ML053560362
| ML053560362 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/22/2005 |
| From: | Satorius M Division Reactor Projects III |
| To: | Pearce L FirstEnergy Nuclear Operating Co |
| References | |
| IR-05-014 | |
| Download: ML053560362 (32) | |
See also: IR 05000440/2005014
Text
December 22, 2005
Mr. W. Pearce
Acting Vice President
FirstEnergy Nuclear Operating Company
Perry Nuclear Power Plant
10 Center Road, A290
Perry, OH 44081
SUBJECT: PERRY NUCLEAR POWER PLANT
CONFIRMATORY ACTION LETTER (CAL) FOLLOWUP INSPECTION
PHASE 2 PERFORMANCE IMPROVEMENT INITIATIVE REVIEW
NRC INSPECTION REPORT 05000440/2005014
Dear Mr. Pearce:
The purpose of this letter is to provide you with Inspection Report (IR) 05000440/2005014,
detailing the results of our recent review of your Phase 2 Performance Improvement Initiative
(PII). You and other members of your staff attended the December 14, 2005, public exit
meeting held at the Quail Hollow Resort in Painesville, Ohio, during which the results of this
CAL followup inspection activity were presented.
As a result of poor performance, the Nuclear Regulatory Commission (NRC) designated the
Perry Nuclear Power Plant as a Multiple/Repetitive Degraded Cornerstone column facility in the
NRCs Action Matrix in August 2004.
By letter dated September 30, 2004, FirstEnergy advised the NRC that actions were underway
to improve plant performance. To facilitate these performance improvements, FirstEnergy
developed the Perry Performance Improvement Initiative (PII). As part of the NRC's IP 95003
supplemental inspection, the team conducted a detailed review of the PII.
As documented in IP 95003 Supplemental Inspection Report 50-440/2005003, in the
assessment of the performance improvements planned and implemented through the PII, the
NRC determined that the PII had a broad scope and addressed many important performance
areas. The IP 95003 inspection team also observed that, although substantially completed, the
PII had not resulted in a significant improvement in plant performance in several areas. There
were a number of reasons identified as why this occurred, one being that the PII was largely a
discovery activity, and as such, many elements of the PII did not directly support improving
plant performance. Instead, the problems identified through the PII reviews were entered into
the corrective action program and the proper resolution of these problems depended upon the
proper implementation of the corrective action program. During the IP 95003 inspection, the
NRC identified that in some cases the corrective action program had not been implemented
adequately to address the concerns identified during PII reviews. In addition, the team
identified that although many PII actions had been completed, some of the more significant
assessments, such as in the area of human performance, were still in progress at the end of
W. Pearce -2-
the IP 95003 inspection. Overall, based on the factors discussed above, the NRC was unable
to draw any definitive conclusions regarding the overall effectiveness of the Perry PII. As a
result, further reviews were deemed to be necessary to determine whether the PII was sufficient
to address and resolve the specific issues identified.
By letters dated August 8, 2005, and August 17, 2005, you responded to the findings contained
in the NRC's IP 95003 supplemental inspection report. As discussed in these letters, the Perry
leadership team reviewed the achievements realized by the PII, the NRC IP 95003 inspection
report, and the conclusions from various assessments, and developed updates to the PII. The
Perry leadership team restructured the PII (Phase 2 PII) into six new initiatives with the overall
purpose of implementing lasting actions to improve the overall performance at the Perry
Nuclear Power Plant.
During this inspection, the NRC reviewed your Phase 2 PII with the following objectives:
1) Determine whether all Phase 1 PII items that were not completed have been properly
dispositioned;
2) Determine whether the Commitments and Action Items identified in the August 8, 2005,
and August 17, 2005, letters adequately address the issues identified during the NRC's
IP 95003 supplemental inspection;
3) Determine whether the Phase 2 PII performance indicators in the corrective action
program and human performance areas are adequate to measure the success of the
revised performance initiatives contained in the Phase 2 PII;
4) Determine whether the process and procedures for accomplishing, monitoring, and
revising the Phase PII are adequate; and
5) Determine whether the Perry Phase 2 PII, if implemented as written, is sufficient to
address the performance issues at Perry.
Based on the results of this inspection, no findings of significance were identified.
The NRC determined that if implemented as written, your Phase 2 PII was sufficient to
adequately address the performance issues at Perry. Notwithstanding this broad conclusion,
the NRC identified some instances where issues that were identified in the Perry IP 95003
supplemental inspection report were not clearly translated into the Phase 2 PII. We note,
however, that these issues appeared to be addressed either directly or indirectly through your
accomplishment of actions within or outside of your Phase 2 PII and therefore did not appear to
rise to a substantial level of concern.
However, to confirm our conclusions in this matter, you are requested to respond within 30 days
of the date of your receipt of this letter. Your response should describe the specific actions that
you plan to take to address the observations identified in this inspection report. In particular, if
you intend to or have revised your planned actions as a result of the observations in this report,
please describe for us the changes you intend to make and provide a basis for those changes.
W. Pearce -3-
Alternatively, if you do not intend to take any additional actions to address an observation in this
report, other than those already planned and/or accomplished, please provide us with a
discussion of your basis for that decision as well.
The NRC will continue to provide increased oversight of activities at your Perry Nuclear
Power Plant, including your actions to improve your Phase 2 PII and its implementation, until
you have demonstrated that your corrective actions are lasting and effective. Consistent with
Inspection Manual Chapter (IMC) 0305 guidance regarding the oversight of plants in the
Multiple/Repetitive Degraded Cornerstone column of the NRCs Action Matrix, the NRC will
continue to assess performance at Perry and will consider at each quarterly performance
assessment review of the following options: (1) declaring plant performance to be
unacceptable in accordance with the guidance in IMC 0305; (2) transferring the facility to the
IMC 0350, Oversight of Operating Reactor Facilities in a Shutdown Condition Due to
Significant Performance and/or Operational Concerns process; and (3) taking additional
regulatory actions, as appropriate. Until you have demonstrated lasting and effective corrective
actions, Perry will remain in the Multiple/Repetitive Degraded Cornerstone column of the NRCs
Action Matrix.
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). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Satorius, Director
Division of Reactor Projects
Docket No. 50-440
License No. NPF-58
Enclosures: Inspection Report No. 05000440/2005014
w/attachments 1. Supplemental Information
2. Perry Performance Background
3. Perry IP 95003 Inspection Results
4. Summary of Phase 2 PII Initiatives
5. Summary of Phase 1 PII Initiatives
6. List of Key Performance Indicators
See Attached Distribution
See Previous Concurrences
DOCUMENT NAME: G:\Perr\ML053560362.wpd
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
OFFICE RIII RIII RIII RIII
NAME RRuiz*:dtp MBielby* EDuncan* MSatorius
DATE 12/13/05 12/13/05 12/15/05 12/22/05
OFFICIAL RECORD COPY
W. Pearce -4-
cc w/encls: G. Leidich, President - FENOC
J. Hagan, Chief Operating Officer, FENOC
D. Pace, Senior Vice President Engineering and Services, FENOC
Director, Site Operations
Director, Regulatory Affairs
M. Wayland, Director, Maintenance Department
Manager, Regulatory Compliance
T. Lentz, Director, Performance Improvement
J. Shaw, Director, Nuclear Engineering Department
D. Jenkins, Attorney, First Energy
Public Utilities Commission of Ohio
Ohio State Liaison Officer
R. Owen, Ohio Department of Health
W. Pearce -5-
ADAMS Distribution:
GYS
KNJ
RidsNrrDirsIrib
GEG
KGO
RJP
CAA1
C. Pederson, DRS (hard copy - IRs only)
DRPIII
DRSIII
PLB1
JRK1
WDL (IRs only)
ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-440
License No: NPF-58
Report No: 05000440/2005014
Licensee: FirstEnergy Nuclear Operating Company (FENOC)
Facility: Perry Nuclear Power Plant
Location: 10 Center Road
Perry, Ohio 44081
Dates: November 7-10, 2005; November 14-18, 2005
Inspectors: M. Bielby, Lead Inspector, RIII
M. Franke, Perry Resident Inspector
R. Ruiz, Reactor Engineer
Approved by: E. Duncan, Chief
Branch 6
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000440/2005014; 11/7/2005 - 11/18/2005; Perry Nuclear Power Plant; Confirmatory
Action Letter (CAL) Followup Inspection - Phase 2 Performance Improvement Initiative Review
This report covers a 2-week period of supplemental inspection by resident and region-based
inspectors that reviewed the Perry Phase 2 Performance Improvement Initiative (PII). The
NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
A. NRC-Identified and Self-Revealed Findings
None.
B. Licensee-Identified Violations
None.
1 Enclosure
REPORT DETAILS
1.0 Development of Perry Phase 2 Performance Improvement Initiative (PII)
By letters dated August 8, 2005, "Response to NRC Inspection Procedure 95003 Supplemental
Inspection, Inspection Report 05000440/2005003" (ML052210512), and August 17, 2005,
"Corrections for Response to NRC Inspection Procedure (IP) 95003 Supplemental Inspection,
Inspection Report 05000440/2005003," (ML052370357) Perry Nuclear Power Plant (PNPP)
responded to the inspection results discussed in the NRC's IP 95003 supplemental inspection
report. A summary of the performance issues that resulted in the IP 95003 inspection is
discussed in Attachment 1, Perry Performance Background, of this report. A summary of the
IP 95003 inspection results is discussed in Attachment 2, "Perry IP 95003 Inspection Results,"
of this report.
As discussed in these letters, the PNPP leadership team reviewed the achievements realized
by the PII, the results of the NRC's IP 95003 supplemental inspection activities, and the
conclusions from various additional assessments, and developed updates to the Perry PII. The
Perry leadership team restructured the PII (Phase 2 PII) into the following six initiatives that are
briefly described in Attachment 3, "Summary of Phase 2 PII Initiatives," of this report:
1. Corrective Action Program Implementation Improvement
2. Excellence in Human Performance
3. Training to Improve Performance
4. Effective Work Management
5. Employee Engagement and Job Satisfaction
6. Operational Focused Organization
The purpose of the Phase 2 PII, as described in the licensees letters, was to implement lasting
actions to improve the overall performance at the Perry Nuclear Power Plant.
In addition to a discussion of the Phase 2 PII, the licensee's August 8 and August 17 letters
also included actions planned to address the NRC's findings and observations detailed in the
IP 95003 supplemental inspection report. Attachment 2, "Actions to Address Key Issues
Identified in the IP 95003 Inspection Report," of these letters focused on the following areas
and summarized the actions that FirstEnergy Nuclear Operating Company (FENOC) had taken
or planned to take to address those issues:
- Implementation of the Corrective Action Program
- Human Performance
- Performance Improvement Initiative
- IP 95002 Inspection Followup Issues
- Emergency Planning
2.0 Inspection Scope
To assess the overall adequacy of the Perry Phase 2 PII, the scope of this inspection included
the following activities:
1) Determine whether all Phase 1 PII items that had not been completed had been properly
2 Enclosure
dispositioned;
2) Determine whether the Commitments and Action Items identified in the August 8, 2005,
and August 17, 2005, letters to the NRC adequately addressed the issues identified in
the NRC's IP 95003 supplemental inspection;
3) Determine whether the licensee's performance indicators in the corrective action
program and human performance areas were adequate to measure the success of the
revised performance initiatives contained in the Phase 2 PII;
4) Determine whether the licensee's process and procedures for accomplishing,
monitoring, and revising the Phase 2 PII were adequate; and
5) Determine whether the Perry Phase 2 PII, if implemented as written, was sufficient to
address the performance issues at Perry.
3.0 Review of Dispositioned Phase 1 Performance Improvement Initiative Items
a. Inspection Scope
The process that governed the Phase 2 PII was described in PYBP-PII-0006,
"Performance Improvement Initiative Process." Included in this process was the closure
of Phase 1 PII Action Items that remained open when the Phase 2 PII was being
developed. Section 4.3, "Dispositioning of PII Phase 1 Action Items," of PYBP-PII-0006
specified a review by PII personnel of all Action Items from the Phase 1 PII (Revision 3
of the Detailed Action and Monitoring plan (DAMP)). Section 4.3 also prescribed that
each Action Item be categorized to ensure all items were addressed in the transition to
the Phase 2 PII.
The inspectors reviewed Revision 3 to the Phase 1 PII DAMP and determined whether
the Action Items that had not been completed had been properly dispositioned in
accordance with Section 4.3 of PYBP-PII-0006 during the transition to the Phase 2 PII.
b. Observations and Findings
No findings of significance were identified.
Section 4.3, "Dispositioning of PII Phase 1 Action Items," of PYBP-PII-0006 specified
the review by PII personnel of all Action Items from the Phase 1 PII (Revision 3 of the
DAMP). Section 4.3 also prescribed that each Action Item be categorized to ensure all
items were addressed in the transition to the Phase 2 PII.
Section 4.3 of PYBP-PII-0006 required that all items were placed in one of the following
categories and that when placed in a particular category, the actions specified for that
category be implemented:
- Closed: This category consisted of Action Items that had been previously
categorized as "Complete" under the Phase 1 PII process. No further action was
3 Enclosure
required in the Phase 2 PII process.
- Pending: This category consisted of Action Items that were previously
categorized as "Pending" under the Phase 1 PII process. To disposition these
items, a PII team member was required to determine the required level of
closure. A "two level" graded approach of item closure was created based upon
the significance of the item.
- Transition to Normal Work Process: This category contained Action Items that
did not reach a level of significance to warrant tracking within the PII, but rather
could be tracked using the normal work process.
- Non-Initiative DAMP Appendix Item: This category contained significant Action
Items that warranted a higher priority within the work management program and
additional oversight by the licensee's management team.
- New Initiative Item: This category contained significant Action Items from the
Phase 1 PII that warranted a high priority and directly aligned with the Phase 2
PII Initiative.
Of the approximately 270 Phase 1 PII Action Items, 90 remained open and were
required to be dispositioned per Section 4.3 of PYBP-PII-0006 when Perry began the
transition towards Phase 2 PII implementation.
The inspectors reviewed the licensees database that identified the category of each of
the 90 open items and selected a sample of 39 total items for review.
The inspectors determined that all items reviewed were appropriately categorized in
accordance with Section 4.3 of PYBP-PII-0006.
No deficiencies were identified.
4.0 Review of Commitments and Action Items to Address IP 95003 Inspection
Findings
a. Inspection Scope
By letters dated August 8, 2005, "Response to NRC Inspection Procedure 95003
Supplemental Inspection, Inspection Report 05000440/2005003," and August 17, 2005,
"Corrections for Response to NRC Inspection Procedure 95003 Supplemental
Inspection, Inspection Report 05000440/2005003," Perry Nuclear Power Plant
responded to the findings contained in the NRC's IP 95003 supplemental inspection
report.
Attachment 2, "Actions to Address Key Issues Identified in the IP 95003 Inspection
Report," to the licensees August 8 and August 17 letters focused on the following areas
and summarized the actions that FENOC had taken or planned to take to address those
issues:
4 Enclosure
- Implementation of the Corrective Action Program
- Human Performance
- Performance Improvement Initiative
- IP 95002 Inspection Followup Issues
- Emergency Planning
Attachment 3, "Summary of Regulatory Commitments," to the licensee's August 8
and August 17 letters identified those actions committed to by FENOC. A total of
13 commitments were included with a schedule that prescribed completion of the final
commitment by December 2006.
During this inspection, the inspectors reviewed the Commitments and Action Items
specified in the licensee's August 8 and August 17 letters and determined whether these
Commitments and Action Items adequately addressed the issues identified in the
IP 95003 inspection report.
b. Observations and Findings
No findings of significance were identified. The inspectors had the following
observations associated with the following two issues:
Issue 1: The inspectors noted that some issues identified in the Perry IP 95003
inspection report were not specifically addressed by Commitments and/or Action Items
in the licensee's August 8 and August 17 response letters. However, upon detailed
review, the inspectors identified that although specific actions to address the issues in
the IP 95003 inspection report were not addressed in these letters, actions were
contained in some form in either the revised PII, the correction action program, or
through departmental initiatives independent of a formal program. The following specific
examples were identified:
Observation: The licensee's response letters addressed an observation in the IP 95003
inspection report that corrective actions for issues entered into the
corrective action program were frequently narrowly focused.
Resolution: The inspectors noted that the action items listed in the response letters
did not specifically address the issue of narrowly focused corrective
actions. The licensee credited a corrective action associated with CR
05-07223 to address the issue. This corrective action prescribed a 5-day
root cause training course. It was unclear to the inspectors or to
interviewed licensee personnel how the addition of this root cause class
to the licensees training program addressed the issue of narrowly
focused corrective actions. Through interviews, the inspectors
determined that the revised PII Human Performance and Corrective
Action Program initiatives generally addressed improvement of standards
associated with the corrective action process and therefore indirectly
addressed the issue.
Observation: The licensee's response letters addressed an observation in the IP 95003
inspection report of a lack of a questioning attitude for off-normal
5 Enclosure
conditions.
Resolution: The inspectors noted that the action items listed in the response letters
did not specifically address a lack of a questioning attitude for off-normal
conditions. The licensee identified four condition reports that were
associated with events related to the issue. The inspectors noted that
these condition reports lacked corrective actions that addressed
questioning attitude. Through interviews, the inspectors determined that
the revised PII Human Performance and Corrective Action Program
initiative actions included training that generally addressed improvement
of standards associated with problem identification and therefore
indirectly addressed the issue.
Observation: The licensee's response letters addressed an observation in the IP 95003
inspection report that a lack of technical rigor in engineering products
resulted in incorrect conclusions, and that a weakness in the
communications between engineering and other organizations hindered
the resolution of problems.
Resolution: The Phase 2 PII Detailed Action and Monitoring Plan included general
action items for training on engineering rigor and conduct; however, the
inspectors noted that more substantial action items, including the
development of engineering procedures to address the specific issues,
were being accomplished outside of the Phase 2 PII and the corrective
action program. As such, actions that more substantially addressed
IP 95003 issues were not formally tracked by the Phase 2 PII or by the
corrective action program. The licensee entered this issue into their
corrective action program as CR 05-07675.
Observation: The IP 95003 inspection report identified the following issues related to
the use of the corrective action program to address action items in the
Phase 1 PII: (1) while PII action items may be considered closed, the
corrective actions to address the problems may not have been fully
identified or implemented; and (2) in some cases the corrective action
program had not been adequately implemented to address the concerns
identified during the Phase 1 PII reviews.
Because closed Phase 1 PII action items were not reviewed by licensee
staff to determine whether the items had been adequately accomplished
and because the IP 95003 inspection identified that some action items
were not adequately addressed, the inspectors questioned whether the
completed Phase 1 PII action items had been adequately accomplished.
Resolution: In response to the inspectors concerns, the licensee reviewed a sample
of closed Phase 1 PII action items to assess whether there were items
that were not captured in the transfer process due to inappropriate
Phase 1 closure. The licensee found no issues with the sample of
Phase 1 closed items that were reviewed. The NRC planned to conduct
independent reviews of closed Phase 1 PII action items and determine
6 Enclosure
whether those actions had been adequately accomplished during future
CAL followup inspection activities.
Issue 2: The inspectors identified that, in some cases, corrective action items for issues
were flexible in nature and relied heavily upon particularly high standards or rigor of
implementation, which was considered a potential vulnerability. The following specific
examples were identified:
Observation: The licensee's response letters addressed an observation in the IP 95003
inspection report that multi-disciplinary assessment teams were not
required for root cause evaluations, leading to potential inadequate
reviews.
Resolution: The inspectors noted that as part of one of the licensees completed
actions in the response letters, licensee personnel revised procedure
NOP-LP-2001, "Corrective Action Program, to address multi-disciplinary
root cause teams. The inspectors noted that although NOP-LP-2001,
Revision 12, addressed multi-disciplined Corrective Action Review Board
membership and Management Review Board membership, this
procedure did not address multi-disciplinary root cause evaluation teams.
Subsequently, the inspectors determined that the procedure change
addressing multi-disciplinary root cause team members had been
relocated to business practice NOBP-LP-2011, "FENOC Cause
Analysis, Revision 3. NOBP-LP-2011 included a statement to provide
multi-disciplined team members as needed. The business practice also
stated that members may serve more than one role. As a result,
NOBP-LP-2011 provided flexibility that allowed a single-member root
cause team. At the end of the inspection, licensee management planned
to consider what additional actions, if any, should be implemented to
address this issue.
Observation: The licensee's response letters addressed an observation in the IP 95003
inspection report that corrective actions to address identified problems
were not always properly prioritized, leading to untimely implementation.
Resolution: An action item established corrective action program performance as a
standing agenda item at the senior management team meetings. An
additional action item prescribed an improvement in the timeliness of
corrective action program actions. Through procedure review and
interviews, the inspectors determined that actual corrective action
prioritization was left to the discretion of the action owner. The licensees
expectation was that problems should be prioritized by safety
significance. The inspectors noted that this expectation, with the lack of
additional guidance for implementation, was extremely subjective.
Overall, the inspectors concluded that although some instances were identified where
issues that were identified in the Perry IP 95003 supplemental inspection report were
not clearly translated into the Phase 2 PII, these issues were not significant, and
generally appeared to be addressed either directly or indirectly through the
7 Enclosure
accomplishment of actions within or outside of the Phase 2 PII process.
5.0 Review of Performance Indicators
a. Inspection Scope
To provide a basis to assess the overall effectiveness of implementation of each of the
licensees performance improvement initiative areas, the licensee planned to select or
develop appropriate performance indicators.
The inspectors reviewed the performance indicators that the licensee selected or
developed to assess the effectiveness of their implementation of actions to address
problems in the corrective action program and human performance areas. The
inspectors determined whether these performance indicators provided an adequate
measure of the success of the revised performance improvement initiatives in the
corrective action program and human performance areas of the Phase 2 PII.
A complete listing of the performance indicators reviewed in these areas is included as
Attachment 5, List of Key Performance Indicators (KPIs) and Perry Safe Plant
Operations (P-SPO) Performance Indicators, to this report.
b. Observations and Findings
No findings of significance were identified.
For the corrective action program and human performance program performance
indicators (PIs) that were reviewed, the scope and thresholds of those indicators
appeared to be acceptable.
At the end of the inspection, the corrective action program and human performance
program PIs were being revised.
With regard to the corrective action program performance indicators, FENOC made a
decision to decrease the number of corrective action program PIs from 17 to 11 and to
replace the 6-month rolling average report with a document that reported actual monthly
data. The revised PIs were also intended to combine FENOC indicators with
facility-specific performance measures. Specific identification of the new PIs and
associated thresholds were not available at the end of the inspection. The licensee
planned to implement the revised PIs by December 2005.
With regard to the human performance program performance indicators, during the
inspection the licensee met with an Institute for Nuclear Power Operations (INPO)
working group to develop revised industry human performance program PIs. The
licensee identified that the current plant human performance program PIs for site and
department clock resets would be retained. However, since these PIs were reactive in
nature, the licensee planned to develop additional PIs that incorporated individual and
process error rates to be more predictive in nature. For example, the licensee expected
predictive performance indicators to be developed in areas such as operator
workarounds, rework, and procedure backlogs. The licensee expected to implement
8 Enclosure
these revised human performance program PIs by January 2006.
As a result, the inspectors were unable to assess whether these revised performance
indicators provided an adequate measure of the success of the revised performance
improvement initiatives in the corrective action program and human performance areas
of the Phase 2 PII. The NRC planned to review the revised PIs during future
inspections.
6.0 Review of Processes and Procedures for Accomplishing, Monitoring, and
Revising the Phase 2 PII
a. Inspection Scope
The PII process was implemented through the following procedures:
- PYBP-PII-0001, "PNPP Performance Improvement Initiative";
- PYBP-PII-0002, "PII Detailed Action & Monitoring Plan";
- PYBP-PII-0003, "PII Program Review Process";
- PYBP-PII-0004, "Perry Performance Overview Panel Charter";
- PYBP-PII-0005, "Perry Closure and Validation of PII Actions"; and
- PYBP-PII-0006, "Performance Improvement Initiative Process"
Each of the six individual initiatives of the Phase 2 PII was comprised of Action Plans to
address identified areas for improvement. The Action Plans were categorized by the
respective PII area, and their status was tracked in Perry Business Plan PII procedure
PYBP-PII-0002, Detailed Action & Monitoring Plan. Each Action Plan was comprised
of Action Items with corresponding due dates.
The inspectors reviewed the licensee's process and procedures for accomplishing,
monitoring, and revising the PII and determined whether these processes and
procedures were adequate.
b. Observations and Findings
No findings of significance were identified.
Of particular note, the inspectors determined that the licensee established procedure
PYBP-PII-0006, "Performance Improvement Initiative Process," to implement the
revised PII. The inspectors viewed this action as an improvement to the overall process
since this procedure more formally prescribed the process of accomplishing, monitoring,
and revising the PII than what existed during the development and implementation of
the Phase 1 PII.
7.0 Assessment of Adequacy of the Perry Phase 2 PII
9 Enclosure
a. Inspection Scope
The inspectors reviewed each of the licensees revised individual performance initiatives
and determined whether the Perry Phase 2 PII, if implemented as written, was sufficient
to resolve and address the performance issues at Perry.
In particular, the inspectors focused on those initiatives associated with the corrective
action program and the human performance areas since these areas were specifically
identified in the NRCs IP 95003 inspection as areas warranting significant attention and
improvement.
A complete discussion of the individual initiatives that comprised the Phase 2 PII is
contained in Attachment 3, Summary of Phase 2 PII Initiatives, of this report.
b. Observations and Findings
No findings of significance were identified.
The inspectors review of the individual performance initiatives in the Perry Phase 2 PII
concluded that the licensees general approach to addressing the identified performance
problems appeared to be reasonable.
Based on the conclusion that the dispositioning of open Phase 1 PII items was
adequate, the overall scope of the Phase 2 PII was adequate, and the Phase 2 PII
process and procedures were adequate, the inspectors concluded that overall, the
Phase 2 PII was adequate and that if implemented as written, could be effective in
addressing the performance issues at Perry.
8.0 Exit Meeting
On December 14, 2005, the inspectors presented the inspection results to
Mr. W. Pearce, Acting Vice President, and other members of his staff, who
acknowledged the findings and observations.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
10 Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
G. Leidich, Chief Nuclear Office, FENOC
D. Pace, Senior Vice President, Fleet Engineering and Services, FENOC
J. Hagan, Chief Operating Officer, FENOC
J. Rinckel, Vice President, Oversight, FENOC
W. Pearce, Acting Vice President, Perry
F. von Ahn, Plant Manager, Perry
F. Cayia, Director, Performance Improvement, Perry
K. Howard, Manager, Design, Perry
J. Lausberg, Manager, Regulatory Compliance, Perry
T. Lentz, Director, Performance Improvement Initiative, Perry
J. Messina, Manager, Operations, Perry
J. Shaw, Director, Engineering, Perry
M. Wayland, Director, Maintenance, Perry
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None.
1 Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC team reviewed the documents in their entirety but rather that selected
sections or 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.
Performance Improvement Initiative Plans
Perry Nuclear Power Plant Performance Improvement Initiative; Corrective Action Program
Implementation Initiative; Revision 2
Perry Nuclear Power Plant Performance Improvement Initiative; Effective Work Management;
Revision 1
Perry Nuclear Power Plant Performance Improvement Initiative; Training to Improve
Performance; Revision 2
Perry Nuclear Power Plant Performance Improvement Initiative; Excellence in Human
Performance; Revision 2
Perry Nuclear Power Plant Performance Improvement Initiative; Employee Engagement and
Job Satisfaction; Revision 1
Perry Nuclear Power Plant Performance Improvement Initiative; Operational Focused
Organization; Revision 1
Performance Improvement Initiative - Corrective Action Program Implementation Effectiveness,
Revision 2, dated September 27, 2005
Performance Improvement Initiative - Excellence in Human Performance, Revision 2, dated
September 19, 2005
Performance Improvement Initiative - Training to Improve Performance, Revision 2, dated
September 20, 2005
Performance Improvement Initiative - Effective Work Management, Revision 1, dated
September 22, 2005
Performance Improvement Initiative - Employee Engagement and Job Satisfaction, Revision 1,
dated September 22, 2005
Performance Improvement Initiative - Operational Focused Organization, Revision 1, dated
September 16, 2005
Condition Reports (CRs)
CR 05-03986; Corrective Action Implementation Effectiveness; dated May 3, 2005
CR 05-06219; NRC Observations From IP 95003 Inspection Report - Procedure Quality; dated
August 23, 2005
CR 05-02517; Human Performance Cross Cutting Issue; dated March 21, 2005
CR 05-07497; Untimely Documentation Package Closure of Phase 1 PII Actions; dated
November 8, 2005
CR 05-07535; Incorrect Version of Root Cause Report in CREST; dated November 9, 2005
CR 04-04059; Site Human Performance Barriers May Be Lost During Stressful Times; dated
August 5, 2004
CR 05-07675; Develop And Implement A Conduct Of Engineering Document; dated
2 Attachment
November 11, 2005
CR 05-07223; CAP PII Action Plan Documentation; dated October 20, 2005
Procedures
PYBP-PII-0001; Performance Improvement Initiative; Revision 3
PYBP-PII-0002; Perry Nuclear Power Plant Performance Improvement Initiative Detailed Action
and Monitoring Plan; Revision 4
PYBP-PII-0003; Performance Improvement Initiative Program Review Process; Revision 0
PYBP-PII-0004, Perry Performance Overview Panel Charter, Revision 1, dated September 23,
2005
PYBP-PII-0006; Performance Improvement Initiative Process; Revision 1
NOBP-LP-2008; FENOC Corrective Action Review Board; Revision 4
NOBP-LP-2011; FENOC Cause Analysis; Revision 3
NOBP-LP-2018; Integrated Performance Assessment/Trending; Revision 1
NOP-LP-2001; Corrective Action Program; Revision 12
NOBP-LP-2603; Human Performance Tools and Verification Practices; Revision 0
NOBP-LP-2604; Job Briefs; Revision 0
NOBP-LP-2602; Human Performance Success Clocks; Revision 1
NOBP-LP-2601; Human Performance Program; Revision 0
NOPL-LP-2008; Human Performance; Revision 00
NOP-LP-2601; Procedure Use and Adherence; Revision 0
PYBP-SITE-0042; Corrective Action Closure Board Charter; Revision 3
PYBP-SITE-0045; Initial Screening Committee; Revision 0
PYBP-SITE-0046; Corrective Action Program Implementation Expectations; Revision 2
PYBPP-PII-0006, Form 3; Action Item Transition Form, for the following Phase 1 PII items:
A.2.5, A.2.5.1, A.2.5.2, A.2.5.3, A.2.5.4, A.7, B.1.10, B.1.10.1, B.1.20, B.1.20.1, B.2.2.3,
B.2.2.5, C.2.6, C.3.1.1, C.3.3, C.5.1, C.5.2, C.5.3, D.1.6, D.10.2, D.10.5,D.10.6, D.10.7, D.11.1,
D.2.8, D.4.5, D.6.2, D.6.4, D.9.2, E.1.1,E.1.6, E.1.7, E.3.4, E.4.2, E.4.5, E.4.6, E.8.2, and E.8.3.
Performance Indicators (PIs)
Common FENOC CAP KPIs and Criteria; dated August 29, 2005
FENOC CAP KPI and MPR Report, dated October 2005
Key Performance Indicator Report; dated November 3, 2005
Other Documents
Assessment of Closed Phase 1 PII Packages; dated November 16, 2005
GAP Analysis of NRC Inspection Report 2005003; Update October 2005
Matrix Showing the Disposition of PII Phase 1 Action Items; Created Mid-2005
List of PII Phase 1 Action Items, dated November 8, 2005
FENOC 0024; Training Performance Monitoring Card; Revision 00
FENOC 0023; Operations Performance Monitoring Card; Revision 00
FENOC 0012; Field Observation Card; Revision 02
FENOC Training Enrollment; Corrective Action Program Continuing Training; dated
November 8, 2005
FENOC Letter PY-CEI/NRR-2897L; Response to NRC Inspection Procedure 95003
3 Attachment
Supplemental Inspection, Inspection Report 05000440/2005003; dated August 8, 2005
FENOC Letter PY-CEI/NRR-2902L; Corrections for Response to NRC Inspection
Procedure 95003 Supplemental Inspection, Inspection Report 05000440/2005003; dated
August 17, 2005
4 Attachment
LIST OF ACRONYMS USED
CAL Confirmatory Action Letter
CAQ condition adverse to quality
CAP Corrective Action Program
CARB Corrective Action Review Board
CFR Code of Federal Regulations
CR condition report
DAMP Detailed Action and Monitoring Plan
ESW Emergency Service Water
FENOC FirstEnergy Nuclear Operating Company
IMC Inspection Manual Chapter
INPO Institute for Nuclear Power Operations
IP Inspection Procedure
IR Inspection Report
KPI Key Performance Indicator
LPCS Low Pressure Core Spray
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
PI Performance Indicator
PII Performance Improvement Initiative
PNPP Perry Nuclear Power Plant
P-SPO Perry Safe Plant Operations
SCAQ significant condition adverse to quality
SDP Significance Determination Process
SHR System Health Review
TS Technical Specification
5 Attachment
ATTACHMENT 2 - PERRY PERFORMANCE BACKGROUND
As discussed in the Perry Annual Assessment Letter dated March 4, 2004, plant performance
was categorized within the Degraded Cornerstone column of the NRCs Action Matrix based on
two White findings in the Mitigating Systems cornerstone. An additional White finding in the
Mitigating Systems cornerstone was subsequently identified and documented by letter dated
March 12, 2004.
The first finding involved the failure of the high pressure core spray (HPCS) pump to start
during routine surveillance testing on October 23, 2002. An apparent violation of Technical Specification (TS) 5.4 for an inadequate breaker maintenance procedure was identified in
IR 05000440/2003008. This performance issue was characterized as White in the NRC's final
significance determination letter dated March 4, 2003. A supplemental inspection was
performed in accordance with IP 95001 for the White finding and significant deficiencies were
identified with regard to the licensee's extent of condition evaluation. Inspection Procedure 95001 was re-performed and the results of that inspection were documented in
IR 05000440/2003012, which determined that the extent of condition reviews were adequate.
The second finding involved air-binding of the low pressure core spray(LPCS)/residual heat
removal (RHR) 'A' waterleg pump on August 14, 2003. A special inspection was performed for
this issue and the results were documented in IR 05000440/2003009. An apparent violation of
TS 5.4 for an inadequate venting procedure was identified in IR 05000440/2003010. This
performance issue was characterized as White in the NRC's final significance determination
letter dated March 12, 2004.
The third finding involved the failure of the 'A' Emergency Service Water (ESW) pump, caused
by an inadequate maintenance procedure for assembling the pump coupling, which contributed
to the failure of the pump on September 1, 2003. An apparent violation of TS 5.4 was
documented in IR 05000440/2003006. This performance issue was characterized as White in
the NRC's final significance determination letter dated January 28, 2004.
As documented in IP 95002 Supplemental Inspection Report 05000440/2004008, dated
August 5, 2004, which reviewed the licensees actions to address these issues, the NRC
concluded that the corrective actions to prevent recurrence of a significant condition adverse to
quality (SCAQ) were inadequate. Specifically, the same ESW pump coupling that failed on
September 1, 2003, failed again on May 21, 2004. This resulted in the ESW pump White
finding remaining open.
As a result, Perry entered the Multiple/Repetitive Degraded Cornerstone column for Mitigating
Systems in the Reactor Safety strategic performance area for having two White inputs for five
consecutive quarters. Specifically, for the third quarter of 2004, the waterleg pump finding
remained open a fourth quarter while the ESW pump finding was carried open into a fifth
quarter as a result of the findings of the IP 95002 supplemental inspection.
1 Attachment
ATTACHMENT 3 - PERRY IP 95003 INSPECTION RESULTS
As a result of poor performance, the Nuclear Regulatory Commission (NRC) designated the
Perry Nuclear Power Plant (PNPP), owned and operated by FirstEnergy Nuclear Operating
Company, as a Multiple/Repetitive Degraded Cornerstone Column facility in the NRCs Action
Matrix1 in August 2004. Accordingly, a supplemental inspection was performed in accordance
with the guidance in NRC Inspection Manual Chapter (IMC) 0305 and Inspection Procedure (IP) 95003, Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded
Cornerstones, Multiple Yellow Inputs, or One Red Input.
In addition, the scope of the IP 95003 inspection included the review of licensee actions to
address deficiencies identified during a previous IP 95002 inspection. In particular, the NRC
reviewed the licensees root cause and corrective actions to address the areas of procedure
adequacy, procedure adherence, and training deficiencies identified in the previous IP 95002
inspection; as well as the problem identification, root cause review, and corrective actions to
address repetitive emergency service water (ESW) pump coupling failures.
By letter dated September 30, 2004, FirstEnergy advised the NRC that actions were underway
to improve plant performance. To facilitate these performance improvements, FirstEnergy
developed the Perry Performance Improvement Initiative (PII). As part of the NRC's IP 95003
inspection, the team conducted a detailed review of the PII.
As documented in IP 95003 Supplemental Inspection Report 50-440/2005003, the NRC
determined Perry was being operated safely. The NRC also determined that the programs and
processes to identify, evaluate, and correct problems, as well as other programs and processes
in the Reactor Safety strategic performance area were adequate. Notwithstanding these overall
conclusions, the NRC determined that the performance deficiencies that occurred prior to and
during the inspection were often the result of inadequate implementation of the corrective action
program (CAP) and human performance errors.
The team identified that a number of factors contributed to CAP problems. A lack of rigor in the
evaluation of problems was a major contributor to the ineffective corrective actions. For
example, in the engineering area, when problems were identified, a lack of technical rigor in the
evaluation of those problems at times resulted in an incorrect conclusion, which in turn affected
the ability to establish appropriate corrective actions. The team also determined that corrective
actions often were narrowly focused. In many cases a single barrier was established to prevent
a problem from recurring. However, other barriers were also available that, if identified and
implemented, would have provided a defense-in-depth against the recurrence of problems. The
team also identified that problems were not always appropriately prioritized, which led to the
untimely implementation of corrective actions. A number of programmatic issues were
identified that have resulted in the observed CAP weaknesses. For example, the team
identified a relatively high threshold for classifying deficiencies for root cause analysis. As a
result, few issues were reviewed in detail. In addition, for the problems that were identified that
required a root cause evaluation, the team found that the qualification requirements for root
cause evaluators were limited and multi-disciplinary assessment teams were not required. The
1
The NRCs Action Matrix is described in Inspection Manual Chapter 0305, Operating
Reactor Assessment Program.
1 Attachment
team also identified that a lack of independence of evaluators existed. This resulted in the
same individuals repeatedly reviewing the same issues without independent and separate
review. In addition, the team identified weaknesses in the trending of problems, which has
hindered the ability to correct problems at an early stage before they become more significant
issues. Finally, the team determined that a lack of adequate effectiveness reviews was a
barrier to the identification of problems with corrective actions that had been implemented.
Overall, the NRC concluded that while some limited improvements may have been realized,
there had been no substantial improvement in the licensees implementation of the corrective
action program since Perry entered the Multiple/Repetitive Degraded Cornerstone column of
the NRCs Action Matrix.
In the area of human performance, the team determined that a number of self-revealed
findings relating to procedure adherence occurred that had a strong human performance
contribution. These findings emanated from events that have resulted in an unplanned
engineered safety feature actuation, a loss of shutdown cooling, an unplanned partial drain
down of the suppression pool, inadvertent operation of a control rod (a reactivity event), and
other configuration control errors. The team reviewed the events that occurred during the
inspection and identified that the procedure adherence problems had a number of common
characteristics. In a number of cases, personnel failed to properly focus on the task at hand.
Although pre-job briefings were held prior to many events, and procedures were adequate to
accomplish the intended activity, personnel failed to sufficiently focus on the individual
procedure step being accomplished and performed an action outside of that prescribed by the
procedure. In some cases, the team determined that a lack of a questioning attitude
contributed to the procedure problems that occurred. Although information was available to
personnel that, if fully considered, could have prevented the procedure adherence issues that
occurred, that information was not sought out or was not questioned. The presence of
supervisors with the necessary standards to foster good procedure adherence could have acted
as a significant barrier to prevent some of the problems that occurred. However, adequate
supervisory oversight was not always available or used. Further, the team identified that
available tools for assessing human and organizational performance had not been effectively
used. Overall, the NRC concluded that while some limited improvements may have been
realized, there had been no substantial improvement in human performance since Perry
entered the Multiple/Repetitive Degraded Cornerstone column of the NRCs Action Matrix.
In the area of design, the IP 95003 inspection team concluded that the systems, as designed,
built, and modified, were operable and that the design and licensing basis of the systems were
sufficiently understood. Notwithstanding the overall acceptability of performance in the
engineering area, the team identified common characteristics in a number of problems
identified during the inspection. These characteristics included a lack of technical rigor in
engineering products that resulted in an incorrect conclusion. Also, there appeared to be a lack
of questioning by the licensee staff of some off-normal conditions. Finally, weaknesses in the
communications between engineering and other organizations such as operations and
maintenance sometimes hindered the resolution of problems.
In the area of procedure adequacy, the team determined that the licensees procedures to
safely control the design, maintenance, and operation of the plant were adequate, but
warranted continued management focus and resource support. In particular, process-related
vulnerabilities in areas such as periodic plant procedure reviews, procedure revisions, and use
classifications were identified by the team.
2 Attachment
In the area of equipment performance, the team acknowledged that the licensee had completed
numerous recent plant modifications to improve equipment performance. In addition, improved
engineering support and management oversight of equipment performance were noted.
Notwithstanding the above, the team identified numerous examples that indicated that the
resolution of degraded equipment problems and implementation of the CAP continued to be a
challenge to the organization.
In the area of configuration control, the team identified numerous examples that indicated the
resolution of configuration control issues and implementation of the CAP continued to be a
challenge to the organization. The team agreed with the licensees assessment that continuing
configuration control problems were primarily the result of inappropriate implementation of
procedural requirements rather than the result of configuration management procedural
shortcomings. However, given the on-going errors associated with equipment alignment, as
well as multiple errors associated with maintenance configuration control such as scaffolding
erection, the team concluded that adequate evaluations of the root causes of configuration
control errors had not been performed. The team also concluded that the licensee lacked rigor
in its efforts to resolve latent configuration control issues. Several licensee-identified issues
have not been corrected, and contributed to configuration control shortcomings.
In addition, in the area of emergency preparedness, the team determined that there were some
performance deficiencies associated with the licensees implementation of the Emergency Plan.
A number of findings were identified in which changes to the Emergency Plan or Emergency
Action Levels were made without required prior NRC approval. In addition, the results of the
augmentation drill where personnel were called to report to the facility for a simulated
emergency were unsatisfactory.
With regard to the NRC's review of issues associated with the previous IP 95002 inspection, the
NRC determined that actions to address procedure adequacy and ESW pump failures was still
in progress at the end of the IP 95003 inspection. In particular, the team identified that one of
the licensees corrective actions to address the verification of the quality of ESW pump work
was inadequate. In addition, in light of the continuing problems in human performance and the
impact on procedure adherence, the team concluded that actions to address procedure
adherence had not been fully effective. Finally, actions to address training were also still in
progress at the end of the inspection. In this case, the licensees corrective actions to address
this issue had not been timely and at the conclusion of the IP 95003 inspection, had not yet
been implemented. As a result, the NRC concluded that the open White findings associated
with the IP 95002 inspection would continue to remain open pending additional licensee actions
and the NRCs review of those actions.
In the assessment of the licensees performance improvements planned and implemented
through the Perry PII, the team determined that the Perry PII had a broad scope and addressed
many important performance areas. The IP 95003 inspection team also observed that,
although substantially completed, the PII had not resulted in significant improvement in plant
performance in several areas. There were a number of reasons identified as why this occurred,
one being that the PII was largely a discovery activity, and as such, many elements of the PII
did not directly support improving plant performance. Instead, the problems identified through
the PII reviews were entered into the CAP and the proper resolution of these problems
depended upon the proper implementation of the CAP. During the IP 95003 inspection, the
NRC identified that in some cases the CAP had not been implemented adequately to address
3 Attachment
the concerns identified during PII reviews. The team identified that although many PII actions
have been completed, some of the more significant assessments, such as in the area of human
performance, were still in progress at the end of the inspection.
Overall, based on the factors discussed above, the NRC was unable to draw any definitive
conclusions regarding the overall effectiveness of the Perry PII. As a result, further reviews
were deemed to be necessary to determine whether the PII was sufficient to address and
resolve the specific issues identified.
4 Attachment
ATTACHMENT 4 - SUMMARY OF PHASE 2 PII INITIATIVES
To correct the identified declining trends in performance at Perry, the Perry Phase 2 PII was
structured around the following six key improvement initiatives:
Corrective Action Program Implementation Improvement
As described in the Phase 2 PII, the Corrective Action Program Implementation Improvement
initiative was designed to drive ownership and accountability for the corrective action program
(CAP) deep into the PNPP organization. The initiative was aimed at driving behavior changes
to increase ownership and accountability of the corrective action program to solve plant issues.
Key objectives of this initiative included improvement in the following areas:
- ownership and station focus,
- management and oversight of the corrective action program,
- prioritization of issues and resolution activities,
- trending capability,
- backlog management,
- quality of corrective actions and documentation,
- individual accountability, and
- corrective action work assignment and resource utilization.
Excellence in Human Performance
As described in the Phase 2 PII, the Excellence in Human Performance initiative was designed
to clarify standards and expectations for human performance; establish line ownership,
alignment, and integration of the Institute for Nuclear Power Operation (INPO) Performance
Model; and strengthen line accountability for human performance. Key objectives of this
initiative included improvement in the following areas:
- performance expectations,
- line ownership, alignment, and integration, and
- line accountability of results.
Training to Improve Performance
As described in the Phase 2 PII, the Training to Improve Performance initiative was targeted at
improving both PNPP Skills Training and Operator Training Programs to improve plant and
personnel performance. Key objectives of this initiative included the following:
- establish training as a dominant tool to improve station performance, and
- develop a comprehensive plan to help line and training managers return the
performance of Perry's training programs to a level consistent with current industry
standards.
Effective Work Management
As described in the Phase 2 PII, the Effective Work Management initiative was designed to
provide a site-wide systematic and focused effort to drive improvements in work management.
1 Attachment
The initiative was intended to implement improvements in the selection, preparation, and
execution of work to achieve excellence in work management. Key objectives of this initiative
included the following:
- a long range plan for equipment performance,
- contingency planning guidance and execution,
- strong use of operating experience in work packages,
- improvement in outage preparation and execution, and
- control of contract workers.
Employee Engagement and Job Satisfaction
As described in the Phase 2 PII, the Employee Engagement and Job Satisfaction Initiative was
designed to increase employee contribution to PNPP success by creating an environment in
which all employees can make a meaningful contribution and feel pride and a sense of
accomplishment in their work. Key objectives of this initiative included the following:
- employee involvement in Phase 2 PII activities,
- leadership behaviors and performance management,
- leadership assessment and development, and
- use of overtime.
Operational Focused Organization
As described in the Phase 2 PII, the Operational Focused Organization initiative was designed
to improve the operational focus of the PNPP organization to achieve a higher order of safe and
reliable operation. Key objectives of this initiative included the following:
- fundamental skills and behaviors required for safe and reliable operation,
- operations-led organization,
- alignment of goals and priorities,
- strong craft ownership and engineering presence, and
- operations resources replenishment planning.
2 Attachment
ATTACHMENT 5 - SUMMARY OF PHASE 1 PII INITIATIVES
By letter dated September 30, 2004, FirstEnergy advised the NRC that prior to receiving the
NRCs August 12, 2004, Assessment Followup Letter in which the PNPP was identified to have
transitioned into the Multiple/Repetitive Degraded Cornerstone column of the NRCs Action
Matrix, actions were underway to improve plant performance. To facilitate these performance
improvements, FirstEnergy developed the Perry PII. This improvement initiative was formed
using insights from NRC Inspection Procedure 95003, lessons learned from the Davis-Besse
Nuclear Power Station, and lessons learned from other stations that were placed under the IP 95003 inspection process. As detailed in the licensees September 30, 2004, letter, to correct
the identified declining trends in performance at Perry, the PII was structured around the
following six key improvement initiatives:
Equipment Performance and Configuration
As described in the Phase 1 PII, the Equipment Performance and Configuration Initiative Plan
provided for reviews of system health to enhance safe and reliable plant operation. The
initiative also included improvement actions relative to fuel reliability and critical calculations.
Two levels of system reviews were identified. The first level of review provided for a System
Health Review (SHR) on selected Maintenance Rule and TS systems. In addition, a number of
Latent Issue Reviews were planned.
Program/Procedure Review
As described in the Phase 1 PII, the Program/Procedure Review Initiative provided for a review
of selected plant programs to ensure that the programs were fulfilling required commitments
and continued to support safe operation at the PNPP. The list of programs assessed was
developed through a review of significant CRs, NRC inspection reports, Institute for Nuclear
Power Operation (INPO) evaluations, QA assessments, Company Nuclear Review Board
reports, other self-assessments, key attributes from IP 95003, and the list of programs selected
as part of the Davis-Besse Restart Plan.
Containment and Safety Systems
As described in the Phase 1 PII, the Containment and Safety System Initiative was designed to
improve the material condition of the containment and strengthen the systems to mitigate
events. The plan also initiated assessments and monitoring strategies to strengthen the
organizational focus on equipment reliability.
CAP Implementation Improvement Initiative
As described in the Phase 1 PII, the CAP Implementation Improvement Initiative was designed
to improve the overall health of CAP implementation. This was intended to be accomplished
through interim actions to affect immediate improvement and longer term actions designed to
ensure sustained improvement for all critical attributes of the CAP. Initially, the primary focus of
the improvement initiative was in three areas; skill improvement of investigators, improved
monitoring and oversight of CAP health, and improvement in the effectiveness of corrective
1 Attachment
action implementation (both timeliness and taking effective action to resolve the issue). A
Corrective Action Board was formed using industry expertise to oversee the completion of
improvement actions as well as to continuously assess CAP implementation.
Organizational Effectiveness Improvement
The Organizational Effectiveness Improvement Initiative was developed to initiate a substantive
and demonstrative change in the organizational effectiveness at Perry.
Validations of Root Cause Actions and Effectiveness Review of Root Cause Corrective Actions
The Validation of Root Cause Actions and Effectiveness Review and Root Cause Corrective
Actions Initiative was designed to ensure that actions identified and implemented to resolve root
cause events were effective.
2 Attachment
ATTACHMENT 6 - LIST OF KEY PERFORMANCE INDICATORS (KPIs) and PERRY SAFE
PLANT OPERATIONS (P-SPO) PERFORMANCE INDICATORS
KPI 1 - Conditions Adverse to Quality (CAQ) Condition Reports (CRs) Initiated Per Month
KPI 2 - Percent Root Cause Evaluations Completed On Time
KPI 3 - Percent Root Cause Evaluations Approved By Corrective Action Review Board (CARB)
KPI 4 - Open CR Work Off Rates
KPI 5 - Percent Apparent Cause Investigations Completed On Time
KPI 6 - Percent Apparent Cause Investigations Approved By Corrective Action Review Board
(CARB)
KPI 7 - Percent Preventive Actions Completed On Time
KPI 8 - Percent Remedial Actions Completed On Time
KPI 9 - Open Corrective Action Work Off Rates
KPI 10 - Percent Repeat Root Cause Events
KPI 11 - Percent Timeliness: Total Open CRs Versus Total of All CR Initiated in Past
12 Months
KPI 12 - Percent CRs Self-Identified by an Individual or Supervision, Not An Oversight Group
KPI 13 - Percent Corrective Actions Rejected
KPI 14 - Percent CR Evaluations Rejected
KPI 15 - Median Age of CRs
KPI 16 - Percent of Effectiveness Reviews That Concluded Ineffective Prevent Recurrence
Actions
KPI 17 - Percent Fix Condition Reports Completed On Time
P-SPO-5 - Corrective Action Program
P-SPO-3 - Human Performance Success Days
P-SPO-4 - Section Clock Reset
1 Attachment