ML051880088

IR 05000266-05-014, 05000301-05-014; Nuclear Management Company; on 06/13/2005 - 06/17/2005; Point Beach Nuclear Plant, Units 1 & 2; Special Inspection, Confirmatory Action Letter Followup

ML051880088
Person / Time
Site:	Point Beach
Issue date:	07/01/2005
From:	Reynolds S Division Reactor Projects III
To:	Koehl D Nuclear Management Co
References
CAL 3-04-001 IR-05-014
Download: ML051880088 (21)

See also: IR 05000301/2005014

Text

July 1, 2005

CAL 3-04-001

Mr. Dennis L. Koehl

Site Vice-President

Point Beach Nuclear Plant

Nuclear Management Company, LLC

6590 Nuclear Road

Two Rivers, WI 54241-9516

SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

NRC SPECIAL INSPECTION REPORT 05000266/2005014;

05000301/2005014

Dear Mr. Koehl:

On June 17, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed a special

inspection at your Point Beach Nuclear Plant, Units 1 and 2. The purpose of the inspection was

to review your progress in meeting the commitments documented in the Confirmatory Action

Letter (CAL) dated April 21, 2004. The enclosed report documents the inspection results. The

preliminary results were discussed on June 17, 2005, with Mr. James McCarthy and other

members of your staff.

The inspection examined activities conducted under the CAL and your license as they relate to

safety and to compliance with the Commissions rules and regulations and with the conditions of

your license. Within these areas, the inspection involved examination of selected procedures

and representative records, observations of activities, and interviews with personnel.

The inspectors identified no violations of NRC requirements and no findings.

On January 19, 2005, I and members of my staff met with Mr. McCarthy and other members of

your staff to discuss previous NRC observations on inconsistency in the quality of the CAL item

closure packages and ambiguity with the actual closure status of several of the packages.

During the present inspection, we noted an overall marked improvement in package quality and

no ambiguity on package status.

As a result of this inspection, we noted improvement in the area of Human Performance. We

will continue to monitor the effectiveness of your actions taken in this area as well as the areas

of Engineering Design Control, Engineering/Operations Interface, Emergency Preparedness,

and the Corrective Action Program. Our focus will be to ascertain whether or not your actions

taken in these areas demonstrate sustainable improved performance.

D. Koehl -2-

If you have any questions regarding the results of the inspection, please contact me or Mr.

Patrick Louden of my staff at (630) 829-9627.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and any response you provide will be available electronically for public inspection

in the NRC Public Document Room or from the Publicly Available Records System (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/

Steven A. Reynolds

Deputy Director

Division of Reactor Projects

Docket Nos. 50-266; 50-301

License Nos. DPR-24; DPR-27

Enclosure: Inspection Report 05000266/2005014; 05000301/2005014

w/Attachment: Supplemental Information

cc w/encl: F. Kuester, President and Chief

Executive Officer, We Generation

J. Cowan, Executive Vice President

Chief Nuclear Officer

D. Cooper, Senior Vice President, Group Operations

J. McCarthy, Site Director of Operations

D. Weaver, Nuclear Asset Manager

Plant Manager

Regulatory Affairs Manager

Training Manager

Site Assessment Manager

Site Engineering Director

Emergency Planning Manager

J. Rogoff, Vice President, Counsel & Secretary

K. Duveneck, Town Chairman

Town of Two Creeks

Chairperson

Public Service Commission of Wisconsin

J. Kitsembel, Electric Division

Public Service Commission of Wisconsin

State Liaison Officer

DOCUMENT NAME: C:\MyFiles\Roger\ML051880088.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

NAME MKunowski:dtp PLouden SReynolds

DATE 06/30/05 06/30/05 07/01/05

OFFICIAL RECORD COPY

D. Koehl -3-

ADAMS Distribution:

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RidsNrrDipmIipb

GEG

KGO

CAA1

RGK

C. Pederson, DRS (hard copy - IRs only)

DRPIII

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PLB1

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ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 50-266; 50-301

License Nos: DPR-24; DPR-27

Report No: 05000266/2005014; 05000301/2005014

Licensee: Nuclear Management Company, LLC

Facility: Point Beach Nuclear Plant, Units 1 and 2

Location: 6610 Nuclear Road

Two Rivers, WI 54241

Dates: June 13 - 17, 2005

Inspectors: M. Kunowski, Project Engineer

J. Jacobson, Senior Engineering Inspector

Approved by: P. Louden, Chief

Branch 5

Division of Reactor Projects

Enclosure

SUMMARY OF FINDINGS

IR 05000266/2005014, 05000301/2005014; Nuclear Management Company; on 6/13/2005 -

06/17/2005; Point Beach Nuclear Plant, Units 1 & 2; Special Inspection, Confirmatory Action

Letter Followup.

This report covers a special inspection conducted to review the licensees progress in meeting

commitments documented in Confirmatory Action Letter (CAL) 3-04-001, dated April 21, 2004.

No findings were identified. The significance of most findings is indicated by their color (Green,

White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination

Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a

severity level after NRC management review. The NRCs program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self-Revealed Findings

None.

B. Licensee-Identified Findings

None.

1 Enclosure

REPORT DETAILS

1. Background

In the first quarter of 2003, Point Beach Nuclear Plant entered the Multiple/Repetitive

Degraded Cornerstone Column (Column IV) of the Action Matrix of NRC Inspection

Manual Chapter 0305, Operating Reactor Assessment Program, as a result of a high

safety significance (Red) inspection finding. The finding involved the potential for a

common mode failure of the auxiliary feedwater system (AFW) following a loss of the

instrument air system. This issue was initially identified in November 2001. A second

Red inspection finding (Yellow for Unit 1 and Red for Unit 2) was subsequently identified

which involved the potential common mode failure of the AFW pumps due to plugging of

the recirculation line pressure reduction orifices. This issue was initially identified in

October 2002. From July 28 to December 16, 2003, the NRC conducted a three-phase

supplemental inspection to review the corrective actions for the two AFW issues, in

accordance with NRC Inspection Procedure (IP) 95003, Supplemental Inspection for

Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow

Inputs, or One Red Input. The results of this inspection were documented in Inspection

Report (IR) 05000266/2003007; 05000301/2003007, dated February 4, 2004.

Subsequently, on March 17, 2004, a Notice of Violation and a $60,000 civil penalty were

issued for a problem identified during the IP 95003 inspection regarding unauthorized

changes to the Emergency Action Level scheme in the Point Beach Emergency

Response Plan.

On April 21, 2004, Confirmatory Action Letter (CAL) 3-04-001 was issued

documenting commitments made by Nuclear Management Company, LLC (NMC) in

a March 22, 2004, letter to address areas of regulatory concern identified during the

IP 95003 inspection. The basis for these commitments is the NMC Point Beach

Excellence Plan, an improvement plan intended to focus the Point Beach organization,

site programs, and initiatives on not only the performance issues identified during the

IP 95003 inspection but also on issues identified through internal assessments and on

areas for meeting NMCs goal of improving performance at Point Beach. Updates of the

Excellence Plan were submitted to the NRC on April 1, August 13, and

December 28, 2004. The Excellence Plan is composed of Action Plans to address

improvement areas. Each Action Plan is composed of Action Steps with corresponding

due dates. Of the total 1841 Action Steps in the Excellence Plan, 143 steps were part of

the NMC March 22nd commitment letter.

In June 2004, the initial special inspection of the licensees implementation of the

commitments in the CAL was conducted (IR 05000266/2004005; 05000301/2004005).

Of the 6 Action Step closure packages reviewed, 2 packages had problems indicative of

a need for licensee management to provide additional oversight of package quality. An

in-progress assessment of additional Action Step closure packages was conducted in

July during an NRC Safety System Design and Performance Capability inspection

(IR 05000266/2004004; 05000301/2004004). In August and September, Action Step

closure packages pertaining to emergency preparedness were reviewed during an

inspection (IR 05000266/2004007; 05000301/2004007). As with the inspection in June,

additional information for several packages was required in order for the inspectors to

conclude that all necessary actions related to emergency preparedness had been

2 Enclosure

completed. In late August to early November 2004, eight Action Step closure

packages were reviewed during an expanded problem identification and resolution

inspection (IR 05000266/2004008; 05000301/2004008). During that inspection, the

inspectors concluded that one of the packages, pertaining to the conduct of an

interim effectiveness review of improvements and corrective actions for the

operating experience program, was closed prematurely. And in January 2005, the

NRC completed its second CAL commitment-specific special inspection

(IR 05000266/2004011; 05000301/2004011). Closure packages for 24 Action Steps

specifically committed to in the CAL by the licensee and packages for two Action Steps

not committed to in the CAL were reviewed by the inspectors. The inspectors identified

no findings; however, they did identify inconsistency in the quality of the closure

packages and ambiguity with the actual closure status of several of the packages. This

issue was discussed further with the licensee and corrective actions were taken.

The main purpose of the current inspection was to review the licensees progress in

implementing CAL commitments. The inspection consisted of interviews with personnel,

attendance at plant meetings, in-plant observations, and a review of procedures, Action

Plan Action Step closure packages, and other plant records. The Action Steps reviewed

by the inspectors are discussed below, grouped in four of the five regulatory areas of

concern from the April 21, 2004, CAL.

2. Review of Completed Excellence Plan Action Plan Action Steps

i. Regulatory Area of Concern: Human Performance

a. Inspection Scope

The inspectors reviewed the following completed Excellence Plan Action Plan Action

Steps associated with the CAL human performance area of regulatory concern.

b. Observations

Action Plan Title Step

OR-01-001 Improve Human Performance and Work Practices 22

This step consisted of conducting a final effectiveness review of Action Plan OR-01-001,

which implemented the infrastructure of human performance improvement at the site.

The inspectors interviewed site personnel, including the human performance

coordinator. In addition, various human performance tools, procedures, and internal

information from the licensee were reviewed.

Implementation of Action Plan Action Step

The effectiveness review, conducted February 28 - March 4, 2005, concluded that

actions taken as part of the Action Plan had been effective at improving human

performance. Inspector followup indicated that much of the success of the Action Plan

had to do with the conscientiousness of the stations Human Performance Coordinator,

who had been assigned to that position since mid-June 2004, and upper management

3 Enclosure

support. Continuation of these efforts and continuing increased buy-in from plant staff

and line management should ensure sustainability of the improvements made to date.

The licensee completed the Action Plan Action Step as committed in the

March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify

any significant problems with actions taken to complete this step. The inspectors also

noted that the closure package for this effectiveness review was complete and of high

quality.

Action Plan Title Step

OR-01-004 Individual Behavioral Excellence 19

This step required that senior managers discuss department performance indicators at

Management Review Meetings (MRMs), monthly meetings of station and offsite NMC

upper management.

Implementation of Action Plan Action Step

The department performance indicators were contained in the licensees ACEMAN

database. Point Beach Nuclear Plant Business Manual Procedure (NP) 1.1.10, Human

Performance Program, Revision 3, was issued on July 28, 2004, and contained the

ACEMAN roll-up requirements and the requirement to have the data reviewed by

management on a monthly basis. This database review was also discussed in the Job

Aid, dated May 9, 2005, for the monthly MRMs and the core agenda slides for the MRM

contained a note to ensure that deletion of this agenda item did not occur because of its

relation to an NRC CAL commitment. The NRC inspectors also verified that the

performance indicators were an agenda item and discussed at the April 30, 2005, MRM.

The licensee has proceduralized the requirement for monthly management review of

department performance indicators and provided reasonable assurance that this practice

would continue in the future. The licensee completed the Action Plan Action Step as

committed in the March 22, 2004, letter and as incorporated in the CAL. The inspectors

did not identify any significant issues with the actions taken to complete this step.

Action Plan Title Step

OR-01-004 Individual Behavioral Excellence 36

This step consisted of conducting a final effectiveness review of efforts to improve

individual behavior/performance. These efforts were based on implementing the

licensees ACEMAN model for human performance improvement and the licensees

Picture of Excellence.

Implementation of Action Plan Action Step

4 Enclosure

The effectiveness review, conducted October 25 - November 5, 2004, concluded that

individual behaviors at Point Beach had improved since implementation of the various

Action Plan steps. The efforts of the Human Performance Coordinator, station upper

management, and corporate upper management, and refinements of the ACEMAN

model and in the implementation of the Picture of Excellence have helped in the

increasingly institutionalized focus of plant staff on individual (and group) performance

improvement. The licensee completed the Action Plan Action Step as committed in the

March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify

any significant problems with actions taken to complete this step. The inspectors also

noted that the closure package for this effectiveness review was complete and of high

quality.

ii. Regulatory Area of Concern: Engineering Design Control

a. Scope

The inspectors reviewed the following completed Excellence Plan Action Plan Action

Steps associated with the CAL engineering design control area of regulatory concern.

b. Observations

Action Plan Title Step

OR-08-005 Improve Human Performance in Engineering 19

This step consisted of performing an effectiveness review (EFR055644) of the efforts to

improve human performance in engineering and to maintain the 12-month average of

days between event clock resets greater than 10.

Implementation of Action Plan Action Step

The objectives of this Action Plan were to establish an engineering Human Performance

Improvement Team (HPIT), establish a process for identifying and evaluating human

performance events, provide training, and achieve an improving trend in the Engineering

Event Clock performance indicator. An interim effectiveness review (EFR055643) was

conducted by the licensee in September 2004 and was reviewed by the NRC inspectors

(IR 05000266/2004011; 05000301/2004011). This review indicated that additional

supervisory training was needed and that sustained improved performance was required

to achieve the greater than 10 day engineering human performance indicator.

Lesson Plan ESC-050-001L, Human Performance Tools for Engineering Supervision,

Revision 0, was prepared and approved on January 10, 2005, and supervisory training

was conducted on January 11. The 12-month average days between event clock resets

had improved from 6.9 days in July 2004 to 15.2 days in May 2005 and reached the

commitment goal of greater than 10 days in January 2005. Evaluation of this

performance indicator was part of the charter for the engineering HPIT and the indicator

was reviewed monthly at the MRM, attended by site and offsite NMC senior managers.

The current effectiveness review concluded that all four objectives for this Action Plan

had been met. The licensee completed the Action Plan Action Step as committed in the

5 Enclosure

March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify

any significant problems with actions taken to complete this step.

Action Plan Title Step

OR-08-015 Establish an Engineering Safety and Design Review

Group (ESDRG) 6

This step required that a process be established to provide feedback to engineering staff

regarding comments or issues identified during ESDRG review of engineering products.

Implementation of Action Plan Action Step

Engineering Supplemental Guidelines (ESG) 6.3, Engineering Safety and Design

Review Group Feedback Process, was issued on June 4, 2004. Subsequent to this, an

effectiveness review (EFR055478) was conducted and identified areas for improvement

in the feedback process. One of the improvements consisted of providing more

descriptive feedback memos to engineering personnel by providing examples of

comments from the reviewers with added details from the reviewed products to provide a

better understanding of the condition and applicability of the comments.

The effectiveness review also determined that the respective engineering supervisors

did not consistently share the content of the feedback memos with the staff. This

resulted in a missed learning opportunity. As a result, ESG 6.3 was revised to include

the requirement that sharing of the ESDRG comments with the engineering staff be

documented. In addition to improving the feedback memos, corrective action CA060195

was issued to track the initiation of information sharing sessions between the ESDRG

and the engineering groups.

The inspectors reviewed the feedback memo dated December 1, 2004, and attended an

information sharing session on March 2, 2005. The memo was found to be effective in

summarizing the ESDRG reviews and the specific examples were an aid in

understanding the comments. The information sharing session was found to

demonstrate a good safety focus and provide informative examples. Staff interaction

was considered excellent. The licensee completed the Action Plan Action Step as

committed in the March 22, 2004, letter and as incorporated in the CAL. The inspectors

did not identify any significant problems with actions taken to complete this step.

Action Plan Title Step

OR-08-015 Establish an Engineering Safety and Design Review

Group 7

This step, part of the licensees effort to improve the products of the engineering group,

consisted of performing an effectiveness review (EFR055478) to evaluate the impact of

the ESDRG on engineering product quality.

6 Enclosure

Implementation of Action Plan Action Step

The licensees effectiveness review was reviewed by the NRC inspectors during a

previous inspection (IR 05000266/2004011; 05000301/2004011). The licensees Quality

Review Team scores of engineering products continued to show an improving trend.

The issues identified in the effectiveness review regarding ESDRG feedback were

adequately resolved and are discussed above. The ESDRG continued to provide an

effective vehicle in assuring quality engineering products. The licensee completed the

Action Plan Action Step as committed in the March 22, 2004, letter and as incorporated

in the CAL. The inspectors did not identify any significant problems with actions taken to

complete this step.

Action Plan Title Step

EQ-15-011 Procure Transformer Tap Change Material 12

This step required that any materials needed to change transformer taps on the Unit

Auxiliary Transformers and the Low Voltage Station Auxiliary Transformer be procured

for the Bolted Fault Project.

Implementation of Action Plan Action Step

The licensee reviewed the Component Instruction Manual for the transformers and

determined that they were equipped with no-load tap changers; therefore, no materials

were required to accomplish tap changes. The licensee completed the Action Plan

Action Step as committed in the March 22, 2004, letter and as incorporated in the CAL.

The inspectors did not identify any significant problems with actions taken to complete

this step.

iii. Regulatory Area of Concern: Engineering/Operations Interface

a. Scope

The inspectors reviewed the following completed Excellence Plan Action Plan Action

Steps associated with the CAL engineering/operations interface area of regulatory

concern.

b. Observations

Action Plan Title Step

OR-08-016 Reduce Operable But Degraded/But Non-Conforming

Backlog 5

This step required that any operability determinations open longer than 1 fuel cycle have

documented justification and plant manager approval.

Implementation of Action Plan Action Step

7 Enclosure

The inspectors were provided with a summary of justifications dated March 9, 2005, for

those operability determinations remaining open greater than 1 fuel cycle. The

inspectors reviewed the justifications for the 12 operability determinations remaining

open and did not identify any significant problems with actions taken to complete this

step. The licensee completed the Action Plan Action Step as committed in the

March 22, 2004, letter and as incorporated in the CAL.

Action Plan Title Step

OR-08-017 Improve Operations Department and Engineering

Department Interface 1

This step required the implementing of an operational decision-making procedure to help

improve the operations/engineering interface.

Implementation of Action Plan Action Step

NP 1.1.12, Operational Decision Making Issue Evaluation Process, Revision 0, was

issued on July 30, 2004. This procedure established requirements for evaluation of

technical and operational decisions that affected plant operations, safety, reliability, and

material condition. The licensee completed the Action Plan Action Step as committed in

the March 22, 2004, letter and as incorporated in the CAL. The inspectors noted that the

licensee has been inconsistent in its use of the procedure when degraded plant

conditions were identified. For example, the procedure was not implemented in

August 2004 when the control room ventilation system was degraded and in

February 2005 after an offsite grid disturbance affected the safety-related battery

chargers, one of which required troubleshooting and repair. Noteworthy, is that the

procedure was implemented during the current Unit 2 refueling outage on two occasions.

Overall, the inspectors concluded that the NP 1.1.12 process has been an effective tool

to address previous concerns in this area. The inspectors will continue to monitor the

licensees use of the process to fully understand the threshold for the implementation of

the process.

Action Plan Title Step

OR-08-017 Improve Operations Department and Engineering

Department Interface 2

This step required a self-assessment be performed of the Plant Health Committee (PHC)

per fleet procedure FP-PA-SA-03, Snapshot Self Assessment Process.

Implementation of Action Plan Action Step

A self-assessment was conducted on August 26, 2004 in accordance with fleet

procedure FP-PA-SA-03. The assessment identified that while good issues were

8 Enclosure

presented to the PHC, the PHC lacked a process to plan and develop a business case

for long-term equipment projects. Also, the PHC had not established a prioritized list of

long-term equipment problems requiring resource allocation. The PHC was formed early

in 2003; however, meetings were not held routinely and were frequently cancelled. The

assessment concluded that the PHC had not yet demonstrated a long term commitment

to review system and program health.

In response to the issues identified above, the licensee issued procedure NP 1.1.15,

Identification, Approval, and Tracking of Plant Health Equipment Issues, dated

June 10, 2005. This procedure described the process for the PHC to identify, rank,

approve, prioritize, and disposition equipment issues. The procedure also provided

guidance on the process to present the issues and requirements to monitor the progress

of action completion. Plant Health Equipment issues were tracked on a list and

prioritized based on the Equipment Grading Sheet score so that site resources could be

applied to those issues determined to be the most important. The list tracked long-term,

operator-burden, and resource-burden issues. Those projects costing in excess of

$50,000 were processed in accordance with procedure NP 12.2.1, Project Management

Process, dated September 22, 2004.

The procedures discussed above appeared to address the weaknesses identified in the

self-assessment and provided a structure to the PHC process. The licensee completed

the Action Plan Action Step as committed in the March 22, 2004, letter and as

incorporated in the CAL. The inspectors did not identify any significant problems with

actions taken to complete this step.

Action Plan Title Step

OR-08-017 Improve Operations Department and Engineering

Department Interface 4

This step required a self-assessment of the Design Engineering Review Board (DRB)

per fleet procedure FP-PA-SA-03, Snapshot Self Assessment Process.

Implementation of Action Plan Action Step

Self-assessment PBSA-ENG-04-013, Revision 1, was issued on May 3, 2005, to

evaluate the effectiveness of the DRB. This assessment reviewed associated

procedures, memos, and corrective actions, and conducted a survey of engineering and

operations DRB members. The assessment concluded that the DRB was an effective

tool to increase ownership and participation in the modification process and provide

comprehensive reviews of modifications. Feedback from the DRB to the engineering

staff provided direct improvements in the modifications, as well as increased awareness

of considerations applicable to future modification work. The licensee completed the

Action Plan Action Step as committed in the March 22, 2004, letter and as incorporated

in the CAL. The inspectors did not identify any significant problems with actions taken to

complete this step.

9 Enclosure

Action Plan Title Step

OR-08-017 Improve Operations Department and Engineering

Interface 6

This step required improved communications between operations and engineering

personnel to achieve a common understanding of system design bases and operational

practice to reduce operator burdens (e.g., operator workarounds, control room

deficiencies, lit annunciators, and temporary modifications).

Implementation of Action Plan Action Step

Procedure NP 2.1.4, Operator Burdens, Revision 5, was issued to define, review,

catagorize, and track these issues. Awareness of operator burdens has been raised by

maintaining a list of these items and including it in the PBNP status report as part of the

daily production meeting. During the plan-of-the-day meetings, on a weekly basis,

operator burdens were reviewed and discussed. Total operator burdens were discussed

and tracked on a monthly basis with NMC management. This increased focus has

resulted in a reduction of operator burdens since the end of the first quarter of 2004 to

consistently under the fleet expectation of less than 36. The licensee completed the

Action Plan Action Step as committed in the March 22, 2004, letter and as incorporated

in the CAL. The inspectors did not identify any significant problems with actions taken to

complete this step.

iv. Regulatory Area of Concern: Corrective Action Program

a. Scope

The inspectors reviewed the following completed Excellence Plan Action Plan Action

Steps associated with the CAL corrective action program area of regulatory concern.

b. Observations

Action Plan Title Step

OP-10-010 Operating Experience (OE) Improvement Plan 23

This step consisted of performing an effectiveness review of the implementation of

CA032717 within the maintenance department as well as effectiveness of the OE

Improvement Plan. CA032717, CAL STEP - Maint Use of OE During Prejob Briefs,

August 12, 2003, was the item established in the stations corrective action program to

track the completion of OP-10-010, step 22, to implement a new electronic method for

accessing OE for pre-job briefs for maintenance.

Implementation of Action Plan Action Step

The effectiveness review was conducted, from January 10-14, 2005, as a self-

assessment of the operating experience program. It concluded that, overall, actions

taken as part of the Action Plan to improve the program had been effective and were

10 Enclosure

sustainable. Several areas were identified where enhancements were deemed

appropriate and corrective action program documents (CAPs) were subsequently

generated to track the completion of these items. For CA32717, the effectiveness

review concluded that, whereas the database had been established and was being

used, a plan was needed to populate the pre-job database with briefs for the various

repetitive jobs performed by the maintenance department and formalized in procedures

and routine surveillances/tasks (so called callups). This issue is discussed below.

The licensee completed the Action Plan Action Step as committed in the

March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify

any problems with actions taken to complete this step. The closure package for this

effectiveness review was complete and of high quality, and the licensee made good use

of expertise from outside of NMC in the conduct of the review, with personnel from a

leading industry group and other utilities.

Action Plan Title Step

OP-10-010 Operating Experience (OE) Improvement Plan 22

This step consisted of implementing a new electronic method for access of OE for pre-

job briefs for maintenance. As discussed above, this step was designated as CA032717

in the stations corrective action program.

Implementation of Action Plan Action Step

The effectiveness review conducted as part of Step 23 of Action Plan OP-10-010

identified the need for a plan to be developed to ensure that the database was populated

with all of the relevant information from the various maintenance documents. Although

some of the documents had been entered into the database and the resulting canned

pre-job briefs had been used or were available for use in November 2004, a large

number of maintenance procedures and callups had not been entered. In addition, the

effectiveness review identified that an understanding of how the database would be

populated and who would do the populating was not clearly understood by relevant

personnel, procedural guidance on this issue was not definitive, most of the OE in the

database was external OE and not internal OE, the level of knowledge in the

maintenance planning group about the database was inconsistent, operations planners

had been given a general familiarization of the database but not detailed training to allow

them to use the database, only one maintenance person and two operations persons

were populating the database, and radiation protection supervisors had not had time to

input radiation protection information into the database.

In the response to the observations during the effectiveness review, the licensee wrote

CAP061651, Need to Populate the Pre-job Brief Data Base, January 24, 2005. From

this CAP, several corrective actions (CAs) were generated, including CAs to train

appropriate staff members, with a due date of June 24, 2005, and fully populate the

database, with a due date of December 28, 2005.

In revision 3 of the Excellence Plan, which was incorporated in the April 21, 2004, CAL,

the licensee committed to complete this Action Step in the third quarter of 2004. Based

11 Enclosure

on the implementation of the database in November 2004, the problems identified with

the database in January 2005 during the effectiveness review, and the protracted due

date of December 28, 2005, needed for fully populating the database, the inspectors

concluded that this Action Step had not been completed by the committed due date.

4OA6 Meetings

.1 Exit Meeting

On June 17, 2005, the inspectors presented the preliminary inspection results to

Mr. James McCarthy and other members of the Point Beach staff. In particular, the

inspectors discussed their observations regarding the pre-job briefing database Action

Step and the need for correspondence from the licensee updating the commitment. The

licensee acknowledged the observations and indicated that the completion dates of the

corrective actions for the identified problems would be evaluated The licensee did not

identify any information, provided to or reviewed by the inspectors and likely to be

included in the inspection report, as proprietary.

4OA7 Licensee-Identified Violation

None.

ATTACHMENT: SUPPLEMENTAL INFORMATION

12 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Arnold, Excellence Team Specialist

T. Carter, System Engineering Manager

S. Cassidy-smith, Communications Manager

B. Cruise, General Supervisor - Maintenance Support

F. Flentje, Regulatory Affairs Principal Analyst

R. Flessner, Excellence Team Lead

M. Lorek, Plant Manager

J. McCarthy, Site Director of Operations

D. Peterson, Human Performance Coordinator

L. Peterson, Design Engineer Manager

S. Pfaff, Acting Performance Assessment Manager

S. Ruesch, Procedures Manager

J. Schweitzer, Site Engineering Director

G. Sherwood, Programs Engineering Manager

W. Smith, Production Planning Manager

Nuclear Regulatory Commission

P. Louden, Chief, Reactor Projects, Branch 5

R. Krsek, Senior Resident Inspector, Point Beach

M. Morris, Resident Inspector, Point Beach

1 Attachment

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None.

Closed

None.

Discussed

None.

2 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection, including

documents prepared by others for the licensee. Inclusion of a document on this list does not

imply that NRC inspectors reviewed the entire documents, but, rather that selected sections or

portions of the documents were evaluated as part of the overall inspection effort. In addition,

inclusion of a document on this list does not imply NRC acceptance of the document, unless

specifically stated in the body of the inspection report.

CA032717; CAL STEP - Maint Use of OE During Prejob Briefs: August 12, 2003

CA061167; Translation of CAL Commitment Into Procedure Needs Improvement;

January 13, 2005

CA061332; Develop a Plan - Need to Populate the Pre-job Brief Data Base; January 26, 2005

CA063322; Need to Populate the Pre-job Brief Data Base - Select Individuals for Inputs;

June 10, 2005

CA063323; Need to Populate the Pre-job Brief Data Base - Identify Training Needs;

June 10, 2005

CA063324; Need to Populate the Pre-job Brief Data Base - Establish Work Off Curves;

June 10, 2005

CA063325; Need to Populate the Pre-job Brief Data Base - Populate With Commonly Used

Maintenance Documents; June 10, 2005

CAP031808; PBNP OE Program Has Severe Implementation Weaknesses; March 25, 2003

CAP061651; Need to Populate the Pre-Job Data Base; January 24, 2005

CAP065112; ACEs Contain Inadequate Use of OE; June 14, 2005

Nuclear Plant Memorandum NPM 2005-0307; First Quarter 2005 Human Performance Analysis;

May 10, 2005

Point Beach Nuclear Plant Business Manual NP 1.1.7; Managing Work Activity Risk;

February 16, 2005

NP 1.1.10; Human Performance Program; February 2, 2005

NP 1.6.10; Pre- and Post-Job Briefs; February 16, 2005

NP 13.6.1; Point Beach Site Observation Program; March 23, 2005

Operating Experience Guideline 007; External Operating Experience Program Guidance;

February 23, 2005

Point Beach Form PDF-9175; Job Walkdown Checklist; May 19, 2005

PBF-9175a; Job Walkdown Facilities Checklist; February 17, 2004

PBF-9205; High Risk Work Pre-job Briefing Checklist; December 16, 2004

PBF-9217; Pre-job Brief Checklist; May 12, 2005

PBF-9218; Post-job Brief Checklist; November 1, 2000

PBF-9812; Categorization and Mitigation of Risk; February 16, 2005

Training Material; NMC Excellence in Human Performance

3 Attachment

LIST OF ACRONYMS USED

ACE Apparent Cause Evaluation

ADAMS Agency Wide Access Management System

AFW Auxiliary Feedwater

CA Corrective Action

CAL Confirmatory Action Letter

CAP Corrective Action Program Document

CE Condition Evaluation

CFR Code of Federal Regulations

DBD Design Basis Document

DRB Design Engineering Review Board

DRP Division of Reactor Projects

EFR Effectiveness Review

ESDRG Engineering Safety and Design Review Group

ESG Engineering Supplemental Guidelines

HPIT Human Performance Improvement Team

IMC Inspection Manual Chapter

IP Inspection Procedure

IR Inspection Report

NMC Nuclear Management Company, LLC

NOS Nuclear Oversight (Quality Assurance)

NP Point Beach Nuclear Plant Business Manual Procedure

NRC Nuclear Regulatory Commission

OD Operability Determination

OTH Other (Corrective Action Program Document)

PBNP Point Beach Nuclear Plant

PHC Plant Health Committee

QRT Quality Review Team

RCE Root Cause Evaluation

SDP Significance Determination Process

TRP Technical Review Panel

TS Technical Specification

URI Unresolved item

WO Work Order

4 Attachment