ML070180564

CAL Closure Request Letter

ML070180564
Person / Time
Site:	Perry
Issue date:	12/20/2006
From:	Pearce L FirstEnergy Nuclear Operating Co
To:	Caldwell J Region 3 Administrator
References
PY-CEI/OIE-0683L
Download: ML070180564 (24)

Text

FENOC ~e~,, NuclearPowerStation 10 Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081 L. William Pearce 440-280-5382 Vice PresiderDecember 20, 2006 Fax: 440-280-8029 PY-CEI/OIE-0683L Mr. JamesL. Caldwell Nuclear Regulatory Commission.

RegionalAdministrator,RegionIII 2443 Warrenville Road, Suite 210 Lisle, Illinois 60532-4352 Perry Nuclear PowerPlant Docket No. 50-440 License No. NPF-58

Subject:

Requestfor Closureof Perry NuclearPowerPlant ConfirmatoryAction Letter Commitments

DearMr. Caldwell,

By letter dated September 28, 2005, the NRCissued a ConfirmatoryAction Letter (CAL)to the Perry NuclearPowerPlant (PNPP).That letter confirmedthe understandingof actions FirstEnergy Nuclear Operating Company (FENOC) was planning to take to improvethe performanceat PNPPand confirmed FENOCs specific commitmentsas stated in previous correspondence dated August8 and 17, 2005. This letter is the first of two letters FENOC is submitting to NRC.This letter provides a summary of actions taken, results achievedand the basis for closure of each of PNPPs13 CALcommitments.FENOC implementedthe PNPP Performance Improvement Initiative (PII), Phase2 to drive completionof eachof the CAL commitments and guide actions to improveperformance in eachof the areas identified in the CAL.Thesecondletter will describe the performanceimprovements achievedthru the PII, Phase2, the results of our closure assessments and the transition to FENOC ExcellencePlans whichprovide reasonableassurancethat the improvements will be sustainable. Collectively, the closure of the individual commitments and the results of those actions demonstratethat FENOC has achievedsustainedimprovedperformancein the four areas listed in the CAL.

As discussed in our letter dated, November 13, 2006, FENOC has completed13 CAL commitments in the following four areas: IP 95002Inspection Follow-upIssues, Corrective Action ProgramImplementation, HumanPerformance, and EmergencyPreparedness. The actions taken to complete these commitments and improve performancewere implementedin 2005and 2006. Theseactions, the resultant improvements achieved, and the basis for closure of eachcommitment are describedin the attachmentto this letter. During 2005and 2006, the NRCconductedCALfollow-up inspections in these areas and confirmed that each of the 13 CAL commitmentswas adequately implemented.

As discussed at the NRCpublic meeting on December13, 2006, FENOC has demonstratedthat it has substantially improvedperformanceat PNPP in the four areas addressedby the CAL.

FENOC is providing the basis for closure of all of the individual CALCommitments in the attachmentto this letter and hasdemonstrated that it has achievedsustainedimproved performancein each of the CALareas. Therefore, FENOC requests that NRCclose the ConfirmatoryAction Letter consistentwith the criteria set-forth in the CAL.

As noted above,in addition to implementingthe individual commitments in the CAL,PNPP also established and implementedthe PNPPPerformanceImprovementInitiative. FENOC and the

PY-CEI-OEI-0683L Page 2 NRCwill discuss overall improvement of station performanceachievedthru the PNPP PerformanceImprovement Initiative, the closure of the individual Performance Improvement Initiatives andthe transition to the FENOC Fleet and PNPP Site ExcellencePlans during the forthcomingpublic meetingscheduledfor January10, 2007. Prior to this meeting, FENOC anticipates sendinga follow-up letter to requesttransition fromColumn IV of the Action Matrix to an appropriatereducedlevel of regulatoryoversight consistent with the guidancein set forth in NRCMC0305.

Thereare no additional commitments containedin this letter. If you havequestionsor require additional information, please contact Mr. Jeffrey Lausberg- Manager,RegulatoryCompliance at (440) 280-5940.

Attachments cc: Document Control Desk NRCProject Manager NRCResident Inspector E. Duncan,NRCRill

Attachment PY-CEI/OIE-0683L Page 1 BASIS FOR CLOSUREOF CONFIRMATORY ACTION LETTER (CAL) COMMITMENTS TheNRCperformedthe Inspection Procedure(IP) 95003supplementalinspection in three phasesin early 2005. Theresults of the inspection weredocumented in Inspection Report 05000440/2005003, dated July 8, 2005. Subsequentto the issuanceof the inspection report, First EnergyNuclear Operating Company (FENOC) provided responseto the inspection report in letters datedAugust8 and 17, 2005andinitiated the Perry Nuclear PowerPlant (PNPP)PerformanceImprovementInitiative, Phase2. In those letters, FENOC describedits plans to improveperformanceand provided 13 specific commitments in the areas of IP 95002Inspection Follow-upIssues, Corrective Action Program,Human Performance, and EmergencyPreparedness. Those specific commitmentsin the FENOC letters werelater identified as PNPP ConfirmatoryActions Letter (CAL)commitments in the NRCletter dated, September28, 2005. Throughthe implementationof the PNPP PerformanceImprovementInitiatives, FENOC has madeconsistent improvementsin the four areasidentified in the CAL.This attachmentdescribesthe results of the actions takento completeeachof the thirteen CALcommitments.

Additionally, as requestedin the NRCCAL,FENOC had provided quarterly updatesto those specific actions specified in Attachment3 of FENOC letters dated August8 and17, 2005.

Thequarterly updateswereprovided in letters dated October28, 2005, January30, 2006, April 17, 2006, July 28, 2006, October31, 2006and November 13, 2006.

For eachof the four areasidentified in the CAL,this attachmentrestates the CAI_

commitment for easeof reference, describes the purposeof the commitment,describes the results of actions taken to completeeachcommitment, provides the basis for closure of the commitment,and demonstratesthat there has been sustained improvedperformancein the area.

In order to provide focused management oversight of these commitments,FENOC placed actions to implementthe commitments in the Detailed Action and Monitoring Plan (DAMP) the Perry Performance Improvement Initiative (PII). Thefollowing discussion referencesthe applicable DAMP actions. Thefour areas andthirteen commitments are listed in table 1 of this attachment.

1.0 IP 95002Inspection Follow-upIssues

1.1 CALCommitmentDescription

"Issues dealing with the quality of maintenance proceduresincluding quality control inspection hold points. Revisionof the Quality Control Inspection Programto focus additional attention on items that haveexperiencedrepeat failures."

1.2 Purpose

TheaboveCALcommitment contains three (3) actions. First, FENOC stated in responseto NRCIP 95003inspection report (IR 2005003),that one hundredeight (108) of the one hundrednineteen (119) procedures been updatedand issued. The remaining maintenanceprocedureswill be updatedand owners review completed. [CAL Commitment l.a]

Attachment PY-CEI/OIE-0683L Page 2 Second,FENOC stated that it wouldrevise Nuclear Quality Assurance Instruction NQI-1001,"QCInspection ProgramControl," to specify a method to establish additional QCinspection items for items that haveexperienced repeat failures. This method wasto include considerationof failure analysis, the risk-significanceof the item, andthe probability of failure occurrence in determiningthe extent of inspection activity. [CALCommitment 1 .b]

Third, FENOC stated that it wouldrevise GenericMechanicalInstructions (GMI)-0039, "Disassembly/Re-assembly of Divisions I and II Emergency Service Water Pumps,"and GMI-0040,"Disassembly/ Re-assemblyof Division III Emergency Service WaterPump,"to include QCinspection points for workactivities associatedwith pumpshaft couplings, as specified by QC.

[CAL Commitment1.c]

1.3 Basis For Commitment Closure:

The CALcommitments for addressingthe IP 95002follow-up issues are complete.Providedbeloware basis for closure of the individual CAL commitmentsand summaryof actions taken to achieve sustained improved performancein eachof the CALareas.

CALCommitment 1.a / DAMPAppendixAction B.2.2.3.1 This commitmentinvolves upgradeof the key maintenanceprocedures. In letter dated, October28, 2005, FENOC stated that the aboveCAL commitment was completedin third quarter 2005.

In third quarter 2005, FENOC completedupgradeof the remainingkey maintenanceprocedures.The scopeof this upgradeproject included those maintenance proceduresthat are directly or indirectly associatedwith select key componentsat PNPP.Thesekey componentsincluded both the high safety-significant components,those having a risk achievementworth (RAW) of greater than 2.0 and a Risk ReductionWorth(RRW)of greater than 1.005, and other risk-significant components, including the Emergency Service Water (ESW)pumps.Also, the scope included those additional maintenance proceduresthat the Senior LeadershipTeamconsideredto be important basedon their significance andother select multi-use maintenance procedures. The upgraded maintenanceprocedures were an improvement to the previousrevisions, both in content, formatting, andeaseof use.

However,several potential deficiencies wereidentified with the upgraded maintenanceprocedures.Theyincluded: typographical errors, formatting inconsistencies, properstep sequencing,faulty references, missing information, andproperuse/ identification of critical steps. Toaddressthese potential deficiencies, FENOC generatedCondition Report (CR) 06-00418 and commenced supplementalprocedure review to revalidate the upgraded maintenanceprocedures. As part of the supplementalreview effort, FENOC undertookthe following actions to improvethe quality of the maintenance procedures:

Developednewprocedurewriters guide for improved formatting / sequencingof procedures(PAP500, "Perry Technical ProcedureWriters Guide")

Attachment PY-CEI/OIE-0683L Page 3 o Revisedthe definition for "Critical Stop" to align with industry standards o Providedtraining for procedurewriters o Provided training on procedureuse and adherencetraining for Maintenancepersonnel (NOP-LP-2601,"Procedure Use and Adherence")

Additionally, procedures that werenot verified by field useor throughthe supplementalreview effort wereput on hold.

Thefollowing dgorousreview andapproval processis being applied during the supplementalreview of the maintenanceprocedures:

o Technicaland Craft review, such that the users of the proceduresinvolved in the review process o Cross-Discipline review (PAP507, "Perry Supplemental ProcedureRequirementGuidance"),such that other site organizations(e.g., engineering)whoprovidedinput to the proceduredevelopare involved in the review process o Validation of procedures(PAP550.3, "ProcedureValidation")

o IndependentQualified Review(NOP-SS-3001, "Procedure Reviewand Approval"), such that independent review/approvalof the proceduresis performedprior to issuance.

At the August15, 2006public meeting,FENOC stated that at least 70 of the original 119 maintenanceprocedures(now 121 proceduressince some proceduresweresplit into two or moreproceduresfor easeduring the revalidation effort) will be re-validated, approved andmadeeffective by October23, 2006. This action was accomplished.The remainderis scheduledfor completion by December 21, 2006.

In October2006, the NRCinspected a numberof of those revalidated maintenanceproceduresand found themto be effective and improvedin quality. Theresults of this inspection werediscussedduring the Decmber 13, 2006public meting.Nofindings wereidentified during the inspection (IR 2006015).

CALCommitment 1.b / DAMP AppendixAction B.2.2.3.:~

This commitment involvesidentification of criteria for the Quality Control (QC) inspectionhold points basedon failure history, risk significanceandfailure probability. In letter dated, October28, 2005, FENOC stated that the above CALcommitment was completedin third quarter 2005.

In third quarter 2005, FENOC revised procedureNQI-1001,"QCInspection Program Control," Revision5, to identify criteria for assigningQCinspection holdpoints, includingfailure history, risk significanceandfailure probability in assigning QCinspection hold points. Although, the changeto the procedure was deemed appropriate during the NRCfollow-up inspection of IP 95002(IR 2006007),the inspectorsidentified that the methods identified andin usedid not take full advantage of all site programs.In particular, the proceduredid not prescribe the review of the maintenance rule database,whichcollects

Attachment PY-CEI/OIE-0683L Page 4 pertinentcomponent failure data, nor did it integrate the probabilistic risk assessment(PRA)model, which provides component-specificrisk information. To addressthis observation, CR06-00366was generatedand corrective actions have beentaken, as discussedbelow. Also, on December 19, 2005, NQ1-1001was supersededby fleet common procedure Nuclear OperatingProcedure,NOP-LP-2018, "Quality Control Inspection of Maintenance andModification Activities."

As discussedin our responseto Inspection Report 2006007(FENOC letter dated May09, 2006), use of the MaintenanceRule databaseis not an optimummethodto identify additional QC/witnesspoints. Since the condition reports drive the maintenance rule evaluationthroughthe corrective actions, historical failure data canbe obtainedthroughthe reviewof condition reports for those components that are consideredto be a maintenance rule failure.

Therefore,historical data fromthe condition reporting systemwill be usedfor the identification of repeatfailure itemsfor potential assignment of hold /

witnesspoints.

The following enhancementswere added to procedure NOP-LP-2018:

o Useof pre-established"Critical Steps" as a factor whenassigningQC hold / witnesspoints o Useof risk significance assessment tool at a component level as a factor whenassigninghold / witnesspoints o Useof risk significance, maintenance rule, critical components, and maintenance modifications as factors that the QCsupervisorwill utilize whenassigning processmonitoring During the subsequentNRCinspection conductedin July/August 2006 (IR 2006014),the inspectors observedthat the QCinspection point assignment programwascurrently effective andlikely to be effective in the future based uponthe programthat has beenestablished.

CALCommitment 1.c / DAMPAppendixAction B.2.2.3.3 This commitment involves updating GeneralMaintenanceInstructions (GMI)

GMI-0039 and GMI-0040 to include QCinspections points for workactivities associated with ESW pumpshaft couplings. In letter dated, October28, 2005, FENOC stated that the aboveCALcommitmentwas completedin third quarter 2005.

During the NRCinspection conductedin first quarter 2006(IR 2006007),the NRCinspector confirmedthat the licensee had addedappropriate QChold points to coupling reassemblysections of ESW pumprebuild procedures GMI-0039and GMI-0040.Additionally, during the subsequentNRC inspection (IR 2006014),the inspectors concludedthat the licensees corrective actions had beeneffective in addressingthe ESW PumpCoupling Assembly concernarea. In particular, the inspectors concludedthat the licensee had established an adequateQCInspection Point Assignment program;hadproperly assignedQCinspection hold pints to all workorder packagesthat werereviewed; and had concludedan adequateself-assessmentof the QCInspection Point Assignmentprogram.

Attachment PY-CEI/OIE-O683L Page5 1.4 Sustained Improved Performance:

With respect to the upgradedmaintenanceprocedures, they wereused during recent maintenance activities (e.g., Division 2 Outageworkactivities, motoroperatedvalve work) with minor or no issues. Theissues identified were further enhancements to those procedures. Theseprocedures providedinstructions to performquality workwith maintenance craft buy-in since they weredirectly involved with the upgradeproject.

Administrative controls havebeenestablished for addressingthe upkeepand upgradeof future maintenanceprocedures. For example,the procedure wdters guide, PAP-500,"Perry Technical ProcedureWriters Guide" provides appropriate guidancefor establishing consistent maintenance procedures (e.g., format, technical content, sequencing of steps). Theuseof station maintenance craft personnelfor procedurereviews andtraining provide for better quality procedures.Additionally, the maintenance personnelwere trained to procedureuse and adherencein accordanceto procedureNOP-LP-2601, "Procedure Use and Adherence," both in classroomand dynamic training settings.

The supplementalreview of the original 119 key maintenanceproceduresare on schedule and are scheduledfor completion by December 21, 2006. As part of the continuingfocusareafor the site, a backlogreductioneffort for outstanding procedurechangerequests will commence in 2007. Additionally, maintenancewill commence Phase2 of the maintenanceprocedure upgrade in 2007(i.e., upgradeof next set of approximately105maintenance procedures).Theseactions are incorporated in the Perry ExcellencePlan.

As discussed above, procedure NOP-LP-2018 was revised to provide appropriatecontrols for establishingQCinspection points for workactivities at PNPP.Additionally, appropriate QChold points wereestablished in GMI-0039 and GMI-0040for work activities associated with ESW pumpshaft couplings.

In October2006, the NRCinspected a numberof revalidated maintenance proceduresand found themto be effective and muchimprovedin quality. No findings wereidentified during the inspection (IR 2006015).

1.5

References:

-NRCIR 2006007, dated March 30, 2006

-NRCIR 2006014,dated September20, 2006

-NRCIR 2006015(to be issued in December 2006)

-FENOC letter ID PY-CEI/NRR-2959L, dated May09, 2006

-FENOC letter ID PY-CEI/NRR-2996L, dated October 26, 2006 2.0 Corrective Action ProgramImplementationImprovement 2.1 CAL. Commitment

Description:

"Developandtrain site staff on expectationsfor successfulcorrective action program(CAP) implementation, Implementmanagement controls to improve line ownershipand accountability for successfulCAPimplementation.

Attachment PY-CEI/OIE-0683L Page 6 Establish a managementprocess to routinely monitor CAPperformance at the site anddepartment / sectionlevels (e.g., operations,electrical maintenance,plant engineering, etc.). Performa self-assessmentthat evaluatesthe overall health of the CAPfollowing implementation of specific improvement initiatives."

2.2 Purpose

The aboveCALcommitment contains four (4) actions. First, FENOC stated in responseto NRCIP 95003inspection report (IR 2005003),that expectationsnecessaryfor successfulimplementation of the corrective action program(CAP)will be developedand site personnelwill be trained to the expectationsandaccountability methodsthat will be usedto improve implementation of the CAP.[CAL Commitment 2.a]

Second,FENOC stated it would implementmanagement controls to improve line ownership andaccountability at the individual level for successful implementation of the CAP.[CAL Commitment 2.b]

Third, FENOC stated it wouldestablish a management review process that routinely monitorsthe sites and section level CAPperformance.Takeaction to improveperformancewhenexpectations are not met and hold the organization accountablefor overall CAPeffectiveness. [CALCommitment.

2.c]

Fourth, FENOC wouldperform a self-assessmentthat evaluates the overall health of the CAP,including an aggregateassessment of key performance indicator trends. Assesswhethersubstantial progresshas beenmadein CAPperformance. [CAL Commitment2.d]

2.3 Basis For Commitment Closure:

TheCALcommitments for improvingthe implementationof the corrective action programare complete.Providedbeloware basis for closure of the individual CALcommitments and summaryof actions taken to achieve sustained improvedperformancein eachof the CALareas.

In 2004mid-cycle plant performanceassessment letter (dated August30, 2004), the NRC identified a substantivecross-cutting issue in the area of problemidentification andresolution involving a numberof findings.

Examples included: the repetitive failure of the Division 1 emergency service water pump,an inadequateextent of condition reviewfollowing the failure of the HPCS pumpto start, and missedopportunities to identify the low pressurecore spray / residual heat removalsystemventing procedure deficiencies. Further, the needto performmultiple revisions of root cause evaluationswasconsideredto be indicative of significant organizational deficiencies. During the IP 95003inspection in early 2005, the NRCteam identified similar performance issuesin this area.

As discussedin our letter dated August17, 2005(PY-CEI/NRR-2902L),

FENOC conductedroot cause analysis (CR 05-03986)to address continued performanceissues with implementationof the CAP.Theroot cause concludedthat although the programmaticaspects of the CAPare adequate,

Attachment PY-CEI/OIE-0683L Page 7 the behaviors necessary for its effective implementationare not. Specifically, the root cause analysis identified the following root and contributing causes as the main contributors for ineffective implementation of CAPat PNPP:

Root Causes The PNPPmanagement team has not owned the CAP and has not used the programto effectively solve problems and improve station performance.

o Managementhas not established adequate expectations to ensure the CAPis effectively implementedat all levels in the organization.

Contributinq Causes o The PNPPorganization has not accepted using the CAPto identify and solve problems in a timely manner.

The PNPPmanagement has not consistently monitored CAPhealth and effectively taken intervention actions to drive improvementin the CAP.

o The existing expectations are not being reinforced by a consistent review process that includes appropriate rewards/accountability.

Appropriate corrective actions weredevelopedand implementedto address the aboveroot and contributing causes.Thefollowing provides the key actions taken for addressingthe ineffective implementationof CAPat PNPP.

CALCommitment 2.a I DAMP Actions 1.1.1 and 1.2.1 This commitment involves developingexpectations necessaryfor successful implementationof the CAPandtraining site personnelto the expectations and accountability methodsthat will be usedto improveimplementation.In letter dated, January30, 2006, FENOC stated that the aboveCAL commitment wascompletedin fourth quarter 2005.

In fourth quarter 2005, FENOC trained site personnelto the CAP implementationexpectations. The course outline wasbasedon procedure PYBP-SITE-0046, "Corrective Action ProgramImplementationExpectations."

Theexpectationdocument identifies the correct behaviorsfor use of the CAP process. Thetraining sessionalso focusedon the two root causesand the three preventrecurrencecorrective actions identified in CR05-03986,which pertains to the root causeanalysis that wasperformedto addresscontinued declining performancein CAP.Thetraining session waspiloted through the Perry Senior Leadership Team(SLT), managersand supervisors, and analystsprior to roll-out to site personnelto obtain their endorsement. Also, the training wastailored to individual sectionsonsite so that emphasis could be placedon the expectationsand accountability methodsfor their sections.

For example,the maintenancetraining wasmorefocused on problem identification and engineeringsessionsweremorefocusedon timely and quality investigations. This training providedthe foundationfor improving ownershipof CAPand station focus on using the CAPthrough better

Attachment PY-CEI/OIE-0683L Page 8 understanding of expectations and accountability for use of the FENOC corrective action program.

Oneobjective for the training included the role of a CAPin an environmentof a learning organization and howit must be used to drive station improvement. The training also emphasized the expectations of site individuals for implementingeffective CAPthat were not consistently reinforced in the past. Theindividual performanceappraisal processwas revised to ensure expectationswere understoodand accountability methods wereestablished.

During follow-up NRCinspections (IR 2006008/ 2006015), the NRC inspection teamdeterminedthat the actions wereadequatelyimplemented andeffective. Theresults of the inspection (IR 2006015)were discussed the December 13, 2006public meeting.

CALCommitment 2.b / DAMPAction 1.1.2 This commitmentinvolves implementingmanagement controls to improve line ownership andaccountability at the individual level for successful implementationof the CAP.In a letter dated, October28,2005, FENOC stated that the aboveCALcommitment wascompletedin third quarter 2005.

In third quarter 2005,FENOC revised the expectationsin the staff performance appraisals.In particular, the differencesin responsibilities for implementingthe corrective action programwereidentified and individual performanceappraisal elementsweremodified for eachdepartmentposition.

Thepurposeof this action wasto establish individual accountability for useof the CAPto identify and solve problemsin a timely mannerandto reinforce existing expectationsby a consistent reviewprocess. This action also established management accountability for monitoring CAPprogramhealth andtaking effective intervention actions to drive improvement in CAP.

During follow-up NRCinspections (IR 2006008/ 2006015),the NRCteam determinedthat the actions taken wereadequatelyimplementedand effective. Theresults of the IR 2006015 werediscussedat the December 13, 2006 public meeting.

CALCommitment 2.c / DAMP Action 1.7.1 This commitment involves establishing a management review process that routinely monitorsthe sites and section level CAPperformance and takes action to improveperformancewhenexpectations are not met and hold the organizationaccountablefor overall CAPeffectiveness. In a letter dated, October 28, 2005, FENOC stated that the above CALcommitmentwas completedin third quarter 2005.

The management review process is administratively governedin several FENOC Fleet and Site procedures. Theseproceduresguide the oversight of the CAPandinitiate intervention activities to ensureweaknesses in CAPare addressed.For example:fleet procedureNOP-LP-2001, "Corrective Action Program," directs FENOC management to ensure effective implementation of the CAPand to monitor CAPprocess performanceto address programmatic

Attachment PY-CEI/OIE-0683L Page 9 weaknesses;fleet procedure NOBP-LP-2008, "Corrective Action Review Board," requires CAPperformanceindicators to be periodically reviewed; and, site procedurePYBP-SITE-0046, "Corrective Action Program ImplementationExpectations; directs the management teamto provide oversight of the condition report processand specifically review the CAP performance indicators on a periodic basis.

In July 2005, an improvedset of CAPkey performanceindicators (KPIs) weredeveloped.TheseKPIs are periodically reviewedby the Corrective Action ReviewBoard. Analyses of weakareas are addressedand gap closure plans developedand implementedto address those weaknesses.

Also, Perry CAPperformancereview has been a standing agendaitem for the weekly Perry Senior Leadership Teammeetings.

Additionally, the following levels of management reviewswereinstituted to ensure adequateoversight of the health of CAPat PNPP.Theyinclude:

o Corrective Action Review Board (CARB)Meetings: The CARB activity is governedby procedureNOBP-LP-2008 and provides oversight of CAP.The CARB review includes: root causeand full apparentcauseevaluations andcorrective actions, condition report effectivenessreview plans andreviews, condition reports documentingadversetrends, operating experienceevaluation reviews, andperiodic review of CAPperformanceindicators.

Additionally, CARB has established a "CARBFocusDay" that provide review of specific CAPfocus areas suchas, review of CR/CA backlogs, analysis of KPIs. Thefocus dayis typically conductedon a once per monthcycle.

o Mana.qement ReviewBoard (MRB)Meetinqs: The MRBactivity is governed by procedure NOP-LP-2001.The MRBmeets daily during the normal workdays to review newly generatedcondition reports. TheMRBreview includes: review of condition report issues to ensurethat they are assignedthe appropriate significance level, ownership,level of evaluationandtimelinessof the evaluation. The MRBmayalso establish: MaintenanceRule component/system evaluation, CARB review of non-root cause condition reports, effectivenessreviewfor non-rootcause condition reports, site or section human performance clock reset evaluations, nominationof good/greatcatches, needfor immediateactions to addressidentified conditions, and needfor common cause analysis.

Senior LeadershipTeam(SLT) Meetin.qs: TheSLTconsists of onsite senior management teamthat provides oversight of current plant activities that includes review of CAPperformance.The SLTmeetson a weekly basis.

Monthly PerformanceReview(MPR): The MPRis held on a monthlybasis at eachof the FENOC sites to review their performance.TheMPRis attendedby fleet directors, managers, and the executive leadership team. The MPRincludes review of the monthlyperformance reports that includesindicators for: plant

Attachment PY-CEI/OIE-0683L Page 10 performance,site performance,NRCregulatory performance, humanperformance,CAPperformance,plant operations, cost effectiveness and people, processes,and procedures.

During the NRCinspection (IR 2006008),the NRCconcludedthat the actions were adequately implementedfor this CALcommitment.However,the NRC teamobservedthat a formal mechanism to addressKPI issues within the corrective action programdid not exist. In particular, written guidancewas not available that prescribedthe generationof a condition report to address declining KPIs, performancegapsbetweenactual and expected performance,the developmentof action plans to reduce the gap between actual andexpectedperformance,or the tracking of the successof action plans to addressidentified performance deficiencies. Althoughspecific guidancedid not exist, the NRCteamdid not identify anydeclining KPIsfor which appropriate corrective actions had not been implemented.The NRC teamconcludedthat the lack of a formal processto addressKPI issue could impactthe long-termeffectivenessof the actions.

To address this observation, FENOC revised procedure PYBP-SITE-0046 to develop and documenta processthat defined Section level responsesto their KPIs, and defined whengap closure plans are to be developedand reviewed(and what communications will be disseminatedfrom these reviews). During the recent NRCCALFollow-up Inspection for CAP(IR 2006015), the NRCteam deemedthat the changesmadeto procedure PYBP-SITE-0046 were effective. The result of the IR 2006015was discussedat the December 13, 2006public meeting.

CALCommitment 2.d / DAMPAction 1.1.12 This commitment involves performing a self-assessmentthat evaluates the overall health of the CAP,including an aggregateassessment of key performanceindicator trends. Also, the assessment will determinewhether substantial progresshas beenmadein CAP.In a letter dated, November 13, 2006, FENOC stated that the above CALcommitmentwas completedin fourth quarter 2006.

In fourth quarter 2006, FENOC completedthe self-assessmentto evaluate the overall health of the CAP,including aggregateassessment of the KPI trends. Theassessmentevaluated whethersignificant progress has been achievedand whetherthere is reasonableevidencethat improvements are continuous and sustainable in CAP.The assessmentteam consisted of industry and FENOC peers, as well as station personnel. This self-assessmentis documentedin report numberSA 846PYRC2006.

Theself-assessmentteamusedstructured data collection and analysis methodsfor assessingthe CAP.Themethodsincluded: interviews with Condition Report (CR) analysts, evaluators and managers from operations, maintenance, engineeringandradiation protection; interviews with root and apparentcauseevaluators; observationof initial CRScreeningCommittee meetings, MRB,CARD,and Corrective Action Closure Board (CACB);review of CAPKPIs; reviewof select root and apparentcauseevaluations relative to quality of analysis, quality andappropriateness of actions and effectiveness of implementation of corrective actions and extent of condition/cause;review

Attachment PY-CEI/OIE-0683L Page 11 of CAPbacklogs and work-off plans; and review of section cognitive binning and Integrated Performance Assessments (IPA) evaluations. Corrective action products (e.g., root and apparent cause evaluations) from 2005 were reviewed and comparedto 2006 products to assist in the determination of whether improvements have been made. The trends in KPls were also reviewed to assess changes in performance from 2005 to 2006.

Overall, the self assessment concluded that:

o Substantial improvement has been made in Stations ownership and implementation of the CAPsince January of 2005 o Improvements are sustainable o Notwithstanding the improvements, opportunities for improvementstill exist In summary,the following noteworthy improvementsand areas for improvement wereidentified during the self-assessment:

Noteworthy Improvements o Station ownership and focus on CAP o Healthythreshold for identifying adverseconditions o Classification and priodtization of issues o Timely completion of root and apparent causeevaluations o Quality of closure documentationfor CRsand CAs o Improved oversight of CAP Areasfor Continuin.q Improvement o Timely review of CAPproducts by Corrective Action Closure Board o Owner manager attendance at CARB o Standardof 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for root cause evaluation teamassemblyis sometimes missed o Standardof supervisory review of newCRsin less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is sometimes missed o Standardfor preparation of trend reports on time is sometimes missed o Additional training on extent of condition and extent of causeis warranted Condition reports weregeneratedto documentissues and Areasfor Improvement (AFI) identified during the self-assessment.TheseAFIs were incorporatedinto the Perry ExcellencePlan for 2007- 2008.

During the NRCinspection (IR 2006015), the NRCteam reviewed the above self-assessmentand determinedthat the self-assessmentadequately addressedthe CALcommitment.The result of the inspection (IR 2006015) wasdiscussedat the December 13, 2006 public meeting.

2.4 Sustained ImprovedPerformance:

As discussedduring the recent NRCinspection (IR 2006015),the CAPKPIs in conjunction with audits andself assessments, provide a basis to assess

Attachment PY-CEI/OIE-0683L Page 12 the overall effectiveness of CAP.Corrective Action Program KPls show substantial improvement in manyof the key areas since early 2005. In particular, the timelinessof completingthe evaluationsandthe implementationof corrective actions has improved,demonstratingownership by the line personnel.Thequality of the productsfrom the CorrectiveAction Programhas improved.Theimprovementin the quality of apparent causeis a product of the improvement actions that increasedthe level of performance of Corrective Action ReviewBoard. Also, as discussedduring the recent NRCinspection (IR 2006015),the quality of the root causeevaluations has improvedsignificantly in 2006whencompared to 2005.

In summary, the threshold for capturing problemsin the Corrective Action Programhas loweredto levels wherevery low significance issues are being identified, providing confidencethat problemsare visible for managements attention. Our staff is able to focus on evaluatingandsolving the problems with improvedtimeliness and improvedquality. Theultimate benefit of good CAPperformanceis morereliable equipmentperformanceenhancingsafety.

Also, as discussedabovethe root and contributing causesdiscussedin CR 05-03986havebeen addressedthrough implementationof the corrective actions. Expectations,roles andresponsibilities for management and site personnel were incorporated into FENOC Fleet and Perry proceduresand businesspractices. Site personnel, including supervisors and managers, havebeentrained to expectationsand accountability methodsusedto measurethe implementationof the CAP.Part of the training included the role of a corrective action programin a "learning organization"andhowit mustbe used to drive station improvement.The newemployeesreceive introductory training of CAPduring the Plant AccessTraining (PAT)and receive an orientation manualthat contains key aspectsof a successful CAP.

In July 2005, an improvedset of CAPKPIs wasdevelopedand are periodically reviewedby management. Various levels of management review processeshavebeeninstituted or improvedto ensureadequateoversight of the health of CAPgoing forward. They include CARB,MRB,SLTand MPR meetings,and these measuresare institutionalized in proceduresand businesspractices. Intervention actions are implemented if declining performance / trends are identified.

Also, a self-assessment(as discussedabove) wasrecently performed assessthe overall health of CAP.Theself-assessmentconcludedthat substantial improvement has beenmadein Stations ownershipand implementation of the CAPsince January 2005 and those improvementsare sustainable.

Fleet ownershipof the proceduresand expectationsof CAP;and oversight providedby the senior leadership teamand executive leadershipteamwill provided reasonableassuranceof sustained performancein CAP.

Finally, the following key Fleet andSite CAPproceduresand processesare in place to assuresustained performance going forward:

o NOP-LP-2001, "Corrective Action Program" o NOP-LP-2100,"Operating Experience Program"

Attachment PY-CEI/OIE-0683L Page 13 o NOBP-LP-2001,"FENOCSelf-Assessment/Benchmarking" o NOBP-LP-2007, "Condition Report Process Effectiveness Review" o NOBP-LP-2008, "FENOC Corrective Action ReviewBoard" o NOBP-LP-2010,"CRESTTrending Codes" o NOBP-LP-2011,"FENOCCause Analysis" o NOBP-LP-2018, "Integrated PerformanceAssessment/ Trending" o NOBP-LP-2019, "Corrective Action ProgramSupplemental Expectations and Guidance" o PYBP-SITE-0046, "Corrective Action ProgramImplementation Expectations" 2.5

References:

-NRCInspection Report 2006008,dated April 19, 2006

-NRCIR 2006015(to be issued in December2006)

-FENOCletter ID PY-CEI/NRR-2968L, dated May24, 2006 3.0 Excellence in HumanPerformanc~

3.1 CALCommitmentDescription

"Define and communicate the Site LeadershipTeamsroles and responsibilities in implementingthe humanperformanceprogram.Focus Site Training Advisory Committeeand department/ section Training Review Committee meetings on humanperformance. The HumanPerformance Programpurposeand key activities will be communicated to all site personnel.Group-specificneedsanalysis will be performedto identify the scope and content of humanperformancefundamentalsand error preventativetool training."

3.2 Purpose

TheaboveCALcommitment contains four (4) actions. First, roles and responsibilities of the Site LeadershipTeamin implementingthe human performanceprogramwill be defined and communicated.[CAL Commitment 3.a]

Second,approximatelymonthly Site Training Advisory Committeeand department/ section Training ReviewCommitteemeetings havebeen held and will continue to be conductedwith a strong focus on humanperformance through fourth quarter 2005. [CALCommitment 3.b]

Third, the purposeandkey activities of the Human Performance Programwill be communicated to Perry Nuclear PowerPlant (PNPP)personnel. [CAL Commitment3.c]

Fourth, group-specific needsanalyseswill be performedby training committeesto determinethe scopeand content of initial and continuing training needson humanperformancefundamentalsand error prevention tools and training will be provided. [CALCommitment 3.d]

Attachment PY-CEI/OIE-O683L Page 14 3.3 Basis For CommitmentClosure:

The CAI_ commitmentsfor improving human performance are complete.

Provided below are basis for closure of the individual CAI_ commitmentsand summaryof actions taken to achieve sustained improved performance in each of the CAI_areas.

In 2004 end-of-cycle plant performance assessment letter (dated March2, 2005), the NRCidentified a substantive cross-cutting issue in the area of humanperformance involving a numberof findings related to personnel performance, with a commontheme of failure to follow procedures or inattention to detail. Examplesincluded: the presence of unattended matedalin the pool swell region in containment, the failure to follow procedures for evaluating and dispositioning impaired tornado barriers, the improper installation of test equipmentthat subsequently damagea valve in the combustiblegas control system, the improper installation of scaffolding underneath an annulus exhaust gas treatment systemexhaust damper that rendered that train inoperable, and the improper use of the Fix-It-Now process on a containment isolation valve that resulted in inadequate post maintenance testing. During the IP 95003 inspection in early 2005, the NRC team identified similar performanceissues in this area.

As discussed in our letter dated August 17, 2005 (PY.-CEIINRR-2902L),

FENOC conducted root cause analysis (CR 05-02517) to address continued performance issues with human performance at PNPP. The root cause concluded that weaknesses in humanperformance practices had degraded our barriers to prevent events. Specifically, the root cause analysis identified the following root and contributing causes as the main contributors for human performance issues:

Root Causes o Less than adequate (LTA) management ownership of the human performance programat the appropriate levels in the organization.

o LTA program performance monitoring and trending Contributinq Causes o Program and process implementation weakness o I_TA procedure content o I_TA supervision o I_TA accountability and expectations o LTAexpectations and standards Condition Report 05-02517identifies the corrective actions that were implementedto address the root and contributing causes identified above.

Theseactions strengthenedthe management support, expectation and ownership of humanperformance, established humanperformance

Attachment PY-CEI/OIE-0683L Page 15 monitoring and trending, established expectations for use of human performance tools, developedqualification processfor procedurewriters, reinforced properbehaviorsfor using the field observationprocessand trained site personnel on humanperformancefundamentals.

Thefollowing provides the key actions taken for addressingthe human performanceissues at PNPP.

CAL Commitment3.a / DAMP 1.1.3.3 This commitment involves defining and communicating the Site Leadership Teamsroles and responsibilities in implementingthe humanperformance program.In the letter dated January30, 2006, FENOC stated that the above commitment was completedin fourth quarter 2005.

Rolesand responsibilities of PNPP management (i.e., managers,directors, and site vice president) are defined in procedureNOBP-LP-2601, "Human PerformanceProgram."

Additionally, in September2005, the President of FENOC issued Nuclear Operating Policy NOPL-LP-2008, "HumanPerformance."The intent of this policy is to establish clear expectationsandprinciples for FENOC personnel to demonstrateevent free behaviorsthroughoutthe organization to support safe andreliable plant operation.Also, this policy reinforces that human performance tools will be usedto establish a workenvironmentin which individuals and leadersroutinely exhibit behaviorswhichwill reduceor even eliminate plant events causedby human error. This procedureestablishes responsibilities andadministrativecontrols that are requiredfor safe and event-free performanceat PNPP.

In fourth quarter 2005, the PNPPmanagement team was requested to review andto affirm their understanding of their roles andresponsibilities as defined in Nuclear Operating Policy, NOPL-LP-2008 and procedure NOBP-LP-2601.

To further enhance the understanding of their roles andresponsibilities, in first quarter 2006, site managers anddirectors wereprovidedwith a training session focused on managinghumanperformance.During this training session, groupdiscussionswereheld that focusedon leadershiproles in promoting excellence in humanperformance.

During the NRCinspection (IR 2006012/ 2006017), the NRCteam concludedthat actions taken adequately implementedthe CALcommitment andwereeffective. Theresults of the inspection (IR 2006017)were discussedat the December 13, 2006public meeting.

CALCommitment 3.b / DAMP Actions 1.2.3.1 and 1.2.3.2 This commitment involves focusing the Site Training Advisory Committeeand department/section Training ReviewCommitteemeetings on human performance.In the letter dated January30, 2006, FENOC stated that the abovecommitment was completedin fourth quarter 2005.

Thepurposeof the actions was to ensure that humanperformanceissues that are resolvableby a training solution are systematicallyidentified and

Attachment PY-CEI/OIE-0683L Page 16 addressed by Section Training Review Committees (TRG), Curriculum ReviewCommittees(GRG)and Senior Training Advisory Committee(STAG).

The training teamcharter for TRC,CRCand STAG is discussedin procedure NOBP-TR-1117, Training TeamCharter (this procedure is a FENOC fleet procedure that supersededthe earlier PNPPprocedure PYBP-PTS-0001).

Thetraining teamat FENOC sites is a functional coalition of line organizationsandTrainingpersonnelthat supportsthe identification, development,implementationand oversight of training programsthrough STAC,TRCand CRC.Curriculum ReviewCommitteesare representatives madeup from the individual site sections (e.g., Chemistry,Maintenance, Operations, Radiation Protection). The CRCdeterminesthe continuing training needsfor their respectivesectionsby reviewingindustry andsite performancedata. TheTRCprovides oversight, coordination and direction to the CRCactivities, performancestandards, and changesthat havepotential impactsacrosstraining programswithin their respectiveorganizationalareas.

Radiation Protection and ChemistrySectionsare not part of the TRCand oversight is provided by the STAC.TheSTAG overseestraining for the site and ensureseachtraining programis effectively implemented and meetsor exceeds,industry standards. Approximately,monthlymeetingsare held by these committeeswith a strong focus on humanperformance.

During the NRCinspection (IR 2006012),the NRCteam concludedthat actions adequately implementedthe commitment.The team determined that STAG,TRC,and CRCmeetings were held about monthly and maintained a strong focus on humanperformance.

CALCommitment 3.c I DAMPActions 1.1.3.1 This commitmentinvolves communicatingthe HumanPerformanceProgram purposeandkey activities to site personnel.In the letter datedJanuary30, 2006, FENOC stated that the abovecommitmentwas completedin fourth quarter 2005.

The purposeand key activities of the HumanPerformanceProgramwere communicated to site personnelthrough the following methods:1) Site personnelparticipated in training sessions(LessonPlan HU-TOOLSINTROFUND_PY-02), "Introduction to HumanPerformance Fundamentals," which focusedon individual behaviors, leader behaviors, and organization processesand values; explained the humanperformance principles; anddescribedhowthose principles providedadditional barriers to plant eventsthroughindividual behaviors,leader behaviors,and organizational processesand values; and2) Site personnelparticipated in full day, "HumanPerformanceFundamentals" training session, with handouts that included proceduresNOPL-LP-2008, "HumanPerformancePolicy," and NOBP-LP-2601,"HumanPerformance Program."

During the NRCinspection (IR 2006012), the NRCteam concludedthat actions adequately implementedthe commitment.

CAL Commitment 3.d / DAMPActions 1.1.3.4 and 1.1.3,5 This commitment involves performinggroup-specific needsanalysis to identify the scopeand content of humanperformancefundamentalsand error

Attachment PY-CEI/OIE-0683L Page 17 preventative tool training. In the letter dated Apdl 17, 2006, FENOC stated that the above commitmentwas completed in first quarter 2006.

FENOC performed the group-specific needs analyses by the following Curriculum ReviewCommittees(CRC)and Training ReviewCommittees (TRC): MaintenanceTRC,Operations TRC,Engineering Support Personnel TRC,Chemistry CRC,Radiation Protection CRC,SupplementalCRCand balance of Perry personnel CRC.Gapsin training weredeterminedby using appropriate SystemsApproachto Training (SAT) methodologyprescribed procedure NOBP-TR-1102,"FENOCNeeds and Performance Gap Analyses."Theanalysesidentified initial and continuoustraining needs.The initial training programs werefurther reviewedto determinetraining needsfor station personnel.

The CRC/TRC determinedthat in addition to specialized humanperformance training providedat eachsection/department levels, personnelassignedto PNPPrequires humanperformancefundamentalsand error prevention tools training. As a result, "HumanPerformanceFundamentals" and "Event Free Tools" training wereprovided to site personnelbetweenOctober2005and March2006. Site personnelreceived the necessarysupplementalskills training with the exceptionof thoseindividuals on long-termdisability or on long-termoffsite assignments. Additionally, training materials were developedfor newemployees (similar to the training providedfor existing employees)and training materials weredevelopedfor supplemental personnel(i.e., tailored for contract outageworkers).Continuingtraining needswill be specifically identified within the Needs Analysisas prescribed by procedure NOBP-TR-1102, and by Training and CRC/TRC.

During the NRCinspection (IR 2006012), the NRCteam concludedthat actions adequatelyimplementedthe commitment.

3.4 Sustained ImprovedPerformance:

The HumanPerformanceprogrampromotesthe prevention of events due to humanerror by focusing on sustaining error-prevention behaviors. The actions taken abovein concert with implementationof the Perry Performance ImprovementInitiative for Human Performancedrove improvementsin the behaviorsresulting in a decline in consequentialeventsthat reset the Station Clock. Theinitiative actions wereorganizedin three distinct stages; program structure, behaviormodifications, and discipline in execution.This program structure provided enhancedroles and responsibilities, management expectations,and improvedprocesses.Serving both to increase the skills and behaviorsof the workers, the newlevel of awarenesson human performance resulted in a decline in station eventsattributable to human error. Finally, the disciplined executionof the processesand behaviors continuedthis decline to a very low and sustainednumberof station events.

Also, as discussedabovethe root andcontributing causesdiscussedin root cause performedto address the humanperformanceissues (CR 05-02517) havebeenaddressedthrough implementationof the corrective actions.

Attachment PY-CEI/OIE-0683L Page 18 FENOC issued fleet Nuclear OperatingPolicy, NOPL-LP-2008 that clearly establishesthe expectationsfor personnelthroughoutthe organizationto supportsafe andreliable plant operation. Also, site procedure NOBP-LP-2601 establishes the roles and responsibilities of FENOC employeesincluding management relative to humanperformanceprogram.

Themanagement teamalso affirmed their understandingof their roles and responsibilities as defined in the policy and human performance program.

Theabovepolicy and procedureprovide the foundation for the management and employeeengagementof humanperformance program at PNPP.

Additionally, site personnelweretrained to "Human Performance Fundamentals" and "Event Free Tools." Thesetrainings reinforced their expectations of the humanperformanceprogramand achieving error free performancewhile performing their jobs. A processhas beendevelopedto assesthe needfor continuing training programsbasedon performing needs analysis per procedure NOBP-TR-1102. The group-specific needsanalyses are conducted by CRC/TRC committees based on this process and STAC provides the oversight function. Training matedalhas beendevelopedfor newemployeesas well as for supplementalpersonnel(contract workers).

Keyperformance indicators (KPI) for monitoringperformance in the area humanperformance were established. The "HumanPerformanceSuccess Days"KPI monitorsthe site clock resets, and the "Section Clock Reset"KPI provides a meansto focus on low level events andto increase focus on procedure use and adherenceissues.

Also, a self-assessment(SA886PYPII2006) wasrecently performed provide a focusedevaluation of the effectiveness of the actions implemented to address humanperformanceissues. The self-assessment concludedthat significant progresshas beenachievedand there is reasonableevidencethat improvement is continuousand sustainable.

Fleet ownershipof the proceduresand expectations of Human Performance, and oversight provided by the senior leadership teamand executive leadership teamwill ensure sustained improvedperformancein Human Performance.

Finally, the following key Fleet and Site Human Performance policy and proceduresare in place to assure sustained improvedperformancegoing forward:

o NOPL-LP-2008,HumanPerformance Policy o NOP-LP-2601,Procedure Use and Adherence o NOBP-LP-2601, HumanPerformance Program o NOBP-LP-2602,HumanPerformance Success Clocks o NOBP-LP-2603,HumanPerformance Tools and Verification Practices o NOBP-LP-2604,Job Briefs o NOBP-LP-2607,Observation and Coaching Program o PYBP-SITE-2601,Perry HumanPerformance TeamCharter

Attachment PY-CEI/OIE-0683L Page 19 3.5

References:

-NRCInspection Report 2006012,dated July 25, 2006

-NRCIR 2006017(to be issued in December 2006)

-FENOC letter ID PY-CEI/NRR-2988L, dated August 25, 2006 4.0 EmergencyPreparedness

4.1 CALCommitmentDescription

"Expandthe populationof qualified EPrespondersto increase the emergency responseorganizations depth and conductdrills to demonstrate appropriate emergencyresponsetimes."

4.2 Purpose

The aboveCALcommitment contains two (2) actions. First, FENOC stated in responseto IP 95003inspection report (IR 2005003),that it wouldexpand the population of qualified emergency planning (EP) respondersto increase the depth of the emergencyresponseorganization. [CAL Commitment 4.a]

Second,FENOC stated that it wouldconductadditional EPddlls to demonstrateappropriate emergencyresponse organization (ERO)response times. [CAL Commitment 4.b]

4.3 Basis For Commitment Closure:

The CALcommitmentsfor improving the performancein the emergency preparednessarea are complete.Providedbeloware basis for closure of the individual CALcommitments and summary of actions taken to achieve sustained improvedperformancein eachof the CALareas.

CAL Commitment4.a / DAMPAppendix EP 1 This commitment involves expandingthe population of qualified EP respondersby approximately125 personsto increase the depth of the ERO.

In a letter dated, January30, 2006, FENOC stated that the aboveCAL commitment wascompletedin fourth quarter 2005.

Theabovecommitment wasachievedby designating and training additional plant staff to fulfill ERO positions thereby,increasingthe depthof the organization. This raised the populationof the qualified EROto 461 personnel at PNPP.

CALCommitment4.b / DAMPAppendix EP 2 This commitment involves performingadditional off-hours unannounced drills to demonstrate drill objectives havebeenachieved.In a letter dated, January 30, 2006, FENOC stated that the above CALcommitmentwas completedin fourth quarter 2005.

Attachment PY-CEI/OIE-0683L Page 20 In 2005, three (3) off-hours unannounceddrills were conducted in August, Novemberand December.Additionally, in 2006, two (2) additional off-hours unannounceddrills were conducted in Marchand April to verify the ability of the EROto staff the Technical Support Center(TSC), OperationSupport Center(OSC)and Emergency OperationFacility (EOF). After eachdrill critique process(self-assessment)wasusedto identify areas for improvement.Corrective actions weregeneratedand implementedprior to the performance of the next drill. All drill objectivesweredemonstrated satisfactory during the December 2005, March2006and April 2006 unannounced drills. Additionally in October2006, a successful GradedEP Exercisewasconducted with no significant issuesidentified in ability to staff the ERO facilities.

4.4 Sustained ImprovedPerformance:

During the past year the depth of the EROresponderswasincreasedto provide for improvedstaffing capability for respondingto site emergencies thereby, providing additional assurancein maintaining adequatemeasures to protect the public health andsafety. Tomonitorthis, a periodic reviewwill be conductedby Managerof Emergency Response Section (ERS)to verify that adequatestaffing is maintainedto support the EROat PNPP.This review will be performedin accordancewith procedure PYBP-ERS-0009, "Annual Reviewof the Perry Plant Emergency Plan."

As stated above, FENOC demonstratedsustained performanceduring the last three (3) performances of the off-hours drills. Additionally, FENOC committedto performing morefrequent off-hours unannounced ddll in the future. Anoff-hour unannounced drill will be conducted at least onceper fuel cycle eventhoughthe Emergency Plan requirementis to conductthe drill onceeverysix years. This frequencyfor performingthe drill is discussedin procedure PYBP-ERS-0033, "Off-hour Unannounced Drill Conduct."

Theseactions demonstratethe commitmentby FENOC to continue the improved performanceof EmergencyPreparednessat PNPPgoing forward.

Followingeachdrill, a critique is conducted andareasfor continuing improvement are identified and acted on. This process provides assurance that the PNPPperformancein the area of Emergency Preparednesswill continue to improve.

During the NRCinspection (IR 2006010),the NRCteam concludedthat actions taken to addressissue in the emergencypreparednesshave been effective. As a result, the NRC stated that they do not intend to conductany additional inspection in this areabeyondthat whichis normallyprescribedby ReactorOversight Processbaseline inspection program.

In October 2006, subsequentto the aboveNRCInspection, a gradedEP exercise wasperformedwith no findings. This exercise demonstratedthe ability of the PNPP EROrespondersto effectively respondto site emergencies and to protect the public health andsafety.

4.5

References:

NRCInspection Report 2006010,dated May22, 2006

Attachment Table 1" PNPPComitments PY-CEI/OIE-0683L Page 21 ITEMS DESCRIPTION QUARTER STATUS DUE 1.0 IP 95002 Inspection Follow-up Issues 1.a To date, onehundredeight (108) of the one hundrednineteen(119) procedureshavebeenupdatedandissued. Theremaining Third 2005 Complete maintenance procedureshavebeenupdatedand are currently going throughthe ownersreviewand acceptance review process.

1.b CA05-03655-01 is to revise NuclearQuality Assurance Instruction NQ1-1001, "QCInspectionProgram Control," to specify a methodby Third 2005 Complete whichclassification canbe establishedfor additionalinspectionattention itemsthat haveexperienced repeatfailures. This methodwill includeconsideration of failure analysis,the risk-significanceof the item, andthe probabilityof failure occurrencein determining the extent of inspection activity.

1.c CA05-03655-03 is to revise GenericMechanical Instructions (GMI)-0039,"Disassembly/Re-assembly of Divisions I andII Emergency Third 2005 Complete Service WaterPumps,"and GMI-040,"Disassembly/Re-assembly of Division III Emergency ServiceWaterPump,"to include QCinspection points for workactivities associatedwith pump shaft couplings,as specified by QC.

2.0 Corrective Action Program Implementation Improvement 2.a Developexpectationsnecessary for successfulimplementation of the corrective action program(CAP).Train the site to the expectations Fourth 2005 Complete andaccountability methods that will be usedto improveimplementation of the CAP.

2.b Implement management controls to improveline ownership andaccountabilityat the individual level for successfulimplementation of the Third 2005 Complete CAP.

2.c Establish a management reviewprocessthat routinely monitorsthe sites and section level CAPperformance.Takeaction to improve Third 2005 Complete performance whenexpectationsare not metand hold the organizationaccountablefor overall CAPeffectiveness.

2.d Performa self-assessment that evaluatesthe overall health of the CAP,including an aggregateassessment of key performanceindicator Fourth 2006 Complete trends. Assesswhethersubstantial progresshas beenmadein CAPperformance.

3.0 Excellence in HumanPerformance 3.a Rolesandresponsibilities of the Site LeadershipTeam in implementing the human performance programwill be definedand Fourth 2005 Complete communicated.

3.b ApproximatelymonthlySite Training AdvisoryCommittee and department/ section Training ReviewCommittee meetingshavebeenheld Fourth 2005 Complete andwill continueto be conducted with a strongfocuson human performance throughfourth quarter 2005.

3.c Thepurposeand key activities of the Human Performance Program will be communicated to Perry NuclearPowerPlant (PNPP)personnel. Fourth 2005 Complete 3.d Group-specific needsanalyseswill be performed by training committees to determinethe scopeandcontentof initial andcontinuing First 2006 Complete training needson human performance fundamentals and error preventiontools andtraining will be provided.

4.0 Emergency Preparedness 4.a FENOC is expandingthe populationof qualified EPrespondersby approximately125 personsto increasethe depthof the emergency Fourth 2005 Complete responseorganization.

4.b Additional drills will be conducted to demonstrate appropriateEmergency Response Organizationresponsetimes. Fourth 2005 Complete

Attachment PY-CEI/OIE-0683L Page 22 LIST OF ACRONYMS USED CAL ConfirmatoryAction Letter CACB Corrective Action Closure Board CARB Corrective Action ReviewBoard CR Condition Report CRC Curriculum ReviewCommittee DAMP Detailed Action and Monitoring Plan EOF Emergency Operation Facility EP EmergencyPlanning ERO EmergencyResponseOrganization ERS EmergencyResponseSection ESW EmergencyService Water GMI GeneralMaintenanceInstructions HPCS High Pressure Core Spray IPA Integrated PerformanceAssessment IR Inspection Report KPI Key PerformanceIndicators LTA Less Than Adequate MPR ManagementPerformance Review MRB ManagementReview Board OSC Operation Support Center PAT Plant AccessTraining PII PerformanceImprovement Initiative PNPP Perry Nuclear PowerPlant PRA Probabilistic Risk Assessment QC Quality Control RAW Risk AchievementWorth RRW Risk Reduction Worth SAT SystemsApproachto Training SLT Senior Leadership Team STAC Senior Training Advisory Committee TRC Training ReviewCommittee TSC Technical Support Center