IR 05000440/1986014

Insp Rept 50-440/86-14 on 860512-0623.No Violations or Deviations Noted.Major Areas Inspected:Operational Safety, Lers,Onsite Review Committee Activities,License Conditions, Operating Events & Startup Test Witnessing

ML20207J854
Person / Time
Site:	Perry
Issue date:	07/22/1986
From:	Knop R, Mccormickbarge, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207J835	List: IR 05000440/1986014 ML20207J832
References
50-440-86-14, NUDOCS 8607290274
Download: ML20207J854 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/86014(DRP)

Docket No. 50-440 License No. NPF-45 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 Inspecticn Conducted: May 12 through June 23, 1986 Inspectors: J. A. Grobe K. A. Connaughto,n W hL ! e J. W. McCormick-B rg'r //22//6 Date P. R. Rescheske .2 2 f PG Date Approved By: R. C. Knop, Chief

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Reactor Projects Section 1B Date

l Inspection Summary

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Inspection on May 12 through June 23, 1986 (Report No. 50-440/86014(DRP))

Areas Inspected: Routine unannounced inspection by resident and region based inspectors of previous inspection items, an allegation, operational safety,

. Licensee Event Reports, onsite review committee activities, license conditions,

! cperating events, a management meeting, and startup test witnessing.

! Results: No violations of regulatory requirements or deviations from commitments were identified in the nine areas inspected. A management meeting was held on June 5, 1986, to discuss Region III concerns with recent operating events involving personnel errors and the technical support and coordination of troubleshooting activities (Paragraph 9). As documented in a letter from l the licensee dated May 30, 1986, personnel reassignments and orgar.lzational

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realignments were made to increase the effectiveness of the organization in support of PNPP, Unit 1, operation.

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DETAILS 1. Persons Contacted

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

+ A. Kaplan, Vice President, Nuclear Operations Division

+ * C. M. Shuster, Manager, Nuclear Engineering Department (NED)

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

D. J. Takas, General Supervisor, Maintenance Section (PP00)

+ R. A. Stratman, General Supervising Engineer, Operations Section, (PPOD)

R. P. Jadgchew, General Supervising Engineer, Instrumentation and Controls Section (PP00)

A. F. Silakoski, Operations Section (PP00)

+ F. R. Stead, Manager, Perry Plant Technical Department (PPTD)

W. R. Kanda, General Supervising Engineer, Technical Section (PPTD)

S. F. Kensicki, Technical Superintendent (PPTD)

• P. A. Russ, Licensing and Compliance Section (PPTD)

• T. L. Heatherly, Licensing and Compliance Section (PPTD)

• G. S. Cashell, Licensing and Compliance Section (PPTD)

• L. L. Vanderhorst, Radiation Protection Section (PPTD)

+ * E. Riley, Manager, Nuclear Quality Assurance Department (NQAD)

B. D. Walrath, General Supervising Engineer, Operational Quality Section(NQAD)

T. A. Boss, Supervisor, Quality Audit Unit (NQAD)

• R. H. Simmons, Operational Quality Section (NQAD)

+ Denotes those attending the management meeting held on June 5, 198 * Denotes those attending the exit meeting held on June 25, 198 The inspector also contacted other licensee and contractor personnel during the course of this inspectio . Licensee Action on Previous Inspection Findings (92701) (0 pen) Open Inspection Item (440/85060-01(DRSS)): Complete the testing and acceptance of the Technical Support Center (TSC)

ventilation and radiation monitoring systems. The inspector reviewed the results of the TSC ventilation system testing and has no further concerns in that area. That review is addressed in Paragraph 7 of this inspection repor (0 pen) Open Inspection Item (440/85060-02(DRSS)): Complete the testing and acceptance of the Emergency Operations Fac11P.y (EOF)

ventilation and radiation monitoring systems. The inspector reviewed the results of the EOF ventilation system testing and has no further concerns in that area. That review is addressed in Paragraph 7 of this inspection repor (Closed) Unresolved Item (440/85069-01(DRS)): Discrepancies noted in Revision 0 of a number of Startup Test Instructions (STIs). The procedures in question were STI-J11-004, STI-C51-012, STI-C91-018,

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and STI-C91-019. The licensee has revised PAP-1104, "Startup Test Program," to require an Operations Quality Section (0QS) signature on the cover sheet of all STIs. This 0QS approval will ensure that the STI is correct as written, e.g., steps are referenced correctly, and steps and attachments are numbered correctly. The inspector has completed the review of the Revision 1 STIs listed above, and verified that they have been properly reviewed and approved for use by the licensee. The inspector has no further concerns in this are d. (Closed) Open Item (440/85069-02(DRS)): Complete review of Startup Test Instruction STI-C91-013, " Process Computer." The inspector has verified that the licensee has reviewed and approved this Revision 1 STI in accordance with the Perry FSAR and PAP-1104. The inspector has no further concerns in this are e. (Closed) Open Inspection Item (440/85085-01(DRP)): Licensee to pe"#orm a review of Alarm Response Instructions (ARIs) and provide a description of their program to assure alarm setpoints and Technical Specification changes are reflected in plant procedure The inspector performed a sample review of ARIs including ARIs identified as being discrepant during the initial ARI inspection (440/85085), and found that technical specification references and alarm setpoints agreed with the current Perry Plant Technical Specifications. The licensee's written response concerning this item, from Mr. Murray R. Edelman to Mr. Charles E. Norelius, dated May 13, 1986, was found to be acceptable. The inspector has no further concern with this ite f. (Closed) Open Inspection Item (440/86005-01(DRP)): Resolution of an observed step increase of 1.5 inches in the suppression pool indicated water level on both the narrow range and wide range level recorders during the January 31, 1986 earthquake. The inspector reviewed the licensee's analysis and conclusions regarding the probable cause of the step change in t.he level instrumentation. The licensee concluded that the most probable cause of the indicated level change was release of air, during the earthquake, which had been entrapped in the sensing lines due to improper filling and venting following a prior suppression pool outage. As a result of the licensee's analysis, a design change to add two additional highpoint vents to each of the two suppression pool level sensing lines was initiated. Installation of the design change was accomplished via Work Orders 86-6314 and 86-6315 which were closed out on May 17 and May 10, 1986, respectively. The inspector has no further concerns in this are g. (0 pen) Violation (440/86006-01(DRP)): System Operating Instruction (S0I) deficiencie In a letter dated March 4,1986, from M. Edelman to J. G. Keppler, the licensee committed to perform a detailed technical review of all SOIs for systems defined as safety-related 1.- PAP-0205, Revision 3, " Operability of Plant Systems," prior to use under the operating license. That commitment

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was incorporated into Attachment 1 of the facility operating license. The inspector verified during this inspection period that the S0Is required prior to the initial criticality milestone had received a detailed re-review by the operations departmen Followup inspection of further licensee 50I reviews will be documented under this ite (Closed) Violation (440/86008-03(DRP)): Failure to properly control operational conditions affecting out of service boundary. The inspector reviewed the licensee's response to this violation contained in a letter from M. R. Edelman to J. G. Keppler dated May 28, 1986. The inspector verified that PAP-1401, " Equipment Tagging," Temporary Change Notice (TCN) No. 12, incorporated appropriate ccntrols to prevent recurrence of this event. The inspector reviewed training records for Operations and Maintenance personnel to ensure the inclusion of PAP-1401, TCN-12. No recent examples of this type of violation have been noted. The inspector has no further concerns in this are (0 pen) Violation (440/86008-04(DRP)): Failure to provide controls necessary to establish the operating status of safety related instruments. In a letter dated March 14, 1986, from M. R. Edelman to J. G. Keppler, the licensee committed to imoplement Special Project Plan 1401, " Instrument Valve Lineup Verification." That commitment was incorporated into Attachment 1 of the facility operating license. The inspector verified that the instrument valve walkdowns, as-built drawings and valve tagging were completed for instruments required for initial criticality (Operational Condition 2). The inspector selected five instruments (1E12-N0056A, IC61-N006, IC41-N004A,1E31-N076B, and 1E21-N0052) to field verify the adequacy of the licensee's action. One discrepancy was noted on the Low Pressure Core Spray pump discharge pressure instrument which supplies an Automatic Depressurization System actuation permissive. The discrepancy was a drain valve shown on the drawing that did not exist in the field. The licensee's instrumentation and Control Section and Operational Quality Section reverified the completed walkdowns on approximately 150 instruments for initial criticality with only six other discrepancies noted. The inspector had no further concerns prior to initial criticalit Further licensee actions will be documented under this ite . _ Followup On An Allegation (99014)

(Closed) Allegation (RIII-86-A-0089): The inspector was contacted by an ex-PNPP employee (the individual) who provided the following potential safety concerns. The individual stated that these concerns were brought to the licensee's " Call For Quality" organization during the individual's exit interview, conducted in January 198 '

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. Due to upper management pressure, Master Deficiency List (MDL) items were being improperly removed from the MDL. The individual stated that shortly after Thanksgiving (1985), the list was drastically reduced without proper justification. The individual and another named employee allegedly complained to management about this concer An audit was performed on the MDL by the licensee's Quality organization. During the audit, the individual stated that the Supervisor of the MDL group avoided audit findings by deceiving the auditors. The individual said that the supervisor was overheard saying that he avoided audit findings by giving the auditors copies of the current MDL and a "1030 report." The individual believed that the auditors compared the MDL to the 1030 report and found no discrepancies. The individual stated that the 1030 report is only a reformatted copy of the MDL, a fact the auditors probably would not have known. The individual believes the auditors should have compared a sample of the MDL items to source documents to determine the accuracy and completeness of the MD Items were not always being added to the MDL, such as fuel load required work orders, probably to deceive the NRC as to the true number of outstanding items that were required to be completed prior to fuel load. The individual stated that, had the MDL management been stronger, this may not have occurre NRC Inspector Followup The inspector performed a review of the licensee's " Call for Quality" files and found a file with similar concerns (Concern No. 66). The file contained a detailed report of the licensee's review of the above allegations and also included an unsigned letter addressed to the '

individual providing a summary of the licensee's review. When asked why the letter had not been sent to the individual the " Call for Quality" Supervisor stated that he was not satisfied with the content of the letter, and intended to have it rewritte l The inspector reviewed the licensee's investigation results which concluded that the concerns were unsubstantiated. With the individual's approval, the inspector informed the " Call for Quality" Supervisor of the individual's call to the NRC and was told by the supervisor that they would expedite the closure of the file and have a letter mailed to the individual in the near futur After the letter was received by the individual, the inspector called the individual to assure that the individual's concerns were adequately addressed to the individual's satisfactio '

The individual informed the inspector that the individual felt the " Call for Quality" response to the concerns were inadequate. Below are excerpts from the " Call for Quality" response letter, a summary of the individual's disagreement with the response, and the inspector's followup inspection results.

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, " Call' For Quality" Investigation Results of Concern A.

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" Call for Quality investigated the method the project utilized to track fuel load restraints. We found the Issues and Items list was the primary list the project used to track restraints to fuel loa While the MDL was part of this list, other tracking mechanisms such as the PPMIS [ Perry Plant Maintenance Information System], NR

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' [NonConformance Report] tracking system, and AR [ Action Request]

tracking system were also part of this list. Consequently, Roc.

Code "5" [ Work orders Required by Fuel Load] were not always required to be incorporated into the MDL since they were being tracked on the PPMIS which was their primary tracking mechanism."

Individual's Disagreement With the Investigation Results

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During the inspector's followup phone call, the individual felt that many items were not included in the " Issues and Items List." The individual stated that the PPMIS was unreliable and prior to the individual leaving the site, some licensee employee's were

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reluctant to use this syste NRC Inspector Followup-During the time frame that the individual worked at the site, the NRC was using the licensee's Issues and Items List as an indicator of the plant's readiness for license. The licensee had been using i the MDL to document all required activities without performing a i

critical evaluation of the need for each of the items to be completed prior to fuel load. Also, many items were being tracked

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by more than one system making it very difficult for the licensee

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and NRC to determine accurately how much work was left to be

, completed prior to fuel load at any given point in time.

, Partially as a result of NRC concern for the large number of items

! indicated as being required to be completed by fuel load on the MDL, l when considering the licensee proposed fuel load date at the time,

! the licensee undertook a massive re-evaluation of the MDL program.

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The re-evaluation included removing or not including items that were addressed by other items or tracking systems or considered not

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essential to safe operations, such as nonrequired enhancements, and i

periodic maintenance. The NRC was aware of this re-evaluation, including the procedural changes required to accomplish the changes i to the MDL Program.

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In addition, due to concerns raised by the NRC in October 1985, that the MDL may not contain all fuel load items, the licensee performed l an extensive audit of the MDL program. This audit included taking a

! sample of source documents, which included Work Authorizations j (WAs), ROC Code 5 (required by fuel load) Work Orders (W0s),

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Nonconformance Reports (NRs), Deficiency Reports (DRs), Field Deviation Disposition Requests (FDDRs), Field Disposition

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Instructions (FDEs), Field Variance Authorizations (FVAs), and Test

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Exceptions, and comparing them to the MDL to assure they were included in the MDL. The NRC had reviewed the inspection plan, which included verifying over 300 source documents, prior to the Audit Team beginning the audit. The Audit Team results indicated that all but one item was properly accounted for and this item was a nonsafety related DR, issued in 1981 (prior to the formation of the MDL).

The inspector reviewed the licensee's Audit report (Audit 85-36) and found it to be complete and in order. In addition, a review of the PPMIS system during a recent inspection of the Perry maintenance program, reported in Inspection Report 50-440/86008, rewaled that although the system was initially unreliable (primarily due to excessive computer down time), improvements had been made and the system has been used as the primary method of tracking all Work Orders as of November 15, 1985. The inspector also contacted the other employee that allegedly complained to management about the improper removal of MDL items. The employee did not have any concerns with the MDL system other than that the consolidation of MDL items made it harder to find particular items from an administrative point of view, but did not, to the employee's knowledge, result in items being improperly removed from the MD Based on the licensee's audit, the re-evaluation of the MDL program, the inspector's review of the audit report and PPMIS, the interview

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with the other employee alleged to have complained about this concern, and lack of specific examples of items allegedly not included in the MDL and therefore possibly not completed, the concern about items not being included in the " Issues and Items List" is considered closed as unsubstantiated. The individual's concern about the PPMIS being unreliable and not being used prior to the individual leaving the site was substantiated in that initially the system was unreliable, primarily due to excessive computer down time. However, after improving the system, the licensee began using the system as the primary method of tracking all work orders. Full PPMIS implementation began in November 1985, and required backfitting of incompleted manually initiated work activitie Therefore, the lack of a reliable PPMIS during the time frame identified by the individual, would not in itself result in work activities being unidentified or not completed as require b. Call For Quality Investigation Results Of Concern " Call For Quality reviewed the results of the audit in question. As a result of our investigation we found that during the audit, the auditors attempted to verify that the MDL contained all construction related work items. During the audit they were unable to locate a number of work activities on the MDL because they were being tracked under different work documents. When this was brought to the attention of the MDL lead, he noted that the 1030 printout provided some information which the MDL did not. This 1030 report enabled the auditors to locate the work activities in question. Call For

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Quality found that while the MDL and the 1030 report are derived from the same computer program, they do, in fact, contain different information and enabled the auditors to verify that all construction work activity was being tracked on the MDL system."

Individual's Disagreement With the Investigation Results The individual did not believe that source documents could have been used. The alleger said the audit took only about 1 to 1-1/2 hours and that only the MDL and 1030 reports were use NRC Inspector Followup Subsequent to calling the individual, the inspector reviewed the audit report in question (Audit 85-36) and (with the individual's permission) discussed the individual's concern with the " Call For Quality" Supervisor who was also the Supervisor of the Quality Audit unit. As discussed in Concern No. 1, this audit included a

, verification of over 300 source documents. The audit report indicated that the audit took two individuals 10 days to complet When the inspector questioned the Quality and Audit Unit Supervisor about the individual's concerns, the inspector was told that his audit team had reported numerous source documents that could not be found on the MDL. The Supervisor then had a meeting with the MDL supervisor to discuss these discrepancies. The MDL supervisor produced a 1030 report that was derived from the MDL but arranged in a way that allow the Audit Supervisor to determine that the items in question were in fact tracked in the MDL but identified under a different source document. The Audit Supervisor stated that the meeting took about an hour and that the individual may have thought that was the audit rather than a followup of audit concern ! From the review of the audit report and the discussions with the

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Audit Supervisor, the inspector concluded that this concern is unsubstantiated and is considered close c. Call For Quality Investigation Results Of Concern " Call For Quality investigated the process of closing out MDL items with emphasis on the time period which you noted in your concer Our investigation revealed that a number of cpen MDL items were closed during this time period. At this time the MDL was being purged to eliminate duplicate entries as well as entries which were being tracked on other tracking mechanisms such as the PPMIS which were already incorporated in the Issues and items list. Since these items were being tracked to fuel load using other mechanisms, Call For Quality found no program violations relating to this activity."

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Individual's Disagreement With the Investigation Results Initially, the individual agreed that many items were consolidated or included on other lists but felt that these other lists were not an adequate tracking system. Also, the individual felt that some items were removed from the MDL with no justification at all. The individual'had no examples of this but gave the inspector four names of Perry personnel that the individual felt could both substantiate the allegation and provide examples. The individual subsequently called several of these other employees and later reported to the inspector that this concern was in error due to the individual's misunderstanding of the scope of the revised MDL progra NRC Inspector Followup The inspector contacted three of the employees on the list of names provided by the individual and questioned them about the validity of the above concern; the fourth person no longer worked at Perry. Two of the individuals contacted stated that to their knowledge there was nothing wrong with the current system for tracking plant deficiencies and did not believe items were closed or removed from the MDL without proper justification. The third individual stated that a great deal of pressure was placed on Perry employees by management to remove items from the MDL by resolving them or properly tracking them, but knew of no examples of items being removed without them either being closed or tracked by other system Based on these interviews and the individual's statement that the concern was in error, this item is considered unsubstantiated and closed.

I Additional NRC Findings Although the licensee used the MDL to track identified work activities required by defined milestones, it was not the primary document used to declare systems operational. The licensee implemented Special Project Plan (SPP) 1028, " Fuel Load Achievement," that required a system Operability Verification (S0V)

checklist be completed for each system prior to declaring the system operational. In order for the System Responsible Engineer (RE) to complete this S0V checklist, they were required to review all source documents and assure that they were either closed or added to the MDL. All MDL items deferred beyond fuel load required RE evaluation. Special Project Plan 1028 was implemented on April 7, 1986, four months after the individual left the site. The licensee's method of assuring that all deficiencies had been resolved prior to declaring a system operational appeared to be

adequate. The NRC reviews of system deficiencies identified subsequent to declaring the systems operational have not identified discrepancies that would indicate that pre-operational items may have been deliberately or inadvertently closed prior to their resolutio ___

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The inspector contacted the individual on May 21, 1986, and presented the individual with the inspector's findings and conclusions. The individual agreed with the inspector's conclusions and had no further concerns with the Perry facilit ' Operational Safety Verification (71707)

The. inspectors observed control room operations, reviewed applicable logs, and conducted discussions with control room operators during this inspection period. The inspectors verified the operability of selected emergency systems, reviewed tag-out records and verified tracking of Limiting Conditions for Operation associated with affected component Tours of the intermediate, auxiliary, reactor, and turbine buildings were conducted to observe plant equipment conditions including potential fire hazards, fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for certain pieces of equipment in need of maintenance. The inspectors by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection control These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications,10 CFR, and administrative procedure No violations of regulatory requirements or deviations from commitments were identified in this are . Licensee Event Reports Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification LER 86004-0 " Cognitive Personnel Error Causes Effluent Monitor Technical Specification Violation" LER 86005-0 " Chlorine Gas Monitor Faults Cause Control Room Emergency Recirculation Actuations" LER 86006-0 " Neutron Monitoring System Spikes Result in Manual and Automatic RPS Actuations" LER 86007-0 " Failure to Follow Procedures Causes Inoperable Containment Isolation Valve" LER 86008-0 " Personnel Oversight Causes Containment Integrity Technical Specification Violation"

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LER 86010-0 " Personnel Did Not Implement Tagout Causing Uncompensated Fire System Impairment" Regarding LER 86005-0, similar events have occurred since the event described in this report and those will require submittal of a LE Further licensee actions to prevent recurrence will be reviewed with the future report Regarding LER 86006-0, the LER is satisfactory, however, further followup of this event is being tracked under open items identified in Inspection Report No. 440/8601 . Onsite Review Committee (40700)

The inspectors reviewed the minutes of the Plant Operations Review Committee (PORC) meetings No. 86-86 through 86-116, conducted prior to and during the inspection period to verify conformance with PNPP procedures and regulatory requirements. These observations and examinations included PORC membership, quorum at PORC meetings, and PORC activitie No violations of regulatory requirements or deviations from commitments were identified in this are . Licensee Action on License Conditions (92701)

In a letter dated February 27, 1986, the licensee committed to complete outstanding preoperational testing activities at appropriate post fuel load operational milestones. That commitment was incorporated into Attachment 1 of the operating licens The inspector examined the results of the preoperational testing activities identified in the referenced letter to be completed prior to initial criticality and verified that the results were properly reviewed and approved in accordance with the licensee's administrative procedures. Test results for the following systems were examine Liquid Radwaste System (G50)

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Solid Radwaste System (G51)

Emergency Service Water System (P45)

Combustible Gas Control System (M51)

Traversing Incore Probe System (C51D)

Containment Vessel Cooling System (M11)

Fuel Handling Area Ventilation System (M40)

Technical Support Center Ventilation System (M52)

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Emergency Operations Facility Ventilation System (MS3)

No violations of regulatory requirements or deviations from commitments were identified in this are . Onsite Followup of Events - Operating Reactors (93702) At 11:45 A.M. on June 20, 1986, the licensee declared an unusual event due to a fire existing in two of the Offgas System Charcoal Adsorber beds. At the time of the declaration of the unusual event, both resident inspectors were in the Regional office in Glen Ellyn, Illinois. Shortly after the declaration, the Region III office activated and manned the Incident Response Center with the Senior !

Resident Inspector and other regional personnel. The Resident Inspector was immediately dispatched to the site and arrived on site that evening. Throughout that evening and the remainder of the weekend, the resident inspection staff monitored licensee response to the event, including establishment of a nitrogen purge and monitoring charcoal bed temperatures and products of combustion in the offgas effluent. The licensee's initial response to the fire following declaration of the unusual event was generally ,

satisfactory. During the next inspection period the inspector will l review in detail the licensee's actions prior to declaration of the event and the licensee's efforts to identify root cause of the fir This inspection activity will be documented under open inspection

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item (440/86014-01(DRP)). On June 11, 1986, Corrective Action Request (CAR) 86-04 was issued documenting a violation of the administrative procedure controlling review of intent temporary changes to surveillance instructions i (SVIs). It was discovered during routine quality assurance activities that several intent temporary changes to SVIs had been

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! l processed using presigned forms, where the reviewer's signature appeared on a blank form and the review date was entered by the i originator of the change. Consequently, it was not possible to ,

l confirm that the required independent review by a qualified I l individual had been performed on those changes. The utility, in response to this identified deficiency, proposed extensive corrective actions and steps to prevent recurrence, including re-review of all intent temporary changes issued during the period involved with this event, personnel action against the individuals involved, training of individuals on the importance of adherence to administrative procedures, and investigation of the extent of this l type of activity including whether or not other administrative i controls were affected. The inspector will review the licensee's l actions in response to this issue during subsequent inspection.

l This review will be documented under open inspection item l (440/86014-02(DRP)).

i No violations of regulatory requirements or deviations from commitments

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were identified in this are l

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Management Meeting (30702)

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On June 5, 1986,.Mr. James G. Keppler, Region III Administrator, and other members of his staff conducted a management meeting with l Mr. Murray R. Edelman, Nuclear Group Vice President, and other members of

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his staff regarding Region III concerns over operating events and troubleshooting efforts.

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. Reactor water cleanup system suction automatic outboard containment isolation valve rendered inoperable without compensatory measures

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(LER86-007-0)

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I .. Unit 1 plant vent radiation monitor taken out of service without compensatory measures (LER 86-004-0)

. Fire water system manual containment isolation valves left open without compensatory measures (LER 86-008-0)

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i Carbon dioxide compensatory fire sup(pression measures LER86-010-0)system made inoperable without l The root cause of these operating events appeared to be multiple i personnel errors. The licensee was informed that while these types of l events and numbers of events are not uncharacteristic to newly licensed facilities, strong management attention is required to ensure that the root causes are addressed and recurrence prevented. The licensee responded describing the corrective actions and analyses performed as a result of these events and discussed the steps taken to prevent recurrence.

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The troubleshooting efforts discussed at the management meeting included:

. Fuel handling equipment problems (not a reportable event)

. Nuclear instrumentation noise problems (LERs 86-001-0 and 86-006-0)

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. Reactor protection system logic problems (LER 86-006-0)

. Rod control and information system problems (LER 86-001-0)

. Control rod drive system hydraulic control unit bolting problems (LER86-014-0)

Regional management expressed concern that initial troubleshooting efforts involved in response to these equipment problems was not always logical and well planne The licensee responded by describing recent personnel reassignments and organizational changes made in the PNPP organization. Those changes are described in detail in a letter dated May 30, 1986, from M. R. Edelman to R. M. Bernero. The reorganization should provide stronger technical management and engineering support to operation .

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While certain of these issues resulted in enforcement action in Inspection Report No. 440/86011, no further violations of regulatory requirements or deviations from commitments were identified in this are . Startup Test Witnessing - Full Core Shutdown Marsin Determination and Intermediate Range Monitor / Source Range Monitor Cverlap (72302,72526)

The inspector witnessed the conduct of Startup Test Instructions (STIs)

J11-004, " Full Core Shutdown Margin," and C51-010. "IRM/SRM Overlap".

The inspector determined by direct observation that; licensee operating and test personnel were knowledgeable in their individual roles and responsibilities, adequate communications were established and maintained throughout the tests, and the approach to criticality was conducted in a cautious, deliberate, and highly professional manner. Prior to and during the subject tests the inspector verified the following:

. Conformance with selected technical specifications requirements and license conditions applicable during the initial approach to critica . SRM and IRM nuclear instruments had been properly calibrated and were operating with required count rate and signal-to-noise rati . Channel functional tests had been performed on nuclear instruments, and instruments had been demonstrated to cause a scram in noncoincidenc . Crew requirements were being met as defined in plant procedures, and staffing satisfied requirements of technical specifications regarding licensed operator . The proper versions of the test procedures were in use were being followed. All referenced procedures had been reviewed and approve . Each of the prerequisites had been satisfie . Changes or revisions to the test procedures were properly reviewed and approve . Data sheet entries were legible and recorded in permanent in . Proper rod pattern after two banks, and at critica Review of the test results as well as the licensee's evaluation and disposition of test deficiencies associated with IRM channels C and D will be conducted during a future inspectio No violations of regulatory requirements or deviation from commitments were identifie .

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11. Open Inspection Items Open inspection items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. Open inspection items disclosed during the inspection are discussed in Paragraph . Exit Interviews (30703)

The inspectors met with the applicant representatives denoted in Paragraph 1 throughout the inspection period and on June 25, 1986. The inspector summarized the scope and results of the inspection and discussed the likely content of the inspection report. The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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