ML060380531
| ML060380531 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/27/2006 |
| From: | Pearce L FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PY-CEI/NRR-2935L | |
| Download: ML060380531 (6) | |
See also: IR 05000440/2005014
Text
U- I FENOC Perry Nuclear Power Station ,% 10 Center Road FirstEnergy
Nuclear Operating
Company Perry Ohio 44081 L. William Pearce 440-280-5382
Vice President
Fax: 440-280-8029
January 27, 2006 PY-CEI/NRR-2935L
United States Nuclear Regulatory
Commission
Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 License No. NPF-58 Subject: Response to NRC Confirmatory
Action Letter (CAL) Followup Inspection
Phase 2 Performance
Improvement
Initiative
Review Inspection
Report 05000440/2005014
Ladies and Gentlemen:
This letter provides the FirstEnergy
Nuclear Operating
Company (FENOC) response to the NRC Inspection
Report 05000440/2005014
for the Perry Nuclear Power Plant (PNPP). The NRC letter provided the results of your review of Phase 2 of the Performance
Improvement
Initiative.
In your letter you requested
that FENOC respond within 30 days of receipt of the letter describing
the specific actions that PNPP plans to take to address the observations
identified
in this inspection
report. There were six (6) observations
contained
in the report. The FENOC responses
to these observations
are contained
in an attachment
to this letter. No commitments
are contained
in this letter or the attachment.
If you have questions
or require additional
information, please contact Mr. Jeffrey Lausberg -Manager, Regulatory
Compliance
at (440) 280-5940.Very truly yours, nx r> e ft -PC,?-4C --Attachment
cc: NRC Region III Administrator
NRC Project Manager NRC Resident Inspector
Attachment
I Issue 1: The inspectors
noted that some issues identified
in the Perry IP 95003 inspection
report were not specifically
addressed
by Commitments
and/or Action Items in the licensee's
August 8 and August 17 response letters. However, upon detailed review, the inspectors
identified
that although specific actions to address the issues in the IP 95003 inspection
report were not addressed
in these letters, actions were contained
in some form in either the revised P11, the correction
action program, or through departmental
initiatives
independent
of a formal program.The following
specific examples were identified:
PNPP Response:
This issue is centered on assuring a concise reconciliation
and ultimately
a complete resolution
of all findings and key observations
detailed in the Perry 95003 Inspection
Report. To that end, a 95003 Inspection
Report "gap analysis" is under development
which will track all findings and key observations
noted in the inspection
report in a matrix. This "gap analysis" will be monitored
by the Perry Performance
Improvement
Initiative
staff to provide additional
assurance
of integrated
issue resolution.
A specific response to each of the supporting
observations
is provided below.Observation:
The licensee's
response letters addressed
an observation
in the IP 95003 inspection
report that corrective
actions for issues entered into the corrective
action program were frequently
narrowly focused.Resolution:
The inspectors
noted that the action items listed in the response letters did not specifically
address the issue of narrowly focused corrective
actions. The licensee credited a corrective
action associated
with CR 05-0722 3 to address the issue. This corrective
action prescribed
a 5-day root cause training course. It was unclear to the inspectors
or to interviewed
licensee personnel
how the addition of this root cause class to the licensee's
training program addressed
the issue of narrowly focused corrective
actions. Through interviews, the inspectors
determined
that the revised PlI Human Performance
and Corrective
Action Program initiatives
generally
addressed
improvement
of standards
associated
with the corrective
action process and therefore
indirectly
addressed
the issue.PNPP Response:
Addressing
the issue of narrowly focused corrective
actions is one specific and substantive
action necessary
to achieve improvement
in the implementation
of the Corrective
Action Program. The approach taken in the Phase 2 PII to improve implementation
of the Corrective
Action program has been to address the basic fundamental
causes and in so doing, encompass
the specific issues identified
in the 95QQ3Irtspection.ReporL.
--_____-Specific to this observation, there are several actions that provide the details for resolution
of this issue. As noted in the inspection
report, CR 05-07223 and additionally, the Detailed Action Monitoring
Plan (DAMP) section 1.4 which are focused on improving the quality of evaluations
and corrective
actions primarily
through training, provide the basis for this action closure. In addition, actions focused on reviews and feedback provided by the Corrective
Action Closure Board (Action 1.6.1 and 1.6.2) and the Corrective
Action Review Board (Actions 1.7.2,1.7.4
and 1.7.5) further support the resolution
of this issue. Collectively, these actions focus on training to improve the quality of investigations
and corrective
actions, and the review and feedback process to assure effective
resolution
of plant issues.
Attachment
2 Observation:
The licensee's
response letters addressed
an observation
in the IP 95003 inspection
report of a lack of a questioning
attitude for off-normal
conditions.
Resolution:
The inspectors
noted that the action items listed in the response letters did not specifically
address a lack of a questioning
altitude for off-normal
conditions.
The licensee identified
four condition
reports that were associated
with events related to the issue. The inspectors
noted that these condition
reports lacked corrective
actions that addressed
questioning
attitude.
Through interviews, the inspectors
determined
that the revised Pil Human Performance
and Corrective
Action Program initiative
actions included training that generally
addressed improvement
of standards
associated
with problem identification
and therefore
indirectly
addressed
the issue.PNPP Response:
Our 95003 Supplemental
Inspection
response letter included four bulleted actions which address the root cause of procedure
adherence
issues, including questioning
attitude.
Additionally, site training on the error prevention
tools of effective communication
and questioning
attitude was provided in April, 2005. During the 4th quarter of 2005 and 1 st quarter of 2006 human performance
fundamentals
training is being provided which addresses
the use of the error prevention
tool of questioning
attitude.These actions, when completed
will address the root cause of questioning
attitude and ultimately
will address the more specific case of lack of questioning
attitude for off normal conditions
by engineering
personnel.
Observation:
The licensee's
response letters addressed
an observation
in the IP 95003 inspection
report that a lack of technical
rigor in engineering
products resulted in incorrect conclusions, and that a weakness in the communications
between engineering
and other organizations
hindered the resolution
of problems.Resolution:
The Phase 2 P1I Detailed Action and Monitoring
Plan included general action items for training on engineering
rigor and conduct; however, the inspectors
noted that more substantial
action items, including
the development
of engineering
procedures
to address the specific issues, were being accomplished
outside of the Phase 2 Pll and the corrective
action program. As such, actions that more substantially
addressed
IP 95003 issues were not formally tracked by the Phase 2 P11 or by the corrective
action program. The licensee entered this issue into their oCR 05-eR675.
-PNPP Response:
The issue of techn cal rigor identified
in the 95003 Inspection
Report will be addressed
through implementation
of the P11. The transition
review from Phase 1 to Phase 2 of the P11 identified
Phase 1 technical
rigor actions requiring
inclusion
in the Phase 2 DAMP Appendix.
Specifically
actions A.5.3.1, A.5.4.1, A.5.5.1 were included in the DAMP as specific actions to address technical
rigor.In addition to the actions specified
in the DAMP, the Perry Engineering
Department
undertook
further action that will be captured through the implementation
of PYBP-PNED-0004
Perry Nuclear Engineering
Department
Conduct of Engineering
document.Effective
implementation
of this document will provide additional
basis to assure an adequate and sustained
resolution
of the issue of technical
rigor. This action has been added to the Phase 2 P11 DAMP Appendix as action A.5.6.1 as a result of condition
report 05-07675.
Attachment
3 Observation:
The IP 95003 inspection
report identified
the following
issues related to the use of the corrective
action program to address action items in the Phase 1 P11: (1) while P11 action items may be considered
closed, the corrective
actions to address the problems may not have been fully identified
or implemented;
and (2) in some cases the corrective
action program had not been adequately
implemented
to address the concerns identified
during the Phase 1 P11 reviews.Because closed Phase 1 P11 action items were not reviewed by licensee staff to determine whether the items had been adequately
accomplished
and because the IP 95003 inspection
identified
that some action items were not adequately
addressed, the inspectors
questioned
whether the completed
Phase 1 PI1 action items had been adequately
accomplished.
Resolution:
In response to the inspectors'
concerns, the licensee reviewed a sample of closed Phase 1 P11 action items to assess whether there were items that were not captured in the transfer process due to inappropriate
Phase 1 closure. The licensee found no issues with the sample of Phase 1 closed items that were reviewed.
The NRC planned to conduct independent
reviews of closed Phase 1 P11 action items and determine
whether those actions had been adequately
accomplished
during future CAL ftllow up inspection
activities.
PNPP Response:
This observation
notes the Phase 2 P11 dependency
on the adequate review and closure of the Phase 1 P11 and questions
whether additional
reviews need to be completed
to assure the adequacy of the closed Phase 1 P11 actions. As noted in the Inspection
Report, for the Phase 1 actions which were not closed a comprehensive
approach was taken to assure proper transition
and integration
into Phase 2.The Phase 1 P11 was in part, a broad-based
discovery
process, developed
to ensure a full understanding
of all key issues associated
with Perry performance.
Much of this effort was focused on reviews (latent issues, system health and programs).
Each of these assessments
reached a conclusion
with regard to overall adequacy/health
of each area.These assessments
would also identify other issues that typically
were entered into the corrective
action process and not tracked by the PII. This is consistent
with the current Phase 2 Pil approach.
As defined in PYBP-PII-0006
section 4.6: Fundamentally, the Pll is aimed at strengthening
execution
of existing process. As a result, unless P11 effectiveness
reviews and performance
assessments
reveal continuing
significant
performance
gaps, problems identified
in these reviews will be handled through existing processes
such as the Corrective
Action Program.As notedin the inspection
report, as part of this PIH inspection
PNPP performed
a sampling of these closure packages to determine
if any actions identified
affected the fundamental
conclusion
of each assessment
that should have been further tracked by the P11. None were identified.
In response to this observation
a review of past condition
reports on Phase 1 P11 action closure was performed.
CR 05-02940 documents
an issue identified
by the Corrective
Action Assessment
Board that identities
that several Phase 1 P11 closure validation
packages did not meet the requirements
for closure under PYBP-PII-0005
'Closure and Validation
of P11 Actions".
Specifically
it identified
two of eleven closure packages did not meet the criteria for closure and five of the eleven packages did not meet the requirements
for documentation
of "results achieved." A review of this CR indicates
that the issues identified
focused on the adequacy of the"results achieved" section of the closure package. As defined in Phase 2 of the PII,"results achieved" are now generally
segregated
from the closure package for individual
action item closure packages and are follow-up
steps in each initiative, typically
in the form of self-assessments
and effectiveness
reviews. It is recognized
that in some cases,
Attachment
4 the Phase 1 P11 actions did not achieve the desired results. The Phase 2 P11 was developed
to focus on achievement
of results. Tools such as results based performance
metrics, self-assessments
and effectiveness
reviews are now integrated
into the P1I to assure that the desired results are achieved.For the two other closure issues identified, the CR investigation
determined
them to be of an administrative
nature that did not affect the ultimate closure disposition
and no additional
actions were determined
to be necessary.
Issue 2: The inspectors
identified
that, in some cases, corrective
action items for issues were flexible in nature and relied heavily upon particularly
high standards
or rigor of implementation, which was considered
a potential
vulnerability.The-following
specific examples were identified:
Observation:
The licensee's
response letters addressed
an observation
in the IP 95003 inspection
report that multi-disciplinary
assessment
teams were not required for root cause evaluations, leading to potential
inadequate
reviews.Resolution:
The inspectors
noted that as part of one of the licensee's
completed
actions in the response letters, licensee personnel
revised procedure
NOP-LP-2001, "Corrective
Action Program," to address multi-disciplinary
root cause teams. The inspectors
noted that although NOP-LP-2001, Revision 12, addressed
multi-disciplined
Corrective
Action Review Board membership
and Management
Review Board membership, this procedure
did not address multi-disciplinary
root cause evaluation
teams. Subsequently, the inspectors
determined
that the procedure
change addressing
multi-disciplinary
root cause team members had been relocated
to business practice NOBP-LP-201
1, "FENOC Cause Analysis," Revision 3. NOBP-LP-2011
included a statement
to provide multi-disciplined
team members as needed. The business practice also stated that members may serve more than one role. As a result, NOBP-LP-2011
provided flexibility
that allowed a single-member
root cause team. At the end of the inspection, licensee management
planned to consider what additional
actions, if any, should be implemented
to address this issue.PNPP Response:
In response to this observation, Perry personnel
have reviewed the situation
and discussed
it with the Fleet Program Manager for the Corrective
Action Program process. As a result, the Nuclear Operating
Business Practice (NOBP-LP-2011) FENOC Cause Analysis has been revised. This revision, effective
December 16, 2005, eliminated
the qualifiers
of "if a team is used" (or similar variation)
from the Business Practice.Additional
actions are also contained
within the CAP P11 that will strengthen
the overall effectiveness
of cause evaluations.
Specifically, Items 1.4.1,1.4.2, 1.4.3, 1.4.4,1.4.5, and 1.4.6 all target the area of improving
the quality of evaluations
and corrective
actions to ensure corrective
actions are smarter and solve the cause of the identified
problem.Observation:
The licensee's
response letters addressed
an observation
in the IP 95003 inspection
report that corrective
actions to address identified
problems were not always properly prioritized, leading to untimely implementation.
Resolution:
An action item established
corrective
action program performance
as a standing agenda item at the senior management
team meetings.
An additional
action item prescribed
an improvement
in the timeliness
of corrective
action program actions. Through procedure
review and interviews, the inspectors
determined
that actual corrective
action prioritization
was left to the
Attachment
S discretion
of the action owner. The licensee's
expectation
was that problems should be prioritized
by safety significance.
The inspectors
noted that this expectation, with the lack of additional
guidance for implementation, was extremely
subjective.
PNPP Response:
A number of Performance
Improvement
Initiative
Action Items address the issue of appropriate
prioritization
of Corrective
Actions. The long-term
resolution
of this issue is anchored in the program fundamentals
that have been communicated
and reiterated
to all site personnel
through the development
of PYBP-SITE-0046, Corrective
Action Program Implementation
Expectations.
This action is a result of CAP P1l Actions 1.1.1, 1.2.1 and 1.2.2. Specifically, this document states: Expectation:
Condition
report investigations
and corrective
action completion
are to be based upon risk significance (not due dates).Purpose: -Assignments
based upon risk significance
and not default due dates.Each activity evaluated
and communicated
with supervisionAheprority
and work schedule.Expectation:
The individual
assigned the activity is to complete the assignment
in a quality and efficient
manner such that the review and approval resources
have sufficient
time to complete the activity prior to the due date.Purpose: Activities
are actively worked based upon their risk significance.
Communication
between the individual
assigned, their supervisor
and the reviewer are occurring
to discuss the schedule.To facilitate
the implementation
of these expectations
there is a focus (via CAP P11 Actions 1.7.1 through 1.7.6) on identifying
the appropriate
corrective
actions in the cause determinations
being performed.
This is implemented
via the Correction
Action Review Board and Corrective
Action Closure Board that ensure high quality cause evaluations
are performed.
Ensuring the appropriate
focused corrective
actions are defined will also control the workload of corrective
actions. Maintaining
control of the corrective
action workload also facilitates
the prioritization
of actions to be completed
based on their significance.
To ensure the desired results are being achieved and the appropriate
performance
oversight
is maintained, several Performance
Indicators
have been established.
These indicators
monitor important
attributes
of the Corrective
Action Program including completion
of Condition
Reports and Corrective
Actions on time, quality of evaluations, median age of CRs, and CA work off rates. These PIs are reviewed monthly to ensure the desired results are achieved.
Should the expected level of performance
not be realized in any given month a recovery plan is developed
to restore performance
to the expected level.The collective
effect of the actions described
above (as implemented
by the CAP P11)address the issue described
in the observation
of corrective
actions not always being properly prioritized
leading to untimely implementation.
Accordingly, no additional
action is required at this time