ML060380531

Response to NRC CAL Followup Inspection Phase 2 Performance Improvement Initiative Review Inspection Report 0500440-05-014

ML060380531
Person / Time
Site:	Perry
Issue date:	01/27/2006
From:	Pearce L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PY-CEI/NRR-2935L
Download: ML060380531 (6)

See also: IR 05000440/2005014

Text

U- I FENOC Perry Nuclear Power Station ,% 10 Center Road FirstEnergy

Nuclear Operating

Company Perry Ohio 44081 L. William Pearce 440-280-5382

Vice President

Fax: 440-280-8029

January 27, 2006 PY-CEI/NRR-2935L

United States Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 License No. NPF-58 Subject: Response to NRC Confirmatory

Action Letter (CAL) Followup Inspection

Phase 2 Performance

Improvement

Initiative

Review Inspection

Report 05000440/2005014

Ladies and Gentlemen:

This letter provides the FirstEnergy

Nuclear Operating

Company (FENOC) response to the NRC Inspection

Report 05000440/2005014

for the Perry Nuclear Power Plant (PNPP). The NRC letter provided the results of your review of Phase 2 of the Performance

Improvement

Initiative.

In your letter you requested

that FENOC respond within 30 days of receipt of the letter describing

the specific actions that PNPP plans to take to address the observations

identified

in this inspection

report. There were six (6) observations

contained

in the report. The FENOC responses

to these observations

are contained

in an attachment

to this letter. No commitments

are contained

in this letter or the attachment.

If you have questions

or require additional

information, please contact Mr. Jeffrey Lausberg -Manager, Regulatory

Compliance

at (440) 280-5940.Very truly yours, nx r> e ft -PC,?-4C --Attachment

cc: NRC Region III Administrator

NRC Project Manager NRC Resident Inspector

Attachment

I 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 P11, the correction

action program, or through departmental

initiatives

independent

of a formal program.The following

specific examples were identified:

PNPP Response:

This issue is centered on assuring a concise reconciliation

and ultimately

a complete resolution

of all findings and key observations

detailed in the Perry 95003 Inspection

Report. To that end, a 95003 Inspection

Report "gap analysis" is under development

which will track all findings and key observations

noted in the inspection

report in a matrix. This "gap analysis" will be monitored

by the Perry Performance

Improvement

Initiative

staff to provide additional

assurance

of integrated

issue resolution.

A specific response to each of the supporting

observations

is provided below.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 05-0722 3 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 licensee's

training program addressed

the issue of narrowly focused corrective

actions. Through interviews, the inspectors

determined

that the revised PlI Human Performance

and Corrective

Action Program initiatives

generally

addressed

improvement

of standards

associated

with the corrective

action process and therefore

indirectly

addressed

the issue.PNPP Response:

Addressing

the issue of narrowly focused corrective

actions is one specific and substantive

action necessary

to achieve improvement

in the implementation

of the Corrective

Action Program. The approach taken in the Phase 2 PII to improve implementation

of the Corrective

Action program has been to address the basic fundamental

causes and in so doing, encompass

the specific issues identified

in the 95QQ3Irtspection.ReporL.

--_____-Specific to this observation, there are several actions that provide the details for resolution

of this issue. As noted in the inspection

report, CR 05-07223 and additionally, the Detailed Action Monitoring

Plan (DAMP) section 1.4 which are focused on improving the quality of evaluations

and corrective

actions primarily

through training, provide the basis for this action closure. In addition, actions focused on reviews and feedback provided by the Corrective

Action Closure Board (Action 1.6.1 and 1.6.2) and the Corrective

Action Review Board (Actions 1.7.2,1.7.4

and 1.7.5) further support the resolution

of this issue. Collectively, these actions focus on training to improve the quality of investigations

and corrective

actions, and the review and feedback process to assure effective

resolution

of plant issues.

Attachment

2 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

conditions.

Resolution:

The inspectors

noted that the action items listed in the response letters did not specifically

address a lack of a questioning

altitude 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 Pil 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.PNPP Response:

Our 95003 Supplemental

Inspection

response letter included four bulleted actions which address the root cause of procedure

adherence

issues, including questioning

attitude.

Additionally, site training on the error prevention

tools of effective communication

and questioning

attitude was provided in April, 2005. During the 4th quarter of 2005 and 1 st quarter of 2006 human performance

fundamentals

training is being provided which addresses

the use of the error prevention

tool of questioning

attitude.These actions, when completed

will address the root cause of questioning

attitude and ultimately

will address the more specific case of lack of questioning

attitude for off normal conditions

by engineering

personnel.

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 P1I 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 Pll and the corrective

action program. As such, actions that more substantially

addressed

IP 95003 issues were not formally tracked by the Phase 2 P11 or by the corrective

action program. The licensee entered this issue into their oCR 05-eR675.

-PNPP Response:

The issue of techn cal rigor identified

in the 95003 Inspection

Report will be addressed

through implementation

of the P11. The transition

review from Phase 1 to Phase 2 of the P11 identified

Phase 1 technical

rigor actions requiring

inclusion

in the Phase 2 DAMP Appendix.

Specifically

actions A.5.3.1, A.5.4.1, A.5.5.1 were included in the DAMP as specific actions to address technical

rigor.In addition to the actions specified

in the DAMP, the Perry Engineering

Department

undertook

further action that will be captured through the implementation

of PYBP-PNED-0004

Perry Nuclear Engineering

Department

Conduct of Engineering

document.Effective

implementation

of this document will provide additional

basis to assure an adequate and sustained

resolution

of the issue of technical

rigor. This action has been added to the Phase 2 P11 DAMP Appendix as action A.5.6.1 as a result of condition

report 05-07675.

Attachment

3 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 P11: (1) while P11 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 P11 reviews.Because closed Phase 1 P11 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 PI1 action items had been adequately

accomplished.

Resolution:

In response to the inspectors'

concerns, the licensee reviewed a sample of closed Phase 1 P11 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 P11 action items and determine

whether those actions had been adequately

accomplished

during future CAL ftllow up inspection

activities.

PNPP Response:

This observation

notes the Phase 2 P11 dependency

on the adequate review and closure of the Phase 1 P11 and questions

whether additional

reviews need to be completed

to assure the adequacy of the closed Phase 1 P11 actions. As noted in the Inspection

Report, for the Phase 1 actions which were not closed a comprehensive

approach was taken to assure proper transition

and integration

into Phase 2.The Phase 1 P11 was in part, a broad-based

discovery

process, developed

to ensure a full understanding

of all key issues associated

with Perry performance.

Much of this effort was focused on reviews (latent issues, system health and programs).

Each of these assessments

reached a conclusion

with regard to overall adequacy/health

of each area.These assessments

would also identify other issues that typically

were entered into the corrective

action process and not tracked by the PII. This is consistent

with the current Phase 2 Pil approach.

As defined in PYBP-PII-0006

section 4.6: Fundamentally, the Pll is aimed at strengthening

execution

of existing process. As a result, unless P11 effectiveness

reviews and performance

assessments

reveal continuing

significant

performance

gaps, problems identified

in these reviews will be handled through existing processes

such as the Corrective

Action Program.As notedin the inspection

report, as part of this PIH inspection

PNPP performed

a sampling of these closure packages to determine

if any actions identified

affected the fundamental

conclusion

of each assessment

that should have been further tracked by the P11. None were identified.

In response to this observation

a review of past condition

reports on Phase 1 P11 action closure was performed.

CR 05-02940 documents

an issue identified

by the Corrective

Action Assessment

Board that identities

that several Phase 1 P11 closure validation

packages did not meet the requirements

for closure under PYBP-PII-0005

'Closure and Validation

of P11 Actions".

Specifically

it identified

two of eleven closure packages did not meet the criteria for closure and five of the eleven packages did not meet the requirements

for documentation

of "results achieved." A review of this CR indicates

that the issues identified

focused on the adequacy of the"results achieved" section of the closure package. As defined in Phase 2 of the PII,"results achieved" are now generally

segregated

from the closure package for individual

action item closure packages and are follow-up

steps in each initiative, typically

in the form of self-assessments

and effectiveness

reviews. It is recognized

that in some cases,

Attachment

4 the Phase 1 P11 actions did not achieve the desired results. The Phase 2 P11 was developed

to focus on achievement

of results. Tools such as results based performance

metrics, self-assessments

and effectiveness

reviews are now integrated

into the P1I to assure that the desired results are achieved.For the two other closure issues identified, the CR investigation

determined

them to be of an administrative

nature that did not affect the ultimate closure disposition

and no additional

actions were determined

to be necessary.

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 licensee's

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-201

1, "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.PNPP Response:

In response to this observation, Perry personnel

have reviewed the situation

and discussed

it with the Fleet Program Manager for the Corrective

Action Program process. As a result, the Nuclear Operating

Business Practice (NOBP-LP-2011) FENOC Cause Analysis has been revised. This revision, effective

December 16, 2005, eliminated

the qualifiers

of "if a team is used" (or similar variation)

from the Business Practice.Additional

actions are also contained

within the CAP P11 that will strengthen

the overall effectiveness

of cause evaluations.

Specifically, Items 1.4.1,1.4.2, 1.4.3, 1.4.4,1.4.5, and 1.4.6 all target the area of improving

the quality of evaluations

and corrective

actions to ensure corrective

actions are smarter and solve the cause of the identified

problem.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

Attachment

S discretion

of the action owner. The licensee's

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.

PNPP Response:

A number of Performance

Improvement

Initiative

Action Items address the issue of appropriate

prioritization

of Corrective

Actions. The long-term

resolution

of this issue is anchored in the program fundamentals

that have been communicated

and reiterated

to all site personnel

through the development

of PYBP-SITE-0046, Corrective

Action Program Implementation

Expectations.

This action is a result of CAP P1l Actions 1.1.1, 1.2.1 and 1.2.2. Specifically, this document states: Expectation:

Condition

report investigations

and corrective

action completion

are to be based upon risk significance (not due dates).Purpose: -Assignments

based upon risk significance

and not default due dates.Each activity evaluated

and communicated

with supervisionAheprority

and work schedule.Expectation:

The individual

assigned the activity is to complete the assignment

in a quality and efficient

manner such that the review and approval resources

have sufficient

time to complete the activity prior to the due date.Purpose: Activities

are actively worked based upon their risk significance.

Communication

between the individual

assigned, their supervisor

and the reviewer are occurring

to discuss the schedule.To facilitate

the implementation

of these expectations

there is a focus (via CAP P11 Actions 1.7.1 through 1.7.6) on identifying

the appropriate

corrective

actions in the cause determinations

being performed.

This is implemented

via the Correction

Action Review Board and Corrective

Action Closure Board that ensure high quality cause evaluations

are performed.

Ensuring the appropriate

focused corrective

actions are defined will also control the workload of corrective

actions. Maintaining

control of the corrective

action workload also facilitates

the prioritization

of actions to be completed

based on their significance.

To ensure the desired results are being achieved and the appropriate

performance

oversight

is maintained, several Performance

Indicators

have been established.

These indicators

monitor important

attributes

of the Corrective

Action Program including completion

of Condition

Reports and Corrective

Actions on time, quality of evaluations, median age of CRs, and CA work off rates. These PIs are reviewed monthly to ensure the desired results are achieved.

Should the expected level of performance

not be realized in any given month a recovery plan is developed

to restore performance

to the expected level.The collective

effect of the actions described

above (as implemented

by the CAP P11)address the issue described

in the observation

of corrective

actions not always being properly prioritized

leading to untimely implementation.

Accordingly, no additional

action is required at this time