IR 05000440/1985033

Insp Rept 50-440/85-33 on 850603-0708.Violation Noted: Failure to Properly Document Matl Control in Reactor Vessel Area

ML20133F346
Person / Time
Site:	Perry
Issue date:	08/02/1985
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133F333	List: IR 05000440/1985033 IR 05000603/2007008 ML20133F330
References
TASK-2.K.3.13, TASK-2.K.3.15, TASK-TM 50-440-85-33, NUDOCS 8508080249
Download: ML20133F346 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/85033(DRP)

Docket No. 50-440 License No. CPPR-148 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000

1. - ' Cleveland, OH 44101-Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, OH Inspection Conducted: June 3 through July 8, 1985 Inspectors: J. A. Grobe J. P. Brown, J Approved By: R. C. Knop, Ch f Reactor Projects Section 1C Date Inspection Summary Inspection on June 3 through July 8, 1985 (Report No. 50-440/85033(DRP))-

Areas Inspected: Routine unannounced inspection by resident inspectors of licensing review followup items, integrated design inspection followup items, safety evaluation report followup items, comparison of as-built plant to Final Safety Analysis Report description, preoperational test program implementation, safety committee activity, station battery operation and maintenance, technical specification review, operating procedures review, and residual heat removal system preoperational test witnessing. The inspection involved a total of 159 inspector-hours onsite by two NRC inspectors including

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26 inspector-hours onsite during off-shift Results: Of the 10 areas inspected, no violations were identified in nine areas; one violation was identified in the remaining area (failure to properly document material control in the reactor vessel area - Paragraph 11). No significant safety issues were identifie M$NE4o PDR

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DETAILS Persons Contacted

• D. Lyster, Manager, Perry Plant Operations Department

• J. J. Waldron, Manager, Perry Plant Technical Department

• C. M. Shuster, Manager, Quality Assurance Department

• F. R. Stead, Manager, Nuclear Engineering Department

• J. H. Bellack, General Supervising Engineer, Nuclear Design and Analysis l Section i

• R. Leidich, General Supervising Engineer, Nuclear Test Section

• K. 9. Pech, General Supervising Engineer, Nuclear Construction Engineering Section

• B. D. Walrath, General Supervising Engineer, Operational Quality Section

• E. Riley, General Supervising Engineer, Construction Quality Section The inspectors also contacted numerous other applicant representatives during the inspection perio * Denotes those persons attending one or more of the exit interviews conducted throughout the inspection period and on July 3, 198 . Licensing Review Followup Inspection Items The Office of Nuclear Reactor Regulation, Division of Systems Integration, Instrumentation and Control Systems Branch (ICSB), has requested that Region III inspectors follow up on the applicant's activities in certain areas identified in a report transmitted on May 31, 1985, documenting a site review by ICSB personnel. Each of the items requiring inspection have been assigned an open item tracking number as listed belo Additionally, the ICSB Trip Report reference section is noted in parenthesis, (0 pen) Open Inspection Item (440/85033-01(DRP)): Verify that Division 3 ATWS cabling is routed in separate conduits from the Division 3 HPCS cabling (ICSB Trip Report, Section 2.d). (0 pen) Open Inspection Item (440/85033-02(DRP)): Verify that Division 2 cabling is not physically touching Division 1 cabling and is in conduit that provides at least 1 inch air space in panel H13-P69 The reverse is true for panel H13-P92 (ICSB Trip Report, Section 1.b). (0 pen) Open Inspection Item (440/85033-03(DRP)): Verify that cover plate on cell 13-15 has been installed as specified in the control '

room cable routing diagram (ICSB Trip Report, Section 1.e). (0 pen) Open Inspection Item (440/85033-04(DRP)): Verify that all nomenclature for the Low Pressure Core Spray and Residual Heat Removal System injection valve pressure permissive instrumentation is correct (ICSB Trip Report, Section 3.f).

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. (0 pen) Open Inspection Item (440/85033-05(DRP)): Verify that all nomenclature for equipment associated with the outboard main steam isolation valves is correct (ICSB Trip Report, Section 3.g.2). (0 pen) Open Inspection Item (440/85033-06(DRP)): Verify that the location of the Class 1E and non-Class 1E boundary for the Reactor Protection System motor generator set control system is located at the EPA In addition, verify the location of the divisional and non-divisional boundary for the RPS MG set control system (ICSB Trip-Report, Section 3.b). (0 pen) Open Inspection Item (440/85033-07(DRP)): Verify that heat

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tracing has been installed on the safety related sensing lines located in the outdoor bunker that is adjacent to the condensate storage tank (ICS8 Trip Report, Section.4.a). Integrated Design Inspection Followup Inspection Items The Office of Inspection and Enforcement has requested that Region III inspectors follow up on the applicant's action in response to two outstanding issues that resulted from the Integrated Design Inspection (IDI) documented in Report No. 440/84029 issued December 12, 198 The items requiring inspection have been assigned an open item tracking system number as listed below. Additionally the IDI report reference item number is listed in parenthesi (0 pen) Open Inspection Item (440/85033-08(DRP)): Verify that the waterhammer loads from various emergency service water system pump start /stop sequences do not exceed the design of the system supports and restraints (IDI Deficiency No. 02.1.3). (0 pen) Open Inspection Item (440/85033-09(DRP)): Verify that the emergency service water system pumps do not exhibit antirotation following pump trip (IDI Deficiency No. D2.1-6). Safety Evaluation Report Followup Inspection Items The Office of Nuclear Reactor Regulation, Division of Licensing, has requested that Region III inspectors confirm that the applicant has acceptably implemented two additional Three Mile Island (TMI) action items as described in the Safety Evaluation Report (SER) .for PNPP, Unit 1 1 (NUREG 0887 with Supplements 1 through 6). The items requiring inspection have been assigned an open item tracking system number as listed belo Additionally, the SER reference section is noted in parenthesi (0 pen) Open Inspection Item (440/85033-10(DRP)): TMI Item II.K.3.13; Verify that the applicant has modified the reactor core isolation cooling system (RCIC) to provide automatic restart on a low reactor water level signal (5.4.1). (0 pen) Open Inspection Item (440/85033-11(DRP)): TMI Item II.K.3.15; Verify that a time delay relay has been installed in the RCIC system isolation logic from the pressure instruments used to sense excessively high steam flow / steam supply line break (5.4.1).

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. Comparison of As Built Plant to Final Safety Analysis Report (FSAR)

Description (37301)

The inspector examined the Division I Standby Diesel Generator Starting Air System (DGSA), the High Pressere Core Spray System (HPCS), the Reactor Core Isolation Cooling System (RCIC), and the Standby Liquid Control System (SLCS) to verify that the as built mechanical configuration of the systems is as described in the controlled facility drawings including posted design change documents. As noted in Inspection Report No. 50-440/85022, the FSAR drawings will be updated at a later date prior to licensing (Reference: Open Item No. 440/85022-46). The inspector examined the following piping and instrumentation diagrams (P&ID)

including posted Engineering Change Notices (ECN) for those systems:

. D-302-351, Revision G, " Standby Diesel Generator Starting Air"

. D-302-701, Revision K, "High Pressure Core Spray System"

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. D-302-631, Revision E, " Reactor Core Isolation Cooling System"

. D-302-632, Revision F, " Reactor Core Isolation Cooling System"

. D-302-691, Revision D, " Standby Liquid Control System"

. D-302-692, Revision D, " Standby Liquid Control System" The inspector used the site controlled P&ID and walked down the system to verify as built configuratio Several discrepancies were observed as

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noted belcw:

i System Discrepancy Item Type

, DGSA Permanent plant equipment identification tags Open were missing from the starting air admission valves (F010A, F015A, F020A, F025A), the air dryers (D001A, D002A), and one aftercooler (B002A).

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l HPCS Piping size is incorrectly indicated downstream Open

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of valve F506.

l -Valve IE22-F530 is labelled IE31-F47 Open

Temperature test point R040 is labelled WO4 Open Two valves did not have permanent plant identi- Open fication tags (F005 and F527).

, RCIC Six valves were missing permanent identification Open i tags (F563, F010, F076, F063, F005, and F004).

! Valve F533 bears blue test jurisdictional tag Open i F053 and is not shown on the P&lD.

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System Discrepancy Item Type Drain pot level sensor NO37 has incorrect blue Open test jurisdictional ta Turbine exhaust steam line drain pot piping is Unresolved incorrectly shown on P&I Valve F534 not shown on P&I Unresolved SLCS Pumps C001B and C002B did not have a perman- Open ent identification ta Temperature switches N405 and N003 and tempera- Open ture element N006 did not have permanent identification tag Valve F550 did not have a permanent identifi- Open cation ta These discrepancies will be followed up under either unresolved item 440/85033-12(DRP) or open inspection item 440/85033-13(DRP), as applicabl In addition to as built verification of those mechanical systems, the inspector examined the as built configuration of the Division 1, 2, and 3 essential DC electrical power systems. The inspector examined the-following electrical one line diagrams and compared them to the field installed systems:

. 0-206-050, Revision L, " Class 1E DC System - Division 3"

. 0-206-051, Revision P, " Class 1E DC System" No discrepancies were noted during the field inspection of those electrical power system During all of these as built verifications, the inspector noted that permanent identification tags are only being placed on equipment included in valve lineup and electrical lineup instructions. This policy results in check valves, strainers, flow elements, orifices and various sensors being unlabeled. The inspector believes that this approach may be short sighted and that proper implementation of operations and maintenance activities may be assured with a more complete tagging program. The concern will be followed as an open item 440/85033-14(DRP).

While unresolved and open items have been identified for later resolution, no violations or deviations were currently identified in this are . Preoperational Test Program Implementation Verification (71302)

The inspector observed control room operation and test coordination, reviewed applicable logbooks and conducted discussions with control room operators and test personnel during the inspection period to ensure that

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test activities were being conducted in accordance with regulatory requirements and facility procedures. Tours of the Unit 1 reactor building, intermediate building, Unit 1 auxiliary building, fuel handling building, control complex, and diesel generator building were conducted to observe test and maintenance work in progress, area housekeeping, equipment condition, and system cleanliness. The inspector also reviewed the minutes from Test Program Review Committee (TPRC) meetings No. 410 through 414, 416, 417, 421, and 425 conducted during this inspection period to verify conformance with Nuclear Test Section procedure No violations or deviations were identified in this are . Safety Committee Activity (40301)

The inspector attended Plant Operations Review Committee (PORC) meeting No. 85-49 and reviewed the minutes of meetings No. 85-43 through 85-53 conducted during the inspection period to verify conformance with PNPP procedures and regulatory requirements. The observations and examinations included PORC membership and qualifications, quorum at PORC meetings, and PORC activitie No violations or deviations were identified in this are . Station Battery Operation and Maintenance - Regional Request and Procedure Review (92705, 42450, 42452)

By memorandum dated March 25, 1985, from C. E. Norelius, the regional office requested that an inspection of battery operation and maintenance practices be performed specifically addressing certain problematic areas:

. Specific gravity correction for temperature and level

. Battery charging records

. Capacity testing methodology

. Equalizing charging procedures

. Routine surveillance prerequisites

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. Routine surveillance corrective actions

. Battery rack and cell installation i The applicant uses calcium flat plate type GC Exide batteries for the Class 1E DC electrical power source. The inspector examined the vendor's manuals and the applicant's maintenance, curveillance, and operating instructions:

. PMI-I-0024, Revision 3 " Plant Batteries Inspection and i Maintenance" 501-R42, Revision 1 "0C Systems: Batteries, Chargers, f .

Switchboards"

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. SVI-R42-T5202, Revision 0 "125V Batteries and Chargers - Cat A Limits"

. SVI-R42-T5211, Revision 0 " Division 1 Battery Capacity Service Test"

. SVI-R42-T5212, Revision 0 " Division 2 Battery Capacity Lervice Test"

. SVI-R42-T5215, Revision 0 " Division 1 Battery Service Test"

. SVI-R42-T5216, Revision 0 " Division 2 Battery Service Test"

. ELI-R42, Revision 0 "0C Systems: Batteries, Chargers, Switchboards (Unit 1)"

The inspector examined those procedures for the attributes of the referenced regional request as well as compliance with Regulatory Guide 1.129, Revision 1, " Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," and IEEE 450, " Recommended Practice for Maintenance, Testing and replacement of Large Lead Storage Batteries for Generating Stations and Substations," Revisions 1972, 1975 and 198 The applicant's battery naintenance and testing program contained the attributes referenced in the regional request. However, PMI-I-0024 contained all of the routine inspection requirements regardless of their periodicity. This could cause confusion when implementing the instruction. The applicant indicated that those routine activities would be broken into eight separate surveillance instructions. When those instructions are written, the inspector will review them for adequac This will be tracked as an open inspection item 440/85033-15(DRP).

The inspector visually inspected the Class IE battery banks and observed

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Operations Section personnel perform the routine battery surveillance and preventive maintenanc No discrepancies were note The inspector examined the applicant's commitments in various sections of the Final Safety Analysis Report (FSAR) with respect to battery maintenance and testing. FSAR Table 1.8, when discussing Regulatory Guide 1.129, states that the applicant will implement IEEE 450-1975. FSAR Table 8.1-2 states that IEEE 450-1980 will be implemented. Also in FSAR Table 8.1-2, the applicant commits to implement NRC Branch Technical Position ICSB 6 which references IEEE 450-1972. The inspector brought these conflicting commitments to the attention of the NRC Office of Nuclear Reactor Regulation (NRR) by memorandum from C. E. Norelius to H. L. Thompson dated June 20, 1985. Resolution of this issue will.be tracked under open

, inspection item 440/85033-16(DRP).

The inspector examined the applicant's service and performance (capacity)

testing procedures and compared those procedures to IEEE 450-1975 and 198 The inspector is concerned that the results of testing performed in accordance with applicant's proposed procedures, which include

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• A performance of an equalizing charge and routine preventive maintenance prior to the tests, will not properly reflect the standby readiness of

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the batteries. This practice is in direct conflict with IEEE 450-1975, Sections 4.2, 4.3, 5.1 and 5.6 which define the limitations placed on i testing initial condition However, IEEE 450-1980 is not as clear on this issu .

In addition to the conflicting IEEE standard commitments issue, the inspector also brought this technical concern to the attention of NRR in that memorandum dated June 20, 1985. Resolution of this concern will also be tracked under open inspection item 440/85033-17(DRP).

The inspector examined battery, charger and switchboard electrical lineup instruction (ELI)-R42, Revision 0, and noted three potential discrepancies:

, . 125 Volt DC Motor Control Center E01809 (1R42-5038) is not addressed in the EL . The function of Switch Nos. 16 and 18 on 125 Volt DC distribution panel EDIA06 (IR42-S012) were reversed by Engineering Change Notice (ECN) 21468-33-3516, Revision A, but this change was not reflected in the EL . The function of Switch No. 3 on 125 Volt DC distribution panel ED1808 (IR42-5014) was changed from " spare" to "PNLIC61-P001" by ECN s 23296-33-3947, Revision E, but this change was not reflected in the EL The resolution of these three potential discrepancies will be tracked as unresolved item 440/85033-18(DRP).

While unresolved and open items have been identified for later resolution, no violations or deviations were currently identified in this are . Technical Specification Review (71301)

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The inspector examined Technical Specifications Section 3.3.2, " Isolation Actuation Instrumentation," Section 3.3.3, " Emergency Core Cooling System Actuation Instrumentation," and Section 3.3.4, " Recirculation Pump Trip Actuation Instrumentation." The inspector noted that each of these specifications requires in the limiting condition for operation (LCO)

that the instrumentation be operable with its trip setpoint set consistent with the trip setpoint value in the specification. The LC0 tction Statement requires that the instrument be declared inoperable if the setpoint is found to be less conservative than the allowabie value in the specification. Consequently, the requirement for the trir setpoint to be at the specified trip setpoint value is not enforceable. The inspector is discussing this issue with the applicant and NRR personnel on its own merit and in conjunction with the ongoing generic analysis of setpoint

,, methodology. Resolution of this concern will be tracked as open inspection

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item 440/85033-19(DRP).

l l No violations or deviations were identified in this are .

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10. Operating Procedures Review (42450)

The inspector examined the valve lineup instruction for the Division 1 diesel generator starting air system, VLI-R44-1, Revision 0, issued April 6, 1984, utilizing the information on the piping and instrumenta-tion diagram (P&ID) for that system, D-302-351, Revision G, issued November 10, 198 The following discrepancies were noted:

Valve Number P&ID Indication VLI Indication F517A Open Closed F563A Locked Open Open F562A Locked Open Open The resolution of these discrepancies will be tracked as unresolved item 440/85033-20(DRP).

While an unresolved itm was identified for later resolution, no violations or deviations were currently identified in this are . Residual Heat Removal (RHR) System Preoperational Test Witnessing (70315)

The inspector witnessed the performance of Step 6.6.9, "FHR Integrated LPCI (Low Pressure Coolant System) Verification," in the RHR preopera-tional test TP-1E12-P001, Revision 1. The inspector fje.1d verified that prerequisites 6.6.1(a)(1), 6.6.1(f), and 6.6.9(a)(2), (3), (5), (6) and (7) had been completed. The inspector verified that four stopwatches, L70R833K and L70R834 F, K and L, which were used for data collection were within their calibration period The inspector verified that RHR pumps A, B, and C flow meters, 1E12R603A, B, and C, which were used for data collection were within their calibration periods. The inspector verified that the acceptance criteria for individual pump flows, integrated LPCI flow injection valve stroke time and full flow time were satisfie During the course of verifying prerequisites for this test the inspector encountered two problems:

. One of the prerequisites required that the main steam isolation valves (MSIVs) be isolated and danger tagge This was accomplished by tagging out the air supply valves in the field for the MSIV' Consequently, while the MSIVs were out of service and inoperable, there was no indication in the control room on the control panel of this situation. The applicant is reviewing their practices for use of red " danger" switch caps in the control room to encompass this situation. This issue will be tracked as open item 440/85033-21(DRP).

. During a tour of the reactor building on June 22, 1985, the inspector noted that while the reactor vessel and B pool had been evacuated and flooded, many of the items on the tool / material inventory log had not been logged out of the vessel. Following subsequent investigation, the inspector found that all materials had

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been removed and not logged out and that the controls implementing the logbook were issued by memorandum and not proceduralized. These are both violations of the requirements to have procedures controlling activities affecting quality and following those procedures (440/85033-22(DRP)).

One open item and one violation were identified in this are . Open Inspection Items Open inspection items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. Open inspection items disclosed during the inspection are discussed in Paragraphs 2, 3, 4, 5, 8, 9 and 1 . Unresolved Inspection Items Unresolved items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or the applicant or bot Unresolved items disclosed during the inspection are discussed in Paragraphs 5, 8 and 1 . Exit Interviews (30703)

The inspectors met with applicant representatives denoted in Paragraph 1 throughout the inspection and at the conclusion of the in;pection period on July 3, 1985. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection repor The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur