ML060940465

Perry CAL Inspection - IP 95002 Action Item Review; CAL 3-05-001

ML060940465
Person / Time
Site:	Perry
Issue date:	03/30/2006
From:	Satorius M A Division Reactor Projects III
To:	Pearce L W FirstEnergy Nuclear Operating Co
References
CAL 3-05-001 IR-06-007
Download: ML060940465 (35)

Text

March 30, 2006CAL 3-05-001 Mr. L. William PearceVice President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant 10 Center Road, A290 Perry, OH 44081

SUBJECT:

PERRY NUCLEAR POWER PLANT CONFIRMATORY ACTION LETTER(CAL) FOLLOWUP INSPECTION INSPECTION PROCEDURE 95002INSPECTION FOLLOWUP ISSUES ACTION ITEM REVIEW NRC INSPECTION REPORT 05000440/2006007

Dear Mr. Pearce:

The purpose of this letter is to provide you with Inspection Report (IR) 05000440/2006007,detailing the results of a Confirmatory Action Letter followup inspection in the area of Inspection Procedure (IP) 95002 Inspection Followup Issues. During this inspection, the NRC reviewedselected Commitments and Action Items in this area that you completed to address issues identified during previous IP 95002 and IP 95003 inspections and determined whether these items had been adequately implemented. You and other members of your staff attended the March 14, 2006, public exit meeting held at the Quail Hollow Resort in Painesville, Ohio, duringwhich the results of this CAL followup inspection activity were presented. A summary of the public meeting was documented in a letter to you dated March 17, 2006.As a result of poor performance, the Nuclear Regulatory Commission designated the PerryNuclear Power Plant as a Multiple/Repetitive Degraded Cornerstone column facility in theNRC's Action Matrix in August 2004. As documented in followup IP 95003 SupplementalInspection Report 55000440/2005003, with regard to the NRC's review of issues associatedwith a previous IP 95002 inspection, the NRC determined that actions to address maintenanceprocedure adequacy and essential service water (ESW) pump failures were still in progress atthe end of the IP 95003 inspection. In addition, the NRC identified that one of your correctiveactions to address the verification of the quality of ESW pump work was inadequate. Also, actions to address training were still in progress at the end of the inspection. In this case,corrective actions to address the issue had not been timely and at the conclusion of the IP 95003 inspection, had not yet been implemented. By letters dated August 8, 2005, and August 17, 2005, you responded to the findings andobservations detailed in the NRC's IP 95003 supplemental inspection report. As discussed inthese letters, the Perry management team reviewed the achievements realized by the Performance Improvement Initiative (PII), NRC findings documented in the IP 95003supplemental inspection report, and the conclusions from various assessments, and developed updates to the PII. The Perry management team restructured the PII into the Phase 2 PII, L. Pearce-2-which contained six new initiatives with the overall purpose of implementing lasting actions toimprove the overall performance at the Perry Nuclear Power Plant. These actions included actions to address the issues associated with the previous IP 95002 inspection that were identified during the IP 95003 inspection.The specific purposes of this inspection were to: (1) determine whether your corrective actionsto address maintenance procedure adequacy issues were adequate, (2) determine whether your corrective actions to address emergency service water (ESW) pump coupling assembly concerns were adequate, and (3) determine whether your corrective actions to address training issues were adequate.Overall, we concluded that you satisfactorily implemented the Commitments and Action Itemsthat we reviewed and therefore your actions to address maintenance procedure adequacy, ESW pump coupling assembly, and training were adequate. Notwithstanding this overall conclusion, we also identified some cases where your implementation of these actions was weak, which potentially impacts your overall ability to effectively resolve these issues. Your staff should carefully consider the issues identified in this report regarding our observations of these weaknesses and supplement your actions, as necessary, to address these weaknesses.

This will help ensure that the desired improvements at Perry can be realized and oureffectiveness review of this area, tentatively planned for later this year, has a positive outcome.In addition, during the course of this inspection, the inspectors identified numerous humanperformance errors in which maintenance personnel failed to adhere to procedural requirements during in-field observations of maintenance activities. The human performance area has been a significant concern to us as reflected in our previous identification of this area as a substantive cross-cutting issue. Based on the observations during this inspection, it is not clear whether your corrective action efforts to date have had a positive impact in resolving this issue. Therefore, your continued attention to this area is warranted.Based on the results of this inspection, two findings of very low safety significance that involvedviolations of NRC requirements were identified. However, because of their very low safetysignificance and because these issues have been entered into your corrective action program, the NRC is treating these violations as non-cited violations (NCVs) in accordance withSection VI.A.1 of the NRC's Enforcement Policy.If you contest the subject or severity of these non-cited violations, you should provide aresponse within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director,Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Perry Nuclear Power Plant.

L. Pearce-3-You are requested to respond within 30 days of the date of your receipt of this letter. Yourresponse should describe the specific actions that you plan to take to address the issues raised during this inspection. The NRC will continue to provide increased oversight of activities at your Perry NuclearPower Plant until you have demonstrated that your corrective actions are lasting and effective.

Consistent with Inspection Manual Chapter (IMC) 0305 guidance regarding the oversight of plants in the Multiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix, theNRC will continue to assess performance at Perry and will consider at each quarterlyperformance assessment review the following options: (1) declaring plant performance to be unacceptable in accordance with the guidance in IMC 0305; (2) transferring the facility to theIMC 0350, "Oversight of Operating Reactor Facilities in a Shutdown Condition withPerformance Problems" process; and (3) taking additional regulatory actions, as appropriate.

Until you have demonstrated lasting and effective corrective actions, Perry will remain in theMultiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC'sdocument system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Sincerely,/RA/Mark A. Satorius, DirectorDivision of Reactor ProjectsDocket No. 50-440License No. NPF-58

Enclosure:

Inspection Report 05000316/2005013 w/Attachments:1. Supplemental Information2. Perry Performance Background

3. Perry IP 95003 Inspection ResultsDISTRIBUTION:See next page L. Pearce-3-You are requested to respond within 30 days of the date of your receipt of this letter. Yourresponse should describe the specific actions that you plan to take to address the issues raised during this inspection. The NRC will continue to provide increased oversight of activities at your Perry NuclearPower Plant until you have demonstrated that your corrective actions are lasting and effective.

Consistent with Inspection Manual Chapter (IMC) 0305 guidance regarding the oversight of plants in the Multiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix, theNRC will continue to assess performance at Perry and will consider at each quarterlyperformance assessment review the following options: (1) declaring plant performance to be unacceptable in accordance with the guidance in IMC 0305; (2) transferring the facility to theIMC 0350, "Oversight of Operating Reactor Facilities in a Shutdown Condition withPerformance Problems" process; and (3) taking additional regulatory actions, as appropriate.

Until you have demonstrated lasting and effective corrective actions, Perry will remain in theMultiple/Repetitive Degraded Cornerstone column of the NRC's Action Matrix. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room or from the Publicly Available Records (PARS) component of NRC'sdocument 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,Mark A. Satorius, DirectorDivision of Reactor ProjectsDocket No. 50-440License No. NPF-58

Enclosure:

Inspection Report 05000316/2005013 w/Attachments:1. Supplemental Information2. Perry Performance Background

3. Perry IP 95003 Inspection ResultsDISTRIBUTION:See next pageDOCUMENT NAME:E:\Filenet\ML060940465.wpd*See previous concurrence G Publicly Available G Non-Publicly Available G Sensitive G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copyOFFICERIIIRIIIRIIIRIII NAMERRuiz/dtp*EDuncan*KO'BrienMSatoriusDATE03/17/0603/17/0603/30/0603/30/06OFFICIAL RECORD COPY L. Pearce-4-cc w/encl:G. Leidich, President - FENOCJ. Hagan, Chief Operating Officer, FENOC D. Pace, Senior Vice President Engineering and Services, FENOC Director, Site Operations Director, Regulatory Affairs M. Wayland, Director, Maintenance Department Manager, Regulatory Compliance T. Lentz, Director, Performance Improvement J. Shaw, Director, Nuclear Engineering Department D. Jenkins, Attorney, FirstEnergy Public Utilities Commission of Ohio Ohio State Liaison Officer R. Owen, Ohio Department of Health L. Pearce-5-ADAMS Distribution

GYS KNJ SJC4 RidsNrrDirsIrib

GEG KGO RJP CAA1 C. Pederson, DRS (hard copy - IR's only)

DRPIII DRSIII PLB1 JRK1 ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)

EnclosureU.S. NUCLEAR REGULATORY COMMISSIONREGION IIIDocket No:50-440 License No:NPF-58 Report No:05000440/2006007 Licensee:FirstEnergy Nuclear Operating Company (FENOC)

Facility:Perry Nuclear Power Plant Location:10 Center RoadPerry, Ohio 44081Dates:January 9 through March 14, 2006 Inspectors:J. Ellegood, Lead Inspector, Palisades SRI, Region IIIP. Finney, Reactor Inspector, Region I C. Long, Project Engineer, Region IObserver:J. McGhee, Reactor Engineer, Region IIIApproved by:E. Duncan, ChiefBranch 6 Division of Reactor Projects

SUMMARY

OF FINDINGSIR 05000440/2006007; 1/9/2006 - 3/14/2006; Perry Nuclear Power Plant; Confirmatory ActionLetter (CAL) Followup Inspection - IP 95002 Issue Followup Action Item Review.This report covers a 2-week period of supplemental inspection by resident and region-basedinspectors. This inspection identified two Green findings, both of which involved non-cited violations of NRC requirements. The significance of most findings is indicated by their color(Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process." Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. TheNRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.NRC-Identified and Self-Revealed Findings*Green. A finding of very low safety significance and an associated non-cited violation ofTechnical Specification 5.4,"Procedures," was identified on January 19, 2006, when theinspectors identified during a safety-related breaker maintenance activity, 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." Specifically, licensee personnel failed to perform required minimum operating voltage testing on the safety-related EF1A05 breaker that provided power to Division 1 Motor Control Center (MCC), Switchgear (SWGR), and Battery Room Supply Fan A. The primary cause of this finding was related to the cross-cutting area of Human Performance because licensee personnel failed to adhere to a step-by-step procedure associated with safety-related equipment. As part of the licensee's corrective actions, an extent of condition review was conducted, which determined that no additionalsafety-related breakers were affected. The inspectors concluded that the finding was more than minor in accordance withexample 4.l in IMC 0612, Appendix E, "Examples of Minor Issues," since the subject breaker was subsequently determined to be out of specification. This issue was also associated with the equipment performance attribute of the Mitigating Systemscornerstone and affected the cornerstone objective of ensuring the availability, reliabilityand capability of systems that respond to initiating events to prevent undesirableconsequences. The finding was of very low safety significance because: (1) it did not represent an actual loss of safety function of a system; (2) it did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time; (3) it did not represent an actual loss of safety function of one or more non-Technical Specification trains of equipment designated as risk-significant per 10 CFR 50.65 for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (4) it did not screen as potentially risksignificant due to a seismic, fire, flooding, or severe weather initiating event.

(Section 3.1)

• Green. A finding of very low safety significance and an associated non-cited violation ofTechnical Specification 5.4, "Procedures," was identified on January 10, 2006, when theinspectors observed during a calibration check of a Division III Emergency DieselGenerator (EDG) Exhaust Air Damper, that licensee personnel failed to perform required steps prescribed by procedure ICI-B12-0001, "ITT NH90 Series MilliampereProportional/On-Off Hydramotor Actuator Calibration." The primary cause of this finding was related to the cross-cutting area of Human Performance because licensee personnel failed to adhere to a step-by-step procedure associated with safety-related equipment. As part of their corrective actions, licensee personnel revised ICI-B12-0001 to clarify the requirements of the procedure. This finding was more than minor because it was associated with the Mitigating Systemcornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiatingevents to prevent undesirable consequences. The finding was of very low safety significance because: (1) it did not represent an actual loss of safety function of a system; (2) it did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time; (3) it did not represent anactual loss of safety function of one or more non-Technical Specification trains of equipment designated as risk-significant per 10 CFR 50.65 for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;and (4) it did not screen as potentially risk significant due to a seismic, fire, flooding, or severe weather initiating event. (Section 3.1)B.Licensee-Identified ViolationsNone. REPORT DETAILS1.0 Backgr oundAs documented in NRC Inspection Procedure (IP) 95003 Supplemental Inspection Report05000440/2005003, with regard to the NRC's review of issues associated with a previousIP 95002 inspection, the NRC determined that actions to address maintenance procedureadequacy and Emergency Service Water (ESW) pump failures were still in progress at the endof the IP 95003 inspection. In addition, the team identified that one of the licensee's correctiveactions to address the verification of the quality of ESW pump work was inadequate. Actions to address training were also still in progress at the end of the inspection. In this case, thelicensee's corrective actions to address this issue had not been timely and at the conclusion of the IP 95003 inspection, had not yet been implemented. As a result, the NRC concl uded thattwo open White findings associated with the previous IP 95002 inspection would continue to remain open pending additional licensee actions and the NRC's review of those actions. Additional details regarding these White findings is discussed in Attachment 2, "Perry Performance Background," of this report.By letters dated August 8, 2005, "Response to NRC Inspection Procedure 95003 SupplementalInspection, Inspection Report 05000440/2005003," (ML052210512) and August 17, 2005, "Corrections for Response to NRC Inspection Procedure 95003 Supplemental Inspection,Inspection Report 05000440/2005003," (ML052370357) Perry Nuclear Power Plant (PNPP) responded to the inspection results discussed in the NRC's IP 95003 supplemental inspectionreport. A complete summary of all of the inspection results is discussed in Attachment 3, "Perry IP 95003 Inspection Results," of this report. As discussed in these letters, the Perry leadership team reviewed the achievements realized by the Performance Improvement Initiative (PII), NRC findings documented in the NRC's IP 95003 inspection report, and the conclusions from variousassessments, and developed updates to the PII. The leadership team restructured the PII into the Phase 2 PII, which contained six new initiatives with the overall purpose of implementing lasting actions to improve the overall performance at the Perry Nuclear Power Plant. These actions included actions to address the issues associated with the previous IP 95002 inspection that were identified during the IP 95003 inspection.2.0Inspection Scope The objectives of this inspection were to:2.Determine whether licensee corrective actions to address maintenance procedureadequacy issues were adequate. 3.Determine whether licensee corrective actions to address emergency service water(ESW) pump coupling assembly concerns were adequate.4.Determine whether licensee corrective actions to address training were adequate. To accomplish these objectives, the following Commitments and Action Items described in thePerry Phase 2 PII Detailed Action and Monitoring Plan (DAMP) and the licensee's August 8 and August 17, 2005, letters that provided the First Energy Nuclear Operating Company (FENOC)response to the findings in the IP 95003 inspection were reviewed:Procedure Adequacy*Commitment Item 1.a/DAMP Item B.2.2.3.1: "To date, one hundred eight (108) of theone hundred nineteen (119) procedures have been updated and issued. The remaining maintenance procedures have been updated and are currently going through the owner's review and acceptance review process."*Commitment Item 1.b/DAMP Item B.2.2.3.2: "CA [Corrective Action] 05-03655-01 is torevise Nuclear Quality Assurance Instruction (NQI)-1001, 'QC [Quality Control]

Inspection Program Control,' to specify a method by which classification can be established for additional inspection attention items that have experienced repeat failures. This method will include consideration of failure analysis, the risk-significanceof the item, and the probability of failure occurrence in determining the extent ofinspection activity."ESW Pump Coupling Assembly Concerns*Commitment Item 1.c/DAMP Item B.2.2.3.3: "CA 05-03655-03 is to revise GenericMechanical Instruction (GMI)-0039, 'Disassemble/Re-assembly of Divisions I and II Emergency Service Water Pumps,' and GMI-040, 'Disassembly/Re-assembly of Division III Emergency Service Water Pump,' to include QC inspection points for workactivities associated with pump shaft couplings, as specified by QC."*DAMP Item B.2.2.5: "Based on the results of the maintenance procedure upgrade planfor key critical components, develop a long term Maintenance Procedure Upgrade Plan and incorporate actions into the FENOC Business Plan (05-04586-01)."Training*Review the corrective action of "...development of proper planning for workmanagement to ensure strict compliance of job planning to eliminate misdirection during conduct of the job," described in Perry letter PY-CEI/

NRR-2897L datedAugust 17, 2005. *Review the corrective action of "...plant manager to discuss 'push back' in the dailyplant updates. This discussion will promote a challenging attitude from the employees,"described in Perry letter PY-CEI/

NRR-2897L dated August 17, 2005.*Review the corrective action of "...new human performance tools have been rolled outwhich reinforce use of human performance during stressful times. These tools are discussed in the following human performance procedures: (1) [Nuclear Operating Business Plan] NOBP-LP-2601, 'Human Performance Program'; (2) NOBP-LP-2603, 'Human Performance Tools and Verification Practices'; (3) NOBP-LP-2604, 'Job Briefs,'and (4) NOP-LP-2601, 'Procedure Use and Adherence,'" described in Perry letter PY-CEI/NRR-2897L dated August 17, 2005.3.0Procedure Adequacy 3.1Commitment Item 1.a/DAMP Item B.2.2.3.1 a.Inspection ScopeThe inspectors reviewed Commitment Item 1.a/DAMP Item B.2.2.3.1: "To date, onehundred eight (108) of the one hundred nineteen (119) procedures have been updated and issued. The remaining maintenance procedures have been updated and are currently going through the owner's review and acceptance review process."To accomplish this review, the inspectors performed a sampling of revised maintenanceprocedures and determined whether the procedures were technically adequate and accurate, were written in a manner that minimized the presence of human performance "traps," had identified critical steps, had incorporated place-keeping, could be accomplished as written, and contained information consistent with that in associatedvendor manuals.When possible, the inspectors also observed the in-field implementation of the revisedprocedures to determine whether the procedures could be implemented as written and accomplished the prescribed activity. b. Observations and FindingsThe inspectors concluded that the licensee's actions adequately implementedCommitment Item 1.a/DAMP Item B.2.2.3.1. b.1Technical Content Review ResultsThe inspectors reviewed 19 of the 119 revised maintenance procedures. Overall, theinspectors 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 forthe overhaul of a Residual Heat Removal (RHR) pump, did not include steps tore-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 thisprocedure deficiency to be of only minor significance. *The inspectors noted numerous instances of typographical errors and improperreferences. 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. b.2Identification of Missing "Critical" Procedure Step DesignationThe inspectors compared the critical steps identified in the procedures reviewed to thecriteria in MAI-0507, "Maintenance Procedures Writer's Guide," Revision 0, which defined a "Critical Step" with the following broad terms:"A Critical Step is an action which, if performed improperly, will l ead to anunintentional change that adversely impacts the plant, a system, or personnelsafety."In order to be considered as a Critical Step, MAI-0507 provided the following conditions:

• The state of the plant, system, or component, or the safety of an individualdepends solely on an individual worker, and*The outcome of the error is intolerable for personnel safety, the plant, orcomponent (independent of when the consequence is experienced).The inspectors identified numerous maintenance procedure steps that warrantedidentification as critical steps in these procedures, but had not been properly identified as such. Specific examples included:*CMI-0016, "Division I and II Emergency Diesel Generator Starting Air ValveRepair," 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 III Air Start Motor Maintenance," Revision 4, did not identifya 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.*GMI-0002, "Maintenance of the Control Rod Drive Pumps," Revision 2, did notidentify the measurement of runout 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 andmitigated 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 tothe next action.However, contrary to MAI-0507, no examples of mitigation strategies for critical stepscould be found in any of the revised procedures. These mitigation strategies were intended to provide additional assurance of proper step completion. Followup 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. b.3Weaknesses in the Use of Placekeeping Tools and Human FactoringThe inspectors confirmed that the licensee added placekeeping blocks to the revisedprocedures 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 notedperformance of one procedure with improper use of placekeeping techniques:*During hydramotor work, the inspectors noted that technicians performedmultiple steps in rapid succession without using proper placekeeping.*In the same procedure, the technicians performed several steps multiple timeswithout using placekeeping 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 thathampered 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 thisactivity 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 maintenanceprocedure 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 theprocedure were unclear. (Section b.4) *The inspectors observed the performance of maintenance procedureICI-B12-001, "ITT NH90 Series Milliampere Proportional/On-Off HydramotorActuator Calibration." During implementation of the procedure, maintenanceworkers failed to remove all required access covers to the hydramotor. The inspectors noted that the procedure did not specifically identify the covers to beremoved. (Section b.5) b.4Inappropriate Use of Not Applicable (N/A) in Procedure StepsThe inspectors identified that many of the revised maintenance procedures applied tomultiple 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 performancetrap. During the inspection, the inspectors identified the following specific example in which a procedure step was inappropriately N/A'd. 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. Failure to Perform Required Steps Prescribed by Procedure GEI-0009Introduction: A finding of very low safety significance and an associated non-citedviolation of Technical Specification 5.4,"Procedures," was identified on January 19, 2006, when 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." Specifically, licensee personnel failed to perform minimum operating voltage testing on the safety-related EF1A05 breaker that provided power to Division 1 Motor Control Center (MCC), Switchgear (SWGR), and Battery Room Supply Fan A.Description: As part of the review of revised maintenance procedures, the inspectorsreviewed completed work orders that implemented revised maintenance procedure GEI-0009, "ABB Low Voltage Power Circuit Breaker Types K-600 & K-600S Through K-3000 & K-3000S Maintenance," Revision 17. During a review of work order (WO) 200038182, which incorporated this procedure for a nonsafety-related condensate transfer pump breaker, the inspectors identified that subsection 5.2.3,"Minimum Operating Voltage and Anti-Pump Verification," was marked as not applicable (N/A) and was therefore not accomplished. Additionally, the verification of associated acceptance criteria in Section 6.0 was "checked" as having been verified although the data that would have been obtained in subsection 5.2.3 to compare against theacceptance criteria was marked as N/A. The inspectors questioned, based on the type of breaker tested, whether this procedure subsection should have been accomplished.

In response to the inspectors' questions, the licensee determined that this procedure section should have been performed. 0Licensee personnel also conducted an extent of condition review to identify additionalsafety-related breakers that may have been impacted. During this review, licensee personnel identified that WO 200035188 accomplished maintenance on breaker "EF1A05, MCC, SWGR & Battery Room Supply Fan A." In this work order, subsection 5.2.3 was left blank and neither "Sat" nor "Unsat" was marked in , the quality document data sheet for the maintenance performed. Thisomission indicated that the subsection could not be credited as having been performed,although required for this particular breaker. Fortuitously, the breaker was not reinstalled in the plant following the maintenance activity. Instead, it was shipped to a vendor facility for refurbishment to address previous breaker failures associated withNCV 05000440/2005005-003 and CR 05-04796. However, vendor facility testingidentified that the as-found minimum trip voltage at the trip coil was 81 Volts Direct Current (VDC), which was well outside the design voltage of 70 VDC. As such, the vendor concluded that the breaker "would NOT have performed its intended function in its 'as found' condition." Proper performance of the licensee's maintenance activity would have identified the discrepant condition.As part of the licensee's corrective actions, an extent of condition review was conducted,which determined that no additional safety-related breakers were affected.The inspectors determined that the licensee's failure to adhere to the steps in procedureGEI-0009 for safety-related breaker maintenance, which prevented the identification of abreaker that did not satisfy all required attributes to be considered functional, was a performance deficiency warranting a significance evaluation.Analysis: The inspectors concluded that the finding was more than minor in accordancewith example 4.l in IMC 0612, Appendix E, "Examples of Minor Issues," since the subject breaker was subsequently determined to be out of specification. This issue was also associated with the equipment performance attribute of the Mitigating Systemscornerstone and affected the cornerstone objective of ensuring the availability, reliabilityand capability of systems that respond to initiating events to prevent undesirableconsequences.This finding also affected the cross-cutting area of Human Performance since licenseepersonnel failed to properly adhere to a step-by-step procedure associated with safety-related equipment where adequate implementation of human performance toolswould have prevented errors from occurring.The inspectors completed a significance determination of this issue using Appendix A,"Determining the Significance of Reactor Inspection Findings for At-Power Situations,"

of IMC 0609, "Significance Determination Process," dated November 22, 2005. The inspectors determined that the finding was of very low safety significance, in accordance with the Phase 1 screening worksheet, because: (1) it did not represent an actual loss of safety function of a system; (2) it did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time; (3) it did not represent an actual loss of safety function of one or more non-Technical Specification trains of equipment designated as risk-significant per 10 CFR 50.65 for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (4) it did not screen as potentially risk significant due to a seismic, fire, flooding, or severe weather initiating event. In particular, no single failure 1would result in loss of heating, ventilation, and air-conditioning (HVAC) to both motorcontrol center (MCC), switchgear and miscellaneous electrical equipment areas. Enforcement: Technical Specification 5.4, "Procedures," required, in part, that writtenprocedures 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 equipmentshould 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, 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 1 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). b.5Failure to Perform Required Steps Prescribed by Procedure ICI-B12-0001Introduction: A finding of very low safety significance and an associated non-citedviolation of Technical Specification 5.4, "Procedures," was identified on January 10, 2006, when during a calibration check of a Division III Emergency Diesel Generator(EDG) Exhaust Air Damper, licensee personnel failed to perform required steps prescribed by procedure ICI-B12-0001, "ITT NH90 Series MilliampereProportional/On-Off Hydramotor Actuator Calibration."

Description:

On January 10, 2006, as part of their review of revised maintenanceprocedures, the inspectors observed the implementation of procedure ICI-B12-0001, "ITT NH90 Series Milliampere Proportional/On-Off Hydramotor Actuator Calibration,"Revision 4, during a calibration check of a Division III Emergency Diesel Generator(EDG) 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," Revision 0, required that "the user shall perform the following: Readeach step prior to performing it. Use approved placekeeping methods. Perform each step as written. Self-Check or Peer Check that the step was performed correctly. Read and perform each step in sequence." During implementation of ICI-B12-0001, the inspectors identified the following examples (listed chronologically) in which licensee personnel failed to adhere to NOP-LP-2601: *Step 5.9.2 of ICI-B12-0001 directed the user to verify the subject hydramotor hadbeen full-stroke cycled a minimum of five times. Although procedure steps whichprescribe this type of verification permit the re-positioning of plant components, in accordance with NOP-LP-2601, these actions must be specifically authorized by plant procedures. In this case, and as observed by the inspectors, although 2this guidance did not exist, licensee personnel performed future procedure stepsout-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 supporttesting. In this case, plant 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 limitswitch in accordance with Attachment 7, Figure 1. Contrary to this, plant 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 thehydramotor actuator for verification and recording of proper valve seating and stem travel. Contrary to procedure use guidance, plant 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 "placekeeping on the steps". These steps were repeated by plant personnel to satisfy the requirements of Step 5.9.2 without separatedocumentation and placekeeping annotation. *Step 5.9.10, 5.9.10.a and 5.9.10.b of ICI-B12-0001 directed the connection of amulti-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 their corrective actions, licensee personnel stopped the work activity andrevised ICI-B12-0001 to clarify the requirements in Section 5.9 of the procedure.

Licensee personnel also revised the use category from "Step-by-Step" to "In-Field Reference." The inspectors determined that the licensee's failure to adhere to the steps in calibrationprocedure ICI-B12-0001 was a performance deficiency warranting a significance evaluation.Analysis: The inspectors concluded that the finding was more than minor in accordancewith Appendix B, "Issue Screening," of IMC 0612, "Power Reactor Inspection Reports,"

dated September 30, 2005. The findings was associated with the Mitigating Systemcornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiatingevents to prevent undesirable consequences. Specifically, to address the issues that occurred during the implementation of this procedure, the licensee incurred more than18 hours of unnecessary unavailability of the Division III EDG Exhaust Air Damperhydramotor, which potentially affected the reliability of the Division III EDG. 3This finding also affected the cross-cutting area of Human Performance since licenseepersonnel failed to properly adhere to a step-by-step procedure associated with safety-related equipment where adequate implementation of human performance toolswould have prevented errors from occurring.The inspectors completed a significance determination of this issue using Appendix A,"Determining the Significance of Reactor Inspection Findings for At-Power Situations,"

of IMC 0609, "Significance Determination Process," dated November 22, 2005. The inspectors determined that the finding was of very low safety significance, in accordance with the Phase 1 screening worksheet, because: (1) it did not represent an actual loss of safety function of a system; (2) it did not represent an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time; (3) it did not represent an actual loss of safety function of one or more non-Technical Specification trains of equipment designated as risk-significant per 10 CFR 50.65 for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (4) it did not screen as potentially risk significant due to a seismic, fire, flooding, or severe weather initiating event. Enforcement: Technical Specification 5.4, "Procedures," required, in part, that writtenprocedures 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 equipmentshould 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 III EDGExhaust Air Damper, licensee personnel failed to perform required steps prescribed by procedure ICI-B12-0001, "ITT NH90 Series Milliampere Proportional/On-Off HydramotorActuator 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 withSection VI.A.1 of the NRC Enforcement Policy (NCV 05000440/2006007-02). 3.2Commitment Item 1.b/DAMP Item B.2.2.3.2 a.Inspection ScopeThe inspectors reviewed Commitment Item 1.b/DAMP Item B.2.2.3.2: "CA 05-03655-01is to revise Nuclear Quality Assurance Instruction (NQI)-1001, 'QC Inspection Program Control,' to specify a method by which classification can be established for additional inspection attention items that have experienced repeat failures. This method willinclude consideration of failure analysis, the risk-significance of the item, and the probability of failure occurrence in determining the extent of inspection activity."To accomplish this review, the inspectors reviewed NQI-1001, Revision 5, anddetermined whether the revised procedure accomplished that stated goal. 4 b. Observations and FindingsThe inspectors concluded the licensee's actions adequately implemented CommitmentItem 1.b/DAMP Item B.2.2.3.2.As part of the corrective actions, the licensee implemented two major revisions toNQI-1001. The first revision was intended to satisfy the commitments to the NRC. Thesecond revision was not only intended to satisfy the specify CAL commitment, but also to achieve fleet standardization. The inspectors reviewed the licensee's most recent revision to NQI-1001 (Revision 5) to determine whether the revised version included additional inspection activities for items that experienced multiple failures. The inspectors concluded that NQI-1001, Revision 5, appropriately incorporated theconsideration of failure history, risk significance, and failure probability in assigning QCinspection hold points. However, the inspectors identified that the methods identifiedand 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. The inspectors reviewed seven work orders performed using NQI-1001, Revision 5, todetermine whether QC inspection points had been appropriately selected. In all cases, the inspection points assigned were consistent with NQI-1001 requirements. 4.0ESW Pump Coupling Assembly Concerns 4.1Commitment Item 1.c/DAMP Item B.2.2.3.3 a. Inspection ScopeThe inspectors reviewed Commitment Item 1.c/DAMP Item B.2.2.3.3: "CA 05-03655-03is to revise GMI-0039, 'Disassemble/Re-assembly of Divisions I and II Emergency Service Water (ESW) Pumps,' and GMI-040, 'Disassembly/Re-assembly of Division III Emergency Service Water Pump,' to include QC inspection points for work activities associated with pump shaft couplings, as specified by QC."To accomplish this activity, the inspectors determined whether appropriate QC holdpoints had been incorporated into all of the subject procedures. b. Observations and FindingsThe inspectors concluded the licensee's actions adequately implemented CommitmentItem 1.c/DAMP Item B.2.2.3.3.The inspectors confirmed that the licensee had added appropriate QC hold points to thecoupling reassembly sections of ESW pump rebuild procedures GMI-0039 and GMI-0040. 54.2DAMP Item B.2.2.5 a.Inspection ScopeThe inspectors reviewed DAMP Item B.2.2.5: "Based on the results of the maintenanceprocedure upgrade plan for key critical components, develop a long term Maintenance Procedure Upgrade Plan and incorporate actions into the FENOC Business Plan (05-04586-01)."To accomplish this activity, the inspectors reviewed the FENOC and Perry BusinessPlans and determined whether these plans incorporated actions from the Perry Maintenance Procedure Upgrade Plan. b.Observations and FindingsThe inspectors concluded the licensee's actions adequately implemented DAMPItem B.2.2.5.The inspectors observed that the licensee completed revisions to the initial set of119 procedures and planned to revise these procedures, as needed. In addition, the inspectors confirmed that the licensee had planned to revise several hundred additional maintenance procedures, some of which had already been accomplished.

The inspectors observed that the licensee had begun organizing plant and contractor personnel to revise additional procedures. The inspectors noted that closer craft involvement was planned for this second phase of procedure updates to improve the procedure validation process. In addition, licensee management planned to place more reliance on the licensee staff to complete these revisions. The inspectors confirmed the FENOC and Perry Business Plans incorporated actionsfrom the Perry Maintenance Procedure Upgrade Plan and provided the necessary resources to upgrade the remaining procedures. 5.0Training 5.1Review of Development of Proper Planning for Work Management a.Inspection ScopeThe inspectors reviewed the corrective action of "...development of proper planning forwork management to ensure strict compliance of job planning to eliminate misdirection during conduct of the job," described in Perry letter PY-CEI/

NRR-2897L, datedAugust 17, 2005. To accomplish this activity, the inspectors reviewed closure documentation for theassociated condition report. In addition, the inspectors interviewed plant personnel to determine what changes had occurred to ensure proper job planning. 6 b. Observations and FindingsThe inspectors concluded the licensee's actions adequately implemented the correctiveaction that prescribed the development of an appropriate work planning process to improve the overall preparation for work activities.The inspectors determined that although the work planning process had not beenrevised, licensee management had taken actions to enforce the existing work planning process requirements. Licensee personnel provided data that demonstrated that the enforcement of existingwork standards had drastically reduced the number of work orders that had not been strictly planned within the constraints of the work order process. The inspectors concluded that the intent of this corrective action, which was to improve preparation forwork activities such that work activities would be ready to work when scheduled, had been met.5.2Review of Plant Manager Discussion of "Push Back" in Daily Plant Updates a. Inspection ScopeThe inspectors reviewed the corrective action of "...plant manager to discuss 'push back'in the daily plant updates. This discussion will promote a challenging attitude from theemployees," described in Perry letter PY-CEI/

NRR-2897L, dated August 17, 2005.To accomplish this activity, the inspectors reviewed available records regarding thisissue and determined whether the discussions were sufficient to address the problem.

The inspectors interviewed licensee personnel from the operations and maintenance departments and determined whether the training had an impact on their attitude toward "push back." b. Observation and FindingsThe inspectors concluded the licensee's actions adequately implemented the correctiveaction that prescribed that the plant manager would discuss push back in the daily plantupdates.The inspectors reviewed the Plant Manager's daily updates. The plant managerprovided periodic daily updates that in some manner discussed push back. The inspectors were only able to identify one example in which the term "push back" was explicitly used to address the issue. However, because other updates discussed situations that in some manner involved workers displaying a questioning attitude toward directions given that were contrary to written instructions or previous training, the inspectors concluded that the intent of the actions had been at least minimally satisfied. The inspectors also noted that this action item was closed after a single update and that no method had been established to identify and trend additional updates. Although the focus of this corrective action was somewhat limited, the inspectors wereaware of other licensee initiatives to address this issue. For example, the licensee had 7an ongoing activity to implement new human performance tools across the site. Inaddition, the licensee had previously emphasized procedure use and adherence as a condition for employment. Finally, the Phase 2 PII contained additional elements that addressed this issue. 5.3Review of Human Performance Tools to Reinforce Human Performance Under Stress a. Inspection ScopeThe inspectors reviewed the corrective action of "...new human performance tools havebeen rolled out which reinforce use of human performance during stressful times.

These tools are discussed in the following human performance procedures:

(1) NOBP-LP-2601, 'Human Performance Program'; (2) NOBP-LP-2603, 'Human Performance Tools and Verification Practices'; (3) NOBP-LP-2604, 'Job Briefs'; and (4) NOP-LP-2601, 'Procedure Use and Adherence.'" To accomplish this activity, the inspectors reviewed the human performance tools thatwere "rolled out" and determined whether those tools were appropriate to address the problem. The inspectors also determined whether the human performance procedures were revised as planned and interviewed operations and maintenance personnel and determined whether these individuals were knowledgeable of these new tools. b.Observations and FindingsThe inspectors concluded the licensee adequately implemented the corrective actionsthat prescribed new human performance tools to reinforce human performance during stressful periods.The license developed four procedures to provide human performance tools. At the endof the inspection, the licensee had completed training about 50 percent of the plantemployees on the new human performance tools with plans to train the remainder. The inspectors observed portions of the training class and reviewed the course syllabus. However, during in-field observations, the inspectors observed that craft personnel,while generally familiar with these tools, were not experienced in their use. Theinspectors noted that first line supervisors appropriately discussed these human performance tools with maintenance workers during pre-job briefings. For example, during several pre-job briefings between mechanics and supervisors, the inspectors observed discussions regarding the suspension of work and placing equipment in a safe condition should conditions arise in the field that could not be resolved without further clarification. In several instances, the inspectors observed workers stop work activities and seek clarification prior to proceeding with the work. However, in one instance the inspectors observed personnel proceed with work activities despite uncertainty of the requirements. While observing the rebuild of a fire protection deluge valve, a procedure step in thework 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 8parts. Despite this lack of knowledge, licensee personnel signed off the step ascomplete. 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 inspectionresults, the inspectors concluded the issue was of only minor significance.6.0Exit MeetingOn March 14, 2006, the inspectors presented the inspection results to Mr. L. Pearce,Vice President, and other members of his staff, who acknowledged the findings and observations. The inspectors asked the licensee whether any materials examined during theinspection should be considered proprietary. No proprietary information was identified.ATTACHMENTS:1. SUPPLEMENTAL INFORMATION2. PERRY PERFORMANCE BACKGROUND

3. PERRY IP 95003 INSPECTION RESULTS 1SUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicenseeG. Leidich, Chief Nuclear Officer, FENOCD. Pace, Senior Vice President, Fleet Engineering and Services, FENOC J. Hagan, Chief Operating Officer, FENOC J. Rinckel, Vice President, Oversight, FENOC L. Pearce, Vice President, Perry F. von Ahn, Plant Manager, Perry F. Cayia, Director, Performance Improvement, Perry K. Howard, Manager, Design, Perry J. Lausberg, Manager, Regulatory Compliance, Perry T. Lentz, Director, Performance Improvement Initiative, Perry J. Messina, Manager, Operations, Perry J. Shaw, Director, Engineering, Perry M. Wayland, Director, Maintenance, PerryLIST OF ITEMS OPENED, CLOSED, AND DISCUSSEDOpened and Closed05000440/2006007-01NCVFailure to Perform Required Steps Prescribed byProcedure GEI-000905000440/2006007-02NCVFailure to Perform Required Steps Prescribed byProcedure ICI-B12-0001DiscussedNone.

2LIST OF DOCUMENTS REVIEWEDThe following is a list of documents reviewed during the inspection. Inclusion on this list doesnot imply that the NRC team reviewed the documents in their entirety but rather that selected sections or portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any partof it, unless this is stated in the body of the inspection report.Condition ReportsCR 04-04059; Site Human Performance Barriers May Be Lost During Stressful Times;dated August 5, 2004 CR 05-03654; NRC ID: Procedure Enhancements to CMI-16 EDG Starting Air Valve Repair;dated April 21, 2005 CR 05-03655; NRC ID: Potential NCV for Inadequate QC Inspection; dated April 20, 2005CR 06-00112; L1109 Blast Deflector Hood Appears to be Misaligned; dated January 10, 2006 CR 06-00125; NRC ID: Procedure Not Followed Correctly; dated January 10, 2006CR 06-00143; NRC ID: Hydraulic Control Unit has Leak on Valve Packing;dated January 10, 2006 CR 06-00148; New Revision Could Not Be Performed As Written; dated January 12, 2006 CR 06-00166; NRC ID: Inadequacies/Issues Identified in IMI-E2-39; dated January 12, 2006CR 06-00181; NRC ID: Inconsistency in Identifying Critical Steps; dated January 12, 2006CR 06-00182; NRC ID: Failure to Follow NOP-SS-3301 Guidance; dated January 13, 2006CR 06-00187; NRC ID: Issues/Improvements Associated with GMI-0187;dated January 12, 2006 CR 06-00198; Pre-job Briefing for 290A Repack Not Up to Standards; dated January 15, 2006 CR 06-00199; Unnecessary Delay in Heater Isolation; dated January 15, 2006 CR 06-00201; NRC ID: F788 Valve Handle Vibrated Loose; dated January 15, 2006CR 06-00204; Valve 290A Stem is Found Steam Cut During Inspection; dated January 15, 2006 CR 06-00205; Alternate Level Controller for Heater Acting Erratically; dated January 15, 2006 CR 06-00235; Foreign Material Found in D1A08 Breaker During Preventive Maintenance; dated January 17, 2006 CR 06-00269; NRC ID: Valve Stem Inspection 'N/A' During Valve Repack;dated January 18, 2006 CR 06-00281; Craft Confusion During Performance of PMI-0030; dated January 18, 2006 CR 06-00283; NRC ID: GEI-0009 Breaker Step Was Incorrectly N/A'd and Not Performed;dated January 19, 2006 CR 06-00295; NRC ID: FME [Foreign Material Exclusion] Observed on Crafts' Hands ForInstallation of Valve Diaphragm; dated January 19, 2006 CR 06-00312; NRC ID: Issues Identified in IMI-E3-23; dated January 20, 2006ProceduresCMI-0016; Division I and II Emergency Diesel Generator Starting Air Valve Repair; Revision 3GEI-0001; Performing Insulation Resistance Checks; Revision 9GEI-0007-A; Instructions for Cable and Wire Terminations; Revision 0 GEI-0009; ABB Low Voltage Power Circuit Breaker Types K-600 & K-600S Through K-3000 &

K-3000S Maintenance; Revision 17 3GEI-0135; ABB Power Circuit Breakers 5KV Types 5HK250 and 5HK350 Maintenance;Revision 10 GEI-0136; ABB Power Circuit Breakers 15KV Type 15HK1000 Maintenance; Revision 16 GMI-0001; Coupling Alignment; Revision 4 GMI-0002; Maintenance of the Control Rod Drive Pumps; Revision 2 GMI-0021; General Torquing; Revision 8 GMI-0037; Disassembly of the Control Complex Chilled Water and ECC [Emergency ClosedCooling] Pumps; Revision 2 GMI-0039; Disassemble/Re-assembly of Divisions I and II Emergency Service Water Pumps; Revision 19 GMI-040; Disassembly/Re-assembly of Division III Emergency Service Water Pump; Revision 6GMI-0042; Reactor Core Isolation Cooling Pump Overhaul; Revision 0 GMI-0050; Residual Heat Removal Pump Overhaul; Revision 0 GMI-0051; Disassembly and Repair of the HPCS Pumps; Revision 0 GMI-0061; Valve Packing Instruction; Revision 6 GMI-0130; Reactor Water Cleanup Pump Overhaul; Revision 0 GMI-0187; Motor Driven Reactor Feedwater Pump Overhaul; Revision 0 ICI-B12-0001; ITT NH90 Series Milliampere Proportional/On-Off Hydramotor ActuatorCalibration; Revisions 4, 5, and 6 IMI-E02-0039; Woodward Motor Operated Potentiometer; Revisions 3 and 4 IMI-E03-0023; Division III HPCS Diesel Generator Woodward Governor Maintenance;Revision 4 NOBP-LP-2019; Corrective Action Program Supplemental Expectations and Guidance; Revision 1 NOBP-LP-2601; Human Performance Program; Revision 0 NOBP-LP-2603; Human Performance Tools and Verification Practices; Revision 0 NOBP-LP-2604; Job Briefs; Revision 0 NOP-LP-2018; Quality Control Inspection of Maintenance and Modifications; Revision 0 NOP-LP-2601; Procedure Use and Adherence; Revision 0 NOP-SS-3001; Procedure Review and Approval; Revision 9 NOP-SS-8001; FENOC Activity Tracking; Revision 0 NQI-1001; QC Inspection Program Control; Revision 5 OJT 5000-003-01; Maintenance Qualification Card Indoctrination PAP-0528; Procedure Use and Adherence Supplemental Items; Revision 4 PAP-0905; Work Order Process; Revision 24 PMI-0019; Division I and II Diesel Generator Rocker Arm and Valve Lifter Maintenance; Revision 6 PMI-0030; Maintenance of Limitorque Valve Operators; Revision 11 PMI-0040; Division III Air Start Motor Maintenance; Revision 4PMI-0053; Division I and II Standby Diesel Generator Connecting Rod and Piston Maintenance; Revision 5 PMI-0065; Division I and II Diesel Generator Starting Air Dryer Maintenance; Revision 2 PMI-0109; V-Belt and Sheave Inspection; Revision 1 PYBP-PMS-0001; Human Performance; Revision 0 PYBP-PNMD-0003; Perry Maintenance Department Directives; Revision 2 4Work OrdersWO 200008968; Division 1 Right Bank #8 Cylinder; Revision 0WO 200034344; Overhaul Breaker EF1C04; Revision 0 WO 200035165; Exercise and Service Breaker D1A08; Revision 0 WO 200010019; Cylinder Left Head #5; Revision 0 WO 200061000; Static MOV/RHR RCIC [Reactor Core Isolation Cooling] Steam SupplyInboard Isolation; Revision 0 WO 200147230; Perform Governor Loop Tuning on the Division 2 Diesel; Revision 0 WO 200098338; Maintenance Division 1 Starting Air Dryer; Revision 0 WO 200173161; Replace J/W [Jacket Water] Outlet Couplings; Revision 0 WO 200115794; Prepare Breaker & Auxiliary/Cell Switch for L1109; Revision 0WO 200076176; Perform Breaker F2C08 Trip Device Checks; Revision 0WO 200078672; Breaker EH1204 Overhaul; Revision 0 WO 200035191; Perform Breaker EF1B05 Overhaul; Revision 0 WO 200034337; Overhaul Breaker EF1D1Q FD>MCC ED2D-11; Revision 0 WO 200034363; EF1D04 10 Year Breaker Overhaul; Revision 0 WO 200035188; Overhaul Breaker EF1A05; Revision 0 WO 200034351; Overhaul Breaker EF1A04 F/P Recirculation Pump; Revision 0 WO 200038182; Exercise-Service/Relay Checks Breaker F1F09; Revision 0WO 200046165; Perform a Preliminary Calibration of Actuator IAW [In Accordance With]

ICI-B12-1; Revision 0 WO 200105690; Performance of PMI-0030 on RCIC Turbine Exhaust Valve; Revision 0 WO 200117498; Heater 6A Drain to Heater 5A, Repair of Valve 160A; Revision 0 WO 200062807; Scram Discharge Volume Level Transmitter; Revision 0 WO 200135940; Functional Test Air Start Valves; Revision 0 WO 200158593; Dry Well Radiation Monitor Lube and Inspection; Revision 0 WO 200012901; Insulation Resistance Test of Division III Room Supply Fan; Revision 0WO 200152120; Insulation Resistance Test of 'A' RHR motor; Revision 0WO 200114544; Replacement of Backup Scram Valve; Revision 0 WO 200002734; Repair of CRD [Control Rod Drive] Flow Control Valve; Revision 1WO 200008639; Replacement of Off Gas 1-Inch Manual Globe Valve; Revision 1 WO 200034344; Overhaul Breaker EF1C04; Revision 0 WO 200134833; Calibration Check AS Voltmeter Bus; Revision 0 WO 200062754; Replace Flow XMTR [Transmitter] 1P45N0051B; Revision 0 WO 200152254; Pressure Switch 1R45N0005A; Revision 0 WO 200170404; Spare Water Leg Pump for E12/E22/E51 Needs to be Refurbished; Revision 0 WO 200188241; ECC "B" Pump Bearing Bubbler Adjustment and Verification; Revision 0Other DocumentsFENOC Letter PY-CEI/NRR-2897L; Response to NRC Inspection Procedure 95003Supplemental Inspection, Inspection Report 05000440/2005003; dated August 8, 2005FENOC Letter PY-CEI/NRR-2902L; Corrections for Response to NRC Inspection Procedure95003 Supplemental Inspection, Inspection Report 05000440/2005003; dated August 17, 2005E-mail from M. McFarland dated January 19, 2006 FENOC Observation Cards - PYF2006-0065 and PYF2006-0067 Human Performance Fundamental Course - Lesson Plan Perry Memoranda dated April 8, 2005 and April 22, 2005 5File #109; Transamerica Delaval Motor Driven Feedwater Pump File #113; Delaval Model DSRV-16-4 Diesel Engine File #110; Standy Diesel Generator Manual - Volume 1; Revision 25 File #906; Valve Operators Manual; Revision 29 File #G49; Union Pump Manual File #165; Installation, Operation, and Maintenance Instruction Manual, Goulds Pumps Inc.,Vertical Pump Division File #0044; Bingham-Willamwette Pump Instruction M anualGE 23A1860; Union Pump Manual Byron Jackson Procedure IT-5981; Bolt Torquing Procedure for Residual Heat Removal, Low Pressure Core Spray and High Pressure Core Spray Pumps for General Electric File #G040; Byron Jackson Pump Division; Pump ManualPerry Maintenance Department Expanded Maintenance Procedure Upgrade Project Plan; Revision 0 Project Plan for Maintenance Procedures Upgrade Associated with Key Critical Components; Revision 1 2006 Perry Excellence Plan; Section PGMT-6500 FirstEnergy Nuclear Operating Company Business Plan 2006-2010 FirstEnergy Nuclear Operating Company Business Plan 2005-2007 Dresser Measurement, Universal RAI Blower Bulletin IRP-103-098 FENOC Field Observation Card PYF2006-0106 Selected Daily Plant Updates from F. von Ahn; dated June 1 through December 31, 2005 6LIST OF ACRONYMS USEDADAMSAgency Document and Management SystemAOVAir-Operated Valve CALConfirmatory Action Letter CAPCorrective Action Program

CFRCode of Federal RegulationsCRcondition report CRDControl Rod Drive DAMPDetailed Action and Monitoring Plan ECCEmergency Closed Cooling EDGEmergency Diesel Generator ESWEmergency Service Water FENOCFirstEnergy Nuclear Operating Company FMEForeign Material Exclusion GMIGeneral Mechanical Instruction HPCSHigh Pressure Core Spray HVACHeating, Ventilation, and Air Conditioning IMCInspection Manual Chapter IPInspection Procedure IRInspection Report J/WJacket Water LPCSLow Pressure Core Spray MCCMotor Control Center MOVMotor-Operated Valve N/ANot Applicable NCVNon-Cited Violation NQINuclear Quality Assurance Instruction NRCNuclear Regulatory Commission PARSPublicly Available Records PIIPerformance Improvement Initiative PNPPPerry Nuclear Power Plant PRAProbabilistic Risk AssessmentQCQuality Control RCICReactor Core Isolation Cooling RHRResidual Heat Removal RIResident Inspector SCAQsignificant condition adverse to quality SDPSignificance Determination Process SRISenior Resident Inspector SWGRSwitchgear TSTechnical Specification XMTRTransmitter Attachment 2 1PERRY PERFORMANCE BACKGROUNDAs discussed in the Perry Annual Assessment Letter dated March 4, 2004, plant performancewas categorized within the Degraded Cornerstone column of the NRC's Action Matrix based ontwo White findings in the Mitigating Systems cornerstone. An additional White finding in the Mitigating Systems cornerstone was subsequently identified and documented by letter dated March 12, 2004.The first finding involved the failure of the high pressure core spray (HPCS) pump to startduring routine surveillance testing on October 23, 2002. An apparent violation of Technical Specification (TS) 5.4 for an inadequate breaker maintenance procedure was identified inIR 05000440/2003008. This performance issue was characterized as White in the NRC's finalsignificance determination letter dated March 4, 2003. A supplemental inspection was performed in accordance with IP 95001 for the White finding. Significant deficiencies in the licensee's extent of condition evaluation were identified. Inspection Procedure 95001 was subsequently re-performed and the results of that inspection were documented in IR 05000440/2003012, which determined that the extent of condition reviews were adequate.The second finding involved air binding of the low pressure core spray (LPCS)/residual heatremoval (RHR) 'A' waterleg pump on August 14, 2003. A special inspection was performed forthis issue and the results were documented in IR 05000440/2003009. An apparent violation of TS 5.4 for an inadequate venting procedure was identified in IR 05000440/2003010. Thisperformance issue was characterized as White in the NRC's final significance determination letter dated March 12, 2004.The third finding involved the failure of the 'A' Emergency Service Water (ESW) pump, causedby an inadequate maintenance procedure for assembling the pump coupling that contributed tothe failure of the pump on September 1, 2003. An apparent violation of TS 5.4 wasdocumented in IR 05000440/2003006. This performance issue was characterized as White in the NRC's final significance determination letter dated January 28, 2004.As documented in IP 95002 Supplemental Inspection Report 05000440/2004008, datedAugust 5, 2004, which reviewed the licensee's actions to address these issues, the NRC concluded that the corrective actions to prevent recurrence of a significant condition adverse to quality (SCAQ) were inadequate. Specifically, the same ESW pump coupling that failed on September 1, 2003, failed again on May 21, 2004. This resulted in the ESW pump White finding remaining open. As a result, Perry entered the Multiple/Repetitive Degraded Cornerstone column for MitigatingSystems in the Reactor Safety strategic performance area for having two White inputs for five consecutive quarters. Specifically, for the third quarter of 2004, the waterleg pump finding remained open a fourth quarter while the ESW pump finding was carried open into a fifth quarter as a result of the findings of the IP 95002 supplemental inspection.

1The NRC's Action Matrix is described in Inspection Manual Chapter 0305, "OperatingReactor Assessment Program."Attachment 3 1PERRY IP 95003 INSPECTION RESULTSAs a result of poor performance, the Nuclear Regulatory Commission (NRC) desi gnated thePerry Nuclear Power Plant (PNPP), owned and operated by FirstEnergy Nuclear Operating Company (FENOC), as a "Multiple/Repetitive Degraded Cornerstone Column" facility in theNRC's Action Matrix 1 in August 2004. Accordingly, a supplemental inspection was performed inaccordance with the guidance in NRC Inspection Manual Chapter (IMC) 0305 and InspectionProcedure (IP) 95003, "Supplemental Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow Inputs, or One Red Input." In addition, the scope of the IP 95003 inspection included the review of licensee actions toaddress deficiencies identified during a previous IP 95002 inspection. In particular, the NRC reviewed the licensee's root cause and corrective actions to address the areas of procedure adequacy, procedure adherence, and training deficiencies identified in the previous IP 95002 inspection; as well as the problem identification, root cause review, and corrective actions to address repetitive emergency service water (ESW) pump coupling failures. By letter dated September 30, 2004, FENOC advised the NRC that actions were underway toimprove plant performance. To facilitate these performance improvements, FENOC devel opedthe Perry Performance Improvement Initiative (PII). As part of the NRC's IP 95003 inspection,the team conducted a detailed review of the PII. As documented in IP 95003 Supplemental Inspection Report 50-440/2005003, the NRCdetermined Perry was being operated safely. The NRC also determined that the programs andprocesses to identify, evaluate, and correct problems, as well as other programs and processes in the Reactor Safety strategic performance area were adequate. Notwithstanding these overallconclusions, the NRC determined that the performance deficiencies that occurred prior to andduring the inspection were often the result of inadequate implementation of the corrective actionprogram (CAP) and human performance errors. The team identified that a number of factors contributed to CAP problems. A lack of rigor in theevaluation of problems was a major contributor to the ineffective corrective actions. For example, in the engineering area, when problems were identified, a lack of technical rigor in the evaluation of those problems at times resulted in an incorrect conclusion, which in turn affected the ability to establish appropriate corrective actions. The team also determined that correctiveactions were often narrowly focused. In many cases a single barrier was established to prevent a problem from recurring. However, other barriers were also available that, if identified and implemented, would have provided a defense-in-depth against the recurrence of problems. The team also identified that problems were not always appropriately prioritized, which led to the untimely implementation of corrective actions. A number of programmatic issues were identified that have resulted in the observed CAPweaknesses. For example, the team identified a relatively high threshold for classifying deficiencies for root cause analysis. As a result, few issues were reviewed in detail. In addition, for the problems that were identified that required a root cause evaluation, the team 2found that the qualification requirements for root cause evaluators were limited and multi-disciplinary assessment teams were not required. The team also identified that a lack ofindependence of evaluators existed. This resulted in the same individuals repeatedly reviewing the same issues without independent and separate review. In addition, the team identifiedweaknesses in the trending of problems, which has hindered the ability to correct problems atan early stage before they become more significant issues. Finally, the team determined that alack of adequate effectiveness reviews was a barrier to the identification of problems with corrective actions that had been implemented. In the area of human performance, the team determined that a number of self-revealed findings relating to procedure adherence occurred that had a strong human performance contribution. These findings were derived from events that resulted in an unplannedengineered safety feature actuation, a loss of shutdown cooling, an unplanned partial draindown of the suppression pool, an inadvertent operation of a control rod (a reactivity event), and other configuration control errors. The team reviewed the events that occurred during theinspection and identified that the procedure adherence problems had a number of common characteristics. In a number of cases, personnel failed to properly focus on the task at hand.

Although pre-job briefings were held prior to many events, and procedures were adequate to accomplish the intended activity, personnel failed to sufficiently focus on the individual procedure step(s) being accomplished and performed an action outside of that prescribed by the procedure. In some cases, the team determined that a lack of a questioning attitudecontributed to the procedure problems that occurred. Although information was available topersonnel that, if fully considered, could have prevented the procedure adherence issues that occurred, that information was not sought out or was not questioned. The presence ofsupervisors with the necessary standards to foster good procedure adherence could have acted as a significant barrier to prevent some of the problems that occurred. However, adequatesupervisory oversight was not always available or used. Further, the team identified thatavailable tools for assessing human and organizational performance had not been effectively used. In the area of design, the IP 95003 inspection team concluded that the systems, as designed,built, and modified, were operable and that the design and licensing basis of the systems weresufficiently understood. Notwithstanding the overall acceptability of performance in theengineering area, the team identified common characteristics in a number of problems identified during the inspection. These characteristics included a lack of technical rigor in engineering products that resulted in an incorrect conclusion. Also, there appeared to be a lack of questioning by the licensee staff of some off-normal conditions. Finally, weaknesses in the communications between engineering and other organizations such as operations and maintenance sometimes hindered the resolution of problems.In the area of procedure adequacy, the team determined that the licensee's procedures tosafely control the design, maintenance, and operation of the plant were adequate, butwarranted continued management focus and resource support. In particular, process-related vulnerabilities in areas such as periodic plant procedure reviews, procedure revisions, and useclassifications were identified by the team.In the area of equipment performance, the team acknowledged that the licensee had completednumerous recent plant modifications to improve equipment performance. In addition, improved engineering support and management oversight of equipment performance were noted.

3Notwithstanding the above, the team identified numerous examples that indicated that theresolution of degraded equipment problems and implementation of the CAP continued to be a challenge to the organization. In the area of configuration control, the team identified numerous examples that indicated theresolution of configuration control issues and implementation of the CAP continued to be achallenge to the organization. The team agreed with the licensee's assessment that continuingconfiguration control problems were primarily the result of inappropriate implementation of procedural requirements rather than the result of configuration management proceduralshortcomings. However, given the errors associated with equipment alignment, as well as multiple errors associated with maintenance configuration control such as scaffolding erection, the team concluded that adequate evaluations of the root causes of configuration control errorshad not been performed. The team also concluded that the licensee lacked rigor in its efforts to resolve latent configuration control issues. Several licensee-identified issues have not beencorrected, and contributed to configuration control shortcomings. In addition, in the area of emergency preparedness, the team determined that there were someperformance deficiencies associated with the licensee's implementation of the Emergency Plan.

A number of findings were identified in which changes to the Emergency Plan or Emergency Action Levels were made without required prior NRC approval. In addition, the results of theaugmentation drill where personnel were called to report to the facility for a simulatedemergency were unsatisfactory. With regard to the NRC's review of issues associated with the previous IP 95002 inspection, theNRC determined that actions to address procedure adequacy and ESW pump failures was stillin progress at the end of the IP 95003 inspection. In particular, the team identified that one ofthe licensee's corrective actions to address the verification of the quality of ESW pump work was inadequate. In addition, in light of the continuing problems in human performance and the impact on procedure adherence, the team concluded that actions to address procedure adherence had not been fully effective. Finally, actions to address training were also st ill inprogress at the end of the inspection. In this case, the licensee's corrective actions to address this issue had not been timely and at the conclusion of the IP 95003 inspection, had not yet been implemented. As a result, the NRC concluded that the open White findings associatedwith the IP 95002 inspection would continue to remain open pending additional licensee actions

and the NRC's review of those actions.In the assessment of the licensee's performance improvements planned and implementedthrough the Perry PII, the team determined that the Perry PII had a broad scope and addressedmany important performance areas. The IP 95003 inspection team also observed that, although substantially completed, the PII had not resulted in significant improvement in plantperformance in several areas. There were a number of reasons identified as why this occurred, one being that the PII was largely a discovery activity, and as such, many elements of the PII did not directly support improving plant performance. Instead, the problems identified throughthe PII reviews were entered into the CAP and the proper resolution of these problems depended upon the proper implementation of the CAP. During the IP 95003 inspection, the NRC identified that in some cases the CAP had not been implemented adequately to addressthe concerns identified during PII reviews. The team identified that although many PII actionshad been completed, some of the more significant assessments, such as in the area of human performance, were still in progress at the end of the inspection. Overall, based on the factors 4discussed above, the NRC was unable to draw any definitive conclusions regarding the overalleffectiveness of the Perry PII. As a result, further reviews were deemed to be necessary to determine whether the PII was sufficient to address and resolve the specific issues identified.