ML051880088
| ML051880088 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/01/2005 |
| From: | Reynolds S Division Reactor Projects III |
| To: | Koehl D Nuclear Management Co |
| References | |
| CAL 3-04-001 IR-05-014 | |
| Download: ML051880088 (21) | |
See also: IR 05000301/2005014
Text
July 1, 2005
CAL 3-04-001
Mr. Dennis L. Koehl
Site Vice-President
Point Beach Nuclear Plant
Nuclear Management Company, LLC
6590 Nuclear Road
Two Rivers, WI 54241-9516
SUBJECT: POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2
NRC SPECIAL INSPECTION REPORT 05000266/2005014;
Dear Mr. Koehl:
On June 17, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed a special
inspection at your Point Beach Nuclear Plant, Units 1 and 2. The purpose of the inspection was
to review your progress in meeting the commitments documented in the Confirmatory Action
Letter (CAL) dated April 21, 2004. The enclosed report documents the inspection results. The
preliminary results were discussed on June 17, 2005, with Mr. James McCarthy and other
members of your staff.
The inspection examined activities conducted under the CAL and your license as they relate to
safety and to compliance with the Commissions rules and regulations and with the conditions of
your license. Within these areas, the inspection involved examination of selected procedures
and representative records, observations of activities, and interviews with personnel.
The inspectors identified no violations of NRC requirements and no findings.
On January 19, 2005, I and members of my staff met with Mr. McCarthy and other members of
your staff to discuss previous NRC observations on inconsistency in the quality of the CAL item
closure packages and ambiguity with the actual closure status of several of the packages.
During the present inspection, we noted an overall marked improvement in package quality and
no ambiguity on package status.
As a result of this inspection, we noted improvement in the area of Human Performance. We
will continue to monitor the effectiveness of your actions taken in this area as well as the areas
of Engineering Design Control, Engineering/Operations Interface, Emergency Preparedness,
and the Corrective Action Program. Our focus will be to ascertain whether or not your actions
taken in these areas demonstrate sustainable improved performance.
D. Koehl -2-
If you have any questions regarding the results of the inspection, please contact me or Mr.
Patrick Louden of my staff at (630) 829-9627.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and any response you provide will be available electronically for public inspection
in the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web
site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Steven A. Reynolds
Deputy Director
Division of Reactor Projects
Docket Nos. 50-266; 50-301
Enclosure: Inspection Report 05000266/2005014; 05000301/2005014
w/Attachment: Supplemental Information
cc w/encl: F. Kuester, President and Chief
Executive Officer, We Generation
J. Cowan, Executive Vice President
Chief Nuclear Officer
D. Cooper, Senior Vice President, Group Operations
J. McCarthy, Site Director of Operations
D. Weaver, Nuclear Asset Manager
Plant Manager
Regulatory Affairs Manager
Training Manager
Site Assessment Manager
Site Engineering Director
Emergency Planning Manager
J. Rogoff, Vice President, Counsel & Secretary
K. Duveneck, Town Chairman
Town of Two Creeks
Chairperson
Public Service Commission of Wisconsin
J. Kitsembel, Electric Division
Public Service Commission of Wisconsin
State Liaison Officer
DOCUMENT NAME: C:\MyFiles\Roger\ML051880088.wpd
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
OFFICE RIII RIII RIII
NAME MKunowski:dtp PLouden SReynolds
DATE 06/30/05 06/30/05 07/01/05
OFFICIAL RECORD COPY
D. Koehl -3-
ADAMS Distribution:
WDR
HKC
RidsNrrDipmIipb
GEG
KGO
CAA1
RGK
C. Pederson, DRS (hard copy - IRs only)
DRPIII
DRSIII
PLB1
JRK1
ROPreports@nrc.gov (inspection reports, final SDP letters, any letter with an IR number)
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos: 50-266; 50-301
Report No: 05000266/2005014; 05000301/2005014
Licensee: Nuclear Management Company, LLC
Facility: Point Beach Nuclear Plant, Units 1 and 2
Location: 6610 Nuclear Road
Two Rivers, WI 54241
Dates: June 13 - 17, 2005
Inspectors: M. Kunowski, Project Engineer
J. Jacobson, Senior Engineering Inspector
Approved by: P. Louden, Chief
Branch 5
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000266/2005014, 05000301/2005014; Nuclear Management Company; on 6/13/2005 -
06/17/2005; Point Beach Nuclear Plant, Units 1 & 2; Special Inspection, Confirmatory Action
Letter Followup.
This report covers a special inspection conducted to review the licensees progress in meeting
commitments documented in Confirmatory Action Letter (CAL) 3-04-001, dated April 21, 2004.
No findings were identified. The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination
Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a
severity level after NRC management review. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
None.
B. Licensee-Identified Findings
None.
1 Enclosure
REPORT DETAILS
1. Background
In the first quarter of 2003, Point Beach Nuclear Plant entered the Multiple/Repetitive
Degraded Cornerstone Column (Column IV) of the Action Matrix of NRC Inspection
Manual Chapter 0305, Operating Reactor Assessment Program, as a result of a high
safety significance (Red) inspection finding. The finding involved the potential for a
common mode failure of the auxiliary feedwater system (AFW) following a loss of the
instrument air system. This issue was initially identified in November 2001. A second
Red inspection finding (Yellow for Unit 1 and Red for Unit 2) was subsequently identified
which involved the potential common mode failure of the AFW pumps due to plugging of
the recirculation line pressure reduction orifices. This issue was initially identified in
October 2002. From July 28 to December 16, 2003, the NRC conducted a three-phase
supplemental inspection to review the corrective actions for the two AFW issues, in
accordance with NRC Inspection Procedure (IP) 95003, Supplemental Inspection for
Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple Yellow
Inputs, or One Red Input. The results of this inspection were documented in Inspection
Report (IR) 05000266/2003007; 05000301/2003007, dated February 4, 2004.
Subsequently, on March 17, 2004, a Notice of Violation and a $60,000 civil penalty were
issued for a problem identified during the IP 95003 inspection regarding unauthorized
changes to the Emergency Action Level scheme in the Point Beach Emergency
Response Plan.
On April 21, 2004, Confirmatory Action Letter (CAL) 3-04-001 was issued
documenting commitments made by Nuclear Management Company, LLC (NMC) in
a March 22, 2004, letter to address areas of regulatory concern identified during the
IP 95003 inspection. The basis for these commitments is the NMC Point Beach
Excellence Plan, an improvement plan intended to focus the Point Beach organization,
site programs, and initiatives on not only the performance issues identified during the
IP 95003 inspection but also on issues identified through internal assessments and on
areas for meeting NMCs goal of improving performance at Point Beach. Updates of the
Excellence Plan were submitted to the NRC on April 1, August 13, and
December 28, 2004. The Excellence Plan is composed of Action Plans to address
improvement areas. Each Action Plan is composed of Action Steps with corresponding
due dates. Of the total 1841 Action Steps in the Excellence Plan, 143 steps were part of
the NMC March 22nd commitment letter.
In June 2004, the initial special inspection of the licensees implementation of the
commitments in the CAL was conducted (IR 05000266/2004005; 05000301/2004005).
Of the 6 Action Step closure packages reviewed, 2 packages had problems indicative of
a need for licensee management to provide additional oversight of package quality. An
in-progress assessment of additional Action Step closure packages was conducted in
July during an NRC Safety System Design and Performance Capability inspection
(IR 05000266/2004004; 05000301/2004004). In August and September, Action Step
closure packages pertaining to emergency preparedness were reviewed during an
inspection (IR 05000266/2004007; 05000301/2004007). As with the inspection in June,
additional information for several packages was required in order for the inspectors to
conclude that all necessary actions related to emergency preparedness had been
2 Enclosure
completed. In late August to early November 2004, eight Action Step closure
packages were reviewed during an expanded problem identification and resolution
inspection (IR 05000266/2004008; 05000301/2004008). During that inspection, the
inspectors concluded that one of the packages, pertaining to the conduct of an
interim effectiveness review of improvements and corrective actions for the
operating experience program, was closed prematurely. And in January 2005, the
NRC completed its second CAL commitment-specific special inspection
(IR 05000266/2004011; 05000301/2004011). Closure packages for 24 Action Steps
specifically committed to in the CAL by the licensee and packages for two Action Steps
not committed to in the CAL were reviewed by the inspectors. The inspectors identified
no findings; however, they did identify inconsistency in the quality of the closure
packages and ambiguity with the actual closure status of several of the packages. This
issue was discussed further with the licensee and corrective actions were taken.
The main purpose of the current inspection was to review the licensees progress in
implementing CAL commitments. The inspection consisted of interviews with personnel,
attendance at plant meetings, in-plant observations, and a review of procedures, Action
Plan Action Step closure packages, and other plant records. The Action Steps reviewed
by the inspectors are discussed below, grouped in four of the five regulatory areas of
concern from the April 21, 2004, CAL.
2. Review of Completed Excellence Plan Action Plan Action Steps
i. Regulatory Area of Concern: Human Performance
a. Inspection Scope
The inspectors reviewed the following completed Excellence Plan Action Plan Action
Steps associated with the CAL human performance area of regulatory concern.
b. Observations
Action Plan Title Step
OR-01-001 Improve Human Performance and Work Practices 22
This step consisted of conducting a final effectiveness review of Action Plan OR-01-001,
which implemented the infrastructure of human performance improvement at the site.
The inspectors interviewed site personnel, including the human performance
coordinator. In addition, various human performance tools, procedures, and internal
information from the licensee were reviewed.
Implementation of Action Plan Action Step
The effectiveness review, conducted February 28 - March 4, 2005, concluded that
actions taken as part of the Action Plan had been effective at improving human
performance. Inspector followup indicated that much of the success of the Action Plan
had to do with the conscientiousness of the stations Human Performance Coordinator,
who had been assigned to that position since mid-June 2004, and upper management
3 Enclosure
support. Continuation of these efforts and continuing increased buy-in from plant staff
and line management should ensure sustainability of the improvements made to date.
The licensee completed the Action Plan Action Step as committed in the
March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify
any significant problems with actions taken to complete this step. The inspectors also
noted that the closure package for this effectiveness review was complete and of high
quality.
Action Plan Title Step
OR-01-004 Individual Behavioral Excellence 19
This step required that senior managers discuss department performance indicators at
Management Review Meetings (MRMs), monthly meetings of station and offsite NMC
upper management.
Implementation of Action Plan Action Step
The department performance indicators were contained in the licensees ACEMAN
database. Point Beach Nuclear Plant Business Manual Procedure (NP) 1.1.10, Human
Performance Program, Revision 3, was issued on July 28, 2004, and contained the
ACEMAN roll-up requirements and the requirement to have the data reviewed by
management on a monthly basis. This database review was also discussed in the Job
Aid, dated May 9, 2005, for the monthly MRMs and the core agenda slides for the MRM
contained a note to ensure that deletion of this agenda item did not occur because of its
relation to an NRC CAL commitment. The NRC inspectors also verified that the
performance indicators were an agenda item and discussed at the April 30, 2005, MRM.
The licensee has proceduralized the requirement for monthly management review of
department performance indicators and provided reasonable assurance that this practice
would continue in the future. The licensee completed the Action Plan Action Step as
committed in the March 22, 2004, letter and as incorporated in the CAL. The inspectors
did not identify any significant issues with the actions taken to complete this step.
Action Plan Title Step
OR-01-004 Individual Behavioral Excellence 36
This step consisted of conducting a final effectiveness review of efforts to improve
individual behavior/performance. These efforts were based on implementing the
licensees ACEMAN model for human performance improvement and the licensees
Picture of Excellence.
Implementation of Action Plan Action Step
4 Enclosure
The effectiveness review, conducted October 25 - November 5, 2004, concluded that
individual behaviors at Point Beach had improved since implementation of the various
Action Plan steps. The efforts of the Human Performance Coordinator, station upper
management, and corporate upper management, and refinements of the ACEMAN
model and in the implementation of the Picture of Excellence have helped in the
increasingly institutionalized focus of plant staff on individual (and group) performance
improvement. The licensee completed the Action Plan Action Step as committed in the
March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify
any significant problems with actions taken to complete this step. The inspectors also
noted that the closure package for this effectiveness review was complete and of high
quality.
ii. Regulatory Area of Concern: Engineering Design Control
a. Scope
The inspectors reviewed the following completed Excellence Plan Action Plan Action
Steps associated with the CAL engineering design control area of regulatory concern.
b. Observations
Action Plan Title Step
OR-08-005 Improve Human Performance in Engineering 19
This step consisted of performing an effectiveness review (EFR055644) of the efforts to
improve human performance in engineering and to maintain the 12-month average of
days between event clock resets greater than 10.
Implementation of Action Plan Action Step
The objectives of this Action Plan were to establish an engineering Human Performance
Improvement Team (HPIT), establish a process for identifying and evaluating human
performance events, provide training, and achieve an improving trend in the Engineering
Event Clock performance indicator. An interim effectiveness review (EFR055643) was
conducted by the licensee in September 2004 and was reviewed by the NRC inspectors
(IR 05000266/2004011; 05000301/2004011). This review indicated that additional
supervisory training was needed and that sustained improved performance was required
to achieve the greater than 10 day engineering human performance indicator.
Lesson Plan ESC-050-001L, Human Performance Tools for Engineering Supervision,
Revision 0, was prepared and approved on January 10, 2005, and supervisory training
was conducted on January 11. The 12-month average days between event clock resets
had improved from 6.9 days in July 2004 to 15.2 days in May 2005 and reached the
commitment goal of greater than 10 days in January 2005. Evaluation of this
performance indicator was part of the charter for the engineering HPIT and the indicator
was reviewed monthly at the MRM, attended by site and offsite NMC senior managers.
The current effectiveness review concluded that all four objectives for this Action Plan
had been met. The licensee completed the Action Plan Action Step as committed in the
5 Enclosure
March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify
any significant problems with actions taken to complete this step.
Action Plan Title Step
OR-08-015 Establish an Engineering Safety and Design Review
Group (ESDRG) 6
This step required that a process be established to provide feedback to engineering staff
regarding comments or issues identified during ESDRG review of engineering products.
Implementation of Action Plan Action Step
Engineering Supplemental Guidelines (ESG) 6.3, Engineering Safety and Design
Review Group Feedback Process, was issued on June 4, 2004. Subsequent to this, an
effectiveness review (EFR055478) was conducted and identified areas for improvement
in the feedback process. One of the improvements consisted of providing more
descriptive feedback memos to engineering personnel by providing examples of
comments from the reviewers with added details from the reviewed products to provide a
better understanding of the condition and applicability of the comments.
The effectiveness review also determined that the respective engineering supervisors
did not consistently share the content of the feedback memos with the staff. This
resulted in a missed learning opportunity. As a result, ESG 6.3 was revised to include
the requirement that sharing of the ESDRG comments with the engineering staff be
documented. In addition to improving the feedback memos, corrective action CA060195
was issued to track the initiation of information sharing sessions between the ESDRG
and the engineering groups.
The inspectors reviewed the feedback memo dated December 1, 2004, and attended an
information sharing session on March 2, 2005. The memo was found to be effective in
summarizing the ESDRG reviews and the specific examples were an aid in
understanding the comments. The information sharing session was found to
demonstrate a good safety focus and provide informative examples. Staff interaction
was considered excellent. The licensee completed the Action Plan Action Step as
committed in the March 22, 2004, letter and as incorporated in the CAL. The inspectors
did not identify any significant problems with actions taken to complete this step.
Action Plan Title Step
OR-08-015 Establish an Engineering Safety and Design Review
Group 7
This step, part of the licensees effort to improve the products of the engineering group,
consisted of performing an effectiveness review (EFR055478) to evaluate the impact of
the ESDRG on engineering product quality.
6 Enclosure
Implementation of Action Plan Action Step
The licensees effectiveness review was reviewed by the NRC inspectors during a
previous inspection (IR 05000266/2004011; 05000301/2004011). The licensees Quality
Review Team scores of engineering products continued to show an improving trend.
The issues identified in the effectiveness review regarding ESDRG feedback were
adequately resolved and are discussed above. The ESDRG continued to provide an
effective vehicle in assuring quality engineering products. The licensee completed the
Action Plan Action Step as committed in the March 22, 2004, letter and as incorporated
in the CAL. The inspectors did not identify any significant problems with actions taken to
complete this step.
Action Plan Title Step
EQ-15-011 Procure Transformer Tap Change Material 12
This step required that any materials needed to change transformer taps on the Unit
Auxiliary Transformers and the Low Voltage Station Auxiliary Transformer be procured
for the Bolted Fault Project.
Implementation of Action Plan Action Step
The licensee reviewed the Component Instruction Manual for the transformers and
determined that they were equipped with no-load tap changers; therefore, no materials
were required to accomplish tap changes. The licensee completed the Action Plan
Action Step as committed in the March 22, 2004, letter and as incorporated in the CAL.
The inspectors did not identify any significant problems with actions taken to complete
this step.
iii. Regulatory Area of Concern: Engineering/Operations Interface
a. Scope
The inspectors reviewed the following completed Excellence Plan Action Plan Action
Steps associated with the CAL engineering/operations interface area of regulatory
concern.
b. Observations
Action Plan Title Step
OR-08-016 Reduce Operable But Degraded/But Non-Conforming
Backlog 5
This step required that any operability determinations open longer than 1 fuel cycle have
documented justification and plant manager approval.
Implementation of Action Plan Action Step
7 Enclosure
The inspectors were provided with a summary of justifications dated March 9, 2005, for
those operability determinations remaining open greater than 1 fuel cycle. The
inspectors reviewed the justifications for the 12 operability determinations remaining
open and did not identify any significant problems with actions taken to complete this
step. The licensee completed the Action Plan Action Step as committed in the
March 22, 2004, letter and as incorporated in the CAL.
Action Plan Title Step
OR-08-017 Improve Operations Department and Engineering
Department Interface 1
This step required the implementing of an operational decision-making procedure to help
improve the operations/engineering interface.
Implementation of Action Plan Action Step
NP 1.1.12, Operational Decision Making Issue Evaluation Process, Revision 0, was
issued on July 30, 2004. This procedure established requirements for evaluation of
technical and operational decisions that affected plant operations, safety, reliability, and
material condition. The licensee completed the Action Plan Action Step as committed in
the March 22, 2004, letter and as incorporated in the CAL. The inspectors noted that the
licensee has been inconsistent in its use of the procedure when degraded plant
conditions were identified. For example, the procedure was not implemented in
August 2004 when the control room ventilation system was degraded and in
February 2005 after an offsite grid disturbance affected the safety-related battery
chargers, one of which required troubleshooting and repair. Noteworthy, is that the
procedure was implemented during the current Unit 2 refueling outage on two occasions.
Overall, the inspectors concluded that the NP 1.1.12 process has been an effective tool
to address previous concerns in this area. The inspectors will continue to monitor the
licensees use of the process to fully understand the threshold for the implementation of
the process.
Action Plan Title Step
OR-08-017 Improve Operations Department and Engineering
Department Interface 2
This step required a self-assessment be performed of the Plant Health Committee (PHC)
per fleet procedure FP-PA-SA-03, Snapshot Self Assessment Process.
Implementation of Action Plan Action Step
A self-assessment was conducted on August 26, 2004 in accordance with fleet
procedure FP-PA-SA-03. The assessment identified that while good issues were
8 Enclosure
presented to the PHC, the PHC lacked a process to plan and develop a business case
for long-term equipment projects. Also, the PHC had not established a prioritized list of
long-term equipment problems requiring resource allocation. The PHC was formed early
in 2003; however, meetings were not held routinely and were frequently cancelled. The
assessment concluded that the PHC had not yet demonstrated a long term commitment
to review system and program health.
In response to the issues identified above, the licensee issued procedure NP 1.1.15,
Identification, Approval, and Tracking of Plant Health Equipment Issues, dated
June 10, 2005. This procedure described the process for the PHC to identify, rank,
approve, prioritize, and disposition equipment issues. The procedure also provided
guidance on the process to present the issues and requirements to monitor the progress
of action completion. Plant Health Equipment issues were tracked on a list and
prioritized based on the Equipment Grading Sheet score so that site resources could be
applied to those issues determined to be the most important. The list tracked long-term,
operator-burden, and resource-burden issues. Those projects costing in excess of
$50,000 were processed in accordance with procedure NP 12.2.1, Project Management
Process, dated September 22, 2004.
The procedures discussed above appeared to address the weaknesses identified in the
self-assessment and provided a structure to the PHC process. The licensee completed
the Action Plan Action Step as committed in the March 22, 2004, letter and as
incorporated in the CAL. The inspectors did not identify any significant problems with
actions taken to complete this step.
Action Plan Title Step
OR-08-017 Improve Operations Department and Engineering
Department Interface 4
This step required a self-assessment of the Design Engineering Review Board (DRB)
per fleet procedure FP-PA-SA-03, Snapshot Self Assessment Process.
Implementation of Action Plan Action Step
Self-assessment PBSA-ENG-04-013, Revision 1, was issued on May 3, 2005, to
evaluate the effectiveness of the DRB. This assessment reviewed associated
procedures, memos, and corrective actions, and conducted a survey of engineering and
operations DRB members. The assessment concluded that the DRB was an effective
tool to increase ownership and participation in the modification process and provide
comprehensive reviews of modifications. Feedback from the DRB to the engineering
staff provided direct improvements in the modifications, as well as increased awareness
of considerations applicable to future modification work. The licensee completed the
Action Plan Action Step as committed in the March 22, 2004, letter and as incorporated
in the CAL. The inspectors did not identify any significant problems with actions taken to
complete this step.
9 Enclosure
Action Plan Title Step
OR-08-017 Improve Operations Department and Engineering
Interface 6
This step required improved communications between operations and engineering
personnel to achieve a common understanding of system design bases and operational
practice to reduce operator burdens (e.g., operator workarounds, control room
deficiencies, lit annunciators, and temporary modifications).
Implementation of Action Plan Action Step
Procedure NP 2.1.4, Operator Burdens, Revision 5, was issued to define, review,
catagorize, and track these issues. Awareness of operator burdens has been raised by
maintaining a list of these items and including it in the PBNP status report as part of the
daily production meeting. During the plan-of-the-day meetings, on a weekly basis,
operator burdens were reviewed and discussed. Total operator burdens were discussed
and tracked on a monthly basis with NMC management. This increased focus has
resulted in a reduction of operator burdens since the end of the first quarter of 2004 to
consistently under the fleet expectation of less than 36. The licensee completed the
Action Plan Action Step as committed in the March 22, 2004, letter and as incorporated
in the CAL. The inspectors did not identify any significant problems with actions taken to
complete this step.
iv. Regulatory Area of Concern: Corrective Action Program
a. Scope
The inspectors reviewed the following completed Excellence Plan Action Plan Action
Steps associated with the CAL corrective action program area of regulatory concern.
b. Observations
Action Plan Title Step
OP-10-010 Operating Experience (OE) Improvement Plan 23
This step consisted of performing an effectiveness review of the implementation of
CA032717 within the maintenance department as well as effectiveness of the OE
Improvement Plan. CA032717, CAL STEP - Maint Use of OE During Prejob Briefs,
August 12, 2003, was the item established in the stations corrective action program to
track the completion of OP-10-010, step 22, to implement a new electronic method for
accessing OE for pre-job briefs for maintenance.
Implementation of Action Plan Action Step
The effectiveness review was conducted, from January 10-14, 2005, as a self-
assessment of the operating experience program. It concluded that, overall, actions
taken as part of the Action Plan to improve the program had been effective and were
10 Enclosure
sustainable. Several areas were identified where enhancements were deemed
appropriate and corrective action program documents (CAPs) were subsequently
generated to track the completion of these items. For CA32717, the effectiveness
review concluded that, whereas the database had been established and was being
used, a plan was needed to populate the pre-job database with briefs for the various
repetitive jobs performed by the maintenance department and formalized in procedures
and routine surveillances/tasks (so called callups). This issue is discussed below.
The licensee completed the Action Plan Action Step as committed in the
March 22, 2004, letter and as incorporated in the CAL. The inspectors did not identify
any problems with actions taken to complete this step. The closure package for this
effectiveness review was complete and of high quality, and the licensee made good use
of expertise from outside of NMC in the conduct of the review, with personnel from a
leading industry group and other utilities.
Action Plan Title Step
OP-10-010 Operating Experience (OE) Improvement Plan 22
This step consisted of implementing a new electronic method for access of OE for pre-
job briefs for maintenance. As discussed above, this step was designated as CA032717
in the stations corrective action program.
Implementation of Action Plan Action Step
The effectiveness review conducted as part of Step 23 of Action Plan OP-10-010
identified the need for a plan to be developed to ensure that the database was populated
with all of the relevant information from the various maintenance documents. Although
some of the documents had been entered into the database and the resulting canned
pre-job briefs had been used or were available for use in November 2004, a large
number of maintenance procedures and callups had not been entered. In addition, the
effectiveness review identified that an understanding of how the database would be
populated and who would do the populating was not clearly understood by relevant
personnel, procedural guidance on this issue was not definitive, most of the OE in the
database was external OE and not internal OE, the level of knowledge in the
maintenance planning group about the database was inconsistent, operations planners
had been given a general familiarization of the database but not detailed training to allow
them to use the database, only one maintenance person and two operations persons
were populating the database, and radiation protection supervisors had not had time to
input radiation protection information into the database.
In the response to the observations during the effectiveness review, the licensee wrote
CAP061651, Need to Populate the Pre-job Brief Data Base, January 24, 2005. From
this CAP, several corrective actions (CAs) were generated, including CAs to train
appropriate staff members, with a due date of June 24, 2005, and fully populate the
database, with a due date of December 28, 2005.
In revision 3 of the Excellence Plan, which was incorporated in the April 21, 2004, CAL,
the licensee committed to complete this Action Step in the third quarter of 2004. Based
11 Enclosure
on the implementation of the database in November 2004, the problems identified with
the database in January 2005 during the effectiveness review, and the protracted due
date of December 28, 2005, needed for fully populating the database, the inspectors
concluded that this Action Step had not been completed by the committed due date.
4OA6 Meetings
.1 Exit Meeting
On June 17, 2005, the inspectors presented the preliminary inspection results to
Mr. James McCarthy and other members of the Point Beach staff. In particular, the
inspectors discussed their observations regarding the pre-job briefing database Action
Step and the need for correspondence from the licensee updating the commitment. The
licensee acknowledged the observations and indicated that the completion dates of the
corrective actions for the identified problems would be evaluated The licensee did not
identify any information, provided to or reviewed by the inspectors and likely to be
included in the inspection report, as proprietary.
4OA7 Licensee-Identified Violation
None.
ATTACHMENT: SUPPLEMENTAL INFORMATION
12 Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
M. Arnold, Excellence Team Specialist
T. Carter, System Engineering Manager
S. Cassidy-smith, Communications Manager
B. Cruise, General Supervisor - Maintenance Support
F. Flentje, Regulatory Affairs Principal Analyst
R. Flessner, Excellence Team Lead
M. Lorek, Plant Manager
J. McCarthy, Site Director of Operations
D. Peterson, Human Performance Coordinator
L. Peterson, Design Engineer Manager
S. Pfaff, Acting Performance Assessment Manager
S. Ruesch, Procedures Manager
J. Schweitzer, Site Engineering Director
G. Sherwood, Programs Engineering Manager
W. Smith, Production Planning Manager
Nuclear Regulatory Commission
P. Louden, Chief, Reactor Projects, Branch 5
R. Krsek, Senior Resident Inspector, Point Beach
M. Morris, Resident Inspector, Point Beach
1 Attachment
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Closed
None.
Discussed
None.
2 Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of licensee documents reviewed during the inspection, including
documents prepared by others for the licensee. Inclusion of a document on this list does not
imply that NRC inspectors reviewed the entire documents, but, rather that selected sections or
portions of the documents were evaluated as part of the overall inspection effort. In addition,
inclusion of a document on this list does not imply NRC acceptance of the document, unless
specifically stated in the body of the inspection report.
CA032717; CAL STEP - Maint Use of OE During Prejob Briefs: August 12, 2003
CA061167; Translation of CAL Commitment Into Procedure Needs Improvement;
January 13, 2005
CA061332; Develop a Plan - Need to Populate the Pre-job Brief Data Base; January 26, 2005
CA063322; Need to Populate the Pre-job Brief Data Base - Select Individuals for Inputs;
June 10, 2005
CA063323; Need to Populate the Pre-job Brief Data Base - Identify Training Needs;
June 10, 2005
CA063324; Need to Populate the Pre-job Brief Data Base - Establish Work Off Curves;
June 10, 2005
CA063325; Need to Populate the Pre-job Brief Data Base - Populate With Commonly Used
Maintenance Documents; June 10, 2005
CAP031808; PBNP OE Program Has Severe Implementation Weaknesses; March 25, 2003
CAP061651; Need to Populate the Pre-Job Data Base; January 24, 2005
CAP065112; ACEs Contain Inadequate Use of OE; June 14, 2005
Nuclear Plant Memorandum NPM 2005-0307; First Quarter 2005 Human Performance Analysis;
May 10, 2005
Point Beach Nuclear Plant Business Manual NP 1.1.7; Managing Work Activity Risk;
February 16, 2005
NP 1.1.10; Human Performance Program; February 2, 2005
NP 1.6.10; Pre- and Post-Job Briefs; February 16, 2005
NP 13.6.1; Point Beach Site Observation Program; March 23, 2005
Operating Experience Guideline 007; External Operating Experience Program Guidance;
February 23, 2005
Point Beach Form PDF-9175; Job Walkdown Checklist; May 19, 2005
PBF-9175a; Job Walkdown Facilities Checklist; February 17, 2004
PBF-9205; High Risk Work Pre-job Briefing Checklist; December 16, 2004
PBF-9217; Pre-job Brief Checklist; May 12, 2005
PBF-9218; Post-job Brief Checklist; November 1, 2000
PBF-9812; Categorization and Mitigation of Risk; February 16, 2005
Training Material; NMC Excellence in Human Performance
3 Attachment
LIST OF ACRONYMS USED
ACE Apparent Cause Evaluation
ADAMS Agency Wide Access Management System
CA Corrective Action
CAL Confirmatory Action Letter
CAP Corrective Action Program Document
CE Condition Evaluation
CFR Code of Federal Regulations
DBD Design Basis Document
DRB Design Engineering Review Board
DRP Division of Reactor Projects
EFR Effectiveness Review
ESDRG Engineering Safety and Design Review Group
ESG Engineering Supplemental Guidelines
HPIT Human Performance Improvement Team
IMC Inspection Manual Chapter
IP Inspection Procedure
IR Inspection Report
NMC Nuclear Management Company, LLC
NOS Nuclear Oversight (Quality Assurance)
NP Point Beach Nuclear Plant Business Manual Procedure
NRC Nuclear Regulatory Commission
OTH Other (Corrective Action Program Document)
PBNP Point Beach Nuclear Plant
PHC Plant Health Committee
QRT Quality Review Team
RCE Root Cause Evaluation
SDP Significance Determination Process
TRP Technical Review Panel
TS Technical Specification
URI Unresolved item
WO Work Order
4 Attachment