ML061360218

Perry, Unit 1 - Response to Nuclear Regulatory Commission Inspection Report 05000440/2006007 - NRC Follow Up Inspection of IP 95002 Action Items

ML061360218
Person / Time
Site:	Perry
Issue date:	05/09/2006
From:	Pearce L W FirstEnergy Nuclear Operating Co
To:	Document Control Desk, NRC/RGN-III
References
IR-06-007, PY-CEI/NRR-2959L
Download: ML061360218 (12)

See also: IR 05000440/2006007

Text

PENOC Perry Nuclear Power Station-"f 10 Center Road FirstEnergy

Nuclear Operating

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

Vice President

Fax: 440-280-8029

May 09, 2006 PY-CEI/NRR-2959L

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 Nuclear Regulatory

Commission (NRC) Inspection

Report 05000440/2006007

-NRC Follow up Inspection

of IP 95002 Action Items Ladies and Gentlemen:

This letter provides the FirstEnergy

Nuclear Operating

Company (FENOC) response to the NRC Inspection

Report 05000440/2006007

for the Perry Nuclear Power Plant (PNPP). The inspection

report provided the results of the NRC Confirmatory

Action Letter (CAL) follow-up inspection

for Inspection

Procedure (IP) 95002 action items. The letter, requests that FENOC respond within 30 days of receipt of the letter describing

the specific actions that FENOC plans to take to address the issues raised during the inspection.

The attached provides the requested

response.There are no commitments

contained

in this letter. If you have any have questions

or require additional

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

Compliance

at (440) 280-5940.Very/trj ly yoP Attachment

cc: NRC Region Ill Administrator

NRC Project Manager NRC Resident Inspector

PY-CEI/NRR-2959L

Attachment

1 Page 1 of 11 Response to NRC Inspection

Report (IR) 06000440/2006007

NRC Follow up Inspection

of IP 95002 Action Items Overall, the inspection

team concluded

that FENOC had satisfactorily

implemented

the commitments

and action items that they reviewed and therefore, the corrective

actions to address maintenance

procedure

adequacy, Emergency

Service Water (ESW) pump coupling assembly, and training were adequate.

Notwithstanding

this overall conclusion, the team identified

some cases where the implementation

of these actions was weak, which potentially

impacts the overall ability to effectively

resolve these issues. These issues are identified

in the Findings and Observations

of the inspection

report.The following

provides the specific NRC Findings and Observations

identified

in Inspection

Report 2006007 followed by the FENOC's response to those Findings and Observations:

SECTION 3.0 PROCEDURE

ADEQUACY 1. 3.1.b.1, Technical

Content Review Results, states: The inspectors

reviewed 19 of the 119 revised maintenance

procedures.

Overall, the inspectors

concluded

that the maintenance

procedures

reviewed were an improvement

on the previous revisions, both in content, formatting, and ease of use. However, the following

weaknesses

were identified:

One procedure

was identified

to contain a significant

technical

error. GMI-0050,"Residual

Heat Removal Pump Overhaul," Revision 0, that was to be utilized for the overhaul of a Residual Heat Removal (RHR) pump, did not include steps to re-insert

pump coupling keys that were removed during pump disassembly.

Therefore, the pump overhaul activity, if performed

as written, would not return the equipment

to a condition

in which it would properly function, which was considered

a significant

technical

procedure

deficiency.

However, because this procedure

had not actually been utilized, the inspectors

considered

this procedure

deficiency

to be of only minor significance.

• The inspectors

noted numerous instances

of typographical

errors and improper references.

While these errors did not significantly

impact the ability to implement

the procedures, it indicated

a lack of attention

to detail in the procedure

development

and review process.FENOC RESPONSE: As stated above, during the NRC inspection, an error was identified

for procedure

GMI-0050, "Residual

Heat Removal Pump Overhaul." The error was the omission of specific instructions

in the procedure

for reassembly

of the pump shaft for the placement

of keys on the pump shaft keyway sleeve and placement

of the split ring. This made the procedure

deficient.

The missing steps could have caused problems during the reassembly

of the pump shaft. When this issue was discovered, GMI-0050 was put on hold pending resolution

of the issue and Condition

Report (CR) 06-00261 was generated

to document the issue. Investigation

found that the RHR pumps have not been overhauled

using this procedure, but rather in the past the vendor manual had been used with the vendor present on site. Additionally,

PY-CEI/NRR-2959L

Attachment

I Page 2 of 11 the procedure

will be reviewed against the vendor manual to verify that no other omission exists.The upgraded procedures

have been categorized

into four (4) groups, with prioritization

based on frequency

of use, scheduled

use, and document change request feedback received from users. The procedures

will be reviewed for adequacy, starting with Group 1 and progressing

through Group 4 (lowest priority).

GMI-0050 is scheduled

to be updated under Group 4 since it is utilized in a forced or refueling

outage. It will not be used until it is updated.In regards to the administrative

errors that were found in the upgraded maintenance

procedures (e.g., typographical

errors, inconsistent

formatting, missing references, etc.), FENOC has generated

CR 06-00418 to address the issue. This CR will collectively

address the issue and capture the lessons-leamed

as well as address the necessary

re-verification

and revalidation

of the upgraded maintenance

procedures.

Corrective

Action 06-00418-02

was developed

to track the Maintenance

Department

re-review

of the 119 procedures

to correct the following

potential discrepancies:

Typographical

errors Formatting

inconsistencies

Proper step sequencing

Redundant

steps Deficient

direction Faulty references

Missing technical

Information

Proper use/identification

of critical steps Additional

resources

are being brought in to help complete the reviews.Discrepancies

identified

during the review process will be documented

via the Corrective

Action Program and addressed, as required, to support procedure

use/plant

operation/scheduled

maintenance

activities.

Overall results of the review will be documented

in the closure of Corrective

Action 06-00418-02.

2. 3.1.b.2, Identification

of Missing "Critical" Procedure

Step Designation, states: The inspectors

identified

numerous maintenance

procedure

steps that warranted identification

as critical steps in these procedures, but had not been properly identified

as such. Specific examples included:* CMI-0016, "Division

I and 11 Emergency

Diesel Generator

Starting Air Valve Repair," Revision 3, did not identify measurement

and evaluation

of cap bore and piston diameter as a critical step although an Improper clearance

could result in a failure of the emergency

diesel generator

to start.* PMI-0040, "Division

IlIl Air Start Motor Maintenance," Revision 4, did not identify a rotation check of the air starter during air start motor reassembly

as a critical step although improper rotation could result in damage to the component

or a slow start.

PY-CEI/NRR-2959L

Attachment

I Page 3 of 11* GMI-0002, "Maintenance

of the Control Rod Drive Pumps," Revision 2, did not identify the measurement

of run out clearances

as a critical step although improper clearances

could lead to premature

bearing failure.MAI-0507 also prescribed

that if possible, Critical Steps should be identified

and mitigated

by using one of the following

methods:* Add a step for breakpoint

review.* Add independent

verification.

• Add a step for peer-check.

• Add a step to contact the supervisor.

• Add a step to contact the Control Room to verify a condition

before continuing

to the next action.However, contrary to MAI-0507, no examples of mitigation

strategies

for critical steps could be found in any of the revised procedures.

These mitigation

strategies

were intended to provide additional

assurance

of proper step completion.

Follow up discussions

with work management

personnel

indicated

that these strategies

were intended to be added during the work package development

process. However, only one example was identified

in which a mitigation

strategy was included with a work order containing

a critical step. The inspectors

concluded

that the licensee had not adequately

implemented

this procedural

requirement.

However, since the inspectors

did not identify any instance where the omission of a mitigating

strategy had resulted in improper procedure

implementation, the inspectors

concluded

the issue was of only minor significance.

FENOC RESPONSE: FENOC acknowledges

that inconsistencies

exist in application

of the critical steps in the upgraded maintenance

procedures.

When this issue was identified, several condition

reports were generated

to document the issues (i.e., CR 06-00181, 06-00276 and 06-00418).

Condition

Report 06-00418 documents

the investigation

summary and provides the corrective

action to address the issue going forward. Since the CR was generated, MAI-0507,"Maintenance

Procedures

Writer's Guide," has been superseded

by a new technical

procedure

guide PAP-0500, "Perry Technical

Procedure

Writer's Guide," Revision 0, that provides improved guidance for mitigation

and application

of critical steps.The investigation

found that the inconsistencies

in the application

of the critical steps in the upgraded maintenance

procedures

were due to less than adequate oversight

and participation

by Perry personnel

during the procedure

upgrade process. The initial maintenance

procedure

upgrade project was mainly supported

by outside contract personnel

utilizing

a format obtained from another site that did not meet FENOC standards.

Additionally, when the maintenance

procedure

upgrade project was initiated

in late 2004, the maintenance

procedure

writers guide, MAI-0507 was not issued yet, which contributed

to the issue.

PY-CEI/NRR-2959L

Attachment

1 Page 4 of 11 As a result of the issues discussed

above, the upgraded maintenance

procedures

will be reviewed for the consistent

application

of critical steps, formatting

and consistency.

Corrective

actions will be taken to address issues found during the reviews. As stated above, this action is being tracked as CA 06-00418-02.

3. 3.1.b.3, Weaknesses

in the use of Placekeeping

Tools and Human Factoring, states: The inspectors

confirmed

that the licensee added placekeeping

blocks to the revised procedures

and had reformatted

the procedures

to address human factoring considerations.

The inspectors

supplemented

this review with in-field observations

of the implementation

of the revised maintenance

procedures.

The inspectors

noted performance

of one procedure

with improper use of placekeeping

techniques:

• During hydramotor

work, the inspectors

noted that technicians

performed multiple steps in rapid succession

without using proper placekeeping.

• In the same procedure, the technicians

performed

several steps multiple times without using peacekeeping

for each Performance

of the step. By procedure, a step may be performed

multiple times, but each Performance

requires separate placekeeping.

In addition, the inspectors

noted multiple instances

of poorly worded steps that hampered the maintenance

worker's ability to successfully

complete the procedure.

For example:* The inspectors

observed the performance

of a motor-operated

valve (MOV)maintenance

activity.

Although the maintenance

procedure

utilized for this activity had been previously

performed

more than 100 times on other valves, the workers stopped several times to obtain clarification

on the requirements

of the procedure.

• The inspectors

reviewed a completed

work package that utilized maintenance

procedure

GEI-0009, "ABB Low Voltage Power Circuit Breaker Types K-600 and K-600S Through K-3000 and K-3000S Maintenance." The inspectors

identified

that workers had incorrectly

N/A'd a section of the procedure.

The inspectors

noted that the procedural

directions

regarding

performance

of that section of the procedure

were unclear. (Section b.4)The inspectors

observed the performance

of maintenance

procedure

ICI-B12-001,"ITT NH90 Series Milliampere

Proportional/On-Off

Hydramotor

Actuator Calibration." During implementation

of the procedure, maintenance

workers failed to remove all required access covers to the hydramotor.

The inspectors

noted that the procedure did not specifically

identify the covers to be removed. (Section b.5)FENOC RESPONSE: The issue with improper use of peacekeeping

during the hydramotor

work activity is addressed

in Item 5 below. This observation

was noted during calibration

check of a Division IlIl EDG Exhaust Air Damper using procedure ICI-B12-0001, -ITT NH90 Series Millampere

Proportional/On-Off

Hydramotor

Actuator Calibration" and is being addressed

in CR 06-01765.

PY-CEI/NRR-2959L

Attachment

1 Page 5 of 1 1 The issue with poorly worded steps in the maintenance

procedure

that hampered the maintenance

workers ability to complete the MOV maintenance

procedure

is related to the issue raised in Item 2 above. This issue is being addressed

as part of CR 06-00418.The issue with incorrect

use of "N/A" during the performance

of maintenance

activity for ABB low voltage circuit breakers is addressed

in Item 4 below.This issue was observed during the review of completed

maintenance

work package that utilized maintenance

procedure

GEI-0009, ABB Low Voltage Power Circuit Breaker Types K-600 and K-600S Through K-3000 and K-3000S Maintenance" and is being addressed

in CR 06-00283.4. (a) 3.1.b.4, Inappropriate

Use of Not Applicable (N/A) in Procedure

Steps, states: The inspectors

identified

that many of the revised maintenance

procedures

applied to multiple different

styles of components.

As a result, these procedures

required that maintenance

workers determine

the applicable

steps of the procedure

to be performed

since all steps may not apply to a particular

component.

When a step was not performed, the worker would mark the step N/A [not applicable].

Based on the procedures

reviewed, the inspectors

concluded

that the typical number of N/As required during the implementation

of a procedure

represented

a potential

human performance

trap. During the inspection, the inspectors

identified

the following specific example in which a procedure

step was inappropriately

N/A'd for which the Enforcement

section is restated here for the example "Failure to Perform Required Steps Prescribed

by Procedure

GEI-0009".

Enforcement:

Technical

Specification

5.4, "Procedures," required, in part, that written procedures

be implemented

covering applicable

procedures

recommended

by Regulatory

Guide 1.33, "Quality Assurance

Program Requirements (Operation),"Revision

2, dated February 1978. Regulatory

Guide 1.33, Appendix A, paragraph 9a, stated, "Maintenance

that can affect the performance

of safety-related

equipment should be properly pre-planned

and performed

in accordance

with written procedures, documented

instructions, or drawings appropriate

to the circumstances." Contrary to this requirement, on January 19, 2006 [it was determined

that], licensee personnel

failed to perform required steps in procedure

GEI-0009, "ABB Low Voltage Power Circuit Breaker Types K-600 & K-600S Through K-3000 & K-3000S Maintenance," Revision 17. Specifically, licensee personnel

failed to perform minimum operating

voltage testing on the safety-related

EF1A05 breaker that provided power to Division I Motor Control Center (MCC), Switchgear (SWGR), and Battery Room Supply Fan A. However, because of the very low safety significance

and because the issue has been entered into the licensee's

corrective

action program (CR 06-00283), the issue is being treated as a non-cited

violation (NCV)consistent

with Section VI.A. 1 of the NRC Enforcement

Policy (NCV 05000440/2006007-01).

FENOC RESPONSE: During a review of work order (WO) 200038182, the NRC inspector

identified

that step 5.2.3, 'Minimum Operating

Voltage and Anti-Pump

Verification," of procedure

GEI-0009, "ABB Low Voltage Power Circuit Breaker Types K-600& K-600S through K-3000 & K-3000S Maintenance," was marked N/A and not performed

during the voltage testing of the non-safety

related breaker that provides power to the condensate

transfer pump A. When the issue

PY-CEI/NRR-2959L

Attachment

1 Page 6 of 11 was raised during the inspection, CR 06-00283 was written to document and to investigate

the issue, The investigation

revealed that step 5.2.3 of GEl-0009 was incorrectly

marked N/A and not performed

as required.

The anti-pump functional

verification

was performed

by a subsequent

step within the procedure.

Step 5.16, "Breaker Anti-Pump," requires that the functionality

of the breaker be verified before it is restored to an operable condition.

From an equipment

perspective, the anti-pump

feature on the breaker was verified to be acceptable

before it was installed

and placed in service. There are no hardware issues associated

with this breaker pertaining

to the NA'd step 5.2.3. The maintenance

work performed

on this breaker satisfied

the purpose of procedure

GEI-0009 yet, as stated above, was not performed

in full compliance

with the requirements.

The breaker was installed

and placed in service on September

9, 2005 and there have not been any operational

issues since that time. This breaker is presently

scheduled

for refurbishment

in June 2006 (with a maximum due date of June 2007). Additionally, an immediate

investigation

was performed

to determine

if any other safety related, electrically

operated breakers had been installed

during 2005 without verification

of their anti-pump

feature. The investigation

determined

that the safety-related

breakers overhauled

during 2005 adequately

met the steps 5.2.3 and 5.16 of procedure

GEI-0009 for proper breaker operation.

Individual

performance

issues associated

with this condition

were referred to line management

for appropriate

actions in accordance

with the FENOC Performance

Management

System.It is noted that for the safety related breaker that provides power to the division 1 motor control center (MCC), switchgear (SWGR) and battery room supply fan A, step 5.2.3 was left blank on the data sheet. However, since this breaker failed as-found, CR 05-04796 was written and the replacement

breaker function was verified as acceptable.(b) 3.1.b.4, In addition to this example, the inspectors

observed a nonsafety-related

air-operated

valve (AOV) rebuild activity during which maintenance

workers improperly

N/A'd a step that prescribed

a valve stem inspection.

FENOC RESPONSE: During performance

of changing the packing for feedwater

heater drain valve, I N25F0290A, step 5.3.2 of the valve packing instruction

per procedure

GMI-0061,"Valve

Packing Instruction," was marked not applicable (N/A). The step states: "IF damage is found, THEN DETERMINE

where information

is available

in Valveman Data Program or Order." The Valveman datasheet

provides the information

that addresses

the packing configuration

to be used. This step was incorrectly

marked N/A while it was applicable.

Step 5.3.2 was subsequently

performed

satisfactorily.

This issue was documented

in CR 06-00269.

The investigation

revealed that the individuals, although qualified

to perform the task, had not performed

the task regularly.

Since the procedure

was of a new format, the individuals

misunderstood

the steps and requirements

of the datasheet.

The use of training along with the procedure

provides the individuals

with sufficient

information

needed to perform the task. Had the individuals

PY-CEI/NRR-2959L

Attachment

I Page 7 of 1 1 followed the procedure

they would have discovered

the data was contained in the Valveman data package. This was a human performance

issue rather than a procedure

deficiency.

Individual

performance

issues associated

with this condition

were referred to line management

for appropriate

actions in accordance

with the FENOC Performance

Management

System.Elimination

of human performance

issues, including "procedure

traps," has been given a high priority.

The Maintenance

Training Review Committee (TRC) is tracking actions for the maintenance

organization

to complete"Procedure

Use And Adherence" classroom

and laboratory

training.

At the end of March, 2006, the classroom

portion had been completed

by all maintenance

supervisors

and worker personnel.

Laboratory

practical training has been captured as an action that is scheduled

to be completed next. The lesson material specifically

includes training on "when procedure steps do not apply." 5. 3.1.b.5, Failure to Perform Required Steps Prescribed

by Procedure

ICI-B12-0001, states: Technical

Specification

5.4, "Procedures," required, in part, that written procedures

be implemented

covering applicable

procedures

recommended

by Regulatory

Guide 1.33, "Quality Assurance

Program Requirements (Operation),"Revision

2, dated February 1978. Regulatory

Guide 1.33, Appendix A, paragraph 9a, stated, "Maintenance

that can affect the performance

of safety-related

equipment should be properly pre-planned

and performed

in accordance

with written procedures, documented

instructions, or drawings appropriate

to the circumstances." Contrary to this requirement, on January 10, 2006, during a calibration

check of a Division IlIl EDG Exhaust Air Damper, licensee personnel

failed to perform required steps prescribed

by procedure

ICI-B12-0001, "ITT NH90 Series Milliampere

Proportional/On-Off

Hydramotor

Actuator Calibration," Revision 4. However, because of the very low safety significance

and because the issue has been entered into the licensee's

corrective

action program (CR 06-00125), the issue is being treated as a non-cited

violation (NCV) consistent

with Section VI.A. 1 of the NRC Enforcement

Policy (NCV 05000440/2006007-02).

FENOC RESPONSE: On January 10, 2006, the NRC inspector

observed the implementation

of upgraded maintenance

procedure

ICI-B12-0001, 'ITT NH90 Series Milliampere

Proportional/On-Off

Hydramotor

Actuator Calibration," Revision 4, during a calibration

check of a Division IlIl Emergency

Diesel Generator Exhaust Air Damper Hydramotor.

This procedure

was categorized

as Step-by-Step Use and in accordance

with procedure

NOP-LP-2601, 'Procedure

Use and Adherence." During the performance

of ICI-B12-0001, several instances

were identified

where procedure

adherence

was not followed in accordance

with NOP-LP-2601.

As discussed

in the NRC inspection

report:* Step 5.9.2 of ICI-B12-0001

directed the user to verify the subject hydramotor

had been full-stroke

cycled a minimum of five times.Although procedure

steps which prescribe

this type of verification

permit the re-positioning

of plant components, in accordance

with

PY-CEI/NRR-2959L

Attachment

I Page 8 of I1 NOP-LP-2601, these actions must be specifically

authorized

by plant procedures.

In this case, and as observed by the inspectors, although this guidance did not exist, personnel

performed

future procedure

steps out-of-sequence

in order to accomplish

Step 5.9.2.* Step 5.9.3 of ICI-B12-0001

directed that screw-on covers be removed to support testing. In this case, personnel

failed to remove the necessary

covers to continue with the proper testing.* Step 5.9.4 of ICI-B12-0001

directed the connection

of a multi-meter

to a limit switch in accordance

with Attachment

7, Figure 1. Contrary to this, personnel

connected

the multi-meter

in accordance

with Attachment

10 and continued

with the calibration

check. This error was identified

by the inspectors

observing

the test when conflicts were discovered

at a later procedure

step.* Steps 5.9.5 through 5.9.9 of ICI-B12-0001

directed the manipulation

of the hydramotor

actuator for verification

and recording

of proper valve seating and stem travel. Contrary to procedure

use guidance, personnel

did not complete these steps via the read-then-perform

approach.

Additionally, NOP-LP-2601

directed that repeated steps shall be provided with "separate

documentation" and "peacekeeping

on the steps". These steps were repeated to satisfy the requirements

of Step 5.9.2 without separate documentation

and placekeeping

annotation.

• Step 5.9.10, 5.9.10.a and 5.9.10.b of ICI-B12-0001

directed the connection

of a multi-meter

to position switches followed by actuator manipulation

until such switches actuate. Contrary to procedure

use guidance, steps were marked as complete concurrently

without verifying

individually

that each step had been completed.

As part of the immediate

corrective

action, personnel

stopped the work activity and revised ICI-B12-0001

to clarify the requirements

in Section 5.9 of the procedure.

A second attempt was made to calibrate

the hydramotor, but the procedure

needed another revision to the steps. The procedure

category was also revised from 'Step-by-Step" to "In-Field

Reference," a more appropriate

category for this procedure.

Upon completion

of the second procedure

revision, the calibration

was completed

satisfactorily

and the hydramotor

was returned to service.Condition

reports 06-00125 and 06-01765 address the above inspection

report issues as follows: The first example of Step 5.9.2 of ICI-B12-0001

directed the user to verify that the hydramotor

had been run through full stroke at least five times. Per NOP-LP-2601, the performer

is allowed to reposition

this hydramotor

if authorized

by plant procedures.

The approval to stroke this valve was authorized

by the order which was released by operations

to allow calibration

of the hydramotor.

Note: The act of stroking the hydramotor

is a skill that is obtained by a qualified

technician

during their on-the-job

training/task

performance

evaluation (OJT/TPE)

training.

PY-CEI/NRR-2959L

Attachment

I Page 9 of I1 Step 5.9.3 of ICI-B12-0001

directed the removal of control and electrical

screw on covers for the PCD actuator.

The technicians

were working to calibrate

the position limit switches instead of the travel limit switch so the correct cover was not removed. The technician

made an error in not removing all of the covers needed for this calibration.

Step 5.9.4 of ICI-B12-0001

directed the connection

of a multi-meter

to an actuator travel limit switch shown on attachment

7, but went to attachment

10 (this issue was addressed

solely by CR 06-00125).

The error was failure to follow the procedure.

The procedures

were revised, the calibration

completed, the hydramotor

was returned to service, and the potential

limiting condition

for operation (PLCO) cleared.Steps 5.9.5 through 5.9.9 of ICI-B12-0001

directed the manipulation

of the hydramotor

actuator for verification

and recording

of proper valve seating and stem travel. The steps were all performed

and then signed off which violates procedure

NOP-LP-2601

for use of a step-by-step

procedure.

Also, as the steps were repeated, the technicians

failed to provide the separate documentation

and placekeeping

as required by NOP-LP-2601.

Although this may be accomplished

by different

methods, the performers

must follow the procedure

requirements.

These were human performance

errors.Steps 5.9.10, 5.9.10a, and 5.9.10b of ICI-B12-0001

directed the connection

of a multi-meter

to position switches followed by actuator manipulation

until such switches actuate. The steps were performed

concurrently

and then signed off after completed

which is contrary to the requirements

of NOP-LP-2601 for a Step-by-Step

procedure.

The roll-up of these issues again emphasizes

the failure to follow proper procedure

use and adherence

expectations.

This issue was addressed

in CR-06-00125.

I&C, Electrical, Mechanical

and Services sections of Maintenance

have completed

a procedure

use and adherence

class. The requirements

and the expectations

for procedure

use and adherence

were emphasized

during the class.As discussed

above, procedure

adherence

and quality of the procedure contributed

to this issue. Corrective

actions were taken in accordance

with the FENOC Performance

Management

Process.6. 3.2, Commitment

Item 1.b/DAMP Item B2.2.3.2, states: The inspectors

concluded that NQI-1001, Revision 5, appropriately

incorporated

the consideration

of failure history, risk significance, and failure probability

in assigning

QC inspection

hold points. However, the inspectors

identified

that the methods Identified

and in use did not take full advantage

of all site programs.

In particular, the procedure

did not prescribe

the review of the maintenance

rule database, which collects pertinent component

failure data, nor did it integrate

the probabilistic

risk assessment (PRA)model, which provides component-specific

risk information.

PY-CEI/NRR-2959L

Attachment

1 Page 10 of II FENOC RESPONSE: To address the above observations, CR 06-00366 was generated.

It should be noted that NQI- I001 was superseded

by Nuclear Operating

Procedure NOP-LP-2018, "Quality Control Inspection

of Maintenance

and Modification

Activities," on December 19, 2005. The CR investigation

was focused on addressing

the following

enhancement

actions to procedure

NOP-LP-2018:

• Assignment

of hold/witness

points to procedure

steps that are identified

as "critical

steps."* Use of Probabilistic

Safety Assessment (PSA) risk significance

for component

level equipment

and non-safety

risk significance

equipment.

• Use of Maintenance

Rule database for the identification

of repeat failure items for potential

assignment

of hold/witness

points.The investigation

determined

that use of the Maintenance

Rule database as a means to identify additional

QC hold/witness

points is not an optimum method. Since the condition

reports drive the maintenance

rule evaluation

through the corrective

actions, historical

failure data can be obtained through the review of condition

reports for those components

that are considered

to be a maintenance

rule failure. Therefore, historical

data from the condition reporting

system will be used for the identification

of repeat failures items for potential

assignment

of hold/witness

points.The following

enhancements

were added to procedure

NOP-LP-2018:

• Use of pre-established "Critical

Steps" as a factor when assigning

QC Hold/Witness

points.* Use of risk significance

assessment

tool at a component

level as a factor when assigning

Hold/Witness

points.* Use of Risk Significance (PSA), Maintenance

Rule, Critical Components, and Maintenance

Modifications

as factors that the QC supervisor

will utilize when assigning

process monitoring.

SECTION 5.0 TRAINING 5.3, Review of Human Performance

Tools to Reinforce

Human Performance

Under Stress, states: While observing

the rebuild of a fire protection

deluge valve, a procedure

step in the work package required the inspection

of valve internals

to evaluate the condition

of the valve, including

the condition

of internal moving parts.When questioned

about the presence of moving parts, licensee personnel

were unsure if the valve contained

moving parts. Despite this lack of knowledge, licensee personnel

signed off the step as complete.

Upon further review, the inspectors

determined

that the work package was incorrect

and referenced

a section of the technical

manual for a valve that contained

moving parts although the valve inspected

did not contain moving parts.However, since this error had no actual adverse impact on the deluge valve inspection

results, the inspectors

concluded

the issue was of only minor significance.

PY-CEI/NRR-2959L

Attachment

1 Page 11 of 11 FENOC RESPONSE: To address the above observation, FENOC generated

CRs 06-00178 and 06-01764.

CR 06-00178 investigated

the issue concerning

the communication

that took place between the inspector

and responsible

system engineer (RSE) during inspection

of the fire protection

deluge valve.The inspector

questioned

what moving parts were inspected

for the valve in accordance

with the work order and whether a vendor manual was reviewed during the valve inspection.

The RSE's initial response was that the valve did not have the same spring arrangement

like the other valves being inspected.

This was confirmed

by the maintenance

personnel

during the inspection.

The proper response should have been that the valve flapper was inspected

during the valve internal inspection

and there was no spring arrangement

for this particular

valve model. This communication

issue was subsequently

clarified

with the inspector.

The investigation

determined

that the initial response by the RSE to the inspectors

question was not clearly communicated.

Condition

report 06-01764 investigated

the issue with potential

for lack of knowledge

and incorrect

work package. During the initial inspection

of the deluge valve, the RSE examined the valve internals

to include flapper, seating surfaces, and body conditions.

After inspection

of the valve, the RSE confirmed

by way of the maintenance

personnel

that this model valve did not have a spring. When questioned

by the inspector

as to what moving parts were inspected, the RSE identified

that the internals

and seating surface were inspected.

The RSE went on to explain that this model did not contain a spring. The inspector

asked if the vendor manual had been reviewed.

The RSE responded

no (note that this was the fourth deluge valve inspected

by the RSE with some models containing

the spring while others do not). In the subsequent

meeting with the inspector, the RSE was more precise in specifically

identifying

that the flapper (moving part) was inspected

and indicated

that he had a conversation

with the mechanic regarding

this particular

model not having a spring. The inspector

was not aware of the conversation

between the RSE and the maintenance

personnel

during the inspection.

The work order package issue was associated

with one of the two models with the manual/drawing (model without spring) not being in the package. The order was for the inspection

of multiple deluge valves that consisted

of both models. The SAP data for the valve being inspected

at the time of this event did not identify the valve correctly

and the proper vendor manual section/drawing

was not provided.

The package only contained

a vendor manual/drawing

of the model with a spring. This oversight

was corrected

by adding the appropriate

manual section/drawing

to the package and changing the SAP data base model number. Therefore, this issue is not a result of lack of RSE knowledge, but rather less than effective communications

and an issue with the work package.