IR 05000440/1987005

Insp Rept 50-440/87-05 on 870316-20.Violations Noted:Form OAP-0507-5 Not Completed for Validation of Rev 1 of Plant Emergency Instructions Required by Administrative Procedure OAP-0507

ML20206C818
Person / Time
Site:	Perry
Issue date:	04/01/1987
From:	Hasse R, Love R, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206C769	List: IR 05000440/1987005 ML20206C765 ML20206C775
References
50-440-87-05, 50-440-87-5, NUDOCS 8704130166
Download: ML20206C818 (6)

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>4 U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No: 50-440/87005(DRS)

Docket No: 50-440 License No: NPF-58 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, Ohio 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio Inspection Conducted: March 16 through March 20, 1987 Inspectors: R. A. Hasse g - I O R.S.Lovekkg,N!p bl-l - % 7

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Approved By: P , Chief Operational Programs Section Date

/7 Accompanying Personnel: I. Schoenfeld, NRR i

Inspection Summary Inspection on March 16-20, 1987 (Report No. 50-440/87005(DRS))

Areas Inspected: Special announced safety inspection to detemine if Emergency Operating Procedures (E0Ps) were prepared and validated in accordance with the approved Procedures Generation Package. The inspection was conducted in accordance with IE Temporary Instruction TI 2515/7 Resul ts: One violation was identified: Violation of 10 CFR 50, Appendix B, Criterion V, - failure to follow procedures (Paragraph 2.b.(3)).

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DETAILS 1. Persons Contacted Cleveland Electric Illuminating Company (CEI)*

C. Shuster, Manger, Nuclear Engineering Department R. Stratman, General Supervising Engineer, Operations Section B. Ferrell, NRC Interface Lead, Licensing and Compliance Section F. Berg, Supervising Operator, Operations Section F. Stead, Manager, Perry Plant Technical Department G. Chasko, Operations Engineer, Operations Section W. Colvin, Nuclear Engineer, ISEG, Nuclear Engineering Department G. Dunn, Compliance Engineer, Licensing and Compliance Section B. Walrath, General Supervising Engineer, Operational Quality Section USNRC*

K. Connaughton, SRI, PNPP I. Schoenfeld, NRR Other personnel were contacted.as a matter of routine during the inspectio *All personnel listed participated in the exit interview held on March 20, 198 . Emergency Operating Procedures Emergency Operating Procedures (E0Ps) have undergone significant changes as a result of the 1979 accident at the Three Mile Island facility. The new E0Ps are required to be symptom-oriented rather than event-oriente Generic Letter 82-33, " Requirements for Emergency Response Capability" (Supplement 1 to NUREG-0737) required all licensees and applicants to submit to the NRC for approval a Procedure Generation Package (PGP)

describing their plan for developing the upgraded E0Ps. The PGP consists of four parts:

Plant-Specific Technical Guideline (P-STG) - the technical basis for the new E0Ps. For the Perry Nuclear Power Plant (PNPP), this consists of the Guidelines (GTG) plant-specific previously version approved by the of the Generic Technical NR Plant-Specific Writers Guide (P-SWG) - the details of the specific

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methods to be used by the licensee in preparing the E0P A description of the program for verification and validation (V&V)

of the E0P A description of the program for training operators on the E0P The purpose of this inspection was to determine if the licensee's E0Ps had been prepared and validated in accordance with their NRC approved PGP. This was accomplished by a detailed comparison of a sample of E0Ps

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against the approved PGP (effectiveness of operator training was twered in Examination Report (50-440/0L-86-01). Documents Reviewed The following documents were reviewed during this inspection:

(NOTE: The E0Ps at the PNPP are titled Plant Emergency Instructions (PEIs)).

(1) 0AP-0507, " Preparation of Plant Emergency Instructions",

Revision (2) PEI-B13, " Reactor Pressure Vessel Control", Revision (3) PEI-D23-1, " Containment Temperature Control", Revision (4) PEI-D23-2, "Drywell and Containment Pressure Control",

Revision (5) PEI-D23-3, "Drywell Temperature Control", Revision Inspection Results The inspectors determined that the licensee's E0Ps were generally prepared, verified, and validated in accordance with the PG Although one violation and several other items of concern were identified, the overall program showed evidence of good management control. The licensee was responsive to the violation and concerns and initiated immediate corrective action when appropriate. The violations and other items of concern are discussed in the following paragraph (1) Plant-Specific Technical Guidelines The technical bases for the E0Ps were found to be adequately documented; however, two concerns were identified:

(a) The technical bases for the E0Ps consisted of the P-STG, submitted to and approved by the NRC as part of the PGP, plus _ change documentation generated for E0P revisions s controlled by PAP-0507, " Preparation, Review, Approval, Revision, and Cancellation of Instructions". The revision documentation contained the basis for the change. These changes were supported by appropriate 10 CFR 50.59 safety evaluations. The original revisions of the E0Ps did not deviate from the P-STG except as documented via Verification Deviation Sheets which were also supported by 10 CFR 50.59 safety evaluations when appropriat This method of documenting the current technical bases for E0Ps effectively amends rather than directly revises the P-STG as changes to the technical bases are made. While this process adequately maintains a documented technical basis, the basis for a specific action or action point

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could be documented in one of three places, the P-STG, a Verification Deviation Sheet, or in PEI revision documenta-tion. Thus, search for a specific basis could be cumbersom The licensee is currently considering methods for directly revising the P-STG as changes in technical bases are mad This will be tracked as an open item (440/87005-01).

(b) The inspectors identified one discrepancy between the Generic Technical Guidelines (GTG) and the P-STG. In the sequence of steps in reactor. coolant level control (guideline RC/L-2), the operator is' instructed to maintain level above the " top of active fuel" (TAF). The TAF is a plant specific value. The next step states that "if the level can be maintained above TAF, reset the Automatic Depressurization Systems (ADS) Timer." The P-STG uses two different coolant levels for TAF in this sequence of steps, 0" in the first step and +16.5" in the second ste Originally, the licensee had selected +16.5" (the level at which ADS timing initiates) as TAF for their plant. Prior to submitting the P-STG to the NRC for review, this was changed to 0". The failure to change the value in the second step was an oversight. The E0P was written consis -

tent with the P-STG. The discrepancy had -little safety significance. The licensee has initiated action to correct the discrepancy. Completion of this action will be tracked as an open item (440/87005-02).

(2) Plant-Specific Writers Guide The P-SWG provides the details of how the E0Ps will be prepare In part, it provides the control of human factors issues in E0P format and presentatio While no violations were identified in this area, the inspectors made a number of recommendations for human factors improvement In addition, several concerns were identified:

(a) There was fairly frequent usage of notes and cautions containing conditional action statements. The licensee agreed that this was not consistent with the general guidelines for the use of notes and cautions; however, they felt there was no other means for highlighting action statements of special significance. The licensee agreed to explore other possibilities for highlighting such action statement (b) Graphs included on the left hand (facing) page as operator aids were at times illegible, cut off on top, and generally cluttered the page. Further, the Writers Guide allowed the violation of margin and grid line requirements when reduced graphs were used on these pages. The licensee noted that full sized graphs were attached to the procedures; however, they agreed to improve the quality and layout of the " facing page" aid ,

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. 4 (c) Some of the E0Ps in the control room had some nearly illegible or faded wording at various points in the procedure. The licensee initiated immediate corrective action during the inspectio These items will be examined further in a future inspection and will be tracked as an open item (440/87005-03).

(3) E0P Verification and Validation The purpose of the verification and validation (V&V) effort is to ensure the technical adequacy and usability of the E0Ps. The licensee's V&V program was documented in 0AP-0507, " Preparation of Plant Emergency Instructions, and was consistent with commitments made in the PG The inspectors reviewed V&V documentation for the current E0Ps, performed a control room walkthrough to determine the consistency between E0P and control room terminology, and reviewed videotapes of simulator exercises using the plant E0Ps. One violation was iaentified:

Procedure 0AP-0507, Attachment 5, "PEI Validation Plan," requires in section 3.1.5 that form 0AP-0507-5, "PEI Validation Form" be completed by the Operations Section General Supervisor. This form documented the validation method to be used for a particular E0P revision, designated observers and reviewers, and completion of the validation process. The form was the planning and control document for the validation process and contained no validation

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data. The inspectors determined that this form had not been completed fc the validation of Revision 1 of the E0Ps. While it was evident trem other documentation that the planning and control functions had been executed, the failure to complete this form represents a failure to follow procedures and is a violation of 10 CFR Part 50, Appendix B, Criterion V (440/87005-04).

(4) Operator Training As noted in Paragraph 2 of this report, the effectiveness of Operator Training in the use of the E0Ps had been addressed in a previous Examination Report. However, the inspectors did identify one item of concern in the area of operator trainin The commitments made in the PGP relative to operator training, while incorporated into lesson plans, had not been incorporated into the training program control documentation. The licensee stated that this effort was in progress with anticipated completion in May 1987. Completion of this effort will be tracked as an open item (440/87005-05).

3. Training and Qualification Effectiveness As noted earlier, the effectiveness of operator training in the use of E0Ps had been previously addressed. The qualifications of personnel involved in the generation and V&V of the E0Ps was assessed during this

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inspection. The inspectors concluded that the technical qualifications of involved personnel were acceptable. Overall knowledge of the E0P control program was good with a weakness evidenced by violation (440/87005-04). When asked why the "PEI Validation Form" had not been completed, a licensee representative stated that it contained only a summary of information (!ocumented elsewhere and was, therefore, of little importanc This response indicated a weakness in knowledge of the need for procedural I compliance as well as the intended planning and control function of the for . Open Items Open items are matters which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 2.b (1)(a), 2.b.(1)(b),

2.b.(2), and 2.b.(4).

5. Exit Interview l

The inspectors held an exit interview with licensee representatives (denoted in Paragraph 1) on March 20, 1987. The inspectors summarized i the purpose, scope, and findings of the inspection. The licensee stated l that the likely informational content of the report would contain no l proprietary informatio l l

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