ML092440409

09/01/09 - Perry - Mid-Cycle Performance Review and Inspection Plan

ML092440409
Person / Time
Site:	Perry
Issue date:	09/01/2009
From:	West K S Division Reactor Projects III
To:	Bezilla M FirstEnergy Nuclear Operating Co
References
FOIA/PA-2010-0209
Download: ML092440409 (8)

Text

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

September 1, 2009 Mr. Mark Bezilla

Site Vice President

FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-A290 Perry, OH 44081-0097

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - PERRY NUCLEAR PLANT

Dear Mr. Bezilla:

On August 19, 2009, the NRC staff completed its performance review of the Perry Nuclear Plant. Our technical staff reviewed performance indicators (PIs) for the most recent quarter and inspection results for the period from July 1, 2008 through June 30, 2009. The purpose of this letter is to inform you of our assessment of your safety performance during this period and our plans for future inspections at your facility.

This performance review and enclosed inspection plan do not include security information. A separate letter designated and marked as "Official Use Only--Security Information" will include the security cornerstone review and resultant inspection plan.

Plant performance for the most recent quarter at Perry Nuclear Plant was within the Licensee Response column of the NRC

=s Action Matrix, based on all inspection findings being classified as having very low safety significance (Green) and all PIs indicating performance at a level requiring no additional NRC oversight (Green). Performance at the Perry Nuclear Power Plant during the assessment period continued to exhibit weaknesses in the area of human performance. The total number of findings with documented cross-cutting aspects in human performance increased from 12 to 20. Our assessment of the findings identified three new cross-cutting themes in the human performance area: work control-planning (H.3(a)), five findings; work practices-human error prevention techniques (H.4(a)), five findings; and work control-oversight (H.4(c)), four findings. In addition, while the number of findings with a cross-cutting aspect of resources -

documentation/procedures (H.2(c)) declined, we are leaving this theme open pending a demonstration of sustainable performance in this area.

M. Bezilla 2

This assessment period is the fourth consecutive assessment period identifying a substantive cross-cutting issue in the human performance area first opened in our March 3, 2008, End-of-Cycle assessment letter [Adams Ref. ML 080600303]. It is

apparent that the development of causal evaluations and implementation of corrective actions has not been effective in demonstrating sustainable performance in the human performance arena. Therefore, the NRC has a continuing concern with the scope of your efforts and progress in addressing this cross-cutting area and has concluded that the substantive cross-cutting issue in human performance will remain open. The human performance substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of human performance. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme. As part of our continuing review of this issue, a problem identification and resolution follow-up inspection item will be performed in accordance with IP 71152, "Identification and Resolution of Problems," Section 03.02, "Selected Issue Follow-up Inspection," during the upcoming assessment period. Because your efforts to effect improvem ents in the human performance area have not been effective as evidenced by the number of significant human performance issues having risen during the assessment period, we would like to discuss the issue with you at a public meeting. The meeting will afford you the opportunity to present the progress of your actions taken in response to this weakness and why you believe future actions will be more effective than actions previously undertaken to address these longstanding substantive cross-cutting issues. We will contact you separately to schedule this meeting. In addition to the negative trend in human performance, we have noted, since July 2008, a declining trend in the PI&R area. For this assessment period, we identified five findings in the PI&R area with the same aspect of corrective action program-thorough evaluation (P.1(c)).

Four of the five findings were identified in the last two quarters of the assessment period.

Condition reports generated through your corrective action program have continued to note the adverse trend in thorough evaluation (P.1(c)), but failed to take corrective actions that were effective in addressing that trend. Because of the continued decline in the area of PI&R, the NRC has a concern with the scope of your efforts and progress in addressing the cross-cutting area performance deficiencies and has concluded that a substantive cross-cutting issue exists in this area. This substantive cross-cutting issue will remain open until all cross-cutting themes have been cleared in the area of problem identification and resolution. To clear each theme, we will assess whether your corrective actions have resulted in a positive sustainable improvement in the area and will consider the number of findings in the theme.

The enclosed inspection plan details the inspections, less those related to security, scheduled through December 31, 2010. The inspection plan is provided to allow for the resolution of any scheduling conflicts and personnel availability issues well in advance of inspector arrival onsite. Routine resident inspections are not listed due to their ongoing and continuous nature. The inspections in the last 9 months of the inspection plan are tentative and may be revised at the End-of-Cycle review.

M. Bezilla 3

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 (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at 630-829-9833 with any questions you may have regarding this letter or the inspection plan.

Sincerely, /RA/ K. Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58

Enclosure:

Perry Inspection/Activity Plan DISTRIBUTION:

See next page

Letter to M. Bezilla from K. Steven West dated September 1, 2009.

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - PERRY NUCLEAR PLANT cc w/encl: J. Hagan, President and Chief Nuclear Officer - FENOC J. Lash, Senior Vice President of Operations and Chief Operating Officer - FENOC D. Pace, Senior Vice President, Fleet Engineering - FENOC K. Fili, Vice President, Fleet Oversight - FENOC P. Harden, Vice President, Nuclear Support - FENOC Director, Fleet Regulatory Affairs - FENOC Manager, Fleet Licensing - FENOC Manager, Site Regulatory Compliance - FENOC D. Jenkins, Attorney, FirstEnergy Corp. Public Utilities Commission of Ohio C. O'Claire, State Liaison Officer, Ohio Emergency Management Agency R. Owen, Ohio Department of Health President, Geauga County Board Director, Department of Emergency Services Geauga County Sheriff President, Ashtabula County Board of Commissioners Ashtabula County Sheriff Director, Ashtabula County Emergency Management Agency Mayor, Village of Genoa Genoa Village Administrator President, Lake County Board of Commissioners Lake County Sheriff Painesville City Manager Lake County Administrator Director, Lake County Emergency Management Agency President, Village of Fairport Harbor Mayor, City of Eastlake Mayor, City of Wickliffe President, Geneva City Council City Manager, Geneva Mayor, City of Kirtland Mayor, City of Mentor City Manager, Mentor Mayor, City of Mentor on the Lake Administrative Director Mayor, City of Willoughby Hills Mayor, City of Willoughby Mayor, City of Willowick Mayor, Village of Madison Village Administrator, Village of Madison Chairman, Board of Madison Township Trustees Mayor, Village of Kirtland Hills Mayor, Village of Geneva-on-the-Lake Mayor, Lakeline Village Mayor, Village of Timberlake Mayor, Village of Grand River G. Mortensen, INPO M. Bezilla 3

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 (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

If circumstances arise which cause us to change this inspection plan, we will contact you to discuss the change as soon as possible. Please contact Jamnes Cameron at 630-829-9833 with any questions you may have regarding this letter or the inspection plan.

Sincerely, /RA/ K. Steven West, Director Division of Reactor Projects Docket No. 50-440 License No. DPR-58

Enclosure:

Perry Inspection/Activity Plan DISTRIBUTION:

See next page

DOCUMENT NAME: G:\Branch TSS\ALL MOC\midcycle 2008 to 2009\Mid-cycle Letters Perry 2009 MOC Letter.doc G Publicly Available G Non-Publicly Available G Sensitive G 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 NAME GWright:dtp JCameron SWest DATE 08/27/09 08/27/09 08/31/09 OFFICIAL RECORD COPY

Letter to M. Bezilla from K. Steven West dated September 1, 2009.

SUBJECT:

MID-CYCLE PERFORMANCE REVIEW AND INSPECTION PLAN - PERRY NUCLEAR PLANT DISTRIBUTION

Susan Bagley

RidsNrrPMPerry

RidsNrrDorlLpI3-2 RidsNrrDirsIpob Resource Cynthia Pederson Jared Heck Steven Orth

Allan Barker DRPIII DRSIII Patricia Buckley Tammy Tomczak ROPreports Resource

Inspection / Activity Plan Page 1 of 2 08/25/2009 Report 22 09/01/2009

-12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Perry BI EP-EP ROUTINE INSPECTION / PI VERIFICATION 2 1 IP Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review 2515/175 09/21/2009 09/25/2009 1 IP A lert and Notification System Testing 7111402 09/21/2009 09/25/2009 1 IP Emergency Response Organization Augmentation Testing 7111403 09/21/2009 09/25/2009 1 IP Correction of Emergency Preparedness Weaknesses and Deficiencies 7111405 09/21/2009 09/25/2009 1 IP Drill/Exercise Performance 71151-EP01 09/21/2009 09/25/2009 1 IP ERO Drill Participation 71151-EP02 09/21/2009 09/25/2009 1 IP A lert & Notification System 71151-EP03 09/21/2009 09/25/2009 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems 7112201 10/19/2009 10/23/2009 1 IP Reactor Coolant System Activity 71151-BI01 10/19/2009 10/23/2009 1 IP RETS/ODCM Radiological Effluent 71151-PR01 10/19/2009 10/23/2009 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radiation Monitoring Instrumentation and Protective Equipment 7112103 11/16/2009 11/20/2009 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 01/25/2010 01/29/2010 1 IP A LARA Planning and Controls 7112102 01/25/2010 01/29/2010 1 IP Occupational Exposure Control Effectiveness 71151-OR01 01/25/2010 01/29/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Review of the Implementation of the Industry Ground Water Protection Voluntary Initiative 2515/173 03/01/2010 03/05/2010 1 IP Reactor Coolant System Activity 71151-BI01 03/01/2010 03/05/2010 1 IP RETS/ODCM Radiological Effluent 71151-PR01 03/01/2010 03/05/2010 ISFSI-ISFSI INSPECTION 2 1 IP Preoperational Testing of Independent Spent Fuel Storage Facility Installation at Operating Plants 60854.1 04/01/2010 09/30/2010 1 IP Operation of an Independent Spent Fuel Storage Installation at Operating Plants 60855.1 04/01/2010 09/30/2010 OL PREP-PERRY INIT PREP - APRIL 2010 3 1 OL - INITIAL EXAM - MAY 2010 - PERR W90223 04/19/2010 04/23/2010 OL EXAM-PERRY INIT EXAM - MAY 2010 3 1 OL - INITIAL EXAM - MAY 2010 - PERR W90223 05/10/2010 05/21/2010 BI ENG-ENGINEERING MODIFICATIONS / 50.59 3 1 IP Evaluations of Changes, Tests, or Experiments and Permanent Plant Modifications 7111117T 06/14/2010 07/02/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radiological Environmental Monitoring Program (REMP) And Radioactive Material Control Program 7112203 06/14/2010 06/18/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP Radioactive Material Processing and Transportation 7112202 08/23/2010 08/27/2010 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.

Inspection / Activity Plan Page 2 of 2 08/25/2009 Report 22 09/01/2009

-12/31/2010 Unit Number Planned Dates Start End Inspection Activity Title No. of Staff on Site Perry BI EP-EP EXERCISE INSPECTION / PI VERIFICATION 3 1 IP Exercise Evaluation 7111401 09/27/2010 10/01/2010 1 IP Drill/Exercise Performance 71151-EP01 09/27/2010 10/01/2010 1 IP ERO Drill Participation 71151-EP02 09/27/2010 10/01/2010 1 IP A lert & Notification System 71151-EP03 09/27/2010 10/01/2010 BI RP-RADIATION PROTECTION BASELINE INSPECTION 1 1 IP A ccess Control to Radiologically Significant Areas 7112101 11/15/2010 11/19/2010 1 IP A LARA Planning and Controls 7112102 11/15/2010 11/19/2010 BI OL-LIC. OPERATOR REQUAL. PROGRAM EVALUATION 2 1 IP Licensed Operator Requalification Program 7111111B 12/06/2010 12/10/2010 OL PREP-PERRY INIT PREP - DEC. 2010 3 1 OL - INITIAL EXAM - JAN 2011 - PERR W90232 12/20/2010 12/24/2010 This report does not include INPO and OUTAGE activities.

This report shows only on-site and announced inspection procedures.