IR 05000440/1987022

Insp Rept 50-440/87-22 on 871103-1221.Violation Noted.Major Areas Inspected:Adequacy of 10CFR50.59 Safety Evaluations

ML20234C189
Person / Time
Site:	Perry
Issue date:	12/29/1987
From:	Darrin Butler, Hasse R, Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20234C171	List: IR 05000440/1987022 IR 07100103/2012021 ML20234C168
References
50-440-87-22, NUDOCS 8801060140
Download: ML20234C189 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

I Report No. 50-440/87022(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: November 3 through December 21, 1987 O lt!seg [D j

Inspectors: . Hasse '

Team Leader Date '

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D. %' M h utler I1lM [17 Date S Q, P. R.'R's eske Ic2;>lm2Q)[h Date '

% % e w \\e Approved By: Monte P. Phillips, Chief \lfd 67 Operational Programs Section Date j Inspection Summary l Inspection on November 3 through December 21, 1987 (Report No. 50-440/87022(DRS))

Areas Inspected: Adequacy of 10 CFR 50.59 Safety Evaluations (conducted under IE Module 92702).

Results: One violation was identified: failure to perform a safety evaluation when required by 10 CFR 50.59 (Paragraph 2.b(3)).

l 8801060140 87122'9 DR ADOCK 05000 0 PDR l

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DETAILS Persons Contacted C,leveland Electric Illuminating Company

• Lyster, General Manager, Perry Plant Operations Department (PP00)

• • B. Ferrell, Licensing and Compliance

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

• B. Walrath, Manager, EPSS, Nuclear Engineering Department (NED)

• D. Green, Manager, EDS, NED

• E. Buzzelli, Manager, LCS, PPTD

• Pech, Manager, MDS, NED

• Chasko, PP0D

• Dunn, Supervisor, Compliance, PPTD

• Igyarto, Supervisor, PP0D

• J. Lausberg, Supervisor, Operations Support and Programs, Nuclear Quality Assurance A. Migas, EDS, NED J. Eppich, MDS, NED US NRC

• K. Connaughton, Senior Resident Inspecter G. O'Dwyer, Resident Inspector

• Denotes those who attended the preliminary exit meeting on December 2, 198 ** Denotes those participating in the exit meeting held by telecon on December 21, 198 The inspectors also contacted other licensee personnel as a matter of routine during the course of the inspectio . 10 CFR 50.59 Safety Evaluations Purpose and Scope The purpose of this inspection was to determine if the safety evaluations performed by the licensee pursuant to 10 CFR 50.59 were adequate to identify any unreviewed safety question or required change to the technical specifications and if the bases for conclusions were adequately documente During this inspection the inspectors reviewed the program for conducting safety evaluations and a sample of the safety evaluations ,

performed for permanent plant modifications, temporary modifications,

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operating procedure changes, special tests, startup test procedure changes, and test exception reports (TER) written against startup test acceptance criteria. A listing of pertinent documents reviewed is given in the appendi ____ _ ____________ -

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DETAILS Persons Contacted Cleveland Electric Illuminating Company

• M. Lyster, General-Manager, Perry Plant Operations Department (PPOD)

• • B. Ferrell, Licensing and Compliance

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

• B. Walrath, Manager, EPSS, Nuclear Engineering Department (NED)

• D. Green, Manager, EDS, NED

• E. Buzzelli, Manager, LCS, PPTD

• K. Pech, Manager, MDS, NED

• G. Chasko, PP0D

• G. Dunn, Supervisor, Compliance, PPTD

• D. Igyarto, Supervisor,.PP0D

• J. Lausberg, Supervisor, Operations Support and Programs, Nuclear Quality Assurance A. Migas, EDS, NED J. Eppich, MDS, NED

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US NRC

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• K. Connaughton, Senior Resident Inspector G. O'Dwyer, Resident Inspector

• Denotes those who attended the preliminary exit meeting on December 2, 1987.

, ** Denotes those participating in the exit meeting held by telecon on l December 21, 198 The inspectors also contacted other licensee personnel as a matter of routine during the course of the inspection.

1 CFR 50.59 Safety Evaluations Purpose and Scope

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The purpose of this inspection was to determine if the safety

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evaluations performed by the licensee pursuant to 10 CFR 50.59 were adequate to identify any unreviewed safety question or required change to the technical specifications and if the bases for conclusions were adequately documente During this inspection the inspectors reviewed the program for conducting safety evaluations and a sample of the safety evaluations performed for permanent plant modifications, temporary modifications, operating procedure changes, special tests, startup test procedure changes, and test exception reports (TER) written against startup .

test acceptance criteri A listing of pertinent documents reviewed I is given in the appendi )

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b. Inspection Results (1) Program The conduct of these safety evaluations was governed by two procedures, PAP-0305 " Safety Evaluations" (PP0D/PPTD) and NEI-0332 " Safety Evaluations" (NED). The procedures were similar except for administrative detail and some technical emphasis based on the types of *< ty evaluations performed by the two groups. Salient features of the program described in these procedures are as follows:

• No distinction is made between safety-related, important-to-safety, or nonsafety-relate The process is controlled by the impact of the change on the technical specifications and the licensing basis (FSAR, SER, SSERs, etc.).

• The need for a safety evaluation is determined via a documented applicability check. This process determines if there is a change to the plant as described in the FSAR, a change to a procedure / instruction as described in the FSAR, a test or experiment not described in the FSAR, or if a change to the technical specifications is required. An attachment to the procedures provides guidance for completing the applicability chec The guidance provides a discussion of each item and typical examples. If a positive determination is obtained for any of the applicability check items, a safety evaluation is require * Guidance for the performance of safety evaluations is included in another attachment to the procedure This guidance also provides a discussion and typical example * Both the applicability checks and safety evaluations receive a peer review and are approved by a General Supervising Engineer (GSE). Safety evaluations are also reviewed by the Plant Operations Review Committee (PORC).

• The preparer and reviewer for both applicability checks and safety evaluations must be qualifie The qualification involves the completion of a required reading list, attending a formal eight hour training class, and completion of a written examinatio * The NED procedure requires that each discipline involved in a modification prepare an applicability and safety evaluation as appropriat The inspectors concluded that the program aescribed by these procedures provided a generally adequate structure for performing safety evaluations as well as determining

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when one was required; however, the violation described in

. Paragraph 2.b(3) and the concern expressed in Paragraph 2.b(6).

below indicate that the guidance and training in the areas of technical specification bases and the term "as described in the FSAR" could be strengthene Licensee management should revicw

'these area (2) Plant Modifications Permanent plant modifications are controlled by a Design Change j Package (DCP) proces This process is controlled by the NED which also performs the applicability checks and safety evaluation The inspectors reviewed 38 DCPs which included 38 applicability checks and 22 safety evaluations. No violations or deviations i were identified. Documentation of the applicability checks and safety evaluations was adequate and had been performed by the appropriate discipline The technical issues were correctly and completely addresse (3) Temporary Modifications The licensee monitors and. controls the temporary installation and/or removal of Mechanical Foreign Items / Lifted Leads, Jumpers., and Electrical Devices (MFI/LLJED) by Procedure

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PAP-1402, " Control of Lifted Leads, Jumpers, Temporary

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Electrical Devices and Mechanical Foreign Items." All MFIs and LLJEDs were required by Procedure PAP-1402 to have a 10 CFR 50.59 applicability check performed in accordance with Procedure PAP-305, " Safety Evaluations." In addition, all MFIs and LLJEDs were technically evaluated for system effects, operating instruction effects and plant limitation Approved MFI/LLJED Tag Orders werc maintained outside the control roo i The tag orders were reviewed monthly by a system engineer and quarterly by a designee of the Unit Supervisor. After the third monthly review, the system engineer was responsible for issuing a Work Order to remove the MFI/LLJED; initiating an Engineering Design Change Regrest (EDCR) to make the MFI/LLJED permanent; or initiating a facility Change Request (FCR) along .

with Nuclear Engineering Department (NED) concurrence that the  ;

MFI/LLJED could remain in effect to a specified dat The inspectors reviewed six temporary modification One violation was identifie The licensee installed (LLJED No. 1-87-077) a harmonic smoothing filter choke in each electrical phase of the HPCS Division III diesel generator immersion water jacket heate The water jacket heater was described in FSAR Chapter 9.5.9. The heater thermostatically maintains the jacket water and lube oil warm to provide the engine with the capability to start a

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quickly. The licensee performed a 10 CFR 50.59 applicability

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check and answered no to all the questions. It appeared to the inspectors that question No. 1 (Is there a change to the plant as described in the FSAR?) should have been answered ye The addition of the smoothing filters is a change to the water jacket heater circuit and as such requires a safety evaluation to be performe The licensee concurred with the inspectors that LLJED No. 1-87-077 was a change to the plant as described in the FSAR and a safety evaluation should have been performe A 10 CFR 50.59 safety evaluation was performed and approved by the PORC on December 2, 1987 prior to the end of the inspection. The evaluation determined that an unreviewed safety question did not exist. The inspectors concurred with this conclusion. This might be considered an isolated case; however, in view of a previous violation (50-440/87003-03(DRP))

issued for the failure to perform safety evaluations for temporary modifications, a continuing weakness in this area may be indicated. The failure to perform a safety evaluation for LLJED No. 1-87-077 is a violation of 10 CFR 50.59 (440/87022-01(DRS)).

(4) Special Tests The inspectors reviewed four special tests and the associated applicability checks and safety evaluations. No violations or deviations were identifie (5) Procedure Changes The inspectors reviewed all changes to five operating procedures (including one emergency operating procedure)

and the associated applicability checks and safety evaluations. No violations or deviations were identifie (6) Startup Tests The inspectors reviewed the changes to six Startup Test Instructions (STI) and the associated applicability checks and safety evaluations. The safety evaluations included those performed in support of Test Exception Reports (TER).

The inspectors had one concern involving the documentation of the bases for concluding that the margin of safety for any technical specification was not reduced. The Level 1 criteria for startup test STI-833-0308 " Recirculation Pump Trip" could not be met in that the recirculating pump flow coastdown was faster than specified in the acceptance criteria flow band. A test exception report (TER-285-1) was written against this discrepancy. The NSSS (GE) resolution of the TER stated that credit is taken for the flow coastdown in the LOCA analysis and is important during the first 1-2 seconds following the brea It further stated that the coastdown rate measured at Perry

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would increase the peak cladding temperature (PCT) during a LOCA by no more than 10 F from that previously calculated (2131 F). Thus, there was still margin to the 10 CFR 50.46 limit (and safety limit) of 2200 F and the measured coastdown was acceptabl The licensee properly performed a 10 CFR 50.59 safety evaluation (SE-87-0335) since the acceptance criteria described in Chapter 14 of the FSAR could not be met. The licensee concluded that there was no reduction in the margin of safety as defined in the basis for any technical specification (based on the GE resolution) and that the flow coastdown was not covered by technical specifications. The bases for Technical Specification 3.2.1 " Average Planar Linear Heat Generation Rate (APLHGR)" states that these limits are based on a LOCA analysis. Since credit is taken for the flow coastdown in the LOCA analysis, it is part of the bases for the APLHGR limit Further, the potential increase in PCT during a LOCA could represent a decrease in the margin of safety for technical specification 3. j The Field Deviation Disposition Request (FDDR) written to l change the Level 1 criterion for this test referenced 10 CFR '

50, Appendix K.II.1.b, as a basis for the acceptability of this chang This section of the appendix states that a change in the LOCA model resulting in a change of 20 F or less in the calculated PCT is not significant and does not require the filing of an amendment with the NRC. The licensee stated that this was the basis for concluding that no unreviewed safety question existed; however, this was not explicitly identified or referenced in the safety evaluation nor was the technical specification of concern explicitly addressed. The inspectors were satisfied that no unreviewed safety question existed and the appropriate analyses had been performed; however, they had a concern that the technical specification safety margin may not have been explicitly considered in the evaluation proces The inspectors reviewed a second safety evaluation (SE 87-0484)

in which a technical specification safety margin was an issu This safety evaluation was written in support of the resolution of TER 339-1 to STI-B21-027 " Turbine Trip and Generator Load Rejection Test." In this case the bypass valve capacity did not meet the 35% rated steam flow as used in the accident analyses in Chapter 15 of the FSAR. The technical spec!fication cf concern in this case was 3.2.2 " Minimum Crithi Power Tatio (MCPR)." The bases for this limit states that the limit is established such that the safety limit for MCPR (1.06) is not exceeded during any abnormal operating transient. The safety evaluation in this case explicitly addressed the technical specification of concern and provided adequate analyses to show that an unreviewed safety question did not exist. T M , the failure to explicitly address technical specification margins (as in the first example) did not appear

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to be a generic preolem; however, the small sample available for review precluded a definitive conclusio Licensee management should reevaluate the guidance and training given in this area as discussed in Paragraph'2.b(1) of this repor . Exit Interviews The-inspectors met with licensee representatives (denoted in Paragraph 1)

on December 2, 1987 to discuss the scope and preliminary findings of the inspection. A final exit meeting was held with a licensee representative (also denoted in Paragraph 1) via telecon on December 21, 1987. The licensee stated that the likely content of the report would contain no proprietary informatio Attachment: Appendix, Documents Reviewed

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Appendix Documents Reviewed Controlling Procedures PAP-0305, " Safety Evaluations," Revision 4 NEI-0322, " Safety Evaluations," Revision 0 Modifications DCP No. 86-0221: ESW Pump House Pressure Switch DCP No. 86-0251: ERIS System Additions DCP No. 86-0289: RWCU Delta Flow Temperature Compensation DCP No. 86-0352: ECCW Pressure and Flow Transmitters-High Point Vent Valves DCP No. 86-0358: Change Fuse Rating for Refueling Bridge DCP No. 86-0371: RWCU Differential Flow Meter DCP No. 86-0377: RWCU Isolation Test Switch DCP No. 86-0393: Startup Neutron Source Change DCP No. 86-0481: Relay Changes 1 DCP No. 86-0495: Mounting Brackets for Instrument Calibration Chambers 1 DCP No. 86-0500: HCU Hold Down Bolts 1 DCP No. 86-0514: HCU Branch Junction Module Changes 1 DCP No. 86-0521: Main Steam Leak Detection Flow Element Connector 1 DCP No. 86-0567: Add Weld to Shroud Head 1 DCP No. 86-0572: EPIS Signed Deletion 1 DCP No. 86-0665: Add Time Delay Relays to MSIV Leakage Control System 1 DCP No. 86-0714: Add Time Delay to RWCU Irolation Timer 1 DCP No. 86-0719: Replace RPS Transformer 1 DCP No. 86-0804 A-D (5 Modifications): RWCU Design Changes 2 DCP No. 86-0875: Replace Fuse with a Resistor on DADC 2 DCP No. 86-0883: Jib Crane As-built Resolution 2 DCP No. 86-1013: Modify CRD Valve 2 DCP No. 86-1042: Modify Reactor Head Vent Flange 2 DCP No. 87-0076: Rewire Feedwater Master Level Controller 2 DCP No. 87-0108: Add Cross Connect Valve in Common Drain Line Between DG Division I and II Air Receiver Tanks 2 DCP No. 87-0486: Modify APRM Flow Cards 2 DCP No. 87-0123: Change Valve From N0 to NC and from DC to AC Operator 2 DCP No. 87-0234: Add Drain Line and Isolation Valve to RHR/RCIC Steamlines 2 DCP No. 87-0724: Change to DG Control System 3 DCP No. 87-0216: Change Limit Switch Gasket Material 3 DCP No. 87-0304: Add Injection Plugs to MSIV Leakage Control Valve 3 DCP No. 87-0037: Add Time Delay to Recirculation Pump Trip from RRCS

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m 3 DCP No. 87-0756: Chenge Valve to Close on High Vessel Pressure Rather Than High Drywell Pressure 3 DCP No. 86-0493: Add Hi-Point Vents to Impulse Lines Temporary Modifications MFI No. 1-87-250: Install Temporary Sensing Line Snubbers LLJED No. 1-87-296: Lift Lead and Install Jumper in Feed Pump Circuitry LLJED No. 1-87-305: Add Redundant Relay Contacts to Feedwater Control System MFI No. 1-87-326: Install Pipe Cap on Root Valve Test Connector MFI No. 1-87-416: Install Thermocouple to Monitor MSIV Solenoid Temperature LLJED No. 1-87-077: Install Harmonic Smoothing Filters in Division III DG Immersion Heaters Operating Procedures (Changes) E21, "LPCS" I0I-6, "Cooldown - Main Condenser Not Available" ONI-R42-3, " Loss of DC Bus ED-1-C" ONI-Sil, " Loss of Offsite Power" PEI-M51/56, " Hydrogen Control" Startup Tests (Changes and TERs) STI-E51-14, "RCIC" STI-821-25A, "MSIV" STI-B33-308, " Recirculation Pump Trip" STI-833-300, " Recirculation Runback" STI-E12-71, "RHR" STI-821-027, " Turbine Trip and Generator Load Rejection Test" Special Tests SXI-0010, "N61 Condenser Temperature Test," Revision 0 SXI-011, "RCIC Vessel Injection Test," Revision 0 SXI-012, "RCIC Injection / Reactor Vessel Level Anomaly Test,"

Revision 0 SXI-013 "RCIC Injection Following Level Instrument Reference Leg Nozzle Insert," Revision 0 2