally
Effective For 1st Trimester 2013
2013-09086 Potential Debris/Missile Material Stored Outside Of MB-100
2013-09461 Cross Cutting Aspect H(3).b For NCV 05000440/2013002-01 Not
Evaluated In CR2013-03863 Or CR2013-03781
2013-09486 SN-SA-2013-0144, CA 2011-97640-001 Not Implemented As Stated
In Corrective Action Closure Comments
2013-09601 Safety Concern Roof Top Workers
2013-09637 License Amendment Implementation Completed Prior To
Amendment Approval
2013-10222 Changes In Procedures 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
5 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 September 2013
Meeting (Handout)
Maintenance Standards Implementation 0
Green News Flash- Awareness Of November 17, 2013
Housekeeping Standards For Switchyard And
Transformer Areas
Maintenance Superintendent And Supervisor November 7, 2013
Weekly Meeting Agenda
Message From Site Leadership Team On Site August 8, 2013
Expectations And Standards
Perry Station Safety & Human Performance September 18, 2012
Recovery Plan For NPS
Perry Nuclear Power Plant Performance November 19, 2013
Indicator 01
Revise Organizational Effectiveness Plan October 31, 2013
200487879 Perform Line KiII On RFPT B Per ECP 08-0712- January 13, 2012
003
GAT 6008631128 Management Alignment And Ownership November 5, 2013
Meeting Agendas November 6, 2013
November 7, 2013
November 8, 2013
MEC-201203-PY-04 Electrical Maintenance Continuous Training October 3, 2012
2012 Third Cycle, Phase Rotation Meters
PY Plant Status Perry Plant Status For Friday, November 8, November 8, 2013
Email 2013; E-Mail From Dave Hamilton
System Health System--S11-Power Transformers August 22, 2013
Report 2013-1
System Health System--S11-Power Transformers August 10, 2012
Report 2012-2
TEEW IC-12-01 I&C Radworker H.I.T. March 14, 2012
TEEW IC-13-01 Human Performance Tools, Verification July 1, 2013
Techniques
TEEW ME-13-01 Human Performance Tools, Lifting And Landing July 1, 2013
Of Electrical Wires/Cables
6 Attachment
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number Description or Title Date or Revision
FENOC Oversight Fleet Summary, September 1, 2012
Third Trimester 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 September 4, 2013
NRC Problem And Identification Inspection
FO-SA-2013-0121 Compare Revision Changes of "INPO 97-011 June 24, 2013
Guidelines For The Use of Operating Experience"
MS-C-13-02-22 Fleet Oversight Audit Report April 15, 2013
PA-PY-13-01 Perry Nuclear Power Plant Fleet Oversight May 29, 2013
Trimester Report, 1st Trimester 2013
PA-PY-13-02 Perry Nuclear Power Plant Fleet Oversight September 26, 2013
Trimester Report, 2nd Trimester 2013
PY-PA-12-01 Review Of All Site Condition Reports From July 31, 2012
January Identified A Trend Of Repeat Issues
SN-SA-2012 0041 Submittal Of OE To The Industry July 20, 2012
SN-SA-2012 0166 Snapshot Of Timeliness Of PJB For Significant August 6, 2012
CRs, CR Report Closure Timeliness And
Evaluator Attendance At CARB.
SN-SA-2012 0254 Per CA-2012-01912-2, Perform A Snapshot 3 January 13, 2013
Months After Implementation Of New Performance
Indicators To Determine Effectiveness Of
Reducing Timeliness Issues In CAP
SN-SA-2012-0079 Perform A Review Of All Limited, Full, Root Cause May 8, 2012
Evaluations That Do Not Have A Cause Code In
Devonway
SN-SA-2012-0095 4th Quarter 2011 Safety Culture Monitoring Panel May 8, 2012
May 8, 2012
SN-SA-2012-0149 1st Q 2012 Management Oversight And August 6, 2012
Awareness Of Conservative Decisions
SN-SA-2012-0181 Management Oversight And Awareness Of March 5, 2013
Conservative Decisions
SN-SA-2012-0246 Switchyard Component Control Assessment November 8, 2012
SN-SA-2012-02-77- Plant Engineering Backlog August 12, 2013
001
SN-SA-2013-004 NRC Inspection 71113004 Equipment July 22, 2013
Performance, Testing, And Maintenance
SN-SA-2013-0342 2013 Perry INPO Organizational Effectiveness October 31, 2013
Survey Analysis
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
7 Attachment
OE 2011-0986 IN 2010-01 Pipe Support Anchors
OE 2011-1187 Failures Of Moore 535 Digital Single Loop Controllers Causing Problems
In Multiple System
OE 2011-1307 Declining Trend In Operability Determination Led To An Inadequate
Evaluation
OE 2011-1372 Preliminary- During 125 Volt DC Electrical Maintenance A Short Circuit
Caused A Reactor Trip
OE 2012-0277 IN 12-01 Seismic Considerations- Principally Involving Tanks
OE 2012-0965 Environmental Qualification (EQ) Program Challenged By Inconsistent
Scheduling Of Required Maintenance
OE 2013-1217 Unit 2 Turbine Trip On Main Generator Lockout
OE 2013-1225 Counterfeit Batteries Identified During Receipt Inspection
CONDITION REPORTS GENERATED DURING INSPECTION
Number Description or Title
2013-17900 2013 NRC PI&R: Enhance Tracking Of Maintenance Rule (a)(1)
System Work Orders
2013-17901 2013 NRC PI&R: Potential Improvement Item Was Identified Regarding
Information Only OE Justification
2013-17984 2013 NRC PI&R: Potential Transformer Yard Debris/Missile Hazards
Stored Outside Of MB-100
2013-18176 2013 NRC PI&R: No Final Effectiveness Review Exist For Root Cause
CR 2009-66058
2013-18180 2013 NRC PI&R: Potential Improvement Item Was Identified Regarding
Justification For No Maintenance Rule Evaluation
2013-18387 2013 NRC PI&R: NRC Questions Perry Response To CR 2013-00511
2013-18579 2013 NRC PI&R: Documentation Of Corrective Action Implementation
Does Not Meet Expectation
2013-18661 2013 NRC PI&R: NRC Questions The Thoroughness Of The Response
To CR 2013-09637, License Amendment Implementation Completed
Prior To Amendment Approval
ROOT CAUSES AND APPARENT CAUSES
Number Description or Title
2011-02542 Unit 1 Start-up Transformer Failure
2012-07454 IRM D Indicating Failure During Power Ascension
2013-01011 Inverter 1R14S004 Was Found On Its Alternate Source And With The
Fail Light On Following A Reactor Scram
2013-05234 Root Cause For Fuel Defect Found During 1R14
2013-07454 IRM D Not Responding Properly
2013-09737 Maintenance And Technical Training Station Identified Finding
8 Attachment
LIST OF ACRONYMS USED
ACE Apparent Cause Evaluation
ADAMS Agencywide Documents Access and Management System
BWROG Boiling Water Reactor Owners Group
CA Corrective Action
CAP Corrective Action Program
CARB Corrective Action Review Board
CCA Common Cause Analysis
CFR Code of Federal Regulations
CR Condition Report
ECP Employee Concerns Program
FENOC FirstEnergy Nuclear Operating Company
GEH General Electric-Hitachi
IMC Inspection Manual Chapter
IP Inspection Procedure
IR Inspection Report
LACE Limited Apparent Cause Evaluation
LAR License Amendment Request
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
OE Operating Experience
P/T Pressure/Temperature
PARS Publicly Available Records System
PI&R Problem Identification and Resolution
PSIG Pounds per Square Inch Gauge
RCE Root Cause Evaluation
SCWE Safety Conscious Work Environment
SDP Significance Determination Process
SRA Senior Reactor Analyst
TS Technical Specification
WIP Work-In-Progress
9 Attachment
E. Harkness -2-
If you contest a violation or significance of these NCVs, you should provide a response within
30 days of the date of this inspection report, with the basis for your denial, to the Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with
copies to the Regional Administrator, Region III; the Director, Office of Enforcement,
U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident
Inspector at the Perry Nuclear Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the
Perry Nuclear Power Plant.
In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections,
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any) will be available electronically for public inspection in
the NRCs 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
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DOCUMENT NAME: Perry IR 2013007
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OFFICE RIII-DRP RIII RIII RIII
NAME JJandovtiz:rj SOrth MKunowski
PLougheed for
DATE 01/02/14 01/02/14 01/03/14
OFFICIAL RECORD COPY
Letter to Ernest Harkness from Michael Kunowski dated January 3, 2014
SUBJECT: PERRY NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION
AND RESOLUTION INSPECTION REPORT 05000346/2013007
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