IR 05000440/2012007

IR 05000440-12-007; Firstenergy Nuclear Operating Company; on 01/09/2012 - 01/27/2012 Perry Nuclear Plant Unit 1, NRC Problem Identification and Resolution Inspection Report

ML12066A195
Person / Time
Site:	Perry
Issue date:	03/06/2012
From:	Jack Giessner Reactor Projects Region 3 Branch 4
To:	Emily Larson FirstEnergy Nuclear Operating Co
References
IR-12-007
Download: ML12066A195 (26)

Text

UNITED STATES rch 6, 2012

SUBJECT:

PERRY NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2012007

Dear Mr. Larson:

On January 27, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution (PI&R) team inspection at your Perry Nuclear Power Plant. The enclosed inspection report documents the inspection results which were discussed on January 27, 2012, with Mr. V. Kaminskas and other members of your staff.

The inspection is an additional inspection of your Problem Identification and Resolution processes authorized by Inspection Manual Chapter 0305, Operating Reactor Assessment Program, Section 10.02c.5, for plants that have entered Action Matrix Column 3, Degraded Cornerstone. 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.

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Perry Nuclear was adequate. Licensee-Identified problems were entered into the corrective action program at a low threshold. Problems were generally prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems, although there were examples where causes of problems were not effectively addressed. Lessons learned from industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions.

Based on the results of this inspection, no findings were identified. However, If you disagree with a characterization of an issue in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for you disagreement, to the Regional Administrator, Region III; and the NRC Resident Inspector 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, its enclosure, and the response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Document Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket No. 50-440 License No. NPF-58

Enclosure:

Inspection Report 05000440/2012007 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-440 License No: NPF-58 Report No: 05000440/2012007 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Perry Nuclear Power Plant, Unit 1 Location: Perry, Ohio Dates: January 9, 2012, through January 27, 2012 Inspectors: J. Rutkowski, Project Engineer, Team Lead T. Hartman, Resident Inspector C. Brown, Regional Inspector Z. Falevits, Senior Regional Inspector Approved by: John B. Giessner, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000440/2012007; 01/09/2012 - 01/27/2012; Perry Nuclear Power

Plant, Unit 1; Non-Routine Problem Identification and Resolution Inspection.

This inspection was performed by three NRC regional inspectors and the Perry resident inspector. The significance of most findings is indicated by their color (Green, White, Yellow,

Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. 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 On the basis of the activities selected for review, the team concluded that implementation of the problem and identification process and the corrective action program (CAP) at Perry Nuclear Plant had varying elements of effectiveness. The licensee normally had a low threshold for identifying problems and entering them in the CAP with some instances of condition reports not generated until after identification by the resident inspectors. Items entered into the CAP were screened and prioritized in a timely manner using established criteria and were evaluated commensurate with their safety significance. However, the thoroughness and effectiveness of some evaluations was found deficient by the team and by licensee audits and self-assessments.

The issues with the effectiveness of evaluations including the effectiveness of identifying root and contributing causes, contributed to corrective actions not consistently correcting conditions.

The team concluded the licensees overall implementation of actions that correct issues and prevent recurrence of issues was marginally effective. The team noted that the licensee reviewed Operating Experience (OE) 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 interviews conducted during the inspection, workers at the site expressed freedom to enter nuclear safety concerns into the CAP or to report them to supervision.

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA2 Problem Identification and Resolution

The activities documented in Sections

.1 through .4 constituted one sample of problem

identification and resolution as defined in Inspection Procedure (IP) 71152.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees Corrective Action Program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC Problem Identification and Resolution (PI&R) inspection in November 2010. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self assessment, licensee audits, operating experience reports, and NRC documented findings as sources to select issues.

Additionally, the inspectors reviewed condition reports (CRs) generated for equipment issues and as a result of facility personnels performance in daily plant activities. In addition, the inspectors reviewed licensee self assessments and a selection of completed investigations from the licensees various investigation methods, which included root cause, apparent cause, equipment apparent cause, and common cause investigations.

The inspectors selected Emergency Power Systems, which included the plants emergency diesel generators, to review in detail. The inspectors review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs including the licensees implementation of their Maintenance Rule Program.

A 5 year review on the emergency diesel generators and associated systems was undertaken to assess the licensee staffs efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of low pressure core spray and emergency closed cooling water. A walkdown of select radioactive waste storage areas was also conducted.

During the reviews, the inspectors determined whether the licensee staffs actions were in compliance with the facilitys corrective action program and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors determined if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including non-cited violations.

b. Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of CRs and interviews, the inspectors concluded that the threshold for identifying issues and initiating CRs or work orders was appropriate and normally consistent with licensees procedural requirements.

The team did determine that it appeared that deviations from stated standards for equipment were not always identified and documented in the CAP. The inspectors noted that the licensee reviews trends in equipment and human performance on a regular basis. However, trend numbers that address rework are not accurate.

Observations The licensee stated that about 6000 CRs are written per year with many being of relatively low significance. About 2500 of the 6000 CRs are of sufficient significance to track to completion. From interviews plant personnel knew they were expected to write CRs for safety-related issues and would either write CRs or refer the issue to a supervisor. The team did not observe any issues that would indicate that sensitivity for issues that should be addressed in CRs was inappropriate but noted that the resident inspectors had identified instances where CRs were not written until after questions from the resident inspectors. However, inspectors found that licensee personnel were usually identifying issues and documenting the severity of the issues at the appropriate level.

The team noted that the licensee initiated several condition reports in response to questions posed by the inspectors including one CR that acknowledged that the licensee did not initiate a CR for an NRC identified non-cited violation. For this particular past finding the inspectors did find actions that technically addressed the missed issue because of a similar finding that was investigated. There were also several CRs written for plant conditions identified by the inspectors.

During a walkdown of the low pressure core spray system, the inspectors noted heavy rust on a cooling water supply to the room cooler which had not been noted previously.

The rust was identified at a location where a water catch device was previously installed (portions of a tie-wrap and flange clamps remained). The licensee staff had not entered the condition into the CAP. Although the external rust did not represent an operability risk, it did need cleaning and preservation to prevent becoming a future risk. The licensee generated CR 2012-1257, "Emergency Closed Cooling Piping Supplying Water to the LPCS Room Cooler Has Rust on Outside of Pipe, to document this issue.

During a walkdown of a portion of the emergency closed cooling water system, the inspectors identified a leaking sample valve with a bucket positioned below the valve to catch the leaking water. There was no tag to indicate that a CR or work order had been initiated. The licensee found that the valve could be further closed to stop the leaking and initiated CR 2012-1290, Emergency Closed Cooling Loop "B" Sample Valve 1P42F0528B Found Leaking.

During a walkdown of radwaste storage areas, the inspectors found building and storage conditions that appeared inconsistent with licensee desired equipment standards.

The licensee initiated CR 2012-1421, Building Housekeeping Standards Do Not Appear to Meet Management Stated Expectations and CR 2012, Warf/Risb Radioactive Material Tag Faded.

CR 2011-5285, Review of Orders Associated with SUT Showed Documentation and Resolution Issues, was initiated on November 11, 2011, to document that several of the work-in-progress (WIP) logs used in work orders (WOs) during the Unit 1 startup transformer (SUT) maintenance outage in September 2011 identified system deficiencies, but no documentation was generated to evaluate and correct the noted deficiencies. In response to questions, the licensee also stated that a CR and a maintenance deferral request should have been initiated when relay surveillance work associated with the transformer outage was not completed as scheduled.

The team also observed an apparent problem with identifying the true number of rework items within the total station. Issues with rework identification are addressed in Section 4OA2.1(2), Effectiveness of Prioritization and Evaluation of Issues.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The team found there was adequate consideration of operability and reportability requirements. The team found that the licensees timeliness of initial classification of CRs was appropriate and that guidelines for the level of classification were routinely followed. The team reviewed prioritization of issues as reflected in assigned due dates and concluded there was appropriate consideration of risk in prioritizing and evaluating issues and assignments appeared consistent with procedural requirements. However, the team found several instances of multiple extensions of corrective actions. The team also reviewed the work order process and determined that the process appeared appropriate to support scheduling and correction of identified equipment issues. The number of open CRs and open online work orders appeared reasonable although the team did question the age of some work orders.

Although the team did not identify any other specific issues with prioritization of issues, the team found indications that evaluations could be improved. The indications were developed from the teams review of CRs and cause evaluations and were reinforced by the fact that actions developed to correct several issues had not prevented recurrence of issues. Issues with corrective actions are addressed in Section 4OA2.1(3),

Effectiveness of Corrective Actions. The team also found several issues with the licensees evaluation of rework issues.

The team reviewed some cause evaluations that were completed prior to licensees recent efforts to improve evaluations. The team determined that the more recent cause evaluations appeared to be an improvement from earlier evaluations. However, for the majority of recent evaluations, there has not been sufficient time to determine if the evaluations were sufficient to identify true root causes and from those causes develop corrective actions that will sustain improved performance.

Observations The team noted that the licensee had several CRs with corrective action extensions.

A licensee-provided summary of extensions showed that most extensions were requested with less than 7 days before the due date with many of these requested within 1 day of the due date. In review of CR 2010-85992, 2010 PI&R; NRC Questions Regarding WARF, RISB, OSSC Yard, the inspectors noted that one of the corrective actions, which had an original due date of January 2011, had been extended five times and was completed in January 2012. Another corrective action was extended four times from February 2011 to January 2012. The inspectors did not identify any extensions that significantly affected plant processes or equipment.

During the period of January 1, 2011, to January 6, 2012, approximately 2400 CRs of significance were generated. During this same time period the number of open CRs increased from 413 to 692. The average age of CRs decreased from about 233 days to 155 days. Also during this period the number of concurrent limited and full apparent causes increased from about 93 to about 171. Root cause evaluations also increased from one to eight. Site resources to accomplish the significant increase in evaluations were augmented with offsite licensee resources and contract personnel.

The inspectors reviewed the licensees on-line equipment work order numbers.

The number of items classified as critical appeared consistent with industry norms.

Although the inspectors did not identify any specific issue of concern, the inspectors questioned the age of the overall backlog. The inspectors noted that there were about 1300 open on-line work order items. About 300 of those were classified as corrective with an average age of 700 days; about 1000 were classified as deficient with an average age of 280 days. There were a few work orders that were over 5 years old.

The inspectors noted that the licensee recently reclassified work orders under a new industry-sponsored classification scheme.

The licensees rework process was described in procedure NOBP-WM-5014, dated October 31, 2011. The inspectors noted that this procedure contained significant responsibilities that did not appear to be well understood by plant organizations other than the maintenance department. Also, it was not clear which of the items designated as rework by the licensee were truly rework items. For example, in December 2011 a large number of items designated as rework by various plant personnel including the Management Review Board were investigated and determined by the maintenance departments rework coordinator to not be rework. The inspectors noted that other departments were not informed by the maintenance rework coordinator when items originally classified as rework were changed to non-rework.

The inspectors reviewed the licensees Maintenance Human Performance Rework Performance Indicator as it existed in December 2011. The indicator was Red in May and October 2011 and White for the 12 month rolling average in 2011 which indicated an ongoing issue with rework attributable to human performance. Licensee CR 2011-05341 was issued to review past human performance related rework to determine the causes and identify corrective actions.

CR 2011-97327, Maintenance Rework Program Reporting Deficiency, was issued by the FENOC Internal Oversight group during special assessment PY-PA-11-02 to document missed or incorrect Rework (Human Performance Related) and Other Rework (Design, Vendor, Parts, Operation, etc.) evaluations which impact the resolution of issues that affect plant reliability. This CR documented numerous examples where CRs were not correctly categorized as requiring rework evaluation. The CR concluded that rework and other work categories could not be appropriately trended or resolved for impact on equipment reliability. As part of the corrective actions, the licensee revised procedure NOBP-WM-5014 (Station Rework Program) and shared lessons learned with plant personnel. Effectiveness reviews to evaluate the corrective actions were not yet conducted at the close of the inspection.

The inspectors reviewed WO 200458296 and identified that the WOs Closure/Feedback Sheet incorrectly identified the failure of Division 2 diesel generators high volume air regulator as normal wear. This did not match the failure mechanism identified in CR 2011-94137 and 2011-94208 which documented that the regulator was found installed backwards. The licensee initiated CR 2012-01192, Failure mechanism of WO 200458296 Does Not Match that in CR 2011-94137 and CR 2012-01173, to correct the existing information and station documents. As a result of the inspectors observations, the licensee planned to conduct training on the rework process.

The inspectors noted that Perry Fleet Oversight Outage Summary Report for 2011 documented that a large amount of rework was performed. The report identified missed or incorrect rework and other rework evaluations that impacted the resolution of issues that affected plant reliability.

By review of CR 07-24775, Division 1 Diesel Overspeed Trip, in combination with discussions with licensee personnel, the inspectors determined that the 2007 root cause analysis team had not determined the root cause of the event. The inspectors also determined that several of the developed corrective actions were modified after completion of the initial analysis or were closed without completion of corrective actions.

Team organization may have contributed to an incorrect root cause determination. The team had only three members and two members had less than 8 months experience.

The assigned cause evaluator and the system engineer had a disagreement which was not resolved prior to completing the cause evaluation. Additionally the team was structured to have co-leads. The licensee initiated CR 12-00716, Division 1 Diesel Generator Overspeed Trip Lessons Learned, to document the inspectors observations.

Other than recent condition reports and recent evaluations not identifying corrective and preventive actions that prevented or minimized recurrence of issues, the inspectors did not identify recent root cause team organization issues similar to those of the 2007 analysis team. The inspectors did not identify any issues with the current operability of the Division 1 Diesel.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions The team reviewed the effectiveness of the corrective actions which included reviewing if developed and implemented corrective actions reduced or minimized the recurrence of issues. The team found, in general, that the licensee could develop and implement corrective action and use risk insights in prioritizing corrective actions. However, in addition to licensee-identified ineffective corrective actions associated with recurring substantive cross-cutting issues, the team identified additional condition reports and issues that indicated problems with consistently implementing effective corrective actions. The team identified that during several of previous refueling outages the licensee experienced similar sump flooding problems. The team also identified that the licensee had a long-standing issue with the use and quality of WIP logs.

Observations CR 2011-2030, Inability to Close Human Performance Substantive Cross-Cutting Issue for Eight NRC Assessment Periods, provided a narrative of the problems the licensee had in developing and implementing corrective actions to address a long standing NRC-identified substantive cross-cutting issue. The inspectors review of the root cause for this CR indicated that the licensee had completed a more thorough analysis of the problem and had developed corrective actions that appeared more comprehensive than those previously developed to address the substantive cross-cutting issue. However, the licensee was still in the process of implementing the corrective actions and their effectiveness was still to be shown.

CR 2012-1516, CAP Was Performance Rated Marginally Effective for the Third Trimester of 2011, documented the results of a licensee internal assessment of the CAP by the licensees Internal Oversight organization. The assessment report (PY-PA-12-01) was generally consistent with previous assessment reports by the Internal Oversight organization and specifically mentioned CR 2011-2030 and other CRs that supported the organizations overall conclusion. The inspectors review of the assessment did not identify any disagreements with the conclusions independently reached by the inspectors. At the conclusion of the inspection, licensee actions were not yet formulated in response to the CR.

The team noted that the licensee had repeated issues with controlling evolutions related to water inventory. In 2005, 2007, 2009, and again in 2011, the licensee inadvertently transferred water from plant systems to undesired locations. All four evolutions resulted in contaminating normally clean areas of the plant. An apparent cause evaluation was performed in 2005 which failed to minimize the rate of occurrence. Another apparent cause evaluation was completed in July 2011 under CR 2011-95107, Aux Building Flooded During RHR Water Leg Pump Test. The long term corrective actions and effectiveness reviews for that CR were not completed prior to the completion of this inspection.

During review of CR 07-24755, Division 1 Diesel Overspeed Trip, and an associated work order, number 200277351, Replace K1 and K2 Relays in Div 1 Diesel Panel, the inspectors noted that the licensee identified issues with inadequate WIP log documentation, which appeared to adversely impact the licensees root cause evaluation and identification of the issues that caused the diesel overspeed trip. On January 20, 2012, CR 2012-01002, was initiated for lack of documentation in the WIP logs of WOs that were used to tighten loose electrical connections identified during thermography since 2008. From 2007 to the current time frame, more than 17 CRs were generated identifying instances of errors in WO WIP logs including WIP log entries providing technical directions, initiating or stopping work; and not providing sufficient detail for proper machinery history documentation. The team found that the directions for WIP log use were scattered through many sections of NOP-WM-4300, Order Execute Process.

The licensee initiated CR 2012-1284, Improvement Opportunity for NOP-WM-4300 WIP Log Requirements" to document this issue.

Findings No findings were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically the inspectors attended program meetings to observe the use of OE information and reviewed implementing operating experience program procedures, completed evaluations of OE issues and events, and select assessments of the OE composite performance indicators. The inspectors review was to determine whether the licensee was effectively integrating 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 future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and effectively and timely implemented.

b. Assessment The operating experience program at Perry was generally implemented effectively with some support issues that, if corrected, might strengthen the overall program.

Observations The OE program focused Self-Assessment has not been performed at the 3-year frequency as required by OE program documents and FENOC self-assessment strategy.

Additionally a number of 2011 OE evaluations assigned to be completed by FENOC fleet personnel were noted to be overdue with no new approved justification for extensions.

The licensees root cause assessment team that performed the root cause for CR 2011-02030, Concerns with Inability to Close Human Performance Cross-Cutting Issues for Eight NRC Assessment Periods, conducted a review of industry OE items related to human performance and stated that they identified what they believed to be Perry plant missed opportunities to identify and correct issues related to the ongoing human performance cross-cutting issue. However, the inspectors noted lack of communication in that the root cause team did not share those potential findings with the Perry OE Coordinator who stated disagreement with these OE related findings.

CR-2011-06019 documented that managers do not evaluate the effectiveness of actions related to significant operating experience reports. The licensee implemented corrective actions to address this issue; however, an effectiveness review of the corrective actions was not completed at the conclusion of the inspection.

The inspectors observed good interaction among Operations, Maintenance, and Engineering staff members during attendance at a weekly OE meeting. There was no FENOC Fleet participation during the meeting.

Findings No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions through efforts from departmental assessments, independent assessments, and audits.

b. Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold level. The inspectors concluded that these audits and self-assessments were completed by personnel knowledgeable in the subject area. The inspectors determined that the licensee did not conduct some assessments on a schedule prescribed by their program. Most notable was that the once per 3 year assessment of the Operating Experience program was not accomplished and the assessment of the Self-Assessment Program had not been accomplished for 3 years.

The inspectors also observed that issues identified in self-assessments and audits were captured in the CAP.

Findings No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

The inspectors assessed the licensees safety conscious work environment through the reviews of the facilitys employee concern program implementing procedures, discussions with the coordinator of the employee concern program, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from a 2010 Independent Safety Culture Assessment, a 2011 Safety Culture Assessment, and a separate 2011 Safety Conscious Work Environment Survey (SCWE).

The inspectors interviewed approximately 23 individuals from various departments to assess their willingness to raise nuclear safety issues. The individuals were selected to provide a distribution across the various departments at the site. The sample was of individuals predominantly at first-line supervision and below first-line supervision. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also addressed:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP;

• willingness to use the CAP; and

• managements support of the CAP.

b. Assessment The inspectors reviews and interviews indicated that the licensee had an environment where people will raise nuclear safety related issues. Most people interviewed said that if they have an issue they will write a CR or talk to their supervisor. However the reviewed survey identified that some plant departments have a higher than desired belief that retaliation might occur from raising an issue (questions 14 and 15 of the SCWE survey) and that the CAP (predominantly questions 32, 33, 34 of the SCWE survey) is not effective at resolving issues. These issues and others were identified in the licensees most recent Safety Culture Assessment dated December 21, 2011.

CRs were generated to initiate action to review the issues. From the small sample of interviewed personnel, the inspectors did not identify any specific issue that was at variance with licensees overall conclusions on the state of their culture or their work environment.

Observations From the interviews, the inspectors found that two themes seemed to be recurring.

The first theme, which was the least predominant of the two themes, was that personnel believed that there was not clear alignment through the organization, from top to bottom, on what needs to be done to improve performance. Expressed by several of the interviewees was that the issue was not at the top or the bottom of the organization but that mis-alignment was caused by intervening layers of the organization. This theme did not seem inconsistent with the results of the licensees safety culture assessments and the SCWE survey.

The other theme was that a number of the people interviewed believed that many of the issues in the plant were due to not having sufficient resources to accomplish properly all the tasks that were needed. It was expressed that issues with work coordination between and among groups were due to not having sufficient resources to take the time to work out issues with other groups; if time was taken to work with other groups, this time detracted from the normal required group work. Some interviewed personnel mentioned that they believed that some corrective actions were ineffective because there were not sufficient resources to properly design and then implement corrective actions. The inspectors also reviewed some licensee self-assessments that stated or inferred that resources were not adequate for some desired or required tasks.

While the inspectors did not attempt to draw any conclusions on the adequacy of licensee resources to accomplish what is being asked of the plant, the team noted that several of the interviewed personnel, believing that plant performance issues were due to insufficient resources, might refrain from trying other methods to improve performance.

Findings No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 27, 2012, the inspectors presented the inspection results to Mr. V. Kaminskas, Site Vice President, and other members of the licensee staff.

The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Brandt

R. Coad

C. Elberfeld

R. Lach

T. Lentz

A. Mueller, Jr.

R. Swartz

L. Zerr

Nuclear Regulatory Commission

M. Marshfield

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

None Attachment