IR 05000440/1986032

Safety Insp Rept 50-440/86-32 on 861110-14 & 17-21.No Violations,Deviations or Safety Significant Issues Identified.Major Areas Inspected:Applicant Actions on Previous Insp Findings & Evaluation Re Maint Activities

ML20215C470
Person / Time
Site:	Perry
Issue date:	12/08/1986
From:	Knop R, Scheibelhut C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215C456	List: IR 05000440/1986032 ML20215C453
References
50-440-86-32, NUDOCS 8612150164
Download: ML20215C470 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/86032 (DRP)

Docket No. 50-440; 50-441 License No. NPF-58 =

Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101

Facility Name: Perry Nuclear Power Plant, Units 1 and 2 I

Inspection At: Perry Site, Perry, OH 5 Inspection Conduc : N vegab r 1 -14 nd 17-21, 1986 g Inspector: Sche b hut  !

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Approved By:

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R. C. Knop, Chief Dat b, jb Reactor Projects Section 1B Date '

Inspection Summary y Inspection on November 10-14 and 17-21, 1986 ( Report No. 50-440/86032 (DRP)) $

Areas Inspected: Routine safety inspection by a NRC Contractor Inspector and Ei the Resident Inspector of app.. ant actions on previous inspection findings, W and evaluation of applicant action with regard to maintenance activitie j

'Results: Of the two areas inspected, no violations, deviations, or safety significant issues were identifie {

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DETkILSL v s

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1. ' Personnel Contacted *

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1. F. R Stead,: Manager, ' Perry Plant Technical: Department (PPTD) f!

p .#P.(A.;RussFLead' Compliance-Engineer,PPTDL

'#D. J. Takacs',1 General. Supervisor, Maintenance, Perry Plant: Operating

LDepartment (PPOD);

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1. TE G R Swansiger/ Material-Control Supervisor, PPOD-

V. K'.1Higaki, General Supervising Engineer, Nuclear Quality Assurance Department:(NQAD)

1. R.:L. Vondrasek,sGeneral Supervising Engineer, Engineering Project; iSupport Services,' Nuclear: Engineering Department-(NED)

1. A. F.'Silakoski, General Supervising Engineer, Reliability and Design-

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Assurance, NED:

1. G. S.1Cashelli. Licensing Engineer,~PPTD

"D. C.-Jones,' Licensing Engineer, PPTD

1. Denotes those attending the exit' meeting-held on November 21, 198 ;

.The. inspector;also contacted other licensee-employees and contractors, p

, ^ Licensee: Action on Previous Inspection Findings (92701) (Clos'ed) Open Item (440/86008-02(DRP)): In a review of the Elicensee's Mechanical / Electrical Preventive Maintenance ~(MEPM)

program, the Inspector identified the following concerns:

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1. ) - Section 6.5 of Plant Administrative Procedure (PAP)-0906,

" Control of Mechanical / Electrical Maintenance", permitted the work supervisor to reschedule repetitive tasks without concurrence from the Technical Section engineer or the Nuclear Design and Analysis Section (NDAS). This could result in the loss of environmental qualification for safety-related equipment if certain maintenance tasks were postpone .) Section 6.8 of PAP-0903, " Repetitive Task Program", stated that if a repetitive task were " missed", the Repetitive Task Program (RTP) (in the computer) should close the task, enter the task as " missed" in the task history file, and reschedule the task'

for the following day. However, it was found that the RTP closed the task, entered it as " missed" in the task history file, and rescheduled it as though it had actually been completed. Therefore, there was no automatic alerting system for identifying missed tasks and it was possible that a task might not be performed for extended lengths of tim .) Section 6.6 of PAP-0906 provided instructions for revising repetitive tasks that did not require review by NDAS when equipment qualifications were involved. Since NDAS had the

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responsibility for assuring qualification of equipment, this

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f 4. )f During (the- course of a: subsequent inspection (documented . in ', . n

Inspection Report 50-440/86011), the' inspector.was' notified b ' theilicensee ofJan ? incident ~ during which a -Work Order was T Lwritten

to; implement' revisioni0 of a' Design Change Package'

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(DCP),( By the time work commenced, revision 2 of the.DCP.was

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J; issued that; contained substantial changes. This-resulted in- .

.the installation of incorrect-equipment. -While this discrepancy was. identified'by theTlicensee,' the inspector, r

elected to-follow the licensee's corrective actions under this open' item.:

sin < response to the 1 concerns, the ~ licensee took the following actions

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, 12) Temporary Change ~ Notice (TCN)-004 to PAP-0906. changed Seetion 6.8.to require concurrence by the Technical Section Engineer and NDAS before the Work. Supervisor can authorize rescheduling ' of any repetitive task. The' inspector reviewed

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the TCN and found that the change had been made. The. inspector Tinterviewed one work supervisor and found that he was aware'of the chang ,

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2.)' PAP-0903'wa's revised (revision 3). Section 6.8~was revised to

, require that when a repetitive task'is active (between its earliest and~ latest completion dates) it must be deleted,

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completed, or rescheduled by:the. latest date or it will be considered outstanding and identified on an Outstanding-

Repetitive Task Report. Upon closing a task as completed previous to the task latest date, the task will be entered in

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the history as " completed" upon closing. Upon closing a task as-completed later ths.n the task latest date the task will be entered in the history as " completed late" upon closing. To accomodate the above change, Information Services change request'RTSK-86-296 was issued.to modify the-RTP. The RTP was to be changed so that a new outstanding repetitive task report is generated showing all tasks not closed by the latest completion date; a task is closed only on entry of the actual completion date; and a task is rescheduled only after it is close The inspector reviewed revision 3 of PAP-0903 and found that it was revised as stated. During interviews with licensee maintenance personnel, the inspector determined that the RTP was performing in accordance with Section 6.8 of PAP-0903 revision 3 and change request RTSK-86-29 .) TCN-004 to PAP-0906 changed Section 6.6 to require NDAS concurrence for revising a repetitive task that was Equipment Qualification related. Revision 1 to Plant Operating Procedure (POP)-0701, "PNPP Equipmen* Qualification Program For Safety-Related Equipment", added a note to section 6.6 stating that environmental qualification special maintenance and replacement requirements shall not be missed or rescheduled without prior approval from NDA e

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The inspector reviewed. TCN-00'4 to! PAP-0906 and 'revisibn '1 of POP-0701 and found they were as stated. During: interviews with'

licensee maintenance personnel and NDAS personnel, the inspector determined that they were aware of the NDAS concurrence requirements when repetitive tasks involving ~'

equipment. qualifications were revise t 4.) Action Request ~(AR) 0077 dated 5/2/86 was written to determine

'cause, provide corrective action,.and delineate steps to prevent recurrence. The cause.was found to be-inattention to detail by theLmaintenance supervisor and craft personnel

. assigned to the work order. Corrective action consisted of revising' the work order to reflect revision 2 of the DCP and performing the work in accordance with the work order. To prevent recurrence',-a policy memo was written to all maintenance supervisors, field engineers, and lead supervisors emphasizing their responsibilities and the programmatic requirements within the work order process. A separate memo was issued.to all grade I mechanics emphasizing their responsibilities. The inspector reviewed the documentation associated with the action request and found it to be responsive to the problem. Interviews with pertinent licensee personnel indicated that they understood the content of the memo Based on the above, the inspector concluded that the concerns were adequately addressed and concluded that the item is close (Closed) Unresolved Item (440/86017-01(DRP)): During a review of the licensee's Design Changes and Modification Program, the inspector found that no completed Design Change Packages (DCPs) had been transmitted to the permanent records vault. The DCPs were filed in engineering pending final review and update of drawings to the as-built configuration. Because installation for some of the packages had been completed for several months, the inspector was concerned that timely reviews and processing of DCPs were not being performe o respond to this concern, the licensee issued Program Revision Notice 2/86 to Nuclear Engineering Instructions (NEI)-0357, " Design Change Packages", Revision 0. The PRN detailed the required review and processing of work-completed DCPs so as to provide a completcly reviewed and approved DCP for transmittal to the permanent record vault. To provide consistent review and processing of DCPs work completed prior to the effective date of the PRN, the licensee has required that they also be reviewed and processed in accordance with the PR The inspector reviewed the PRN and found that it provided an effective review and processing instruction for work-completed DCPs. The inspector also determined that of the 560 DCPs that were work completed prior to the effective date of the PRN, 510 have been reviewed and processed in accordance with the PRN. The balance, 50, had to wait for the current planned outage to perform required field

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inspections. Thesefare expected to be completed in the next few-

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L Based on these actions, the inspector has no further concerns in this, are (Closed) Unresolved Item;(440/86017-02): In conjunction with the-same review detailed in paragraph 2.b. above,'the inspector also

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Lfound-that the completed work order (which provides the DCP installation record) ~did not indicate the revision of the DC While the_ information was available in the computerized status and 3 racking' system JDor work orders, the inspector was -concerned that the computerized information was not afforded appropriate quality assurance record protectio In response to this concern, revision 5 to PAP-0905, " Work Order Process", contained requirements that the revision level of all-documents, including DCPs, used in the installation of DCPs be identified on the Work Order Closing and Summary Shee The inspector _ reviewed revision 5 of PAP-0905 and found the

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requirements as stated. Interviews with appropriate personnel indicated that this requirement was understood and being implemented. _Since the Work Order Closing and Summary Sheet is part of a completed DCP, the information is provided appropriate quality assurance record protection, (Closed) Open Item (440/86021-01(DRP)): During a review of the licensee's design change program, the inspector found that a contractor was being used to perform the work required by DCP work orders. In a review of _the Work Order packages, it was found that the contractor was using his own work procedures to perform the work in lieu of licensee procedures. While the inspector had no specific safety concerns with the Work Orders reviewed, two generic concerns were expressed. One, the licensee appeared to lack a program that assured that changes to their installation procedures are also reflected in the contractor installation procedures. Two, changes to contractor installation procedures did not appear to require licensee engineering revie On further review, the licensee found that Plant Administration (PA)

procedure 502, " Review of Contractor's Paocedures", covered the concerns. Specifically, PA 502 requires:

1.) The contractor's installatica procedures must meet the requirements of the licensee's installation specification (The licensee's installation procedures must also meet these specifications.)

2.) The contractor's procedures must be reviewed and approved by the license _

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-3.) 'Any revisions to_the contractor's procedures must.also be-

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reviewed and approved'by-the licensee.

l 4.) The contractor _ must be notified of any revisions to the cinstallation' specifications To further assure that no discrepancies existed, the licensee-required.the contractor (letter PY "E" SO #3546 dated July 31,-

1986) to review his procedures (a total of four) to-determine

'if the technical requirements of the licensee's installation specifications were defined and incorporated-in the procedures. By letter of_ August 15, 1986 to the licensee, the contractor stated that no discrepancies were~ foun The inspector reviewed the PA and th'e contractor's letter giving-the results of the review and found-that'the concerns were adequately addressed. ~The inspector has no further concerns in this are No violations of regulatory requirements or deviations from ccmmitments were identifie Maintenance Program Implementation / Monthly Maintenance Observations (62700, 62703)

The inspector observed / reviewed the work in progress on three safety-related mechanical work order ' Work Order No. 86-13699 covered the shop rebuilding of a damaged heating and ventilating damper operator. At the time of the observation the work was approximately 95% complete. The work package was present and the two mechanics were following the step-by-step procedure. Parts and materials present were properly certified. The work package was reviewed and found to be in accordance with PAP-0905, " Work Order Process". QC hold and witness points were stamped and initialed. The inspector reviewed the training records of the mechanics and found they were qualified to perform the wor Work Order 86-15107 covered the routine refurbishing of two spare control rod drives. The work was essentially complete with final external cleaning and preparation for storage in progress. The inspector did not enter the " clean room" area. However, the work order package was visible and being used, and a QC inspector and a vendor representative were in attendance. Further observation and review were not done in this instanc Work Order 86-9506 was a trouble-shooting work order to determine the cause of unusual noises from the division 2 screen wash pump located in the emergency service water pump house. The equipment identifier was OP49-C0002B. When it was found that the causi was a damaged pump motor bearing, the work order was revised to replace the pump motor bearing At the time of the observation, the mechanical work on the motor was almost complete with the electrical re-termination and motor-pump realignment remaining. Two mechanics and a QC inspector were presen The work order package was at the work area and was reviewe The review-6-

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. indica,tedithat:11.t;was:in accordance with PAP-0905, permission to do the

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work'had been.given,(electricalLtag-outs!were-identified 1(and' observed),-.

s ir ~^ w -;QC hold points had been stamped and' signed, and' post-maintenance: testing

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swasLspecified.: cSince' the fplantJatatus was a plannedioutage,{and- Division :

'* 11.was.' ope able,:nollimiting conditions for operations'were impose Because:o:';the work location, radiological and fire prevention controls

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f ;were not 1 ecessary. A l review Lof training records 11ndicated that. the

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mechanics were qualified.

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Alreview of; outstanding safety-related mechanical work orders indicate , (that; thera.were none. :This.was expected because the plant was almost at

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~ the'end of a planned outag ~

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Many maintenance activities require the use'of solvents. The use of improper l solvents .can cause premature equipment fai'ure or contribute to~-

Lcracking?of stainless steel piping. . The inspector: reviewed the?

slicensee's' controls on the use of solvents in the plant. PAP-0803,

" Chemical Control Program",.is the administrative procedure that controls;

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thel use of all. chemicals at the plant. To use a chemical for any

purpose, % chemical permit'must be submitted. This form-lists the chemical:and'its. intended use. The permit is reviewed (by two different organizations) and, if appropriate, approved. The chemical is then

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-listed on an " Approved Chemical Index" with reference to the chemicalc

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permit. . While subsequent use of the same chemical for the same purpose'

requires the su.bmission of a chemical permit, review is not required if reference to the index and the original' permit shows the original approval. . In addition, work orders must list solvents used, if rpertinent, .and the work order also is reviewed before approval. The

. inspector considered these controls adequate and has no further. concerns in-this: are Since all activities affecting quality must be accomplished by documented

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' instructions', procedures, etc. and these instructions must be reviewed and approved, vendor manuals used or referenced by maint(nance procedures are required to have the same level-of review and approval as the procedure. The inspector reviewed the licensee's controls of vendor

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manuals for safety-related equipment. PAP-0609, " Vendor Manuals", is the administrative prociedure that controls vendor manuals. This procedure requires a review and apprcval of all vendor manuals for safety-related equipment. The levd of review and approval is the same as that required

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by4he maintenance procedures they supplement. Any subsequent vendor changes or amendments also receive the same review and approval. Sheets documenting the reviews and approvals are filed with the manuals in the document control center. When pertinent parts of a manual are included in a work order, the parts are photo-copied, identified, and stamped with a 30-day expiration date to prevent possibly invalid information from being used in the futur The inspector reviewed a number of randomly selected vendor manuals in the document control center and found the required review and approval sheets. During the review of the work package for the screen Wash pump motor repair mentioned earlier, photocopies of pertinent parts of the vendor manual were observed with the required identification and expiration date. The insoector considered these controls to be adequate and has no further concerns in this are '

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, . 3 ;y. JNo. violations.ofiregulatory gequirements okdeviations from comitments ?

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J;9 T N. J EEit' Meeting l: ' '

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U ' i Thelinspector meti with"thefresidentLinspector: and. licensee . _,

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Crepr' esentativesi(denoted iri paragraph'11 at -the conclusion.of the

, einspection'onl November?21, 1986._- Thefresident: inspector summarized the.~ .

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scope.:and L findings ' ofl the inspection. , The licensee. acknowledged' the -.

. inspectors: findings. Theilicensee did not indicate that any of the

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p, f 'information-disclosed-during the-. inspection could be' considered

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