IR 05000440/1986025

Insp Rept 50-440/86-25 on 860911-1016.Violation Noted:On 860711,technicians Performing Maint to Replace Electrical Termination Screw Failed to Follow Precautions

ML20213E558
Person / Time
Site:	Perry
Issue date:	11/05/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213E414	List: IR 05000440/1986025 ML20213E409 ML20213E461
References
50-440-86-25, IEB-86-001, IEB-86-1, NUDOCS 8611130216
Download: ML20213E558 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/86025(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, Ferry, OH Inspection Conducted: September 11 through October 16, 1986 Inspectors: K. A. Connaughton G. F. O'Dwyer J. W. McCormick-Barger B. H. Little C. H. Brown Approved By:

gc R. C. Knop, Chief 4 Il[F[F5 Reactor Projects Section IB Date Inspection Summary Inspection on September 11 throuch October 16, 1986 (Report No. 50-440/86025(DRP))

Tr'eas Inspected: Routine unannounced inspection by resident and region based inspectors of previous inspection items, I.E. Bulletins, 10 CFR Part 21 Reports, allegations, surveillance test activities, startup test activities, Licensee Event Reports, operational safety, and onsite review activitie Results: Of the 9 areas inspected, one violt.iion was identified with four examples in one area (failures to conduct activities affecting quality in accordance with prescribed instructions - Paragraph 9). During this inspection period, augmented inspector coverage was maintained during low power operations. Inspector observations of operating activities were generally favorable. The rate at which Reportable Events occurred remained higher than desirable.

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DETAILS 1. Persons Contacted 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 (PP0D)

• R. A. Stratman, General Supervising Engineer, Operations Section, (PP0D)

R. P. Jadgchew, General Supervising Engineer, Instrumentation and Controls Section (PP0D)

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

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

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

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

• E. M. Buzzelli, General Supervising Engineer, Licensing and Compliance Section (PPTD)

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

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

• Denotes those attending the exit meeting held on October 16, 19 The inspector also contacted other licensee employees and contractor . Licensee Action on Previous Inspection Findings (92701, 92702) (Closed) Open Item (440/85059-01(DRP)): Development of an abnormal operating procedure for loss of reactor cavity / fuel storage pool water inventory. The inspector reviewed Off Normal Instruction (ONI) G41, " Loss of Reactor Cavity / Fuel Storage Pools Level (Unit 1)," Revision 0, dated January 10, 1986. The subject ONI listed indications, including annunciator alarms and changes in plant operating parameters, available to the operator to identify a loss of water inventory in the reactor cavity or fuel storage pool The ONI directed immediate actions for suspending core alterations, the placement of in-transit fuel assemblies in safe locations, and evacuation of personnel from the affected areas. Supplemental actions for the identification and isolation of possible leakage paths and for restoring water inventory were also prescribed in the ONI. The inspector has no further concerns relating to this matte (Closed) Open Item (440/86008-01(DRP)): Identification of tha root cause for the installation of probe data receiver cards in the rod control and information system which were of the improper revisio Licensee inquiries conducted pursuant to this item disclosed that General Electric, the supplier of the cards, had misidentified the revision level of the cards. By letter dated May 23, 1986, General Electric informed the licensee that new part numbers were not assigned to cards revised for application at Perry and other similar facilities. New part numbers should have been assigned to the revised cards since they were not interchangeable with previous revisions. When General Electric shipped the cards to Perry, the

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part numbers of the cards were verified to be the same as those requested, however, the revision levels of the cards were not checked. According to General Electric, procedures had since been changed to assure that the identified problem did not recu Additionally, General Electric performed a survey of printed circuit cards to determine if any cards in safety-related applications had been supplied to customers without suitable identification of restrictions on interchangeability. No such instances were identified. The inspector has no further concerns in this are (0 pen) Unresolved Item (440/86018-01(DRP)): Investigation and resolution of electrical lineup procedural and equipment labeling discrepancies. In response to this item, the licensee conducted walkdowns and comparisons of existing electrical circuit breaker and switch labels, electrical lineup instructions and as-built electrical design drawings. As a result, several identified discrepancies were resolved by revision of electrical lineup instructions or the installation of temporary labels to eliminate the potential for operator error due to confusion between equipment labels and equipment identifiers contained in electrical lineup instructions. Additional actions to be taken by the licensee to address this matter included the fabrication and installation of permanent equipment labels. Upon completion of these actions, the inspector will verify on a sampling basis that consistency has been achieved between permanent equipment labels, electrical lineup instructions and, electrical design drawing (Closed) Violation (440/86018-02(DRP)): Failure to report less of Special Nuclear Material in a timely manner. The inspector reviewed the licensee's response letter dated September 12, 1986, which specified that revisions had been made to administrative procedures to extend licensee controls for Special Nuclear Material to nuclear instrumentation and to include a definition to assist personnel in determining when Special Nuclear Material is actually lost. The inspector reviewed Plant Administrative Procedure (PAP)-0802,

" Control of Special Nuclear Material," Revision 1, dated August 11, 1986, and Refuel Instruction (FTI)-D02, "SNM Physical Inventory,"

Revision 1, dated July 30, 1986. The inspector determined from this review that the procedures had been revised as stated in the licensee's response. Proper implementation of these procedures should preclude the occurrence of similar violations in the futur The inspector has no further concerns in this are . Inspection and Enforcement Bulletin (IEB) Followup (25581)

(Closed) IEB 86-01 (440/86001-BB): " Minimum Flow Logic Problems That Could Disable RHR Pumps." The inspector reviewed the licensee's response letter dated June 6, 1986, and determined that it had been submitted within 7 days of licensee receipt of the subject IEB. The licensee's response stated that the Perry RHR system was not susceptible to the single failure vulnerability described in the subject IEB. Each Perry RHR pump had an associated minimum flow valve controlled by a separate

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s l flow element in the discharge path for the respective pump. The inspector verified this information by review of the Perry FSAR as well as controlled, as-built piping and instrument diagrams for the RHR system. Based upon the foregoing, none of the additional actions specified in IEB 86-01 were applicable to Perr . 10 CFR Part 21 Report Followup (92701) (Closed) 10 CFR Part 21 Report (440/86003-PP) (DAR 264): Saturation point of radiation detectors supplied by Kaman Instruments is indeterminate / unknown. The inspector verified by review of licensee file information that the subject report was reccived, reviewed, and acted upon by the licensee in accordance with established administrative controls. The licensee performed testing specified by Kaman Instruments to determine whether or not the reported defect existed in each of the four high range effluent monitors utilized at Perry. This testing determined that saturation indication occurred at a count rate corresponding to a Noble gas concentration of 1.65 E5 microcuries per cubic centimeter. This value was less than the expected value. It was, however, in excess of the required value of 1.0 E5 microcuries per cubic centimeter. The instrumentation was determined to meet design requirements of NUREG-0737, Regulatory Guide 1.97, and FSAR Table 7.1-4. The licensee concluded that the reported defect did not present a potential safety hazard. The inspector concurred with the licensee's determination, (Closed) 10 CFR Part 21 Report (440/86004-PP) (DAR 265):

Discrepancies in impact test reports of ECCS flow orifice bolting hardware supplied by General Electric. The inspector verified by review of licensee file information that the licensee received, reviewed, and dispositioned the subject report. The licensee determined that ECCS flow orifice bolting installed in Perry, Unit 1 flow elements was not supplied by General Electric. Instead, the bolting was purchased by Pullman Power Products in accordance with installation specification SP-44. The inspector reviewed Pullman Power Products Heat Number Tabulation Forms which identified the suppliers of the subject bolting. This review confirmed the licensee's finding (Closed) 10 CFR Part 21 Report (440/86005-PP (DAR 260): Potential problem with a K-1 relay in the generator voltage regulator on Diesel Generators supplied by Transamerica DeLaval. The inspector verified that the licensee received, reviewed, and appropriately dispositioned the matter raised by the subject report. The K1 relays supplied to Perry by Transamerica DeLaval had an operating range of 100-140 Volts DC, which was contrary to the design specification which required an operating range of 90-140 Volts D If the voltage supplied to the relays was between 90 and 100 Volts DC, the relays may not have operated properly, adversely affecting diesel generator output. The licensee's engineering evaluation involved a calculation of supply voltage to the relay coil under worst case conditions (end of duty cycle voltage)

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accounting for voltage drops between the 125 Volt DC batteries and the relay coils. This evaluation concluded that the minimum supply voltage to the relay coil will be more than 104 Volts DC which exceeded the minimum operating coil voltage of 100 Volts. The licensee, therefore, concluded that no further actions were necessary. The inspector is satisfied that this matter was appropriately addresse . Followup on an Allegation (99014)

(Closed) Allegaticn (RIII-86-A-0138)

On August 19, 1986, a citizen telephoned the NRC Region III office and stated that he/she had recently attended a public meeting in which another person (unidentified) stated that for two days, water was shooting up in Lake Erie by the outfall of the Perry plant. The citizen was concerned that radiation from the Perry plant may be leaking into Lake Eri Inspector Followup The inspector reviewed the subject allegation. The inspector determined; while water was and is being discharged to the lake there was no cause for concern. The water to be released to the lake is processed through a system of tanks and radiation monitors prior to release to the lak Therefore, only water without radioactivity is sent to the lake. Further, at the time the allegation was received, Perry Unit I had virtually no power history and therefore, there existed no significant source term for liquid radiological effluents. The reactor had operated for a total time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 8 minutes, at power levels well below 1% of rated powe . Monthly Surveillance Observation (61726)

On September 20, 1986, the inspector observed the performance of technical specification required testing of the Division 2 Diesel Generator contained in Surveillance Instruction (SVI)-R43-T1318, " Diesel Generator Start and Load Division 2," Revision 1, with Temporary Change Notices Nos. 4 and 5, and verified that testing was performed in accordance with adequate procedures, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that the test results conformed with technical specifications and proudure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne No violations of regulatory requirements or deviations from commitments were identified in this are . Startup Test Results Evaluation (72301)

The inspector verified that the following startup test results were documented, reviewed, and approved by the licensee in accordance with the requirements of Perry FSAR, licensee administrative procedures, and applicable Regulatory Guide .

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STI-C51-010 " Intermediate Range Monitor (IRM) Performance," Revision 2, Sections 8.1 and STI-C51-006 " Source Range Monitor (SRM) Performance and Control Rod Sequence," Revision 1 Section STI-B21-016B " Water Level Reference Leg Temperatures," Revision 2, Section STI-B21-33 "Drywell Piping Vibration," Revision 1, Sections 8.1 and STI-F41-034 " Reactor Internals Vibration," Revision 2, Section STI-N33-129 " Steam Seal Test," Revision 2, Section STI-P44-116 " Turbine Building Closed Cooling Water Test," Revision 1, Section No violations or deviations were identifie . Startup Test Observation (72302)

On October 9,1986, the inspector witnessed various portions of step 8.3, " Single Rod Scram Testing," of Startup Test Instruction STI-C51-011,

" Control Rod Drive System," Revision 2. This testing was accomplished at a. reactor pressure of 552 psi and reactor temperature of 540 F. The appropriate revision of the procedure was available and in use by test and operating personnel. Test equipment in the control room was calibrated, in service, and cross-calibrated to a common time base. The test was performed in accordance with the test procedure. Personnel actions appeared corre.t and timely. Coordination and communications were goo No violations or deviations were identified at the reactor pressure observe . Licensee Event Reports Foliowup (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 86019-0 " Diesel Generator Building Ventilation Fan Autostarts for Unknown Reason" LER 86019-1 " Control Tachometer Problems Cause a Diesel Generator Building Fan Autostart" LER 86023-0 " Chlorine Monitor Fault and Personnel Error Cause Emergency Recirculation Actuations"

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LER 86024-0 " Communication and Knowledge Deficiencies Result in Missed Gaseous Effluent Samples" LER 86026-0 " Technician Inadvertantly Grounds Power Lead Causing Containment Valve Isolation" LER 86028-0 " Deficiency in Test Instruction Results in RPS Actuation Upon Reactor Recirculation Pump Start" LER 86030-0 "CVDPS Damper Failure Due to Solenoid Valve Opens Containment Vacuum Relief Valve" LER 86031-0 " Diesel Generator Building Ventilation Fan Autostarts for Unknown Reason" LER 86031-1 " Control Tachometer Problems Cause Diesel Ger.erator Building Fan Autostarts" LER 86032-0 " Test Instruction Deficiency and Personnel Errors Result in RHR System Isolations" LER 86032-1 " Test Instruction Deficiency and Personnel Errors Result in RHR System Isolations" LER 86034-0 " Failure to Follow Work Instruction Results in RHR System Isolation" LER 86035-0 " Failure to Follow Procedure Causes Reactor Water Cleanup System Isolation" LER 86036-0 " Auxiliary Contact Mechanism Fault Causes Full Scram" LER 86039-0 "RWCU System Design Problems Cause High Differential Flow Isolations" LER 86039-1 "RWCU System Design Problems Cause High Differential Flow Isolations" LER 86040-0 " Misunderstanding of Technical Specification Results in Missed Action and MSL Isolation" LER 86041-0 " Voltage Fluctuations in Battery Charger Output Cause High Pressure Core Spray Actuation" LER 86043-0 " Personnel Error Causes Reactor Water Cleanup System Isolation" LER 86044-0 " Capacitor Failure Results in Loss of Reactor Protection System Bus" LER 86045-0 " Procedure Errors Cause Technical Specification Violations"

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LER 86045-1 " Procedure Errors Cause Technical Specification Violations" LER 86046-0 " Failure to Follow Procedure Causes Effluent Monitor Technical Specification Violation" LER 86047-0 " Procedure Errors Cause Emergency Recirculation Actuations" LER 86048-0 " Deficient Test Instruction and Jumper Connection Result in RHR System Isolations" Events described in LERs 86024-0, 86040-0, 86045-0, 86045-1, and 86046-0 involved violations of Technical Specification requirements. The inspector reviewed these occurrences for significance, method of identification, timeliness and adequacy of licensee corrective actions, and to determine whether or not the violations were repetitive of previous violations. The inspector's review concluded that these violations were identified by the licensee in the course of the performance of activities mandated by existing administrative controls, the violations were of minimal safety significance, corrective actions were prompt and appropriate based upon identified root causes, and the circumstances surrounding the violations were not repetitive of those associated with previous violations. The inspector will continue to monitor licensee performance in these areas and evaluate future identified violations in light of these violations and licensee actions taken to prevent recurrenc Regarding the events reported in LER 86032-0, -1, LER 86034-0, LER 86035, and LER 86043 the inspector determined that certain of the events resulted from violations which were repetitive of previous events for which the licensee was issued Notice of Violation (440/86006-01b(DRP)),

in that activities affecting quality were not conducted in accordance with required instructions, procedures, or drawing One of the events reported in LER 86032-0/86032-1, involved an inadvertant isolation of shutdown cooling on July 12, 1986. Instrument technicians performing a surveillance test violated surveillance test instruction requirements by performing test steps out of sequence. An electrical jumper installed to prevent shutdown cooling isolation during the surveillance test was removed prior to the performance of system restoration steps which would have eliminated the need for the jumpe Licensee corrective actions for this particular event involved additional training of the technicians regarding proper communications when conducting plant evolutions and their responsibilities to maintain strict compliance with test instruction step sequence The event described in LER 86034-0, involved an inadvertant residual heat removal system outboard containment isolation which occurred on July 11, 1986. The event occurred during the performance of maintenance which replaced an electrical termination screw. The technician performing the maintenance failed to perform actions prescribed by the governing work

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instruction to prevent the isolation. Licensee corrective actions conducted in response to this event included training of instrument technicians to emphasize the need to review and follow precautions identified in work packages to prevent unnecessary safety system actuation The event described in LER 86035-0, involved an inadvertant reactor water cleanup system isolation on July 14, 1986. This event occurred during the performance of a channel functional test of main steam line tunnel temperature instrumentation. The instrument technician performing the surveillance test instruction skipped a surveillance instruction step which required returning the reactor water cleanup letdown isolation test switch to the " Normal" position prior to returning the reactor water cleanup letdown isolation bypass switch to the " Normal" positio Licensee corrective actions in response to this event included additional training of the technician, emphasizing the need to read and follow instructions carefull LER 86043-0 also involved an unplanned reactor water cleanup system isolation due to manipulation of the reactor water cleanup letdown isolation bypass switch and reactor water cleanup letdown isolation test switch in an improper sequence on August 5, 1986. Licensee corrective actions in response to this event included the training of control room operators regarding the function and proper operation of the reactor water cleanup letdown isolation test and bypass switches. The particular control room operator involved in this event was counseled to be more cautious when conducting evolutions and to do so in accordance with operating instruction These four events resulted from failures to perform activities affecting quality in accordance with required instruction, procedures, or drawings and are considered examples of a violation (440/G6025-01).

10. Operational Safety Verification /0perational Readiness (71707)

During this inspection period, augmented inspection coverage was provided by the Resident and Regional Office based inspectors. Extensive control room observations were performed by the the inspectors to evaluate licensee shift crew and plant performance. The inspection focused on operators attentiveness and responsiveness to plant parameters and conditions, procedural discipline, maintenance of logs and records, shift turnovers, and overall supervision of plant activitie Operators were ebserved to be attentive and responsive to plant parameters and conditions. Off-normal conditions, events, and significant alarms were promptly acknowledged and communicated to supervisio Operators interviewed demonstrated a positive and responsible attitude towards plant operation and were found to be knowledgeable of plant problems and system and alarm status. Plant logs and records were generally well maintained and current. Chart recorders were appropriately checked and annotated on a periodic basis. Deficiencies were noted in the maintenance of the Emergency Core Cooling System Status Board and the Potential Limiting Condition for Operation Lo . - _ __ _- -_ . _ .

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These appeared to be isolated oversights which were promptly corrected when brought to the attention of supervisory operating personne Subsequent observations indicated that the status board and logs were appropriately maintained. Shift turnovers were observed to be exceptionally thorough. The oncoming crew supervisors and operators devoted approximately one hour to turnover activities. These included detailed discussions, panel walkdowns, log reviews, and attendance at a formal pre-shift briefin Overall Control Room activities were well supervised. Both the Shift Supervisor and Unit Supervisor were in the Control Room providing direction and overview during major testing, plant evolutions, and unplanned events. The control room operators held detailed discussions and procedure reviews with non-licensed operators prior to performing plant evolution The inspectors verified the operability of selected emergency systems, reviewed tag-out records, and verified tracking of Limiting Conditions for Operation associated with affected components. Tours of the intermediate, auxiliary, reactor, and turbine buildings were conducted to observe plant equipment conditions including potential fire hazards, fluid leaks, and excessive vibration. The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security pla The inspectors 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 . Onsite Review Committee (40700)

The inspectors reviewed the minutes of the Plant Operations Review Committee (PORC) meetings No.86-183 through 86-206, conducted prior to and during the inspection period to verify conformance with PNPP procedures and regulatcry 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 . Exit Interviews (30703)

The inspectors met with the licensee representatives denoted in Paragraph 1 throughout the inspection period and on October 16, 198 The inspector summarized the scope and results of the inspection and discussed the likely content of the inspection report. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur . -. . . _ - ._- .- --. __ .- .-_.