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
uary 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
05000440/2009006-01 NCV Failure to Adhere to Procedures for Scaffold Affecting
Containment Systems (Section 4OA2.1)
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.
PLANT PROCEDURES
Number Description or Title Date or Revision
GCI-0016 Generic Civil Instruction: Scaffolding Rev. 15
Erection, Modification or Dismantling
Guidelines
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 & Rev. 00
Control Room Deficiencies
NOBP-LP-2100 FENOC Operating Experience Reference Rev. 3
Guide
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: Rev. 7
Temporary Instruction Control
SOI-P42 Emergency Closed Cooling System 9/11/2008
SOI-P47 Control Complex Chilled Water System 12/16/2008
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
Number Description or Title Date or Revision
CR 00-3709 DG Fuel Oil Strainer Differential Pressure 11/30/2000
Switch
CR 07-14232 Division 2 Emergency Service Water 02/08/2008
CR 07-14306 Inappropriate ASME Code Case Revision 02/08/2007
Applied to Support Prompt Operability
Determination for CR 07-14065
CR 07-16389 Initial License Class 05-01 NRC Exam 3/5/2007
Failures
CR 07-19058 EH-1201 Relay 86g1 Reset Step Missed In 4/22/2007
Svi-R43t1328
CR 07-20446 Unexpected Turbine Trip during Startup 05/13/2007
CR 07-20576 Reactor Scram During Digital Feedwater 05/15/2007
Control System Testing under TXI-373
Attachment
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 05/15/2007
Scram during Reactor Feedwater Pump
Turbine Digital Control Tuning
CR 07-20588 Training Issues - Reactor Scram during 05/15/2007
Reactor Feedwater Pump Turbine Digital
Control Tuning
CR 07-21864 -C-07-05-17 Operations Training Program 6/11/2007
Rated Marginally Effective
CR 07-22981 RHR B Min Flow Valve Disconnect Not 7/2/2007
Closed On Entering Cold Shutdown
CR 07-23175 Potential Mis-Interpretation Of Tech 7/9/2007
Spec 3.4.1 During Recirc Pump Trip Event
CR 07-24458 Common Cause of Site Issues 7/31/2007
CR 07-27641 Continuing FME Problems In Vicinity Of Open 10/2/2007
Pools And Vessels
CR 07-28746 Additional Concerns with Bolt Torque for 10/17/2007
Recirculation Flow Control Valves
CR 07-30660 RCIC System Tripped Shortly after Initiation 11/28/2007
CR 07-31437 Housekeeping and Potential Scaffold Issues 12/12/2007
in RCIC Room
CR 07-31788 RHR A Suction Press Low Alarm 12/20/2007
CR 08-34551 Limitorque Valve Operator Grease/Oil 1/28/2008
Separation
CR 08-35163 Unplanned Tech Spec Entry Which Declared 2/10/2008
ECC B And Associated Systems Inop
CR 08-35817 RHR A Suction Pressure Low Alarm 2/23/2008
Received On Pump Start
CR 08-37980 RCIC Venting for CA 07-30660-027 Is 2/14/2008
Causing Unnecessary Unavailability Time
CR 08-40969 High Pressure Core Spray Inoperable 5/28/2008
CR 08-41138 NRC NCV: Failure to Implement Appropriate 5/08/2008
RCIC Instrument Test Procedures
CR 08-41574 Cross Cutting Theme for Human Performance 06/10/2008
Aspect H.2(c), Documentation
CR 08-42164 NRC Questions on Protected Train Postings 06/21/2008
and Risk Assessment
CR 08-42974 Division 1 Diesel Generator Fuel Pump 7/9/2008
Strainer Dp High
CR 08-42982 Fuel Oil Strainer Differential Alarm Received 7/9/2008
During Division 1 EDG Operation
CR 08-43197 H.4(a) Cross Cutting Aspect Trend: Human 7/14/2008
Error prevention Technique
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 7/30/2008
Inadvertently Dropped into Manhole
CR 08-44438 Alternate Decay Heat Removal Work Impact 8/06/2008
Attachment
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 8/07/2008
Technical Basis to be Exceeded by
Concurrent Barrier Removal
CR 08-44634 Turbine Building Crane PM Activity in PMI- 8/12/2008
0039 Needs to be Updated and Revised
CR 08-44804 Weak Level of Documentation of Prompt 8/14/2008
Operability Determination (POD)
CR 08-46585 RHR C Min Flow Valve 1e12f0064c Closed 9/13/2008
On Pump Start
CR 08-47659 H.4(b) Cross Cutting Aspect Trend: 10/09/2008
Procedural Compliance
CR 08-48248 Third Quarter Trend Shows an Increase 10/22/2008
Trend - Human Error and Inappropriate
Action
CR 08-48768 Additional Controls for Movement of Light 10/31/2008
Loads
CR 08-48921 Protected Train Walkdown by Shift Manager 11/04/2008
Revealed Issues with Postings
CR 08-49842 NRC Third Quarter Inspection Report Finding: 10/31/2008
Fail to Implement Required Risk Management
for Protected Train
CR 08-50267 Oil Separation In MOV Operator 12/2/2008
CR 08-50270 Oil/Grease Separation In Operator
CR 08-50803 Excel Scaffold Not Meeting Procedure 12/12/2008
Requirements
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 1/23/2009
Needs Clarification
CR 09-52687 Locked Closed Valve Does Not Appear To Be 1/27/2009
Fully Closed
OPERATING EXPERIENCE
Number Description or Title Date or Revision
200237831 FENOC Evaluation of IN 2006-22 6/30/2007
200239207 FENOC Evaluation of SER 07-06 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 FENOC Evaluation of TR 7-57 9/18/2007
200294004 PY Evaluation of SOER 07-02 7/8/2008
200294208 FENOC Evaluation of TR 7-60 1/5/2009
200318117 FENOC Evaluation of IN 2008-02 3/21/2008
Attachment
OPERATING EXPERIENCE
Number Description or Title Date or Revision
200318386 FENOC Evaluation of IN 2008-04 4/9/2008
CR 02-03435 OE Evaluation of SOER 02-3 9/24/2002
CR 02-03435 OE SOER 02-3 Large Power Transformer 9/24/2002
Reliability
CR 04-05506 OE Evaluation of TR 4-40 10/20/2004
CR 05-02678 GE/GNF Notified the Site of a Potential Part 21 3/24/2005
Issue Affecting TS 2.1.1.1
CR 05-04199 Vendor Potential Reportable Condition due to 5/10/2005
Non-Conservatism in the R-Factor
CR 06-01358 10CFR21 Issued against Rosemount 1153 3/22/2006
pressure transmitters
CR 06-02757 Grand Gulf valve failure OE 22791 Div 1/2 DG 5/12/2006
susceptibility
CR 06-02895 Industry Experience of Unexpected Control 6/28/2006
Rod Fail-to-Settle Events
CR 07-14065 ESW B piping weld leak on outlet of ECC B 2/8/2007
Heat Ex.
CR 07-14235 NRC GL 07-01 Inaccessible or underground 2/8/2007
power cable failures
CR 08-37125 PY-PA-08-01: Organizational Response to 3/20/2008
NRC GL 2008-01 less than adequate
CR 08-44869 Late Coordination of field activities to support 8/15/2008
GL 08-01 laser scanning
CR 08-50367 Fisher 10CFR21 Notice Affects SW2930, 12/3/2008
Sw2931 and SW2932
CR 08-50515 PY Review of Fisher 10CFR21 Notice 2008-02 12/8/2008
OE 25127 Reactor Scram / Digital Feedwater Control 7/05/2007
System Logic Flaw
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 4/11/2008
Output Documents Not Identified
Audit-MS-C-08-05-07 Maintenance and Work Management 7/23/2008
Programs
Audit-MS-C-08-08-22 Composite Human Performance Indicator 4/18/2008
For 1st Qtr 2008
Attachment
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number Description or Title Date or Revision
AFI From PY-SA-08-012 GESILl -
CR 06-09998 159 Modification Not Implemented For 6/8/2008
RWCU Filter Demineralizers
CR 07-12910 Critical Component Failure Are Not Being 1/18/2007
Classified Correctly In The Cap Program
CR 07-14065 Pinhole Leak On "B" ESW Outlet From "B" 7/11/2008
ECC Hx
CR 07-14120 NRC event number 43071, Potential Part 21 1/9/2007
CR 07-14120 Snapshot Sa PY-SA-07-68 Found Design Silt 7/22/2008
Depth Exceeded In The ESW Intake Tunnel
CR 07-14232 Root Cause Analysis Report: Division 2 3/09/2007
Emergency Service Water System through
Wall Leakage Operability Review
CR 07-14306 Inappropriate ASME Code Case Revision 7/22/2008
Applied To Support Pod For Cr 07-14065
CR 07-19932 LTA 50.59 Review of Div. 2 DG Slow Start 5/3/2007
FEA
CR 07-19932 Py-Pa-07-02: LTA 50.59 Review Of Div. 2 Dg 7/22/2008
Slow Start Feature
CR 07-20446 Root Cause Report Main Turbine 6/12/2007
Unexpectedly Tripped
CR 07-20576 Root Cause Analysis Report: Automatic 6/20/2007
Level 3 Scram
CR 07-20585 Plant Restart And Testing And Oversight Plan 8/6/2008
CR 07-20587 Organizational Issues Evaluation - Rx Scram 10/13/2008
During RFPT Digital Controls Tuning
CR 07-20588 Training Issues - Reactor Scram During RFPT 10/22/2008
Digital Controls Tuning
CR 07-22860 HPCS ESW Draindown Test Portion Of SVIi 11/13/2008
P45 T2003 Failed.
CR 07-24458 Common Cause Of Site Issues 11/17/2008
CR 07-24847 Maintenance Enforcement Of Worker 12/11/2008
Standards - Continued Improvement
Required
CR 07-24847 Review Of CRs For Ineffective Corrective 8/8/2007
Actions Results In Emergent Trend
CR 07-25439 Non-Safety Lubricant Utilized on Safety 8/21/2007
Related Equipment without justification
CR 07-28806 Failure Of Work Management And Condition 10/18/2007
Report Process
CR 07-29242 EDG Hallway inspections not performed as 10/26/2007
required
CR 07-30660 and Root Cause Analysis Report: Reactor Core 2/19/2008
CR 07-31441 Isolation Cooling (RCIC) System Trip following
Plant Scram
CR 07-30676 RPV and RCS Transients vs ASME Fatigue 11/28/2007
Limits
Attachment
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number Description or Title Date or Revision
CR 07-31183 Cr 07-29026 Investigation Finds Chemistry's 12/7/2007
Ineffective Use Of Cap
CR 08-32531 Valve Found Out Of Position And Near 1/4/2008
Miss
CR 08-32972 Cross-Cutting Theme For Human Performance 1/17/2008
Aspect H.3.A, Work Control
CR 08-33656 2nd Half PYRC/PIU IPA AFI: LTA 1/17/2008
Implementation Of PI Processes
CR 08-34592 Review and process of significant event 1/30/2008
reports
CR 08-37049 MS-C-08-03-01 - MRB inappropriate corrective 3/18/2008
action
CR 08-3709 Pre-CDBI Investigate The Need To Flow 4/25/2008
Test The EDG Fuel Oil Eductors
CR 08-38929 MS-C-08-03-01 Inconsistent Implementation 4/11/2008
Of The Corrective Action Program
CR 08-39035 MS-C-08-03-01 Control Of Work On A Dg In 4/9/2008
Standby
CR 08-39275 Pre-CDBI - Minor Discrepancy In Design 4/25/2008
Minimum Flow Rate Value Shown In SVI
CR 08-39363 MS-C-08-03-01 Safety Equip Not Available To 4/25/2008
Support PEI
CR 08-39452 MS-C-08-03-01 Access To PEI Ladders Is 4/25/2008
Inhibited
CR 08-39873 MS-C-08-04-15: NOBP-NF-1013 References 5/5/2008
Outdated Nop-Cc-4001 Steps & Requirements
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 5/15/2008
Implemented As Written
CR 08-41630 Self-Assessment # PY-SA-08-092 - 5/29/2008
Addition Of Simulator Vendor Drs To
SCMS
CR 08-42032 MS-C-08-05-07: Risk Self Assessment Not 6/19/2008
Performed
CR 08-42034 MS-C-08-05-07: Use Of Loop Multipliers 6/19/2008
During Risk Evaluations
CR 08-43587 Snapshot Assmt PY-SA-08-091: Carb Actions 7/22/208
Not Taken, Effectiveness Review LTA
CR 08-43822 Ineffective Corrective Actions For Cr 04-06719 7/25/2008
Scram Vent And Drain Valves
CR 08-44698 Adverse Trend Identified In The Containment 8/13/2008
Air Lock Doors
CR 08-44852 Potential Cross Cutting Theme In Problem 7/29/2008
Identification And Resolution (PI&R)
CR 08-45397 Procedure Enhancement 8/27/2008
CR 08-45505 OE Program AFI - SOER Effectiveness 8/28/2008
reviews
Attachment
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 10/1/2008
Objective 3, Initial Training
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 10/15/2008
timely manner
CR 08-48385 MS-C-08-09--08 - Implementation Issues 10/24/2008
Regarding Delinquent M&TE
CR 08-48388 MS-C-08-09-08 - Delinquent M&TE Not 10/24/2008
Returned By The Due Date
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 6/14/2007
OE Program Utilizing Guidelines For The Use
Of operating Experience
PY-SA-07-087 Problem Solving and Decision Making 8/31/2008
PY-SA-08-020 Evaluate the actions taken to improve the 11/14/2008
Human Performance in the INPO identified
AFIs have been successful
PY-SA-08-058 Effectiveness of Corrective Actions for 7/31/2008
Contamination Control AFI - Tracked by CA
07-29353-4
PY-SA-08-091 Extent of Condition/Effectiveness Reviews 7/25/2008
Assessment
PY-SA-08-117 Follow up to Common Cause Analysis (CR 07- 10/28/2008
24458)
DRAWINGS
Date or Revision
Number Description or Title
C-937-333 Intermediate Building - Elevation 654-6 A
Miscellaneous Duct Supports
D-912-604 System Diagram: Containment Vessel and BB
Drywell Purge
D-936-742 Intermediate Building - Northwest Elevation E
654-6 - Duct Support Locations
CONDITION REPORTS GENERATED DURING INSPECTION
Number Description or Title Date or Revision
CR-09-51876 NRC PI&R 2009: All Part 21 Notifications are 1/12/2009
not routed through vendor coord.
Attachment
CONDITION REPORTS GENERATED DURING INSPECTION
Number Description or Title Date or Revision
CR-09-51882 NRC PI&R 2009: IN 2006-022 Evaluation not 1/12/2009
complete
CR-09-51896 NRC PI&R 2009; Incomplete CA Closure 1/13/2009
Documentation
CR-09-52038 Scaffold Not in Compliance with Plant 1/15/2009
Procedures
CR-09-52075 NRC PI&R 2009: Corrective Actions and PM 1/16/2009
not appropriately cross-referenced
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 1/23/2009
Procedures - No Prompt Operability
Determination Performed
CR-09-52476 NRC PI&R 2009; The EOC for CR 08-40969 1/23/2009
Needs Clarification and Increased Scope
CR-09-52641 NRC PI&R 2009 Indiv. Offered to Open HRA 1/27/2009
Lock for an Indiv. Not in his Work Crew.
CR-09-52670 NRC PI&R 2009: OE Evaluation of TR 7-57 1/28/2009
nor IAW procedure
CR-09-52687 Locked Closed Valve Does Not Appear To Be 1/27/2009
Fully Closed,
CR-09-52702 Engineering Evaluation Completed for Scaffold 1/27/2009
Configuration Identified in CR 09-52038 Was
Incorrect
CR-09-52756 NRC PI&R 2009; CR 08-34584 Analysis Did 1/29/2009
Not Address Problem Statement
CR-09-52772 Scaffolding Seismic Qualification Calculation 1/27/2009
Issues
MISCELLANEOUS
Number Description or Title Date or Revision
23:02.039 Calculation: Seismic Qualification of 1
Order 200299311 Perform RCIC Instrument Line and Transmitter 2/14/2008
Venting
Order 200299322 Perform RCIC Instrument Line and Transmitter 5/15/2008
Venting
Attachment
List of Acronyms Used:
CAP Corrective Action Program
CFR Code of Federal Regulations
CR Condition Report
ECP Employee Concerns Program
NCV Non-cited Violation
NRC Nuclear Regulatory Commission
OE Operating Experience
PI&R Problem Identification & Resolution
SCWE Safety Conscious Work Environment
TS Technical Specification
Attachment