IR 05000440/1986006

Insp Rept 50-440/86-06 on 851230-860303.Violations Noted: Inadequate Instructions for Sys Operation,Inadequate Procedural Control safety-related Maint Activity & Failure to Implement Housekeeping/Cleanliness Controls

ML20154R630
Person / Time
Site:	Perry
Issue date:	03/24/1986
From:	Dave Hills, Knop R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154R621	List: IR 05000440/1986006 ML20154R619 ML20154R625
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-TM 50-440-86-06, 50-440-86-6, NUDOCS 8603310112
Download: ML20154R630 (36)

Text

__ _ _ . _ _

,

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/86006(DRP)

Docket No. 50-440 Lice nse No. CPPR-148-Licensee: Cleveland Electric Illuminating Company Post' Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, OH Inspection Conducted: December 30, 1985 through March 3, 1986

- Inspectors: J. A. Grobe

K. A. Connaughton J. W. McCormick-Barger ( ,17 . Uf 1 J. M. Ulie

6.e.C/L D. E. Hills Approved By:

1. Fc #Q R. C. Knop, Chief M0 Reactor Projects Date Section 1B Inspection Summary Inspection on December 30, 1985, through March 3, 1986 (Report No.50-440/86006(ORP))

Areas Inspected: Routine, unannounced inspection by resident.and region base inspectors of previous inspection items, TMI Action Plan items,10 CFR 50.55(e)

. items, reg'onal requests, ;ystem operating instructions, housekeeping, seismic event of January 31, 1986, Confirmatory Action Letters, Generic Letters,

'

8603310112 860324 PDR ADOCK 05000440-G PDR

, I

.. - _ . -- =. - . --. - - - . _ - - - .- _

.

o i

r- .

L

'

emergency procedures, operational readiness,. ENS phone operability, maintenance, surveillance testing, operating staff training, safety committee activities, allegations, an Information Notice, ar.d a management meeting. .This inspection involved a total'of 414 inspector-hours onsite by five NRC inspectors including ~

l

~

70 inspector-hours during off-shift .

.

Results: Of the nineteen areas inspected, one. violation was identified with one example in each of two areas (inadequate instructions for systems operation, Paragraph 7, and inadequate procedural control of a safety related. maintenance activity, Paragraph 15c) and one violation was identified in one other area-(failure to adequately specify and implement housekeeping / Cleanliness Controls,

,

Paragraph 8).

l .

On January 31, 1986, the facility was subjected to a seismic event.

'

Resident and project inspector followup verified that well. coordinated and controlled actions were executed by the applicant to. preserve event data and to detect an damage that may have resulted from the even Inspector identified deficiencies .

in System Operating Instructions resulted in a program of re-review ty the applicant to~ ensure technical adequacy. Inspector concerns relating to~

implementation of operating administrative controls resulte'd.in augmented management overview of personnel training and administrative controls implementation. On January 30, 1986, NRC Commissioner Bernthal toured the Perry facility.

I i

l

.

. .. .- - - . - _ _ _ . . . -. -- _ - _ _ _ . _

,

o i

,

1 DETAILS- Persons Contacted

. M. R. Edelman,.Vice President, Nuclear Group

,

A. Kaplan, Vice President, Nuclear Operations Division L .1 C. M. Shuster, Manager, Nuclear Quality Assurance Department (NQAD)

'

12 M. D. Lyster, Manager, Perry Plant Operations Department (PPOD)

12 R. A. Stratman, General Supervising Engineer, Operations Section, PPOD' '

.2 J. J. Waldron, Manager, Perry Plant Technical Department (PPTO)-

';

2 S. F.' Kensicki, Technical Superintendent, PPTD 2 R. L. Vondrasek, General Supervising Engineer, Reliability and Design

.

i . Assurance Section, Nuclear Engineering Dep'artment 2 R. P. Jadgchew, General Supervising Engineer, Instrumentation and j Controls.Section, PPTD . .

2 B. D. Walrath, General Supervising Engineer, Operational Quality *

Section, NQAD

,

12 A. F. Silakoski, Operations Section, Senior Engineer, PP0D 1 1 D. J. Takas, General Supervisor, Maintenance-Section, PP00~

,

1- T. A. Boss, Supervisor, Quality. Audit. Unit,-NQAD-1 2 P. A. Russ, Compliance Engineer, PPTD j 1 2 T. L.'Heatherly, Operations Engineer, PPTD 2 Denotes those persons attending an . interim exit meeting held on j February 17, 1986.

,

2 Denotes those attending the exit meeting held on March 3, 1986.

" Other plant staff personnel were also contacted during the inspection'

period.

f~ Applicant Action on Previous Inspection Items (92701, 92702)

~ (Closed) Open Inspection' Item (440/85053-07(DRS)): Complete review

'

,

_of~ administrative control _s for preoperational testing conducted after j fuel load, following applicant approval of implementing procedures.

'

As noted-in Inspection Report No. 440/85081(DRS),;the inspector had previously. conducted a preliminary review of this subject area. .The

< Linspector has now completed a review of. Revision 0 to PAP-0113,

" Nuclear Test-Section Organization.and Responsibilities,".and has no

, further concerns in this area.

j 1-

- (Closed) Open' Inspection Item.(440/85074-01(DRS)): Inoperable fire

. doors due to latching mechanism problems. During:a previous

inspection the

inspector walked down 52 fire doors to~ verify door F operability and found 4 doors that would not latc These' doors were

,

numbered Control Complex.(CC)-521,-CC-517, and Intermediate Building-(IB)-218'and 18-217. During this inspection ~ period the inspector

~

i

'

' walked down those 4 fire. doors and verified proper operability of the i

'

doors. Strengthened closure mechanisms were added.to the Control Complex doors to' overcome heating,fventilating_and air conditioning i

l-

[ 3

_ - _ _ , _ __ ___ . _ _ . . _ . . . . . . . . - - . _

- . . . . . . - . _ .__ . _ _ . _ _ . _ _ _ _ _ _ . _

i 'l

a l

i . .

system pressure imbalances. 'The Intermediate Building doors'had the

~

!

j latching mechanisms repaired and were properly functioning. The

! inspector verified that routine inspections'for. operability of the 4 doors are performe The inspector has no further concerns in this  ;

d area.

. (Closed) Open Inspection Item (440/85078-01(DRP)): Independent.

,~

verification practices not in accordance with Plant Administrative Procedure (PAP)-0205. This item was initiated because independent i verifications using remote indicators were observed to be performed using the same remote indicator.for both.the independent verification .

~

hs well as the original. valve position-verificatio PAP-0205 at that  :

'

time required that independent remote indicators be utilized for those independent position. verification Those procedural requirements 1 were conservative. The. inspector reviewed Revision 3 to PAP-0205,

. effective' February 3, 1986, which among other things,-modified Section 6.5.3 of the procedur Section 6.5.3 now permits that the

. observation of associated. electrical position indicators.may be used

! as both the original and independent verifications for the same piece

of equipment. The inspector has no further concerns in~this are (Closed) Unresolved Item (440/85059-0?(DRP))

Resolution of Incomplete Procedural Items. On February 25, 1986,- the applicant reported that all incomplete procedural items (excluding startup test

'

instructions) had been identified, tracked, and/or resolved by either i incorporating the required information into affected procedures /-

! instructions or obtaining review.and approval'of the Plant Operations

Review Committee (PORC) for deferring incorporation of the items  ;

,

beyond fuel loa Responsibility for tracking resolution.of deferred

-

items and deferral milestones had been assigned in writing.- The  ;

>

inspector selected the following procedures and performed a cursory t review to identify whether or not incomplete items still remained and, l~ if so, whether or not the items.had been identified, reviewed, and approv'ed by h1RC for deferred incorporation.

! Plat.t Administrative Procedures (PAPS)~

!

, PAP 1115 " Snubber Augmented Visual Inservice i

Inspection / Examination and Functional Testing Program" i

, PAP 1201 " Control and Calibration.of Measuring and Test Equipment".

'

PAP 1304 " Radioactive Shipment Criteria"'

PAP'1305 " Shipment of Limited Quantity Radioactive ,

~ Material" l PAP.130 " Shipment of Radioactive Waste for Disposal"

PAP 1501- " Perry Plant Department Nonconformance Control"

,

'

.

.;-- m . ~ - s -

.- 4 ,, ,_ - _ u_ _ 4 , . - - . . , , -- _g, ,~, - , , _

.

1~ i

_l

'

l i

'

'

Radiological Administrative Procedures (RAPS) -I RAP 1101 " Chemistry Sampling Frequency and Analysis Program"

'

RAP 1102 "10 CFR 61 Compliance'Samp?ing" RAP 1703 " Radiological Trend Analysis" ,

Operating Administrative Procedures (OAPs)

OAP 0201 " Interface with System Operations Center" 0AP 0216 " Operations Section Lock and Key Control Program" OAP 0506 " Preparation of Alarm Response Instructions" ,

I OAP 1702 "

Operations Section Rounds Sheets, Logs and Records" Surveillance Instructions (SVIs_),

-

SVI B21-T9415 " Type C Local Leak Rate Test of B21 Penetration P415" SVI B33-T5263 "Special Test Exception ' Recirculation Loops" SVI B33-T5433 "APRM/IPRM Neutron Flux Noise Level Determination" SVI.C11-T0044 "SDV Water Level High Channel D Functional For 1C11-N601D" i The inspector's review did not disclose.any incomplete items which had yet to be identified and resolve (Closed) Open Inspection Item'(440/85078-03(DRP)): The NRC's review of System Operating Instructions (SOIs) and Valve Lineup Instructions (VLIs), documented in Inspection Report 440/85078, identified findings,.

both technical and administrative, that resulted in the applicant committing to perform a re-review and revision prior to use of all S0Is and VLIs.for systems. defined as safety-relatedLin PAP-0205. The inspector.'s review of these revised instructions is ' discussed in Paragraph 7 of this repor (Closed) Open Inspection Item-(440/85078-04(DRS)): As a result of the

~

licensing initiative.-directed at transferring the fire' protection

' program from the technical specifications into the FSAR, the .

,

previously evaluated technical; specification requirements needed to be i re-evaluated to verify adequate incorporation of.~those requirements 1 ' into Plant Administrative. Procedure (PAP)-1923,'" Actions on Inoperable Fire Protection Systems" and PAP-1921,;" Fire Barrier Removal."~ The

regional based fire protection inspector was'provided PAP-1923 and PAP-1921. 'These.are the two procedures that' incorporate the previous

- fire protection technical. specification requirement A comparison o the fire protection Standard Technical Specification (STS) requirements

to-PAP-1923 and PAP-1921 was performed, and it was determined by the

,

inspector that the procedures meet the intent of the=STS requirements.

~

i

'v -

, -, - -n. , s -a -w.- -r,; ~ , ,g -,a rr . -, , w 'm>

-- .. -. . . - . -- -

- . -

. _( Closed) Unresolved Item (440/85081-01(DRS)): Determine adequacy of

,

diesel generator consecutive start testing. As noted in Inspection Report No. 440/85081(DRS), consecutive starts conducted per preoperational test procedures TP1R43-P002 were not conducted from the

'

most conservative start conditions that might be expected ( minimum standby temperature conditions). In response to this concern,

NRR has provided clarification of regulatory and technical requirements

'

'as documented in the memorandum from R. M. Bernero.to C. J. Paperiello, l

,

dated January 24, 1986. This guidance indicates that the intent of i

! Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units As  !

Onsite Electric Power Systems at Nuclear Power Plants", Revision 1, is met as long as this testing is accomplished from start conditions l

!

within or below the manufacturer's recommended standby temperature .l rang In the case of Perry, this range corresponds to 140 F. to

180 F. There is no regulatory requirement that necessitates consecutive start testing to be conducted from the minimum. standby 'l temperature condition. This letter also stipulates that from technical '

,

F rationale, the temperat.ure variation within the manufacturer's recomended standby temperature range would not appreciably effect 1 engine start reliability. The NRR response concludes that "the-Perry '

1 EDG 69/n start tests have been acceptably' conducted by C.E.I. in.

j accordance with the intent of Position C.2.a.(9) of Regulatory j

Guide 1.108, and a repeat of any-of the tests performed will not be- a j necessary." Therefore, the inspector has no further concerns in this l

'

! area.

. (Closed) ' Unresolved Item (440/85081-02(DRS)): . Determine adequacy'of j the technical specification value for minimum diesel fuel oil storage i

tank capacity. As a result of the inspector's concerns, the. applicant )

has completed additional calculations as depicted in Design

'

=) l Verification Record (DVR) Assignment No. 919-86-1. These calculations- '

are based upon consumption rates projected from actual preoperational test data at the varying accident loads during a worst case seven day J

accident. In addition, the unusable portion of the storage tank volume is considered, as well as the incorporation of a ten percent

~

] ,

> conservative buffer. These results indicate a minimum storage tank

"

volume of 66,964 gallons which is well.within the technical

~ specification value of 69,430 gallons. Furthermore, the inspector has

,

~

consulted with Bob Giardina of the Office of Nuclear Reactor Regulation (NRR) who has concurred on.the. adequacy of the' technical specification value. Therefore, the inspector has no further concerns-l in this are r (Closed) Violation (440/85081-03(DRS)): Res_olutions of failures to meet acceptance criteria in preoperational test procedure results i

represent inadequate documentation and evaluation to assure that' tes '

requirements have been satisfied. As noted in Inspection Report j

.

No. 440/85081(DRS), the applicant generated Field Change . Request 116 )

in response to the inspector's concerns involving acceptance of the Reactor Protection System (RPS) Motor-Generator _(MG) Set underfrequency

trip test results. The inspector reviewed this. document and

considered it sufficient justification to resolve.the test exceptio In regard to the inspector's concerns over the justification for i

!

,

12'

!

.-- ,_ . . - , . . - .

- - , . . , , . - . . - - , . - , . - . - - . . - - - - - . . -- - -

- _ _ _ _ _ _ . _ _ _ . - _

_ _ - _ _ _ _ _ _ _

.

.

acceptance of the upper pool to suppression pool dump times, the applicant has now generated calculations depicted in Field Change Request 1360. The inspector has also reviewed this document and considers it sufficient justification to resolve the test exceptio However, the inspector noted that in order to show that minimum suppression pool vent submergence is maintained, these calculations depend upor, design assumptions that differ from those currently depicted in the Perry Final Safety Analysis Report. In particular, these calculations use the Emergency Core Cooling System (ECCS) runout flowrate determined from preoperational testing, which is less conservative than the design value used in the FSAR analysis. In addition, these calculations show that the available suppression pool volume for short term. temperature and pressure effects has been reuuced from that value depicted in the FSAR. The applicant has indicated that there are no plans to indicate this additional information to NRR through an FSAR amendmen This would preclude NRR from reviewing this additional information for adequate system design. The inspector has, therefore, informed John Stefano of NRR concerning these

~

discrepancies. In consideration of the remaining test exceptions that the inspector has reviewed and determined to be adequately dispositioned, the inspector has concluded that these examples of inadequately dispositioned test exceptions are isolated cases. In addition, following identification of these examples by the inspector, the applicant was able to generate additional rationale that provided adequate justification for acceptance. As a result, these example's appear to be of little safety significanc Based upon these considerations, the inspector believes that a generic problem with test results documentation and evaluation does not exist. Therefore, the inspector has no further concerns in this are (Closed) Open Inspection Item (440/86002-01(DRP)): As a result of the NRC's review of Integrated Operating Instructions (I0Is) and subsequent findings documented in Inspection Report 440/86002, the applicant committed to perform a 100% re-review of the.I0Is to assure that the information provided in them correctly reflected the latest technical specifications and supporting operating instruction The inspector performed a re-review of the revised I0Is to verify that previous inspector concerns, identified in Inspection Report No. 440/86002, were adequately addressec in the 10Is. The~ inspector also reviewed a. random sample of individual steps in the I0Is to assure t'n at-information and references to technical specifications were correct and that supporting operating instructions were appropriately referenced then required. The results of the inspector.'s review indicited that the applicant's re-review adequately resolved the inspector's concerns. This item is considered close . Foll'owup of'TMI Action Plen (NUREG-0737) Items (25401)

(Closed) TMI Item I.A.1.2.2.A Shift Manning. The inspecto.r determined by review of personnel wcrk schedules and discussions with applicant management and supervisory personnel that shift manning had been established in accordance with Plant Administrative Procedure (PAP)-0110,

_ _ _

- _ _ __ __ _ _ _ _ . _._.__ _ _ . - - . _ _ _ - - _ _ - - _ - -

-

'

i

.

" Shift Staffing." .The subject procedure was previously reviewed during i an inspection documented in NRC Inspection Report No. 440/85078 and j was found to meet the requirements of this-item. The inspector's review

included verification of. shift manning by licensed and non-licensed-i operators, radwaste technicians, health physics technicians, ca mistr technicians, and instrument and control technician . Licensee Actions on 10 CFR 50.55(e) Items (99020) >

'

(Closed) 10 CFR 50.55(e) Report (440/85007-EE)(DAR 226)): Applicant may not be in compliance with Appendix R due to lack of adequate separation of associated Division 1 and Division 2 circuitry. In NRC Inspection Report No.-50-440/85090, Open Inspection Item No. 440/85015-02(DRS) also addressed

]. .the concern of adequate separation of associated circuits. As discussed in

Report No. 85090, the applicant's modifications consisted of wrapping cable raceways, rerouting cables and conduits, installing / extending sprinkler

'

systems, and installing heat shield Based on the modifications and verification of these modifications, this item is considered close . Operating Procedures (42450)

During a review of Perry Integrated Operating Instructions (I0Is), the inspector selected various non routine technical specification surveillance

<

requirements and attempted to ascertain whether or not they had been i incorporated into the 10Is or other operating instructions. Technical

,

Specification 4.4.1.1.2 required that baseline APRM and selected-LPRM neutron flux noise values be established within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.of entering the j

power / flow region where total core flow is _less than 45% of' rated core flow

_

!

and THERMAL. POWER.is greater than the limit specified in Technical-Specification Figure 3.4.1.1-1 with both recirculation loops-in operatio ~

l' Integrated' Operating Instruction-3, " Power Changes", Revision 1, dated -

September 5,1985, specified the manner in which normal power- changes were to be accomplished by control rod movement and variation of core. flo Attachment 3 to the subject I0I,- " Power to Flow Operating Map", specifies-

{ allowable operating regions. Neither the t~e xt of the'I0I nor Attachment 3 i to the I0I specified the power / flow region of operation which required

!j entry into' Limiting Condition for Operation 3/4.4.1, " Recirculation l System-Recirculation Loops", and performance of the nonroutine surveillance required by-Specification 4.4.1. .The applicant instituted a. procedure

change to 10I-3, approved by the Plant Operating Review Committee on March 3, 1986, which resolved this matte ~

!

No violations of regulatory requirements or deviations-from commitments-i were identifie . Inspection in~ Response to Regional Requests (92705) A request from the Region III Division of Reactor. Projects was

,~

.' received by the inspector to review the applicant's administrative procedures that address control room staffing:and reactor operator!

supervision. -This inspection was to verify that an individual holding a. Senior Reactor Operators.(SRO) license is required to be in the -

!.

i-

-, - - . - . -- , . - . . , . . , - - , - - - . . . - , , . ~ . . . - , , . - . , , , - , - ,,....--;

__ - _ - _ - _ _

.

.-

control room during operations other than' cold shutdown and refueling and that the performance of all licensed activities is supervised by a " Senior Operator" holding an SR0 license, as specified in

,

10 CFR 50.54(m)(2)iii and 10 CFR 55.4 (d) and (e).

!

The inspector. performed a review of Plant Administrative

, Procedure (PAP)-0110, Revision 1, " Shift Staffing", which described the plant's minimum shift staffing requirements and qualifications of Shift Supervisors and Unit Supervisors. Shift Supervisors and Unit Supervisors are required to be NRC licensed Senior Reactor Operators (SRO).

As required by.the applicable sections of 10 CFR Parts 50 and.55, as listed above, the applicant's procedure stipulates that a licensed reactor operator is required to be at the controls while fuel is in the vessel and a licensed SR0 shall be in the control room at all times while the reactor is in operational conditions 1, 2 or 3 (conditions other than cold shutdown and refueling). The administra-tive procedure also requires that the supervisors of reactor operators be SR0 license The regional office was contacted by a concerned member of the general public who indicated that fuel was being handled by the applicant at the time of the seismic event on January 31, 1986. The individual further indicated that a fuel bundle was dropped because of the seismic acceleration and damaged and radioactive material was released to the environmen Immediately following the event, the inspector ensured that no fuel or source movement had been in progress through discussions with the shift supervisor and examination of the unit log in the control roo On February 3,1986, the inspector visually examined the fuel stored on the 620 foot elevation in the Fuel Handling Building (FHB) and on the 689 foot elevation in the Unit 1 Reactor Building (RB) and visually examined the radioactive startup sources. stored in the R The inspector verified that the fuel and sources were still in their pre-earthquake geometr The inspector reviewed the Unit 1 log and Fuel Movement Checklists and identified that the only fuel or scurce ,

movement during 1986 occurred between January 20 through 24, 1986, l (180 fuel-bundles and startup sources from FHB to RB) and on

'

l February 6, 1986, (sources loaded into reactor vessel). No fuel

'

movement or source movement was occurring at the time of'the earthquak i In addition, the inspector examined area radiation survey measurements,

~a irborne effluent radioanalysis and fuel pool water radioanalysis to determine if radioactive materials were released during or after the even Area radiation surveys made between 11:55 a.m. and 3:10 on January 31, 1986, of the Unit 1 Drywell,.RB, and FHB resulted in no measurable beta, gamma, or neutron radiation levels above backgroun Airborne effluent samples taken on the_ Unit 1 vent stack covering the period from January 27 through February 3,1986, showed no detectable

\

_-_

. , , . .. -

- _ _ _ - _ _ _ . _ ___ - . , . .. . .. -- -,

.

.

~

radioactivity above background. Fuel storage poo1 water analysis

. performed on samples taken at 1:00 p.m. on January ;31,1986, and at 1:40 a.m. ,10:50 a.m. and 7:05 p.m._ on February 1,1986, resulted in

,

no detectable radioactivity above~ background. No. radioactive materials were released to the environment as a result of the earthquake.

The inspector has no further concerns in this are No violations of regulatory requirements or' deviations from commitments were identified in this are . System Operating and Valve Lineup Instruction-Review (42450)

The inspector performed a detailed technical review of the following revised SOIs and VLIs to' ensure that the applicant's procedure improvement

program identified in Inspection Report No. 440/85078(DRP) adequately

resolved the concerns. The inspector employed the applicant's Operations Administrative Procedure (0AP)-0502, Revision 0, " Preparation of System

~

Operating Instructions", OAP-0503, Revision 1, " Preparation of Valve Lineup Instructions", and the applicable Piping and Instrumentation Diagrams

'

(P& ids) during the review.

l SOI-E21, Revision 3, " Low Pressure. Core Spray System (Unit 1)"~

VLI-E21, Revision 3, " Low Pressure Core Spray System (Unit 1)"

SOI-G33, Revision 2, " Reactor Water Cleanup System (Unit 1)"

, S0I-P47, Revision 2, ' Control Complex Chilled Water System"

! VLI-P47, Re'ision v 2, " Control. Complex Chilled Water System" i

i The inspector's' review of S0I-E21, " Low Pressur.e Core Spray" (LPCS),

resulted in_ identification of two cases where components _(pump and valve)

were mislabeled in the instruction. -In addition, Section 7.2- " Fill and- ,

Vent after System Outage", step 2,. instructed the operator to close LPCS

'

manual shutoff valve 1E21-F007,- but not lock it, as specified in theHVLI,

'

nor was-it verified to be locked on the verification checklist-in  :

. Attachment 3.to the 50I. ' Review of the associated VLI revealed no concern +

~d.'

The inspector's review of SOI-G33, " Reactor Water Cleanup System" (RWCU),

! identified the'following technical inadequacies:

• Section.4.2, " Hot Startup to Normal Recirculation Mode", instructs

. the operator to startup the RWCU. Pump A(B),~1G33-C001A(B) and establish flow of.at least 70 gpm within 30 seconds (to prevent a pump

<

trip), without instructing'the operator to open RWCU heat exchanger outlet throttle valve, IG33-F04 By not instructing the' operator to open this valve, starting the RWCU pump would result- in a pump trip since no other flow path was made available.

10 -

.

w -- -

, ._.a m., y , _ - - _ . ,- - , , _ . , - , . , . v w .y ....%.y . s

, . , .. - - .

't

1. i

?-

-

t 1

-

! * Section 5.2,'"RWCU Blowdown / Dump to the-Radwaste", instructs th ,

operator to line up a portion of-the system to achieve a flow path'to the Radwaste system. The instruction-did not include steps to open RWCU Blowdown Header Inboard and Outboard Isolation Valves 1G33-F028,

and 1G33-F034. Without opening these valves, blowdown to the Radwaste'

system could not occur.

l- * Section'7.4, "RWCU Temperature Control for Reduced Feedwater

[ Temperature," pro _vided. instructions to circumvent'the Regenerative Heat Exchanger Shell Side Bypass Valve, 1G33-F107, to. help reduce the

! temperature of the RWCU return flow to the Reactor Feedwater line. .In addition, the instruction directs the operator to open the RWCU-from~

, Vessel Drain Suction Valve, 1G33-F101, to max'imize flow from the lowe ; head region. However, the procedure does not provide instructions to l terminate this mode of operation and close valves 1G33-F107 and 1G33-F10 .

!

l * Section 7.5.4, "RWCU H'X Fill and Vent, Step 9,: requires the operat'or

, to open RWCU Filter /Demin Bypass Valve, 1G33-F044, to allow a flow

!

path around the Filter /Demin system during venting. .However, the Fill j and Vent instruction failed to provide an instruction to close the valve after venting. ; Valves 1G33-F100, F106, and F102, which are RWCU

! Inlet Isolation Valves, were also open during the venting activity and

$

not subsequently closed. Having the operator-leave these valves open, q in themselves, does not cause a system operation concern,'but'does

leave the system in a condition not reflected in other secti.ons of the

! procedure (e.g., s.tartup).

.

The inspector's review of S0I-P47, " Control Complex Chilled Water System" i (CCCW), identified the following technical concerns. Review of the i

associated VLI revealed no NRC concerns.

!

* .Section 5.3, " Shifting from.the A(B) CCCW Chiller to the.C CCCW l Chiller", Step 1.a. instructs the operator to " Shutdown the CCCW

[ Chiller A(B) and Chilled Water Pump A(B) to the Secured Status per i the Shutdown to Standby Readiness Section". However, Step 1.a. .

'

should have shutdown the system per the Shutdown to Secured Status Section. This error also-existed in Steps 5. ~

L .

.

• Section 5.4, "Shiftin~g from the.C CCCW Chiller to the A(B)2CCCW

'

Chiller",. Step 1.a.'and 1.b. directs the operator to Shutdown the A(B) Chiller and Pump and Startup the C Chiller and Pump.- The instruction should have directed the operator to do the opposite,

~

i that is,. shutdown C chiller and pump and startup the A(B) chiller

.

{ and pum ~

• Section 7.2, " Chemical Addition",. directs the operator t'o Shutdown the

!

A(B)' pump and chiller, which is safety related, and startup the C pumpi

and chiller, which is non-safety related.1in order to perform chemical l additions. However, the section does not instruct the. operator to'

1 return the system to the A(B) pump and chiller or referenc ;

chemistry instruction ~to be used to perform the chemical additio i i

_

'

11'

. - .- - - -- . - -- - - . -

_ _ _ _ . - _ _ _ _ - _ _

.

~

.

.

• Attachment 8 to the 50I is a verification checklist for Section 6.2, ,

,

" Shutdown to Secured Status". The checklist provided for independent-verification of "CCCW Chilled Water Pump C, P42-C001C, EF2805", to be

" Racked in" when it should have been verified " Racked out" and

"0N-STOP Keylock Switch" to be "On" when it should have been verified

"Stop".

• The inspector identified three examples where components were mislabeled in the attachments to the S0 The inspector's findings, identified above, indicated that althcugh-noticeable improvements in the S0Is and VLIs were obtained from the applicants re review program, the 501s appeared to be technically inadequate. This is considered a violation of 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings", in that some of the quality related activities, which were identified in the SOIs listed above, were not adequately prescribed by documented instructions (440/86006-01a(DRP)).

As a result of the inspector's findings, the applicant committed to perform a detailed technical review of all SOIs for systems defined as safety-related in in PAP-0205 prior to use under the operating license. This commitment was documented in a letter from Mr. Murray R. Edelm'a n, Vice President, Nuclear Group, CEI, to Mr. James G. Keppler, Regional Administrator, Region III, NRC, dated March 4, 198 ~

j 8. Housekeeping and Cleanliness Control Program (71302)

The inspector examined the adequacy and implementation of the facility housekeeping and cleanliness control program contained in Plant Administrative Procedure (PAP)-0204, Revision 1, " Housekeeping /Cleanline s Control Program", effective July 15, 1985, with two posted temporar changes, TCN-004, effective January 18, 1986, and TCN-005, effective January 13, 1986. The inspector. examined that procedure against the requirements.of Regulatory Guide 1.39, Revision 2,." Housekeeping Re~ quire-ments for Water Cooled Nuclear Power Plants", and ANSI N45.2.3-1973,

" Housekeeping Requirements During the Construction Phase of Nuclear Power l Plants". The applicant had committed, in FSAR Table 1.8-2, to comply with

'

those guidelines and standards pursuant to 10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program."

PAP-0204, Revision 1, Section 3,.specified the managers', supervisors' and employees' respective responsibilities for implementation of the progra Sectica 6.6.1 specified.that all plant areas shall be classified into one

>

of five housekeeping zones and that.all.in plant areas shall be classified as Zone IV unless designated'otherwise. With the exception of the normal work control processes requiring work planners to consider area' housekeeping classification changes during work activities, no individual or. organization was assigned the' responsibility to otherwise designate. area classification ANSI N45.2.3-1973, Section 3.2, requires that control of areas be established and maintained. Certain areas of the plant require, by the

~

_ -

,

.. .. . - . .- - . .. - .. .. . - .- _ _ _ _ _ _ _ _

T

'

!.

.

-nature of.the area, more restrictive housekeeping controls than Zone IV; for example, the fuel handling and storage areas inside the Fuel Handling

_

. ,

and Reactor Buildings and the suppression pool areas. The relaxed classification of the suppression pool area resulted'in foreign materials including coats and shirts being dropped.into the suppression pool.

$ In addition to this inspection, the applicant's Operational Quality i Section performed a surveillance of. housekeeping activities identifying

that housekeeping inspections were not being properly documented as l' required.by' ANSI N45.2.3-1973, Section 4. This finding was properly documented in Action Req'uest No. 0081 (File No. PSO' 0122) and adequate resolution had been identifie In addition to the'se procedural discrepancies, the inspector noted on numerous tours of the. facility during the inspection period, examples of failure to properly implement the procedure. As required.by-ANSI N45.2.3-1973, Section 3.4,' PAP-0204, Section 6.5,~ requires that tools, supplies and equipment not being used to support an ongoing task as evidenced by a current identification tag shall be removed from the Throughout the Unit 1 drywell and containment, equipment

'

facilit i including scaffolding, temporary power leads, ladders, and'a large i

portable bandsaw were observed by the inspector either without identification tags or with expired identification tag The inadequate procedural control over assigning area housekeeping zone requirements and failure to properly implement the equipment control l

'

aspects of. PAP-0204 represent examples of-a violation of 10 CFR 50,

Appendix B, Criterion II (440/86006-02(DRP)).- Followup on Significant Event That Occurred While

, Inspector was Onsite (93701)

At approximately 11:48 a.m. on January 31,:1986,- the inspectors noted ,

loud, deep rumbling sound and moderate vibration which lasted several i seconds in the Perry P.lant-service'ouilding. The inspectors immediately

'

proceeded to the control room to investigate and determine the cause of the 4 disturbance. Upon arriving at the control room, theLinspectors. observed

applicant personnel assessing plant status'and dispatching individuals to inspect various plant areas and structure The inspectors noted that'the

, seismic monitoring system.had alarmed and that preliminary observations by-applicant personnel had not disclosed any plant' conditions'that would have-accounted for the disturbance. Between 10 and 15' minutes following the-

! event and after concluding.that the facility had been subjected to a

[ seismic event, apr.licant personnel declared a." precautionary" Site Area j Emergency and employed the Perry Emergency Plan-to direct subsequent actions

'

as though the plan was in effect and that an actualLSite; Area Emergency had

been declare i

!

.

. ,,_s44m , , , , ,,,-,,,_,r..g- , , . - ,- r #-,-_v ., . , --r- - - -- ~'-

_ _ _-______ ___- __ _

.

.

The Emergency Action Level (EAL) of Site Area. Emergency was chosen based upon guidance contained in Emergency Plan Instruction (EPI)-A1, Attachment 2, which stated, in part, that an Alert shall be assigned for:

" Severe natural phenomena being experienced beyond " Unusual Event" levels."

including:

" Earthquake beyond operating basis earthquake (0BE) level (.075g) as detected by seismic instrument on H51-P021."

and that a Site Area Emergency shall be assigned for:

" Severe natural phenomena being experienced or projected with plant not in cold shutdown."

including:

" Earthquake above Safe Shutdown earthquake (SSE) levels (.15g)

detected on plant seismic instrumentation panel-H51-P021."

Seismic instrumentation on panel H51-P021 included lights which indicated for 12 discrete frequencies in each of three orthogonal directions whether

'

or not accelerations-in excess of either 70% of the OBE or 100% of the OBE building response spectra were detected. The setpoint values for these annunciators were frequency dependent and varied considerably from the

.075g and .15g peak ground accelerations (zero period accelerations)

derived for respective OBE and SSE design response spectra and which apparently were the referenced values in EPI-A The senior resident inspector remained in the control room after declaration of the precautionary Site Aret Emergency and observed shift activities. The inspector monitored contre room activities and communica-j tions in coordinating followup to the event and verified that inspections i

of the stored fuel and startup' sources were accomplished. The inspector noted congestion due to communicators at the-Unit Supervisor's Console. In response to this, following the event, the applicant extended the phone cords on the intra plant and local emergency phones and requested from NRC an extension on the Emergency Notification System phone cords. This should alleviate future congestion problem Upon declaration of the precautionary Site Area Emergency, the resident inspector proceeded to the Technical Support Center (TSC) and observed establishment of communications, staffing, TSC activation, transition of emergency response direction from the control. room to the TSC, updating of plant status information, downgrading of the event to an Alert at 1:02 p.m.,

and termination of the event at 2:25 The resident inspectors advised applicant personnel that all information

pertaining to the seismic event, including seismic monitoring instrumentation data, any abnormal or deficient conditions not posing an immediate hazard, and records of actions taken in response to the event,

.. .. - - - - -. - - - - _ _ _ _

s 6

.

. .

}

was to be preserved. The inspectors also informed'the' applicant that-a

~

.

'

Confirmation of Action Letter (CAL) providing additional-guidance on these and other matters would be forthcoming from Region III. sInspector followup 1 and confirmation of specific actions described in the CAL are discussed in i Paragraph 10 of this repor ;

The' inspectors made tours of general plant areas to determine whether or 4 not any structural or equipment damage directly. attributable to the seismic ,

'

l event was evident. The inspectors noted hairline cracks in certain'

reinforced concrete walls in the intermediate and auxiliary buildings'and what appeared to be several minor leaks from instrument tubing connections.

'

. These and other discrepancies noted by the. applicant were subsequently reviewed by an NRC Augmented Inspection Team during an inspection i documented in NRC Inspection Report No. 440/86005. .

i At 5:00 p.m. the senior resident inspector attended a recovery meeting

<

where a formal recovery organization was established addressing the areas of operations, maintenance, engineering, licensing, emergency planning, and 1 public relations. At approximately 6:10 p.m. _the inspector recei.ved facsimile transmission of CAL-RIII-86-01' confirming actions agreed upon by-

,

the applicant and Region III management. The inspector reviewed that CAL-

with the applicant to ensure mutual understanding of each item.

!

Subsequent to the earthquake the applicant revised EPI-Al and Off Normal

~ ~

Instruction (ONI)-D51, " Earthquake", through the . issuance of Temporary Change Notice (TCN)-004 and (TCN)-003,. respectively, to provide guidance i

for determination of the proper EAL utilizing indicators and instrumenta-

} tion available at the plant. The method for_ determining whether or not the OBE was exceeded, for use in establishing the EAL, is adequate. The method

'

l for determining whether or not the SSE was exceeded, for use in establishing ,

the EAL, is conservative; it still requires a comparison between zero period

'

ground acceleration limits and peak building acceleratio The applicant is undertaking long term corrective actions to refine the

<

SSE EAL determination process which may involve equipment modifications.

Th'e inspector will follow the applicant's lo'gn term corrective actions in

'

this area as an open item (440/86006-03(DRP))- .

~

i No violations of regulatory requirements or deviations from commitments were identified in'this~ are l

! -

-

-l 1 10. ' Confirmatory Action Letter Followup (92703).  ;

$ Background

'

Following.the seismic event on January 31, 1986, the NRC Region III Office issued a Confirmatory Action Letter-(CAL)-RIII-86-0 The CAL documented discussions between the applicant.and Region ~III management regarding. actions to be taken by the applicant in response to th seismic event. Followup on CAL-RIII-86-01 is documented in ~

Inspection Report No.- 50-440/8600 Following the NRC's Augmented

>

i-

- - - - . _, _ _ - _ ,_ , 2 . _,,_c _ , . . . . . . . ~ . - . - ._

-

. , . -. ,

__ . . . _ . _ _ _ - - _ _ - - - _ - -

.

'

!

-

!

. Inspection Team' (AIT) onsite inspection on February 1 through 3,1986, eCAL-RIII-86-01A was issued to. provide clarification as to how the

, applicant was to preserve data related to the seismic event.

'

Specifically, CAL-RIII-86-01A documented that the following measures were to be established

~

'

(1) Maintain all seismic monitoring instrumentation in the "as

' found" condition. Take no action such as' removing, repairing,

'

calibrating or replacing instrumentation which would destroy or cause to be lost, any evidence which would be needed-to investigate the' event. Maintenance, surveillance, and calibration will be performed only with the prior concurrence of

, . NRC Regica III managemen '

(2) Resume all other activities including work such as, but not-limited to, maintenance, training, surveillance, operations and calibrations ~under the following conditions':

I (a)- All off normal conditions identified during these activities will be documented in accordance with CEI's -

programs and procedures.

-

(b) Off normal con'ditions will be evaluated to determine if they were potentially earthquake relate ,

(c) Equipment identified in an off normal condition will be

! maintained "as found" until evaluate Equipment determined to.be potentially earthquake affected will be maintained in (j an "as found" condition until released by the NRC.

4 (d) The NRC will be notified of all off normal potentially

,

earthquake related conditions within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ;

(3) Develop special procedures to implement Item These measures, previously documented as item 5 of CAL-RIII-86-01,

! were assigned to the resident inspectors for followup and verificatio x Followup of CAL-RIII-86-01A, Item'1

Actions by the resident inspectors following the seismic event

,

included observation of scratch plate replacement on certain of the i

f Engdahl Model PSR1200-H/V seismic monitor Additionally, the

,

inspectors informed the applicant that seismic monitoringsinstrumenta-4 tion data was to be impounded and preserved until the NRC AIT arrived

, onsite. Actions by the AIT relative to duplication and acquisition of seismic monitoring instrumentation data is documented in NRC Inspection'

,

Report No.'440/8600 t The resident inspectors verified that prior to recalibration of

. seismic monitoring instrumentation, the applicant obtained \

concurrence from Region III managemen .

i

• i

.y

,

16 ,-

- - , . ~ _ . ._ _ , . . _ . , _ . . - - , .,. - - , , - . ~w

_ _ _ _ - _ _

.

.

The project inspector witnessed the performance of the calibration of the. plant seismic monitoring system following the January 31, 1986, earthquak Calibration was performed per Work Request 36-076 and the following Surveillance ~ Instructions (SVIs):

'

SVI-D51-f5370, " Triaxial Time-History Accelerographs Seismic

,

Trigger Channel Calibration for D51-N100 and D51-N110",

Revision 1, dated October 30, 198 SVI-051-T0279, " Triaxial Time-History Accelorograph Channel Calibration for 051-N101 and D51-N111", Revision 1, dated November 23, 198 SVI-051-T0295, " Triaxial Seismic Switch Channel Calibration for D51-N150", Revision 1, dated November 22, 198 In addition, the seismic control panel equipment was calibrated in accordance with Instrument Calibration Instruction ICI-C-D51-9,

"Kinemetrics Seismic Control Panels and Cassette Recorder Calibration Instruction", Revision 0, dated November 22, 198 As found data on the seismic triggers, switch, and accelerometers was within the tolerances provided in the instructions and did not require adjustment prior to reinstallatio The battery charger associated with control panel equipment.was found to have an output voltage slightly below the manufacturer's provided tolerance and, therefore, required a slight adjustment. The battery chargers low output voltage condition would not be expected to affect the data obtained during the January 31, 1986, earthquake, since the voltage of the battery serviced by the charger was found to be within required tolerance Data, additional to that required by the applicant's surveillance instructions, was taken by the Kinemetrics vendor representative and also found to be within tolerance The results of the calibration indicated that the seismic monitoring system was operational and within tolerance The resident inspector witnessed portions of the calibration of seismic monitor 051-R170 in accordance with Engdahl Enterprises'

" Peak Shock Recorder, Model PSR1200-H/V Calibration and Installation Procedure", dated February 20,-1984 and Perry. Surveillance Instruction .

(SVI)-D51-T0304-B, " Triaxial Response' Spectrum Recorder Channel l Calibration for D51-R170 (Reactor Recirculation Piping Support) on l February 14, 1986. As found data for the instrument was within I tolerances provided in the calibration procedure l

4

_a

,

.

\

.

As-found and as-left calibration data for the seismic monitoring instruments discussed above as well as all other. seismic monitoring instruments in service at the time of the January 31, 1986 earthquake was obtained by the resident inspectors and forwarded to Region.II personnel in the Division of Reactor Safety for revie Item l' of CAL-RIII-86-01A is, therefore, considered closed.- Followup of CAL-RIII-86-01A, Items 2 and 3 Immediately following the seismic event on January 31, 1986, the applicant imposed a hold on work activities with potential to alter or destroy evidence necessary to evaluate the even On February 2,1986, the hold on work activities was conditionall lifted with NRC concurrences. The conditions for processing work were documented in memos dated February 2 and 3, 1986, from.the Manager, Perry Plant Operating Department, to Managers and General Supervisors in the Perry Project Organization. These menos described actions to be taken to evaluate all abnormal or deficient conditions identified by plant walkdowns.specifically conducted to determine if the plant had sustained damage from the seismic even Additionally, all abnormal or deficient conditions identified by any .other means were to be documented on Work Requests and evaluated to determine whether the items were earthquake related. Work items reviewed and determined to be unrelated to the earthquake were authorized to proceed. If, however, in the course of any such work additicnal abnormal conditions .

were identified, the work activities were to be immediately stopped and the abnormalities' documented and evaluated. Any conditions evaluated as earthquake-related or potentially earthquake-related were not to be worked until further guidance was subsequently provided by applicant management in consultation with the NRC staf The applicant provided additional instructions to operating personnel via Daily Instructions issued on February 1, 2, and 3', 1986 requiring that prior to operati~ng plant equipment, the equipment was to be inspected and that equipment operation was 'to be directly observed.

t Any abnormal conditions identified by operating personnel were to b processed as previously describe Following the issuance of CAL-RIII-86-01A on February 4, 1986, the resident inspectors were notified of items determined to be potentially earthquake-related within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1of such determination To ~ provide more formalfand detailed guidance for implementation of the -

actions specified in' CAL-RIII-86-01A, . Items 2 and 3, the applicant issued ~ General Temporary 1 Instruction (GTI)-0003, " Identifying and l Evaluating. January 31,11986 Earthquake Related Damage", on February 7, i 1986. .This instruction described those~ measures already in place for

~

the review and evaluation of findings'from initial plant walkdowns'as 4 l

wellf as newly identified. abnormal or deficient conditions 1.dentified in the course of other activities. Based upon resident inspector comments, GTI-0003'was clarified, revised and reissued on February 8, 198 _ <

a

. . ..

. . .

. .

.

.

.

.

.

Prior to releasing work on potentially earthquake-related items, the resident inspectors were notified and in accordance with GTI-0003, provided an opportunity to establish " hold" or witness points in the work procedures. The inspectors established such hold points for work activities on the safety-related suppression pool level instrumentation and a nonsafety-related clearwell pum Inspector observations of these activities are discussed in Paragraphs 15b and 15c of this report, respectivel On February 27, 1986, the. resident inspector reviewed the applicant's Seismic Review-Tracking Log to determine whether the~ applicant had subjected Work Requests to the evaluations required by GTI-0003 and had notified the resident inspectors of all potentially earthquake-related item The inspector determined from this review that all but-40 Work Requests 1 remained to be evaluated by the applicant's engineering organization. The inspector also determined that NRC notification of potentially earthquake-related items was' documented for each item so dispositione Actions specified in Items 2 and 3 of CAL-RIII-86-01A were discontinued on February 28, 1986, based upon discussions between applicant and NRC Region III management. The applicant agreed that~ remaining engineering evaluations of Work Requests would be completed and that any abnormal or deficient conditions identified in the future as earthquake-related would be reported to the NR Items 2 and 3 of the subject CAL are, therefore, considered close No violations of regulatory requirements or deviations from commitments were identifie . Generic Letter Followup (92703)

On February 27 through March 3, 1986, the inspector conducted a review of the applicant's procedures, actions and documentation related to NRC Generic Letters. The inspector reviewed Nuclear Licersing and Fuel Management -(NL&FM) Instruction 0601, " Licensing Correspondence Handling",

Revision 1, dated December 16, 1985. The. procedure, which was generic to all -licensing correspondence, was utilized for the. handling of NRC Generic Letters. The procedure specified that the incoming' correspondence would be stamped with a "date received" and logged in the NL&FM correspondence

' log. The correspondence was then to be reviewed by NL&FM personnel and a

~

determination made as to which applicant personnel were to be provided a copy. The procedure did not further specify a~ mechanism for followup to-assure that issues raised by the Generic Letters were, in fact, reviewed for applicability and suitably dispositioned or, that required responses were formulated and transmitted. The procedure did not. require that documentation attesting to the foregoing actions be established and

~

maintaine l a

. . ._ , . .. . . . _ _ _ _ _ _ _ _ _ - - -

i

..

.

While there were no specific regulatory requirements pertaining to i procedural controls for the handling of NRC Generic Letters, the-inspector was concerned that, absent _these controls,~ actions directed by NRC Generic Letters may not have been taken and that Generic Letters providing NRC staff recommendations or of-an informational nature may not have been suitably reviewed, evaluated, and dispositioned.

! The inspector revie'wed documentation in the NL&FM files ~ pertaining to the j following Generic Letters:

,

Subject

~

l Generic Letter No.

! '

84-23 "

Reactor Vessel Water Level Instrumentation in'BWRs"

'

85-03 "

Clarification of Equivalent Control Capacity-for j

Standby Liquid. control Systems" 85-07 "

Implementation of Integrated Schedules.for Plant Modifications" 85-13 "

Transmittal of NUREG-1154 Regarding the Davis-Besse-Loss of Main and Auxiliary Feedwater Event" 85-14' "

Commercial Storage at Power Reactor Sites of-Low-Level i 1 Radioactive Waste Not Generated by the Utility" 85-22 - " Potential for Post-LOCA Recirculation Capability Due.

. to Insulation Debris Blockage"

>

Regarding Generic Letter 84-23, the applicant's file contained. licensing correspondence which addressed the issues. raised by the letter and indicated that the modifications recommended for improved reactor water level instrumentation reliability had been incorporated into the Perry design. The file'information established that the Generic Letter was satisfactorily dispositione The file information for Generic Letter 85-03 indicated only that the

~

. letter had been received and slated for distribution. While the letter

'

did not direct any. actions be taken,'it provided clarification of

, 10 CFR 50.62(c)(4). Specifically, the letter outlined the considerations l to be made in demonstrating that the plant specific standby liquid control

system design conformed to the requirements of the rule.

s Subsequent to receipt of 'he t letter by the applicant, an NRC_ inspection j documented in NRC Inspection Report No. (440/85013) disclosed a deficiency in the applicant's-standby liquid control system'preoperational test j procedure concerning the' very issue discussed in the subject letter.

j Preoperational test procedure acceptance criteria for system capacity were

' not supported by a demonstrated equivalence to 10 CFR 50.62 (c)(4) criteri ~

,

This-was -identified as a violation of NRC requirements and was subsequently corrected by-the applicant.

.

-

4 Y * r e T e ir er er v gue rre- fdvr-+' 7 'ty_9-1 - ==,e y vw,w w yM ----*7p---y-w- =

grew 7,ir-v-W"www- warw P- y y o g g - v,* *-o e r'- 3

. -

, . . ~ .. . . . .

,. . - ._ -. ..

f

.

.

! The foregoing-information' indicated to the inspector that the subject

) letter was not suitably' distributed, evaluated and dispositioned by.the

. ' applicant-in'a timely manner.

l Generic Letter 85-07 was issued to. encourage and solicit the views of

! operating licensees relative to participation in development of integrated schedules for plant modifications and associated licensing action As i such, the applicant was not required to respond. The' applicant's file information~ indicated that the letter was slated'for distribution to l personnel within the NL&FM organization. 'While no additional information I was_ contained in the applicant's files, the inspector was satisfied that

no additional review or evaluation of this'1etter was warranted.

~

Applicant file information for Generic Letter '85-13 ' indicated only that -

L it had been received and-slated for distribution. -The letter did not '

require that any actions be taken by the applicant but contained several

recommendations for the review and evaluation of information contained in i NUREG-1154. The recommended reviews and evaluations were to. focus on i problems and weaknesses identified as. contributors to a total loss-of .

,

feedwater event at the Davis-Besse plant. The recommended actions were intended to allow a determination of whether similar weaknesses existed in ,

-the applicant's management controls and to identify any necessary corrective- l

action l Generic Letter 85-14 transmitted NRC licensing policy and planning related J

to the commercial storage of low level radioactive waste at reactor sites or other commercial facilities. . The applicant's file information indicated

~

,

that the letter h'ad been received and slated for distribution to personnel

> .in the applicant's licensing organizatio Given the subjectLand informa-

,

tional nature.of the letter, the inspector felt that appropriate personnel were placed on distribution. _The need for followup-actions will depend

'

upon the applicant's intentions regarding future storage and disposal of low level radioactive waste.

} Generic Letter 85-22 contained recommendations regarding.the application of Regulatory Guide 1.82, Revision 1, " Sumps for. Emergency Core Cooling and Containment Spray Systems" for 10 CFR 50.59 evaluations associated with the change out and/or modification of thermal insulation installed on i

'

primary coolant system' piping and components. . The applicant's fi1_e _

information indicated.only that the letter had been received and slated

for' distribution. ~ Perry FSAR,' Section 6.2.2.2 was offered by' applicant ~

licensing personnel as a' basis for not requiring followup actio The 1- FSAR secti.on discussed the applicant's analysis of~the potential for ECCS-l suction strainer blockage due to LOCA generated thermal insulation debris.

j'

"

The analysis was based upon the thermal insulationicurrentlyfemployed by; the applican It was not apparent to.the inspector that the analysis

'

obviated the need to consider the recommendations of the. subject Generic-

, Letter as it related to future. change out and/or modifications to the'

! thermal insulatio Documentation further supporting such a disposition

,

was not available.

.

21

}' _ . _. _ .. -

. . _ .- _ _ . _ _ _ , _ _ _ _ _ _ , _ _ , _ - . ,

. ~_ = _ . . _ _ ~ ~. _ _ _ - -- - - _ - -

,

,

.

In addition to the individual Generic Letter' files discussed above, the

inspector. reviewed a Generic Letter 1og maintained by the applicant's licensing organization. The log, which was not required by applicant-procedures, contained additional information relative to the disposition-

_

ing of the letters. The inspector noted that many of the letters were

-dispositioned as "Not Applicable" because they.were not addressed to BWR

'

Construction Permit Holders.

i

.In summary, the inspector's review did not identify failures to take

~

required actions contained in Generic Letters. The inspector did, however, i identify one instance where the applicant's evaluation of information contained in a Generic. Letter was either not timely or not factored into

. the establishment of preoperational test acceptance limits (GL 85-03) and I one instance where the dispositioning of' recommended actions contained in a Generic Letter was not apparent (GL 85-22). Generic. Letters not

.specifically. addressed to BWR Construction Permit Holders were'often

. dispositioned as "Not Applicable" though issues raised in the letters may

,

well have applied to Perr Further review will be required to determine

.; whether or not issues raised-in Generic Letters not requiring action by the applicant were'otherwise properly addressed. This matter is considered i an open in'spection item (440/86006-04(DRP)).

,

'1 Emergency Procedures (42452)

On January 17, 1986, the inspector witnessed the-Plant Emergency Instruction

(PEI) Validation Scenario #2 which was intended to exercise the following PEIs:

• PEI-813 " Reactor Pressure Vessel Control"

* PEI-D23-1 " Containment Temperature Control"

"Drywell Containment Pressure Control"

~

• PEI-D23-2

• PEI-D23-3 "Drywell Temperatur'e Control"

• PEI-E12 " Suppression Pool Temperature"

,

• PEI-G42 " Suppression Pool Level Control"

'

.

.i

The' scenario involved main steam line isolation caused by low condenser l

'

vacuum followed by a safety relief valve failure and a small break loss of coolant accident inside the drywell. The inspector observed the integrated performance of the shift crew including shift supervisor, unit supervisor,.

~

supervising operators and shift technical advisor. -Entry into and exit'

from the various PEIs was made at the appropriate times in response ~to plant conditions. Adequate guidance and. direction was provided to the

, appropriate personnel by the shift supe'rvisor and the unit supervisor. No-concerns were identified during .the ~ validation regarding' control room'

equipment physical layout or labelling. No significant problems ~were identified with the emergency instructions. With' respect to this. scenario

!

and the emergency instructions exercised, the operator / instruction / machine

.

interface ~ appeared to be adequat . .

! '22

_ . - . _ - - . ._ ,__, ;_ -_a_ __ - . . - . . - , . . _ , , _ _ , , . . . , , , , , ,

_ . _ - . . _ - . _ _ _. . _ _ __ ,

,

,-

,

i No violations of regulatory requirements of deviation:: from commitments were noted in this are . Operational Readiness - Administrative Controls (42400)'

,!

On November 1, 1985, the applicant began employing the PNPP Operations ~

Manual to control activities affecting quality in accordance with.

,

'

10 CFR 50, Appendix Approximately 2 weeks were allotted ~from that. time for the completion.of previously identified work items under administrative controls established for the construction phase:or conversion of associated

documentation to that: required by.the Operations. Manual to control work completion. All plant systems, regardless of the construction status, were

turned over to the Perry Plant Operations Department on November 1, 1985.

.This transition was intended to focus all project organizations on completion of Unit 1 and provide more control by the operating organization

, in defining, prioritizing,. scheduling, and accoaplishing remaining work.

1 This transition also provided an opportunity, prior to operating license

{ issuance, to. exercise the system of operating administrative controls to ensure they were workable (e.g. that procedures were compatible with one

,

another, internally consistent, and otherwise adequate to control covered-

>

activities). '

i Certain NRC inspections conducted prior to and during January 1986, i included reviews of selected procedures contained in the Operations Manual

'

'

to verify that they had received required reviews and approvals and that

.they were adequate to co'ntrol covered activities. Findings resulting'from these reviews have been~or are currently being addressed by.the applicant to enhance procedural adequacy.

- As pre-operating license NRC reviews of the Operations Manual have. neared

'

completion, the resident inspectors' . attention has increasingly shifted

, towards monitoring procedure implementation. During this inspection ,

! period,' concerns have been identified regarding Operations Manual' '

implementation as discussed below.

l Many of the procedural requirements contained in-the Operations Manual

addressed circumstances, conditions, or regulatory requirements that ar not encountered or applicable prior to issuance of.the operating license or later operating milestones. .~Some examples included tracking of potential

.LCOs, radiation work permits for containment entry, shift staffing and.

, overtime restrictions, Shift Technical Advisor duties, and identification of out o.f service equipment in shift turnover logs. These requirements and others were specified in the Operations Manual in "effecti.ve" procedures.

. While, by definition contained in Operations Manual,' Plant Administrative-I Procedure (PAP) 0501, Section.6.4.2, compliance with " effective" procedures -

is mandatory, these requirements and others were not'being implemented..

i The failure to implement these procedural requirements was based on the

~

applicants undocumented informal consensus that implementation-was not desirable or'necessary rather than by documented management direction prepared within the framework of the plant: administrative: control ,

!

!- -

>

,

g - - -wy-,e w-g %, y - w w+,--c.my,i,.-r%.,-wy,----c-v, ,e-+n,--- .mm.p~y-, r .y w. . w 4 yey , +,e.y,-.~-wdu+%,-3 ,, .- ,,,v-33- y- wwt 4.,e-+-v-- --w-~,-.,w,.--rr %

_ - , , -- - - . . - . . .._._---- _

.

'

i Based upon the foregoing examples of failures to implement effective

"

. (though perhaps marginally consequential) procedures,.the inspectors attempted to ascertain by direct inspection' effort and review.of applicant ~

4 QA organization findings whether or not deficient implementation practices j existed in procedures. controlling ongoing activities affecting' qualit :The results of direct inspection effort disclosed deficiencies in procedure implementation in the areas of work order control, housekeeping, security, and independent verification ~of. valve lineups. The results of the review-

. of applicant QA findings disclosed numerous instances of failure to adhere

'

tofspecific procedural requirements in the areas of design control, work control, surveillance testing control,. document control, corrective action,

, and other The applicant's findings were documented in Action Requests

'

(AR) and Corrective Action Requests (CAR) during the period starting

, November 1, 1985, to the present. These findings have~ ranged from. isolated t

instances to. programmatic failures. The inspectors have subsequently reviewed corrective actions to these findings and determined that they were adequate to address the individual findings and that improved performance -

in affected program areas had been obtaine The inspectors expressed concern to applicant management that, based on i the number and type of procedural and program. compliance problems and the

results of similar findings identified by NRC' inspection during.this

!-

inspection period,-the root cause of the problems may not yet have'been identified. In response to the inspectors concerns, the applicant committed to complete the following activities:

i * Training directed toward all individuals explaining the procedural _and:

_

instructional framework for controlling activities and emphasizing the requirement for comprehensive procedure / instruction conformanc {

• Closing out' Corrective Action Request 85-24 resulting in all-persons

being up-to-date with procedure / instruction training.~

• Performing a broad scope surveillance inspection under the-QA program directed at assessing overall adequacy of the implementation of the Operations Manual in the operations, maintenance, surveillance and j health physics' area These commitments were documented by the applicant in a surveillance

>

inspection. plan. The' inspectors believe.that a high level of management attention will continue to be required to ensure that the existing plant administrative controls are adequately implemented. This will continue to be a strong focus.of future inspection effor . Inspection in Response to Headquarters Requests - Emergency Notification System (Red Phone) Operability (92704)

In response to problems occurring following initial installation of the red

~

,

phone, a functional test of the plant red phone used to communicate between

'

, the plant and the NRC Headquarters Duty.0fficer was ' conducted on January 14, 1986, by the inspector. . The inspector verified that when picking up 'the j- phones the appropriate Auto-Call features were operational.as.follows:

j'

-

24-r

_ _ ___ _ - _ = _ _ . _ _ _ - _ . _ _ _ - - _ _ . _ _ _ _ - _ - _ - - - _ _ _ _ . _ _ _ _ _ -- - _ _ _ _ _ _ _ _ _ - _ _ _ . _ _ _ - _ _

. - . _ . . . _ . _ ___ . - - _ _ - - ---

'

.

' When picking up the Control Room ' red phone, the H.eadquarters Duty

'

Officer and Resident Inspector's red phones auto-ran l

.

b .' When-picking up .the Resident's red phone, the Headquarters Duty Officer's red phone auto-ran !

I When picking up .the Technical ~ Support Center's (TSC) red phone, -the Headquarters Duty Officer and Resident's red phone auto-rang.

{

j When picking up the Emergency Off-site Facility's (EOF) red phone, the j Headquarters Duty Officer and Resident's. red phone auto-ran lWhen picking up the EOF NRC red phone, the Headquarters Duty Officer and. Resident's red phone auto-rang.

i

[; All features described above were found to be functional and comunication clarity was acceptabl l In addition to this functional test, the red phone was utilized extensively during the~ followup to'the-earthquake on. January 31, 1986, with no problems l note ~

l

!

No violations of regulatory requirements or deviations:from comitments l

'

were identified in this are'a.

15. Monthly Maintenance Observations (62703) .

1  !

j During this inspection period, the inspectors examined the work order

! generation and control process and field observed two maintenance

. activities: troubleshooting of a nonsafety related pump motor that would not start, and verification that the-suppression pool level instrument

! sensing lines wer~e filled and vente During this inspection period.the inspector conducted a walkthrough

'

. ; of the work control process described in current revisions of Perry Administrative Procedure (PAP) 0902, " Work Request System," and PAP 0905,'" Work Order Process". -The walkthrough was conducteu to:

,

ascertain whether or not actual control'and~ processing of work was

.; accomplished as described in the subject procedures and to' gain

-

'

familiarity with the detai.ls of how each responsible organization carried out designated actions. The 'inspec. tor noted that since the t

time of NRC reviews of PAP-0902 and PAP-0905 documented-in NRC-Inspection Report (440/85059) the applicant had modified the l procedure's in several respects. ;These changes provided clarification as to what' kinds'of tasks. required a Work Order'and assigned certain work control functions to the Project Work Center (PWC).

The'PWC, located in the Unit.2 control-room, was established'to ..

accomodate the large volume of remaining unit 1 and unit-comon work items which had yet to'be accomplished following the transition from i

construction phase administrative controls to operating administrative

, controls on November 1, 1985. The PWC ~ staff is responsible for:

,

25 i

'

-

-

, 9 w yy ,

9,r,,-, - , - ,, - -r -y. -

, , y , ,,.,,,+,r, .

,,, ,p y -rv.y,- 9y- ,.,-y,,-. ,aw,-

.

y & w y py , y ,y,.g-

.

_ _ - _ _ _ _ _ _ _ _ _ _ _ .

.

.

• Reviewing incoming work requests for completenes * Recommending whether or not a work order should be issued to accomplish requested wor * Recommending assignment of priority code * Issuance of Work Order numbers and entry of work items into the applicant's computer-based work management syste * Forwarding of Work Requests to appropriate work planner * Scheduling and coordination with operations ~for necessary tagouts and authorizations for commencement of wor * Issuance of work packages to t'he fiel * Receipt and transmittal of completed work packages'to the applicant's quality assurance organizatio The PWC, therefore, acted as a " traffic control" center for work activitie The PWC had reduced the level of work control activities taking place in the Unit 1 control room and reduced the administrative burden placed upon on-shift operating personnel. According to applicant personnel, the PWC will remain in existence indefinitely to aid in the management of work for completion of Unit 1, routine plant

operations, and outage The inspector's walkthrough of the work. control process included discussions with PWC personnel involved in each of'the above described functions, work planners in the electrical, mechanical, and instrumentation and control. maintenance organizations, and on-shift operating personne b. Following the January 31, 1986, earthquake, the applicant reported the failure of a nonsafety related clear well pump associated with-the Service Water System. The inspector witnessed the performance of . troubleshooting Work Order (W0)86-2137, to determine the cause of pump failure and' subsequent repair. During troubleshooting, applicant personnel determined that failure was due to bad starter motor contacts. .The inspector examined the starter motor contacts and concurred with the applicant's evaluation that. failure was due to fatigue caused by prolonged heating and apparently not the result of the earthquak c. During the January 31, 1986, earthquake, the chart recorders documenting suppression pool level experienced a step increase in indicated level. The applicant initiated Condition Report (CR)86-106 to document review and resolution ~of this discrepancy. One of the suspected causes of this step increase was believed to have been event related release of entrapped air in the sensing lines for the suppression pool level instruments which may have resulted from

- . - - . . . . - - - . . . .___ _ .

.

. improper fill and vent operations that occurred prior to the earthquak To -identify whether in fact there was..any' remaining entrapped air in '

the sensing lines, the applicant issued Work Order (WO) No. 86-2829 to vent the high points on the high side impulse . lines and drain the low points on the low side impulse lines'to the suppression pool level instruments. The inspector examined the WO using Plant Administrative-Procedure (PAP)-0905, Revision 3, " Work Order Process;" The inspector also witnessed a portion of the field work associated with that work order to verify conformance with PAP-0905, PAP-0501, Revision 2,

"PNPP Operations Manual," PAP-0205, Revision 3, "Operabili.ty.'of Plant ~

Systems," and. PAP-0607,' Revision 0, " Perry Plant Department Drawing-Control."

During review of this WO and the associated traveller, ano during observation of the work activities, numerous discrepancies were noted between the required administrative' controls and the implementation of'

the activitie * During preparation of_a Work Order,'when the work order is used as a temporary work instruction, Section 6.3.1.1 of PAP-0905'

requires that the Planners Remarks Section contain the purpose of the WO. WO 86-2829, Planners Remarks Section, did not contain~

the purpose of the W * PAP-0905, Section 6.2.3 specifies that the WO traveller is.used to outline the job steps and the sequence.that the job steps shall be. performed. Section 6.2.3 of PAP-0905, specif.ies that the effective'date of the temporary-work instruction contained in the WO is the date when the Control Room Supervisor approves the W " Effective date" as defined in Section.6.4.2 of PAP-0501-is-the date when adherence to the requirements of the instruction:

is mandatory. During performance of the work, the technicians decided to perform the B train instruments prior to the A train-instruments. This. required entering the instruction at Step 1 In' actuality, the technicians entered the' instruction at Step 16 and performed Steps 16 through the completion of the B' train instruments prior to realizing Step 15-had been missed. Both entering the_ instruction at-the middle of.the instruc_ tion ~and-performing the B train section of the instruction out of sequence are not in accordance with PAP-0905 and PAP-050 * Section 6.3.1.6 of PAP-0905, requires that the' job travelle contain sufficient detail ~to permit the_ work to be performed'

correctly and safely. The temporary work instruction contained

~

in the' job traveller did not contain enough detail to properly

_

accomplish the work to be performed. The temporary instruction specified valves in the instrument' sensing line loop with alpha

'designators which were recorded by pen and ink additions to an -

information only copy of a non as-built isometric _ design drawing for_the sensing line installationi Consequently' the instruction cannot be properly implemented without the referenced drawin During final processing of the.WO package, after completion of.-

the work, the-_ drawings were_ discarde ,

- _ . _ . _ _ _ _mm.____s_mm-_ ___._.____________.t___.__

_ _ . -

-.

...

!

'

• Procedure Step-23a directed the technicians-to open drain valve

"P" which as indicated on'the attached drawings'was a hip side drain. _ Step 23b.says, "close valve when water is drained".

As identified on the attached drawing, that. drain valve communi- ,

cated directly with the suppression pool._ At'this point, because l of the apparent improper procedure, the t'echnicians in accordance with PAP-0905 should have stopped and obtained a procedure chang Instead,'the technicians performed the function they believed was proper in the scheme of the ' procedure which was opening the low side (dry) sensing line drain valve at that poin * The-comple' tion of each step in this procedure requires independent. verification that restoration from the step was properly. accomplishe Regarding valve position verification guidelines for manual valves, PAP-0205, Section 6.6.2.2 specifies that "to verify that a manually operated valve is full closed turn the handwheel in the close direction.until the valve is closed and verified by position inification and firm tightness."

While each step in the work order instruction required-independent verification of proper restoration and PAP-0205 defined the mechanism for verifying proper' closure of manual valves, independent verification of Steps 17, 20, 21, 22 and 23 which the inspector observed, was performed by simply observing the technician performing the.workfand signing off on the procedure. No active verification was performed. Steps 15, 16, 18 and 19 required instrument venting. No guidance was provided for accomplishing vent plug restoration verification and no active verification was performe * The drawings incorporated into-the work package (Dwg. No. D814-727'

and D-814-728) were incorporated as information only copie PAP-0607, Section 5.5, indicates that ongoing as-built drawings are " drawings which are required to depict the current as-built plant configuration for the safe maintenance and operation of the

~

plant." PAP 0607, Section 6.4.1, indic'ates that-individuals-intending to utilize drawings for operations, design,' testing, or maintenance activities would obtain a working. copy drawing from'-

an as built-drawing. file. ' PAP-0607, Attachment 2, indicates that

~

the 814 series drawings which were util,ized in the work order package are design status drawings only and no as-huilt:

information has been or will be' incorporated into tne drawing ~

Utilization of those drawings to accomplish maintenance of the plant-is not in accordance with PAP-060 The above examples of inadequate instructions and failure to follow instructions represent-violation of 10 CFR 50, Appendix B criterion V, " Instruction, Procedures and Drawings" in that adequate instructions were not provided to accomplish activities affecting quality and activities affecting quality were not accomplished in accordance with instructions (440/86006-01b(DRP))..

.

.28

. . _ .

.

1 Monthly Surveillance Observations (61726)

On February 5,1986, the inspe-tor observed the. conduct of surveillance test instruction SVI-R43-T1331, " Division 1/2 Standby Diesel Generator LOOP (Loss of Offsite Power) Test", Revision 0, with one active Temporary Change Notice (TCN-002). This surveillance activity was perforned to satisfy Technical Specification surveillance requirement 4.8.1.1.2.e.4(a).

Following LOOP simulation, three components did not function as described in the SVI: the motor control center, switchgear.and miscellaneous heating ventilation and air conditioning system return fan (M23C0028) was not running, and two battery room exhaust system dampers M24F051A and B were not ope Condition Report (CR)86-116 was initiated to document and resolve these discrepancie Preliminary investigation indicated that the fan did not start due to a blown fuse and that the SVI was in error regarding the dampers. The dampers should have remained closed as observed. Final resolution of these items and retest where required will be tracked under CR 86-11 No violations of regulatory requirements or deviations from commitments were. identifie . Operating Staff Training (Radiological Controls) (41301) General On Jontary 22-23, 1986, the inspector participated in the applicant's radiological controls training course.(Course No. GEN-1002). The inspector participated in the course in lieu of NRC in-house radiological controls training in order to evaluate -the course against applicant commitments contained in the Perry FSAR and the dccumented course objectives contained in the classroom handout. Participation in the course also served to satisfy the applicant's program requirements for unescorted access to radiologically controlled area Classroom Training The inspector found that the format utilized by the applicant for the i classroom portion of the course was particularly effectiv The l classroom handout included documented course objectives but required

.

student attentiveness and comprehension of lecture material in order to obtain knowledge necessary to satisfy the objectives (i.e. the

<

handout did not simply list facts to be memorized for successful completion of.the written examination). The lecture presentations ,

were generally clear with concepts conveyed in a manner appropriate

' '

to the various levels.of experience and education of the. students comprising the class. The inspector provided clarifying comments and suggestions to the. instructor regarding in plant contamination limits and the definition of specific activit .,

- _ _ - _ _

.

. Practical Training The practical portion of the course was well thought out and covered most major aspects of radiological controls and work practices peculiar to work in radiologically controlled areas. The training ,

included: use of radiological surveys, radiation work permits, ALARA planning, donning and removal of protective clothing, respiratory protection equipment inspection and use, dosimetry, use of step-off pads, frisking, and response to radiation monitor alarm The inspector considered this training most effectiv No violations of regulatory requirements or deviations from commitments were identified.

.

18. Safety Committee Activity (40301)

The inspector reviewed the minutes of the Plant Operations Review Committee (PORC) meetings No.85-137, 85-138 and 86-01, 86-03 through 86-05, 86-07, 86-09, 86-10, 86-12 through 86-20, 86-22 through 86-26, 86-30 through 86-36 and 86-41 conducted during the inspection period to verify conformance with PNPP procedures and regulatory requie u ; ct These observations and examinations included PORC membership, quorum at PORC meetings, and PORC activitie ;

No violations of regulatory requirements or deviations from commitments were identifie . Followup on Allegations (99014) (Closed) Allegation (AMS-RIII-A-86-0019): The NRC received allegations from a third party concerning information obtained from an ex-Perry Plant employee (the alleger). In addition to the allegations, the third party also gave the NRC the identification ,

and phone number of the alleger in order for us to obtain more specific information, if neede The following are the original allegations, as presented to the NRC by the third party, followed by information obtained by the inspector during a phone call to the .

alleger, and findings and/or conclusions made by the inspector for !

each allegatio (1) Original allegation: In 1981, there was a 700 foot weld defect-in the containment structure which was not properly resolved and all workers 'were told that anyone who talked to a reporter about the defects would be fire Followup call to alleger: The alleger stated that to his knowledge the defect was repaired and that he was not told directly by management personnel that he would be fired; only that there was among his pears talk that "if you talk :

to reporters you walk" (i.e., would be fired).

,

_ _ _ _ _ - _ _ _ _ _

.

.

Inspector's findings and/or conclusions: Weld. defects in the-containment vessel were reported by CEI to the NRC as a 10 CFR 50.55(e) report on May 6, 198 These defects were identified when the CEI NDE team was reviewing radiographs of the containment vessel welds. Due to the NDE team findings, a.100% review of all containment vessel radiographs was performed in order to determine the extent of the deficiencie As reported to the NRC in CEI's final report pursuant to 10 CFR 50.55(e) concerning the weld defects,' dated September 30, 1983, the review identified numerous defects that were either later found to be acceptable, repaired, or if inaccessible, evaluated by an outside engineering firm to determine the ac'ceptability of tne welds, assuming the indications were in

~

fact defects in the weld and would remain unrepaired for the design life of the structure. 'CEI's evaluation was submitted

, to and accepted by the NR l Region III reviewed this 10 CFR 50.55(e) report, including the

-

licensee's actions, and closed the deficiency in Inspection Report No. 440/8303 Based on this review, this allegation is considered close (2) Original allegation: It was alleged that an. individual (name given) was being " blackballed" .from work at Perry since 1981 because the individual complained about qualit Followup call to alleger: The alleger stated that the )

individual was blackballed due to raising Industrial Safety, j not radiation safety or quality concerns. The alleger said H that the individual filed a complaint with the National Labor Relations Board (NLRB) and won the case'.

Inspector's findings and/or conclusions: The alleged blackballing incident concerned industrial safety issues, not

radiological or quality issues. Therefore, no further inspection ,

by Region III was warranted and this allegation is considered i I close l l

(3) Original allegation: It was alleged that voids exist in the bioshield that resulted from not properly fixing previously identified voids. It was alleged that the problem involved the fact that the heavy concrete would not properly flow into the patche Followup call to alleger: The alleger added that he was personally aware that.the voids were identified and repaired by the applicant or. contracto __-__________-____---________-_-____________---____-________-_________-__-_--_l

o o

Inspector;s findings and/or conclusions: This concern was not substantiated since the alleger stated that he personally saw the voids repaired. In addition, Region III has received three CEI~50.55(e) reports concerning bioshield wall voids (DARs 62, 74, and 151), which were reviewed by Region III and closed in Inspection Report No. 440/84002. This item is considered close (4) ' Original allegation: A " white ticket welder" from out of town -

was permitted to weld on site and was not qualifie The welder was allegedly not able to turn on the welding machine and was known to be a cousin of a foreman on the projec Followup call to alleger: The alleger said that-he did not know if the welder was qualified or not, only that the welder did not know how to turn on a particular welding machine. When-asked about the presence of Quality Control (QC) inspectors, the alleger said QC inspectors reviewed all work and guessed the

" white ticket" welder's work had also been inspected. The alleger also said that another welder had told him that he had performed a " vertical up weld" for the " white ticket" welder because the

" white ticket" welder could not. The alleger did not know the

" white ticket" welder's name.

!

Inspector's findings and/or conclusions: The alleger'did not state that the welder was not qualified; although it was implie Since the alleger could not remember the welder's name or provide first or even secondhand knowledge that the welder had performed less than acceptable work, further NRC inspection was not warranted. With regard to another welder doing a " vertical up weld" for the " white ticket" welder, it is possible that the white ticket welder was allowed to do only horizontal welding based on his qualification testing and may not be a reflection of his welding abilities'. Other review of qualification of welders was reported in Inspection Report No. 50-440/8502 This allegation is considered close (5) Original - allegation: During October of 1985, the reactor vessel was filled with water'and was " leaking like a sieve" in the lower elevations of the drywel '

Followup call to alleger: The alleger stated that it was the Fuel Transfer Pool that was filled resulting in the leaks at the lower elevations of the drywel The alleger also stated that he was told the leaks had been rep. aire Inspector findings and/or conclusions: The inspector notified the applicant of the concern about the leaking upper fuel poo ~

The applicant informed the ' inspector that every time the upper pools are emptied and refilled, water is observed in the leak chase system. The applicant stated that engineering had determined that this water is from condensation. The flow rate i reportedly drops'off and after one or two days will sto The j l

.. - _ - __ . . . __ _. -_ _

-

~.

,

.

..-

'

. .

condition has been documented on Nonconformance Report-(NCR)

, NTS-049, dated August 1, 1984. The inspector reviewed the NCR, which documented the apparent 1.eakage (maximum leakage was recorded to be approximately 200 drops per min.) and concurs

-

,

with the applicant's conclusion that the moisture was due to condensation. This allegation is considered close (6) Original allegation: The " third party" alleged that an l individual (name and address given) is suing Cleveland Electric L Illuminating Company for :" blackballing" him from the site l; because he complained about quality. problem Followup call to alleger: (None)

i

,

Inspector's findings and/or conclusibns: .The inspectors could j not-telephone the alleged " blackballed" individual because he i had an unlisted numbe A certified letter was sent to the j individual on February 18, 1986, and received by him on

February 19, 1986, as documented by his signature on the return

-

receipt card,'asking him to call the Perry NRC resident office (collect) to discuss the construction quality aspects of his J

alleged " blackballing" case.

The individual'did not contact the NRC resident's office,

~

i therefore, due to lack of specific information, this allegation t is considered closed.

lI In addition to the six allegations received from the third party, as-

-

j described above, during the followup call to the alleger an additional

! allegation was made to the NRC. This allegation concerns a rumor the alleger.had heard that'the lower suppression pool was composed of only one type of stainless steel when two types were required--one type to be used from the floor to the 10' level and the other type above the

10'-leve The inspector reviewed plant specification SP-660-4549-00, " Design

'

.and Fabrication of Steel Containment Vessels and related items for

~

Reactor Buildings 1 and 2", dated 5/2/83, and applicable construction

drawings. Those reviews confirmed that two types of stainless steel were required in the fabrication of the lower walls of the suppression

. -pool. The material for the lower 13'-6" and the base liner exposed to i the suppression, pool water was to be carbon steel with a stainless

steel cladding conforming to SA-240, Type.304 of the ASME Code, j Section II. The material for the next 9'-6" was to be carbon steel i with a stainless steel cladding conforming to SA240, Type 304L of the j ASME' Code,Section II.

1 .

'j The inspector performed a' limited random review of the containment vessel wall installation documentation, including Test Certificates 1 (chemicals and physicals) of the material used,-Quality: Control weld i documentation (Weld History Cards) that contain material types, and

-

l- Quality Control inspector recorded heat numbers traceable to'the Test-

$ '

p ,

33

.

.

,

.. - - - .. . - . . -_- . . - - .-. - - - _ _ _ _ _ _ _ _ _ - _ - - _ _ _ .

! *

I

.

Certifications. The inspector found that the installation documenta-tion reviewed, conformed to the requirements identified in the. design documentation. In addition,-the inspector's review of the design drawings revealed that due to"the size and shape of the individual plates, which had been fabricated offsite, accidental misconfiguration of the plates would be difficult or in'some cases impossible.

L This allegation was not substantiated and is considered closed.

!

p (Closed) Allegation (AMS-RIII-A-85-0194): The NRC received an ,

allegation that an unqualified individual was granted access to the

~

l

, protected area of the Perry Nuclear Power Plant without adequate

security screening. In addition, the alleger stated that the security screening program, which permits bypassing of the Minnesota Multiphasic Personality Inventory (MPI) test by using supervisors'

recommendations when individuals have been employed for more than

. three years, is being invalidated by improper supervisor analyses of l employees background The alleger gave, as an example, the l

.desc'ription of an employee who was alleged to be a chronic alcoholic

~

i yet was allowed access'to-the' plant based on the recommendation of a

'

)

i supervisor who was also accused of being an alcoholic, rather than by

[ use of the MPI.

!

,

The NRC transmitted specific details of this allegation to the i

{ applicant by a letter from Charles' E. Norelius, Director, Division of j Reactor Projects, to Mr._Murray R. Edelman, Vice President, Nuclear j Group, CEI, dated December 18, 198 The letter requested that CEI l

J perform a review of the allegation to determine the validity-and ~

significance of the issu !

The inspector reviewed the applicant's-results report (Concern: 65, dated January 14,1986)'which indicated that' the individual identified 4 by the alleger had been adequately screened including taking the MPI and having a comprehensive. background investigation performe The applicant stated that the MPI revealed results that were well within i normal limits in all categories including the McAndrews Scale, a scale

! assisting in the identificatinn of a propensity toward substance abuse.

[. The individual and his supervisor were also reported to have an j excellent work and attendance record.

f Based on the finding that the individual di.d'have a MPI~t'est, that

.

he successfully passed that test, and that the individual had an j excellent work record this allegation is not substantiated.' Therefore

this item is considered to be close !

20. IE Information Notice Followup (92717)

L

The inspector reviewed the applicant's response to IE Information 1 Notice 86-02, " Failure of Valve Operator Motor During Environmental j' Qualification Testing," issued-January.6, 1986. The Information Notice l4- discussed environmental qualification testing of Limitorque fast acting SMB-3-150 valve motor. operators containing motors manufactured by i

!

'

!

! 34

'

- - _ __ - _ _ ___ -

- _ _ _ _ _ _ _ _ _ _

o

'

.

.

Reliance Motor Corporation. The testing was conducted by General Electric Company and had been the subject of a previous Service Information Letter (SIL)-425. The results of that testing indicated that the magnesium alloy rotor in the Reliance Motor Corporation AC motor was subject to corrosion in high temperature steam environment In review of this IE Information Notice and the reference SIL, the applicant identified that eight valves in safety related systems in the plant used the subject type motor operator. The eight valves are located in various equipment qualification profiles, the most severe being the CT-3 profile inside containmen The applicant's analysis of the'information notice and SIL was centered predominantly on the need of these various systems and valves to provide post accident long term core cooling. Two of the valves located inside containment also serve inboard manual containment isolation functions on the low pressure cooling injection system injection lines. The applicant did not consider in their analysis the long term requirements for containment isolation valve operability or other functions of those valves. The inspector's followup of this information notice will remain .open and review of the applicant's response to Information Notice 86-02 will be the subject of a future inspectio No violations of regulatory requirements or deviations from commitments were noted in this are . Management Meeting (30702)

A meeting was held at the Perry site on February 11, 1986, between Messr J. G. Keppler and R. M. Bernero and other members of the NRC Region III and licensing staffs and Mr. M. R. Edelman and other members of the applicant's staff to discuss the completion status of PNPP, Unit 1. Major topics of discussion at this meeting included the Master Deficiency List, Operations Manual, open inspection issues, and system operational readines . Commissioner Bernthal's Visit (37302)

On January 30, 1986, Commissioner Frederick M. Bernthal and other members of his and the NRC staffs met with Robert Ginn and other members of the i applicant's staff to discuss Unit 1 operational readiness. The visit included a simulator exercise; meetings with the applicant, the NRC staff, and the public; and an extensive tour of the facilit . 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 l inspection items disclosed during the inspection are discussed in Paragraphs 9, 11 and 2 _ _ - _ _ _ _ _ - _ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

-- .

'

.

.'

.

24. Exit Interviews (30703)

'

The inspectors met with the applicant representatives denoted in Paragraph 1 throughout'the inspection period and on February 14 and {

'

March 3, 1986. The inspector summarized the scope and results of the inspection and discussed the likely content of the inspection report.

j' The applicant did not indicate that any of the information disclosed .!

during the inspection could be considered proprietary in natur l l

l l

i

.i

1

,

i j

.

I a

i

4