ML070610103

Ltr 03/02/2007, Perry Nuclear Power Plant Closure of CAL 3-05-001, Closure of Long-Standing Open White Findings Transition from Multiple/Repetitive Degraded Cornerstone Column

ML070610103
Person / Time
Site:	Perry
Issue date:	03/02/2007
From:	Caldwell J Region 3 Administrator
To:	Pearce L FirstEnergy Nuclear Operating Co
References
CAL 3-05-001
Download: ML070610103 (6)

Text

March 2, 2007 CAL 3-05-001

Mr. L. William Pearce Site Vice President

FirstEnergy Nuclear Operating Company

Perry Nuclear Power Plant

P. O. Box 97, 10 Center Road, A290

Perry, OH 44081-0097

SUBJECT:

PERRY NUCLEAR POWER PLANT CLOSURE OF CONFIRMATORY ACTION LETTER (CAL) 3-05-001

CLOSURE OF LONG-STANDING OPEN WHITE FINDINGS

TRANSITION FROM MULTIPLE/REPETITIVE DEGRADED CORNERSTONE

COLUMN

Dear Mr. Pearce:

The Perry Nuclear Power Plant was placed in the Multiple/Repetitive Degraded Cornerstone column of the Nuclear Regulatory Commission (NRC) Action Matrix as a result of multiple White

findings that were open for more than four consecutive quarters. Specifically, in the third

quarter of 2004, a White finding associated with the air-binding of a Low Pressure Core

Spray/Residual Heat Removal waterleg pump remained open a fourth quarter while a White

finding associated with the failure of an Emergency Service Water pump was carried open into a

fifth quarter as a result of a second failure of the pump during an NRC Inspection Procedure (IP) 95002 inspection.

As a result of these findings, a supplemental inspection was performed in accordance with the guidance in NRC Inspection Manual Chapter (IMC) 0305 and IP 95003, "Supplemental

Inspection for Repetitive Degraded Cornerstones, Multiple Degraded Cornerstones, Multiple

Yellow Inputs, or One Red Input." As documented in the IP 95003 supplemental inspection

report, the NRC determined that Perry was being operated safely. The NRC also determined

that the programs and processes to identify, evaluate, and correct problems, as well as other

programs and processes in the Reactor Safety strategic performance area were adequate.

Notwithstanding these overall conclusions, the NRC determined that the performance

deficiencies that occurred prior to and during the inspection were often the result of inadequate

implementation of the corrective acti on program and human performance errors.

By letter dated September 30, 2004, FENOC advised the NRC that actions were underway to improve plant performance. Your letter stated that to facilitate these performance

improvements, FirstEnergy Nuclear Oper ating Company (FENOC) developed the Perry Performance Improvement Initiative (PII) to identify the specific issues that contributed to the

declining performance, implement immediate compensatory measures, and identify necessary longer-term corrective actions. As part of the IP 95003 inspection, the NRC conducted a

detailed review of the PII. Notwithstanding FENOC's efforts to improve performance through the PII, the NRC concluded, based upon the IP 95003 inspection results, that while FENOC L. Pearce may have realized some limited performance im provements, a substantial improvement in human performance or the implementation of the corrective action program after Perry entered the Multiple/Repetitive Degraded Cornerstone column of the NRC Action Matrix in August 2004

had not been realized. Following the IP 95003 inspection, FENOC submitted a letter to the

NRC dated August 8, 2005, which described the actions that FENOC would take to address

performance issues identified by the NRC and through internal assessments. A subsequent

letter was submitted on August 17, 2005, which made some corrections to the August 8, 2005, letter. The letters contained specific line item actions that FENOC was planning and a number

of commitments to the NRC of actions FENOC would take to improve and sustain Perry

performance. The letters included mechanisms for monitoring the effectiveness of the

performance improvement actions. Further, the le tters provided a description of the revised, or Phase 2, Perry PII.

On September 28, 2005, the NRC issued Confirmatory Action Letter (CAL) 3-05-001 to FENOC to confirm the commitments regarding the implementation of the Phase 2 PII at Perry. The

actions confirmed in the CAL were designed to address long-standing performance issues in

the areas of IP 95002 Inspection Follow-up Issues, Corrective Action Program Implementation, Human Performance, and Emergency Preparedness.

Subsequent to the issuance of the CAL, the NRC implemented a number of inspection and assessment activities to review your actions to address the long-standing performance issues at

Perry. These activities, eight in all, were staffed with inspectors of varying technical

backgrounds and expertise from all four NRC regional offices and headquarters. These

inspectors comprehensively reviewed your co rrective action development, implementation, and effectiveness, in all four areas of the CAL. These activities accounted for nearly 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of

supplemental inspection above and beyond our ROP baseline inspection program. These inspections also involved the independent assessment of programs, actions, and plant activities

to determine whether our assessment results were consistent with your own performance data

and assessments.

By letter dated December 20, 2006, you informed the NRC that FENOC had satisfactorily completed the actions associated with the CAL and requested that the NRC close the CAL. By

letter dated January 3, 2007, you provided the NRC with your perspective regarding the key

actions implemented and perform ance improvements achieved at Perry since entering the Multiple/Repetitive Degraded Cornerstone column of the NRC Action Matrix. In this letter you

also requested that the NRC close the long-standing open White findings, close the

long-standing open cross-cutting issues in the areas of human performance and problem

identification and resolution, and transition Perry to an appropriate reduced level of regulatory

oversight. Subsequently, at a meeting held in the Region III office on January 10, 2007, FENOC met with the NRC to inform us of the Perry performance improvement activities and the results achieved to date, including actions that were planned to ensure that these performance

improvements would be sustained.

Based upon the results of NRC inspections and our assessment of the results of your actions and self-assessments, we have concluded that y ou have satisfactorily addressed the underlying issues that led to the performance probl ems at Perry and have established programs and procedures to effect sustained performance improvements. The NRC has also concluded that L. Pearce you have completed the commitments described in the CAL and that these actions have been effective in addressing the specific performance issues. Because your commitments and

planned actions were designed to address the long-standing open White findings discussed

above, we have therefore also concluded that you have satisfactorily addressed all of the issues associated with the open White findings that resulted in Perry being categorized in the

Multiple/Repetitive Degraded Cornerstone column of the NRC Action Matrix. Therefore, effective the date of this letter, March 2, 2007, all commitments documented in CAL 3-05-001, dated September 28, 2005, as well as the long-standing open White findings in the Mitigating

System cornerstone are closed. As a result, NRC oversight of Perry will be reduced to a level

consistent with the applicable column of the NRC Action Matrix absent the two long-standing

White findings in the Mitigating Systems cornerstone, which at this time is the Licensee

Response Column of the Action Matrix.

With regard to your request to close the open substantive cross-cutting issues in the human performance and problem identification and resolution areas, as discussed in our 2006 Perry

Annual Assessment Letter dated March 2, 2007, we have determined that as a result of your

effective implementation of the CAL and PII effo rts, that the number and significance of human performance and problem identification and resolution related findings have declined

measurably. Therefore, as discussed in the 2006 Perry Annual Assessment Letter, we have

concluded that the substantive cross-cutting issues in the human performance and problem

identification and resolution areas can also be closed.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) co mponent of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/James L. Caldwell Regional Administrator Docket No. 50-440 License No. NPF-58 DISTRIBUTION:

See next page L. Pearce you have completed the commitments described in the CAL and that these actions have been effective in addressing the specific performance issues. Because your commitments and

planned actions were designed to address the long-standing open White findings discussed

above, we have therefore also concluded that you have satisfactorily addressed all of the issues associated with the open White findings that resulted in Perry being categorized in the

Multiple/Repetitive Degraded Cornerstone column of the NRC Action Matrix. Therefore, effective the date of this letter, March 2, 2007, all commitments documented in CAL 3-05-001, dated September 28, 2005, as well as the long-standing open White findings in the Mitigating

System cornerstone are closed. As a result, NRC oversight of Perry will be reduced to a level

consistent with the applicable column of the NRC Action Matrix absent the two long-standing

White findings in the Mitigating Systems cornerstone, which at this time is the Licensee

Response Column of the Action Matrix.

With regard to your request to close the open substantive cross-cutting issues in the human performance and problem identification and resolution areas, as discussed in our 2006 Perry

Annual Assessment Letter dated March 2, 2007, we have determined that as a result of your

effective implementation of the CAL and PII effo rts, that the number and significance of human performance and problem identification and resolution related findings have declined

measurably. Therefore, as discussed in the 2006 Perry Annual Assessment Letter, we have

concluded that the substantive cross-cutting issues in the human performance and problem

identification and resolution areas can also be closed.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) co mponent of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/James L. Caldwell Regional Administrator Docket No. 50-440 License No. NPF-58 DISTRIBUTION:

See next pageDOCUMENT NAME:G:\PERR\PerryCALClosureLetterRev1.wpd G Publicly Available G Non-Publicly Available G Sensitive G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy*See previous concurrenceOFFICERIIIRIII/EICSRIIINRRRIII/RANAMEEDuncan*/klgGShear*MSatoriusJDyerJCaldwellDATE2/21/072/21/072/22/072/24/073/02/07 OFFICIAL RECORD COPY L. Pearce-4-cc:J. Hagan, President and Chief Nuclear Officer - FENOC J. Lash, Senior Vice President of Operations - FENOC

D. Pace, Senior Vice President, Fleet Engineering - FENOC

J. Rinckel, Vice President, Fleet Oversight

R. Anderson, Vice President, Nuclear Support

Director, Fleet Regulatory Affairs

Manager, Fleet Licensing

Manager, Site Regulatory Compliance

D. Jenkins, Attorney, FirstEnergy

Public Utilities Commission of Ohio

Ohio State Liaison Officer

R. Owen, Ohio Department of Health

President, Geauga County Board

Director, Department of Emergency Services

Geauga County Sheriff

President, Ashtabula County Board of Commissioners

Ashtabula County Sheriff

Director, Ashtabula County Emergency

Management Agency

Mayor, Village of Genoa

Genoa Village Administrator

President, Lake County Board of Commissioners

Lake County Sheriff

Painesville City Manager

Lake County Administrator

Director, Lake County Emergency Management Agency

President, Village of Fairport Harbor

Mayor, City of Eastlake

Mayor, City of Wickliffe

President, Geneva City Council

City Manager, Geneva

Mayor, City of Kirtland

Mayor, City of Mentor

City Manager, Mentor

Mayor, City of Mentor on the Lake

Administrative Director

Mayor, City of Willoughby Hills

Mayor, City of Willoughby

Mayor, City of Willowick

Mayor, Village of Madison

Village Administrator, Village of Madison

Chairman, Board of Madison Township Trustees

Mayor, Village of Kirtland Hills

Mayor, Village of Geneva-on-the-Lake

Mayor, Lakeline Village

Mayor, Village of Timberlake

Mayor, Village of Grand River

INPO L. Pearce DISTRIBUTION

ADAMS (PARS)

SECY OCA L. Reyes, EDO

W. Kane, DEDR

C. Carpenter, OE

D. Solorio, OE

D. Starkey, OE

J. Caldwell, RIII

G. Grant, RIII

L. Chandler, OGC

B. Jones, OGC

J. Dyer, NRR

D. Holody, Enforcement Officer, RI

C. Evans, Enforcement Officer, RII

G. Shear, Enforcement Officer (Acting), RIII

K. Fuller, Enforcement Officer, RIV

R. Pascarelli, Enforcement Coordinator, NRR

E. Brenner, OPA

H. Bell, OIG

G. Caputo, OI

J. Schlueter, OSTP

V. Mitlyng, RIII:PA

R. Lickus, RIII

J. Lynch, RIII

S. Minnick, RIII

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MEF1 CAA1 DRPIII DRSIII PLB1 TXN