IR 05000440/2009006
| ML090570686 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/25/2009 |
| From: | Jamnes Cameron NRC/RGN-III/DRP/B6 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| References | |
| IR-09-006 | |
| Download: ML090570686 (26) | |
Text
February 25, 2009
SUBJECT:
PERRY NUCLEAR POWER PLANT PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION 05000440/2009-006
Dear Mr. Bezilla:
On January 30, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed a routine biennial PI&R inspection at your Perry Nuclear Power Plant. The enclosed report documents the inspection results, which were discussed on January 30 with Mr. Kruger and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The team concluded that problems were properly identified, evaluated, and resolved within the corrective action program. The team also concluded that improvements have been made in the quality of root and full apparent cause analyses and in the handling of human performance issues. However, the team also concluded that the sites recognition and evaluation of potentially negative trends continues to be a challenge.
Based on the results of this inspection, one NRC-identified finding of very low safety significance was identified (Green). The finding was also a violation of NRC requirements.
However, because of the very low safety significance and because the issue was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors Office at the Perry Nuclear Power Plant. 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).
Sincerely,
/RA/
Jamnes L. Cameron, Chief Projects Branch 6 Division of Reactor Projects Docket Nos. 50-440 License Nos. NPF-58 Enclosure:
Inspection Report 05000346/2009006 w/Attachment: Supplemental Information
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
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. OClaire, State Liaison Officer, Ohio Emergency Management Agency
R. Owen, Ohio Department of Health
SUMMARY OF FINDINGS
IR 05000440/2009-006; 01/12/2009 - 01/30/2009; Perry Nuclear Power Plant, Unit 1; routine biennial Problem Identification and Resolution Inspection (PI&R).
This inspection was performed by four regional inspectors and the Perry Resident Inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Problem Identification and Resolution Based on the sample selected for review, the team concluded that implementation of the corrective action program (CAP) was adequate. The licensee had a low threshold for identifying problems and entering them in the CAP. Items entered into the CAP were screened and prioritized in a timely manner using established criteria; were properly evaluated commensurate with their safety significance; and corrective actions were generally implemented in a timely manner, commensurate with the safety significance.
The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies. On the basis of licensee self-assessments and interviews conducted during the inspection, workers at the site expressed freedom to raise safety concerns. The team observed that improvements have been made in the licensees identification and assessment of human performance issues and in root and full apparent cause analyses quality. While noting some improvement in the identification of negative trends, the team also noted that in at least one case the licensee had not identified a negative trend in an area previously highlighted by an NRC finding and associated non-cited violation.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Barrier Integrity
- Green.
A finding of very low safety significance and associated non-cited violation of Technical Specification 5.4, Procedures, was identified by the team for the failure to erect scaffolding in accordance with procedural requirements.
Specifically, scaffold constructed in the Intermediate Building had seismic bracing attached to a safety-related cable tray support and was connected to a duct support without an approved engineering document as specified in procedural requirements.
Although the licensee was able to demonstrate that the cable tray support and duct support were operable, the finding was determined to be more than minor because there was reasonable doubt that the licensee routinely performed engineering evaluations on similar scaffold issues. The finding was determined to be of very low safety significance because it did not represent an actual open pathway in the physical integrity of reactor containment. This finding had a cross-cutting aspect in the area of human performance, work practices, because the licensee failed to ensure supervisory and management oversight of work activities such that nuclear safety is supported. Specifically, the licensee failed to provide effective oversight of the erected seismic scaffold to ensure compliance with procedural requirements H.4(c). (Section 4OA2.1)
Licensee-Identified Violations
None.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
Completion of Sections
.1 through.4 constitutes one biennial sample of problem
identification and resolution as defined in Inspection Procedure 71152.
.1 Assessment of the CAP Effectiveness
a. Inspection Scope
The team reviewed the licensees corrective action program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.
The team reviewed risk and safety significant issues in the licensees CAP since January 2007. The selection of issues ensured an adequate review of issues across NRC cornerstones. The team used issues identified through NRC generic communications, department self-assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the team reviewed condition reports (CRs) generated as a result of facility personnels performance of daily plant activities. In addition, the team reviewed CRs and a selection of completed root cause, apparent cause, and common cause assessments.
The team specifically reviewed CRs associated with the residual heat removal (RHR) system and performed a partial system walkdown of the RHR system to ensure the condition of the system was appropriately portrayed by the corrective action program. In addition, the team observed new fuel unloading, inspection, and transfer to the fuel pool to assess the effectiveness of the licensees corrective actions associated with a root cause evaluation performed on its Foreign Material Exclusion program. Further, the team reviewed condition reports associated with open control room deficiencies, operator burdens, and operator work-arounds to assess the level of review and appropriateness of corrective actions.
The teams reviews were designed to determine whether the licensees actions were in compliance with the facilitys CAP and 10 CFR Part 50, Appendix B requirements. Specifically, the teams activities were designed to determine whether licensee personnel were identifying plant issues at the proper threshold, entering issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. In addition, the teams activities were to determine whether the licensee assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The team also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed assessments, and NRC findings, including non-cited violations.
b.
Assessment
- (1) Effectiveness of Problem Identification Overall, based on the description of the CAP, the number of condition reports (CRs) generated by all plant departments, and the types of issues in the program, the team concluded that the licensee was appropriately identifying issues and entering them into the CAP.
Observations The team identified that the licensee was identifying significantly more human performance issues than in the past and using the CAP to evaluate the conditions. For example CR 08-32531, Valve Found Out Of Position And Near Miss, provided insights into the human performance issues associated with an out-of-position reactor water cleanup valve. Another example was CR 08-47779, Unrecognized OPDRV Results in LER, where an individual questioned the results from a previously performed activity thus allowing the facility to address the issues in a broader context.
During the walkdown of the RHR system two issues were identified. A drain valve on the RHR C Heat Exchanger, while locked, was not fully closed as required by the locked valve program; observation of the valve stem indicated the valve to be about 10 percent open. This issue was reported to the site operations department and a condition report was written (CR 09-52687, CR 09-52687, Locked Closed Valve Does Not Appear To Be Fully Closed).
This issue was considered minor because there was a second closed valve in the series with the valve in question, the drain line was capped, and the licensee took prompt action to lock the second valve in the line. The second issue dealt with the use of keys to high radiation area doors. During the radiation protection briefing for access to the RHR rooms, radiation protection personnel informed the team members that they would be issued an electronic door key programmed to only open doors to rooms for which they had been briefed. During the briefing it was explained that the electronic keys were a corrective action to prevent individuals from entering rooms for which they had not been briefed. Following the briefing, when attempting to enter a RHR room, a worker at the gate, noting the team member having difficulty with the lock, offered to use his key to open the gate. Using a key issued to another work group to access locked radiation area would have violated station procedure and bypassed the corrective actions to earlier problems. This issue was considered minor because the area in question was locked due to a licensee administrative limit and the individual did not actually open the gate for the inspectors. The area was conservatively posted and no regulatory limits requiring posting were exceeded. This issue was reported to the site radiation protection department and a CR was written (CR 09-52641, NRC PI&R 2009, Individual Offered To Open HRA Lock For An Individual Not In His Work Crew).
While improvements were noted in the licensees identification of negative trends, for example the root cause evaluation for the containment airlock ball valve failures, (CR 08-44698, Adverse Trend Identified in the Containment Air Lock Doors), the team identified that the licensee had not identified a similar negative trend with scaffolding. Based on the teams questions related to scaffolding, a licensee search of scaffold program issues in the last 6 months of 2008 identified 41 related CRs and a potential adverse trend in the scaffold program. In addition, as detailed below, the team identified a scaffold where a required evaluation had not been performed. The licensee entered the concern into the corrective action program, CR 09-52450, Potential Adverse Trend in Scaffold Program, with a recommendation that a common cause evaluation be conducted to determine the cause of the apparent adverse trend.
Findings
- (1) Failure to Adhere to Procedures for Scaffold Affecting Containment Systems
Introduction:
A finding of very low safety significance and associated non-cited violation (NCV) of Technical Specifications (TS) 5.4, Procedures, was identified by the team for the licensee failing to adhere to Procedure GCI-0016 Scaffolding Erection, Modification, or Dismantling Guidelines.
Description:
On January 15, 2009, the team performed a walkdown of plant scaffolding. While at elevation 654-6 in the Intermediate Building, the team observed the configuration of scaffold number IB 654-05#18 for compliance with Procedure GCI-0016. The team observed that this scaffold had seismic bracing attached to an L4x3x3/8 structural angle component of cable tray support 1IB5-T7. Procedure GCI 0016 Scaffolding Erection, Modification, or Dismantling Guidelines, paragraph 5 of Attachment 4, Acceptance Pre-Approved Scaffold Points for External Seismic Bracing to Prevent Overturning and Lateral Movement Adjacent to Safety Related Components and Equipment, specified a minimum L4x4x3/8 structural angle. In addition, the team observed that vertical scaffold legs connected to Containment Drywell Purge exhaust duct support DS-IB-5015 were not in conformance with paragraph 13.b of Section 3.0, Precautions and Limitations, of Procedure GCI-0016.
The team noted that Procedure GCI-0016 specified the above procedural deviations be approved by an engineering document. The licensee confirmed that an engineering evaluation of these procedural deviations had not been performed.
Based on the observations, the team determined that the licensee failed to adhere to Procedure GCI-0016 for the installation of the scaffold 1B 654-05#18.
The licensee identified several nuclear safety-related circuits were routed through the cable tray at support 1IB5-T7 including containment atmosphere radiation monitor isolation valves associated with TS 3.6.1.3 and containment air lock isolation valves associated with TS 3.6.1.2.
In addition, the licensee identified that at-duct support DS-IB-5015, the Containment Drywell Purge exhaust duct is classified as non-nuclear safety-related. However, duct support DS-IB-5015 is classified as nuclear safety-related for Seismic II/I considerations, i.e., a structure not classified as Seismic Class I but whose failure due to a seismic event could affect the function of a seismic structure, system, or component. The licensee identified that a failure of this duct support could affect several nuclear safety related circuits routed through a nearby cable tray including containment atmosphere radiation monitor isolation valves associated with TS 3.6.1.3 and containment air lock isolation valves associated with TS 3.6.1.2.
Analysis:
The team determined that the failure to adhere to scaffold procedures affecting containment systems was contrary to TS 5.4 and was a performance deficiency.
The finding was determined to be more than minor because the finding was similar to Example 4a of IMC 0612, Appendix E. Although the licensee was able to demonstrate that cable tray support 1IB5-T7 and duct support DS-IB-5015 were operable, there was reasonable doubt that the licensee routinely performed engineering evaluations on similar scaffold issues. Therefore, this performance deficiency impacted the Barrier Integrity Cornerstone objective to provide reasonable assurance that physical barriers (containment) protect the public from radio-nuclide releases caused by accidents or events.
The team determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Barrier Integrity Cornerstone. Specifically, since all four questions under the Containment Barrier column were answered no, the finding was determined to be Green, of very low safety significance, because it did not represent an actual open pathway in the physical integrity of reactor containment.
This finding had a cross-cutting aspect in the area of human performance, work practices, because the licensee failed to ensure supervisory and management oversight of work activities such that nuclear safety is supported. Specifically, the licensee failed to provide effective oversight of erected seismic scaffold to ensure compliance with procedural requirements. H.4(c)
Enforcement:
Technical Specification Section 5.4.1 states, in part, that Written procedures shall be established, implemented, and maintained covering the following activities: The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Paragraph 9.a of Appendix A of this Regulatory Guide states, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures appropriate to the circumstances. The licensee established Procedure GCI-0016 as the implementing procedure for scaffolding erection, modification, or dismantling.
Paragraph 13.b of Section 3.0 of Procedure GCI-0016 states, in-part, unless specifically approved by this instruction, scaffolds shall not be connected to, or in contact with any plant equipment, piping, conduits, cable trays, HVAC supports, unless approved by an engineering document. Paragraph 5 of Attachment 4 of Procedure GCI-0016 allowed attachment of scaffold seismic bracing to cable tray support member sizes (angle size) L4x4x3/8 or larger.
Contrary to the above, on January 15, 2009, scaffold IB 654-05#18, was not erected in accordance with Procedure GCI-0016 and no engineering analysis was performed. Specifically, scaffold seismic bracing was attached to an L4x3x3/8 structural angle component of cable tray support 1IB5-T7 and the scaffold was connected to duct support DS-IB-5015 without an approved engineering document. Because this violation was of very low safety significance and it was entered into the licensees corrective action program as CRs 09-52038, Scaffold Not in Compliance with Plant Procedures, and 09-52474, Scaffold Not in Compliance with Plant Procedures - No Prompt Operability Determination Performed, this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy (NCV 05000440/2009006-01).
- (2) Effectiveness of Prioritization and Evaluation of Issues The team concluded that issue resolutions established and monitored through the management review board and the corrective action review board were correctly assigned significance and priority in accordance with station procedures. The team noted an improvement in the completeness of root and full apparent cause evaluations compared to previous inspections. While the team had questions on numerous evaluations, the evaluations were mainly categorized as limited apparent cause or fix type issues, where in the past the questions involved full apparent or root cause evaluations. The reduction in questions on full apparent and root cause evaluations indicated an overall improvement in the quality of the licensees implementation of these assessment tools.
Findings No findings of significance were identified.
- (3) Effectiveness of Corrective Actions The team concluded that the corrective action program was generally effective in addressing identified issues. The effectiveness of the program is hampered by the licensee not consistently identifying negative trends thereby only addressing individual issues, as was the case with the scaffolding issue noted above. As previously noted, the team identified that the licensee was identifying more human performance issues and using the CAP to evaluate the items. In reviewing the corrective actions associated with human performance issues, the team concluded that the actions were appropriate; however, the corrective actions have not been in place for a sufficient amount of time to allow for a conclusive assessment of their effectiveness.
The team did identify a number of examples where assessments have had a positive impact on the facility. For example, in CR 08-44698, Adverse Trend Identified in the Containment Air Lock Doors, the licensee stepped back from the individual failures with the air locks and they were able to effectively identify and address a number of process deficiencies.
Findings No findings of significance were identified.
.2 Assessment of the Use of Operating Experience (OE)
a. Inspection Scope
The team reviewed the licensees implementation of its Operating Experience (OE) program. Specifically, the team reviewed implementing operating experience program procedures, attended OE program meetings to observe the use, disposition, and dissemination of OE information, and reviewed OE performance indicators. In addition, the team reviewed completed evaluations of OE issues and events identified through NRC generic communications, reports made under 10 CFR Part 21, and external and internal OE. The team also compared the information provided in the vendor manuals of the low pressure core spray (LPCS) pump and motor with the licensees procedures and equipment environmental qualification. The teams review was to determine whether the licensee effectively integrated OE experience into the performance of daily activities, whether evaluations of issues were proper and conducted by qualified personnel, whether the licensees program was sufficient to prevent occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits.
The team also assessed whether corrective actions, as a result of OE experience, were identified, and effectively and timely implemented.
b.
Assessment The team noted that the OE program has improved and that, as a result of a recent self-assessment and condition report, the licensee has several corrective actions in place or being implemented to improve the program. The corrective actions seek to improve the thoroughness and timeliness of OE evaluations, the dissemination of OE information, and other areas determined to have vulnerabilities like the OE program procedure. The team did not have any major observations that were not already being addressed by the licensees CAP at the time of this inspection.
Observations Timeliness of OE evaluations has improved The team noted that the backlog of OE evaluations at the corporate level has decreased. Specifically, the licensees performance indicators show that the number of overdue OE evaluations decreased from 125 in January of 2008 to 15 in December 2008. The team noted, however, that the evaluation of NRC Information Notice (IN) 2006-022, New Ultra-low-sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance, had not been complete by the time it was requested as a sample for this inspection. The licensee received this IN during the last quarter of 2006 and completed the evaluation during this inspection; exceeding its 60 day goal to evaluate OE. This timeliness issue was documented by the licensee in CR 09-51882 NRC PI&R 2009: IN 2006-022 Evaluation not complete.
Potential missed opportunities to identify an adverse condition exists The team noted that some OE evaluations determined that existing procedures were adequate to address the issues communicated by the OE notifications without a thorough explanation of the basis for this determination. Even though the conclusions may be correct, not documenting why the procedures were adequate to address the OE could lead to a potential missed opportunity to identify an adverse condition.
In addition, it was noted during this inspection that the Vendor Information Coordinator, who is responsible for tracking all Part 21 notifications, may not be receiving all the Part 21 notifications. The licensee initiated CR 09-51876, NRC PI&R 2009: All Part 21 Notifications are not routed through vendor coord, to review and address this issue.
Findings No findings of significance were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The team assessed the licensees 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.
b.
Assessment The programs for self-assessments and audits were scheduled and included a broad cross section of performance areas. Procedures for performing assessments were in place and implemented providing guidance and consistency. For the audits and assessments reviewed, observations were documented and for deficiencies that were identified, CRs were written and evaluated to address the deficiencies. Overall, self-assessments were adequately performed. The team noted that self-assessments and audits were identifying more human performance issues than in the past.
The team noted an instance where the Oversight Department identified an issue with an evaluation. Specifically, the licensee determined during a prompt operability determination that a revision to a 10 CFR 50.59 evaluation was not needed. However, because of QA intervention, the process was followed and a revision to the 10 CFR 50.59 evaluation was performed.
A self assessment of the OE program had recently been performed. This assessment was thorough and well organized. The issues that were identified were evaluated appropriately and corrective action assigned. The assessment conclusions closely matched those of the inspection team.
Findings No findings of significance were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The team assessed the licensees safety conscious work environment through discussions with the employee concern program coordinator, interviews with 24 individuals from various departments, and review of the licensees 2008 Safety Conscious Work Environment (SCWE) survey.
b.
Assessment As part of its ongoing assessment of SCWE, the licensee used an anonymous survey tool first developed in 2002 at the Davis-Besse facility. Results for 2008 indicated no significant areas of overall weakness in a safety conscious work environment, although some organizations were notably more negative in their perceptions of management. The team noted that the survey was returned by approximately 71 percent of the staff. The survey also included security staff and contractors. Based on its review of the survey and interviews, the team concluded that the licensee staff was willing to raise safety concerns without fear of negative consequences.
The team also noted one technical issue brought to the ECP coordinator was appropriately placed in CAP for evaluation.
c. Findings
No findings of significance were identified.
4OA6 Management Meetings
Exit Meeting Summary
On January 30, 2009, the team presented the inspection results to Mr. Kruger and other members of the licensees staff. The licensees staff acknowledged the issues presented. The team confirmed that none of the potential report inputs discussed was considered proprietary.
SUPPLEMENTAL INFORMATION
Key Points of Contact
Licensee
- K. Krueger, Plant General Manager
- A. Cayia, Director, Performance Improvement
- K. Cimorelli, Director, Maintenance
- J. Grabner, Director, Site Engineering
- R. Coad, Manager, Regulatory Compliance
- A. Mueller, Manager, Training
- L. Lindrose, Manager, Security
- M. Wesley, Manager, Maintenance
- T. Hilston, Manager, Design Engineering
- F. Smith, Manager Emergency Planning
P McNulty, Manger, Radiation Protection
- C. Elberfeld, Supervisor, Nuclear Compliance
- V. Forbuch, Human Performance
LIST OF ITEMS OPENED, CLOSED, DISCUSSED
Opened and Closed
Failure to Adhere to Procedures for Scaffold Affecting
Containment Systems (Section 4OA2.1)
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.
PLANT PROCEDURES
Number
Description or Title
Date or Revision
GCI-0016
Generic Civil Instruction: Scaffolding
Erection, Modification or Dismantling
Guidelines
Rev. 15
NOPB-LP-2011
FENOC Cause Analysis
Rev. 07
NOP-LP-2001
Corrective Action Program
Rev. 19
NOBP-LP-2008
FENOC Corrective Action Review Board
Rev. 8
NOBP-OP-0012
Operator Work Arounds, Burdens &
Control Room Deficiencies
Rev. 00
NOBP-LP-2100
FENOC Operating Experience Reference
Guide
Rev. 3
NOP-LP-2100
Operating Experience
Rev. 3
NOP-WM-1001
Order Planning Process
Rev. 10
NOP-WM-4300
Order Execution Process
Rev. 6
PAP-1107
Plant Administrative Procedure:
Temporary Instruction Control
Rev. 7
SOI-P42
Emergency Closed Cooling System
9/11/2008
SOI-P47
Control Complex Chilled Water System
2/16/2008
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Date or Revision
CR 00-3709
DG Fuel Oil Strainer Differential Pressure
Switch
11/30/2000
CR 07-14232
Division 2 Emergency Service Water
2/08/2008
CR 07-14306
Inappropriate ASME Code Case Revision
Applied to Support Prompt Operability
Determination for CR 07-14065
2/08/2007
CR 07-16389
Initial License Class 05-01 NRC Exam
Failures
3/5/2007
CR 07-19058
EH-1201 Relay 86g1 Reset Step Missed In
Svi-R43t1328
4/22/2007
CR 07-20446
Unexpected Turbine Trip during Startup
05/13/2007
CR 07-20576
Reactor Scram During Digital Feedwater
Control System Testing under TXI-373
05/15/2007
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Date or Revision
CR 07-20585
Plant Restart and Testing and Oversight Plan
05/15/2007
CR 07-20587
Organizational Issues Evaluation - Reactor
Scram during Reactor Feedwater Pump
Turbine Digital Control Tuning
05/15/2007
CR 07-20588
Training Issues - Reactor Scram during
Reactor Feedwater Pump Turbine Digital
Control Tuning
05/15/2007
CR 07-21864
-C-07-05-17 Operations Training Program
Rated Marginally Effective
6/11/2007
CR 07-22981
RHR B Min Flow Valve Disconnect Not
Closed On Entering Cold Shutdown
7/2/2007
CR 07-23175
Potential Mis-Interpretation Of Tech Spec 3.4.1 During Recirc Pump Trip Event
7/9/2007
CR 07-24458
Common Cause of Site Issues
7/31/2007
CR 07-27641
Continuing FME Problems In Vicinity Of Open
Pools And Vessels
10/2/2007
CR 07-28746
Additional Concerns with Bolt Torque for
Recirculation Flow Control Valves
10/17/2007
CR 07-30660
RCIC System Tripped Shortly after Initiation
11/28/2007
CR 07-31437
Housekeeping and Potential Scaffold Issues
in RCIC Room
2/12/2007
CR 07-31788
RHR A Suction Press Low Alarm
2/20/2007
CR 08-34551
Limitorque Valve Operator Grease/Oil
Separation
1/28/2008
CR 08-35163
Unplanned Tech Spec Entry Which Declared
ECC B And Associated Systems Inop
2/10/2008
CR 08-35817
RHR A Suction Pressure Low Alarm
Received On Pump Start
2/23/2008
CR 08-37980
RCIC Venting for CA 07-30660-027 Is
Causing Unnecessary Unavailability Time
2/14/2008
CR 08-40969
High Pressure Core Spray Inoperable
5/28/2008
CR 08-41138
NRC NCV: Failure to Implement Appropriate
RCIC Instrument Test Procedures
5/08/2008
CR 08-41574
Cross Cutting Theme for Human Performance
Aspect H.2(c), Documentation
06/10/2008
CR 08-42164
NRC Questions on Protected Train Postings
and Risk Assessment
06/21/2008
CR 08-42974
Division 1 Diesel Generator Fuel Pump
Strainer Dp High
7/9/2008
CR 08-42982
Fuel Oil Strainer Differential Alarm Received
During Division 1 EDG Operation
7/9/2008
CR 08-43197
H.4(a) Cross Cutting Aspect Trend: Human
Error prevention Technique
7/14/2008
CR 08-43277
Oil Leaking From Valve Gearbox
7/15/2008
CR 08-43483
RHR Pump Min Flow Valve Found Closed
7/20/2008
CR 08-43997
Non-Safety Electrical Manhole Cover
Inadvertently Dropped into Manhole
7/30/2008
CR 08-44438
Alternate Decay Heat Removal Work Impact
8/06/2008
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number
Description or Title
Date or Revision
Due to Reinstallation of Floor Plugs
CR 08-44524
Potential for Engineering Evaluation Requests
Technical Basis to be Exceeded by
Concurrent Barrier Removal
8/07/2008
CR 08-44634
Turbine Building Crane PM Activity in PMI-
0039 Needs to be Updated and Revised
8/12/2008
CR 08-44804
Weak Level of Documentation of Prompt
Operability Determination (POD)
8/14/2008
CR 08-46585
RHR C Min Flow Valve 1e12f0064c Closed
On Pump Start
9/13/2008
CR 08-47659
H.4(b) Cross Cutting Aspect Trend:
Procedural Compliance
10/09/2008
CR 08-48248
Third Quarter Trend Shows an Increase
Trend - Human Error and Inappropriate
Action
10/22/2008
CR 08-48768
Additional Controls for Movement of Light
Loads
10/31/2008
CR 08-48921
Protected Train Walkdown by Shift Manager
Revealed Issues with Postings
11/04/2008
CR 08-49842
NRC Third Quarter Inspection Report Finding:
Fail to Implement Required Risk Management
for Protected Train
10/31/2008
CR 08-50267
Oil Separation In MOV Operator
2/2/2008
CR 08-50270
Oil/Grease Separation In Operator
CR 08-50803
Excel Scaffold Not Meeting Procedure
Requirements
2/12/2008
CR 09-51818
RHR A Hx Outlet Valve Has A 200 DPM
1/9/2009
CR 09-52476
NRC PI&R 2009: The EOC For Cr 08-40969
Needs Clarification
1/23/2009
CR 09-52687
Locked Closed Valve Does Not Appear To Be
Fully Closed
1/27/2009
OPERATING EXPERIENCE
Number
Description or Title
Date or Revision
200237831
FENOC Evaluation of IN 2006-22
6/30/2007
200239207
1/7/2007
200251244
FENOC Evaluation of IN 2007-01
4/8/2007
200252088
FENOC Evaluation of IN 2007-05
4/15/2007
200252089
FENOC Evaluation of IN 2007-06
2/15/2007
200267694
9/18/2007
200294004
PY Evaluation of SOER 07-02
7/8/2008
200294208
1/5/2009
200318117
FENOC Evaluation of IN 2008-02
3/21/2008
OPERATING EXPERIENCE
Number
Description or Title
Date or Revision
200318386
FENOC Evaluation of IN 2008-04
4/9/2008
CR 02-03435
9/24/2002
CR 02-03435
OE SOER 02-3 Large Power Transformer
Reliability
9/24/2002
CR 04-05506
10/20/2004
CR 05-02678
GE/GNF Notified the Site of a Potential Part 21
Issue Affecting TS 2.1.1.1
3/24/2005
CR 05-04199
Vendor Potential Reportable Condition due to
Non-Conservatism in the R-Factor
5/10/2005
CR 06-01358
10CFR21 Issued against Rosemount 1153
pressure transmitters
3/22/2006
CR 06-02757
Grand Gulf valve failure OE 22791 Div 1/2 DG
susceptibility
5/12/2006
CR 06-02895
Industry Experience of Unexpected Control
Rod Fail-to-Settle Events
6/28/2006
CR 07-14065
ESW B piping weld leak on outlet of ECC B
Heat Ex.
2/8/2007
CR 07-14235
NRC GL 07-01 Inaccessible or underground
power cable failures
2/8/2007
CR 08-37125
PY-PA-08-01: Organizational Response to
NRC GL 2008-01 less than adequate
3/20/2008
CR 08-44869
Late Coordination of field activities to support
GL 08-01 laser scanning
8/15/2008
CR 08-50367
Fisher 10CFR21 Notice Affects SW2930,
Sw2931 and SW2932
2/3/2008
CR 08-50515
PY Review of Fisher 10CFR21 Notice 2008-02
2/8/2008
OE 25127
Reactor Scram / Digital Feedwater Control
System Logic Flaw
7/05/2007
PAP-0607
Document and Vendor Information Control
Rev. 11
SOI-E21
LPCS System
Rev. 22
SVI-E21-T2001
LPCS Pump and Valve Operability Test
Rev. 20
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number
Description or Title
Date or Revision
Audit-MS-C-06-10-07 Preventable Equipment Failures Challenges
2/7/2008
Audit-MS-C-08-05-07 Perry CDBI Pre-Assessment PY-SA-08-079
Output Documents Not Identified
4/11/2008
Audit-MS-C-08-05-07
Maintenance and Work Management
Programs
7/23/2008
Audit-MS-C-08-08-22 Composite Human Performance Indicator
For 1st Qtr 2008
4/18/2008
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number
Description or Title
Date or Revision
CR 06-09998
AFI From PY-SA-08-012 GESILl -
159 Modification Not Implemented For
RWCU Filter Demineralizers
6/8/2008
CR 07-12910
Critical Component Failure Are Not Being
Classified Correctly In The Cap Program
1/18/2007
CR 07-14065
Pinhole Leak On "B" ESW Outlet From "B"
ECC Hx
7/11/2008
CR 07-14120
NRC event 43071, Potential Part 21
1/9/2007
CR 07-14120
Snapshot Sa PY-SA-07-68 Found Design Silt
Depth Exceeded In The ESW Intake Tunnel
7/22/2008
CR 07-14232
Root Cause Analysis Report: Division 2
Emergency Service Water System through
Wall Leakage Operability Review
3/09/2007
CR 07-14306
Inappropriate ASME Code Case Revision
Applied To Support Pod For Cr 07-14065
7/22/2008
CR 07-19932
LTA 50.59 Review of Div. 2 DG Slow Start
FEA
5/3/2007
CR 07-19932
Py-Pa-07-02: LTA 50.59 Review Of Div. 2 Dg
Slow Start Feature
7/22/2008
CR 07-20446
Root Cause Report Main Turbine
Unexpectedly Tripped
6/12/2007
CR 07-20576
Root Cause Analysis Report: Automatic
Level 3 Scram
6/20/2007
CR 07-20585
Plant Restart And Testing And Oversight Plan
8/6/2008
CR 07-20587
Organizational Issues Evaluation - Rx Scram
During RFPT Digital Controls Tuning
10/13/2008
CR 07-20588
Training Issues - Reactor Scram During RFPT
Digital Controls Tuning
10/22/2008
CR 07-22860
HPCS ESW Draindown Test Portion Of SVIi
P45 T2003 Failed.
11/13/2008
CR 07-24458
Common Cause Of Site Issues
11/17/2008
CR 07-24847
Maintenance Enforcement Of Worker
Standards - Continued Improvement
Required
2/11/2008
CR 07-24847
Review Of CRs For Ineffective Corrective
Actions Results In Emergent Trend
8/8/2007
CR 07-25439
Non-Safety Lubricant Utilized on Safety
Related Equipment without justification
8/21/2007
CR 07-28806
Failure Of Work Management And Condition
Report Process
10/18/2007
CR 07-29242
EDG Hallway inspections not performed as
required
10/26/2007
CR 07-30660 and
CR 07-31441
Root Cause Analysis Report: Reactor Core
Isolation Cooling (RCIC) System Trip following
Plant Scram
2/19/2008
CR 07-30676
RPV and RCS Transients vs ASME Fatigue
Limits
11/28/2007
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number
Description or Title
Date or Revision
CR 07-31183
Cr 07-29026 Investigation Finds Chemistry's
Ineffective Use Of Cap
2/7/2007
CR 08-32531
Valve Found Out Of Position And Near
Miss
1/4/2008
CR 08-32972
Cross-Cutting Theme For Human Performance
Aspect H.3.A, Work Control
1/17/2008
CR 08-33656
2nd Half PYRC/PIU IPA AFI: LTA
Implementation Of PI Processes
1/17/2008
CR 08-34592
Review and process of significant event
reports
1/30/2008
CR 08-37049
MS-C-08-03-01 - MRB inappropriate corrective
action
3/18/2008
CR 08-3709
Pre-CDBI Investigate The Need To Flow
Test The EDG Fuel Oil Eductors
4/25/2008
CR 08-38929
MS-C-08-03-01 Inconsistent Implementation
Of The Corrective Action Program
4/11/2008
CR 08-39035
MS-C-08-03-01 Control Of Work On A Dg In
Standby
4/9/2008
CR 08-39275
Pre-CDBI - Minor Discrepancy In Design
Minimum Flow Rate Value Shown In SVI
4/25/2008
CR 08-39363
MS-C-08-03-01 Safety Equip Not Available To
Support PEI
4/25/2008
CR 08-39452
MS-C-08-03-01 Access To PEI Ladders Is
Inhibited
4/25/2008
CR 08-39873
MS-C-08-04-15: NOBP-NF-1013 References
Outdated Nop-Cc-4001 Steps & Requirements
5/5/2008
CR 08-40311
MS-C-08-03-01 Clearance Program Shortfalls.
5/14/2008
CR 08-40395
Root Cause Corrective Action 07-20576-8 Not
Implemented As Written
5/15/2008
CR 08-41630
Self-Assessment # PY-SA-08-092 -
Addition Of Simulator Vendor Drs To
SCMS
5/29/2008
CR 08-42032
MS-C-08-05-07: Risk Self Assessment Not
Performed
6/19/2008
CR 08-42034
MS-C-08-05-07: Use Of Loop Multipliers
During Risk Evaluations
6/19/2008
CR 08-43587
Snapshot Assmt PY-SA-08-091: Carb Actions
Not Taken, Effectiveness Review LTA
7/22/208
CR 08-43822
Ineffective Corrective Actions For Cr 04-06719
Scram Vent And Drain Valves
7/25/2008
CR 08-44698
Adverse Trend Identified In The Containment
Air Lock Doors
8/13/2008
CR 08-44852
Potential Cross Cutting Theme In Problem
Identification And Resolution (PI&R)
7/29/2008
CR 08-45397
Procedure Enhancement
8/27/2008
CR 08-45505
OE Program AFI - SOER Effectiveness
reviews
8/28/2008
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number
Description or Title
Date or Revision
CR 08-45509
OE Program AFI - OE in work packages
8/28/2008
CR 08-47153
PY-PA-08-03 Finding: Adverse Trend In
Objective 3, Initial Training
10/1/2008
CR 08-47206
Neg. Note. Item ID'D In Tech. Skills Prgm. SA
9/26/2008
CR 08-47779
Unrecognized OPDRV Results In LER
10/13/2008
CR 08-47895
MS-C-08-08-22: CA not responded to in
timely manner
10/15/2008
CR 08-48385
MS-C-08-09--08 - Implementation Issues
Regarding Delinquent M&TE
10/24/2008
CR 08-48388
MS-C-08-09-08 - Delinquent M&TE Not
Returned By The Due Date
10/24/2008
CR 09-51621
Untimely Review of TR 6-56
1/6/2009
FL-SA-08-004
Focused SA - Operating Experience Program
9/5/2008
PY-SA-07-025
Perform A Ongoing Self-Assessment Of The
OE Program Utilizing Guidelines For The Use
Of operating Experience
6/14/2007
PY-SA-07-087
Problem Solving and Decision Making
8/31/2008
PY-SA-08-020
Evaluate the actions taken to improve the
Human Performance in the INPO identified
AFIs have been successful
11/14/2008
PY-SA-08-058
Effectiveness of Corrective Actions for
Contamination Control AFI - Tracked by CA
07-29353-4
7/31/2008
PY-SA-08-091
Extent of Condition/Effectiveness Reviews
Assessment
7/25/2008
PY-SA-08-117
Follow up to Common Cause Analysis (CR 07-
24458)
10/28/2008
DRAWINGS
Number
Description or Title
Date or Revision
C-937-333
Intermediate Building - Elevation 654-6
Miscellaneous Duct Supports
A
D-912-604
System Diagram: Containment Vessel and
Drywell Purge
BB
D-936-742
Intermediate Building - Northwest Elevation
654-6 - Duct Support Locations
E
CONDITION REPORTS GENERATED DURING INSPECTION
Number
Description or Title
Date or Revision
CR-09-51876
NRC PI&R 2009: All Part 21 Notifications are
not routed through vendor coord.
1/12/2009
CONDITION REPORTS GENERATED DURING INSPECTION
Number
Description or Title
Date or Revision
CR-09-51882
NRC PI&R 2009: IN 2006-022 Evaluation not
complete
1/12/2009
CR-09-51896
NRC PI&R 2009; Incomplete CA Closure
Documentation
1/13/2009
CR-09-52038
Scaffold Not in Compliance with Plant
Procedures
1/15/2009
CR-09-52075
NRC PI&R 2009: Corrective Actions and PM
not appropriately cross-referenced
1/16/2009
CR 09-52385
NRC PI&R 2009 Ca Inappropriately Closed
1/22/2009
CR-09-52450
Potential Adverse Trend in Scaffold Program
1/23/2009
CR-09-52474
Scaffold Not in Compliance with Plant
Procedures - No Prompt Operability
Determination Performed
1/23/2009
CR-09-52476
NRC PI&R 2009; The EOC for CR 08-40969
Needs Clarification and Increased Scope
1/23/2009
CR-09-52641
NRC PI&R 2009 Indiv. Offered to Open HRA
Lock for an Indiv. Not in his Work Crew.
1/27/2009
CR-09-52670
NRC PI&R 2009: OE Evaluation of TR 7-57
nor IAW procedure
1/28/2009
CR-09-52687
Locked Closed Valve Does Not Appear To Be
Fully Closed,
1/27/2009
CR-09-52702
Engineering Evaluation Completed for Scaffold
Configuration Identified in CR 09-52038 Was
Incorrect
1/27/2009
CR-09-52756
NRC PI&R 2009; CR 08-34584 Analysis Did
Not Address Problem Statement
1/29/2009
CR-09-52772
Scaffolding Seismic Qualification Calculation
Issues
1/27/2009
MISCELLANEOUS
Number
Description or Title
Date or Revision
23:02.039
Calculation: Seismic Qualification of
Order 200299311
Perform RCIC Instrument Line and Transmitter
Venting
2/14/2008
Order 200299322
Perform RCIC Instrument Line and Transmitter
Venting
5/15/2008
List of Acronyms Used:
Corrective Action Program
CFR
Code of Federal Regulations
CR
Condition Report
Employee Concerns Program
Non-cited Violation
NRC
Nuclear Regulatory Commission
Operating Experience
Problem Identification & Resolution
Safety Conscious Work Environment
TS
Technical Specification