IR 05000440/1993008

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Insp Rept 50-440/93-08 on 930419-23.No Violations Noted. Major Areas Inspected:Maint Activities Using Selected Portions of NRC IP 62700 & 92702 to Ascertain Whether Maint Effectively Accomplished & Assessed by Licensee
ML20044E266
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 05/19/1993
From: Jablonski F, Pegg W, Tella T, Walker H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20044E256 List:
References
50-440-93-08, 50-440-93-8, NUDOCS 9305240119
Download: ML20044E266 (7)


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U. S. NUCLEAR REGULATORY COMMISSION l

REGION 11f'

Report No.

50-440/93008(DRS)

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Docket No.

50-440 License No. NPF-58 Licensee:

The Cleveland Electric Illuminating Company 10 Center Road Perry, OH 44081-9514 i

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Facility Name: Perry Nuclear Power Plant

Inspection At: Perry Nuclear Power Plant, Perry, Ohio

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Inspection Conducted: April 19 through 23, 1993

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Inspectors:

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T. Tella, Lead Inspector Date

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c.v. 3w/L rhovs W. D. Pegg /g Da'te

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h-8V S/ 9 '93 n

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Wal ke~r Da te' /

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Approved By:

0.7. M 6//9/93 e

F. J. JablonstF, Chief Date

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Maintenance & Outages Section Inspection Summary Inspection on April 19-23.1993 (Report No. 50-440/93008(DRS))

Areas Inspected: Routine, announced inspection of maintenance activities

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I using selected portions of NRC Inspection Procedures 62700 and 92702 to ascertain whether maintenance was effectively accomplished and assessed by the

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licensee, and to determine if corrective actions were effective.

Results: The inspectors determined that implementation of the maintenance program on the residual heat removal (RHR) system appeared to be generally effective in meeting the safety objectives of the program, except as noted for

,I the RHR strainer issue. This conclusion was reached by a detailed evaluation of maintenance, review of the corrective maintenance backlog, examination of the system's materiel condition, observation of ongoing maintenance work, and

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review of the maintenance self assessment.

Corrective action was adequate for three previously identified violations.

No

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l violations of NRC requirements were identified.

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9305240119 930519 l

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DETAILS i

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1.

Principal Persons Contacted

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The Cleveland Electric Illuminatino Company (CEI)

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  • D. Igyarto, General Manager
  • D. Cobb, Operations Superintendent

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  • W. Coleman, Manager, Quality Assurance Section j
  • V. Concel, Manager, System Engineering
  • K. Donovan, Manager, Licensing and Compliance
  • J. Eppich, Manager, Mechanical Design

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  • D. Graneto, Superintendent, Maintenance

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  • S. Kensicki, Director, Nuclear Engineering
  • E. Riley, Director, Quality Assurance
  • W. Wright, Manager, Instrument Controls

U. S. f4uclear Reaulatory Commission (NRC)

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  • D. Kosloff, Senior Resident inspector

Other persons were contacted as a matter of course during the inspection.

2.0 Licensee Action on Previous inspection Findinos Several issues identified in past f4RC inspections were reviewed for appropriate licensee corrective actions.

The inspectors' evaluations of the corrective actions for these issues are discussed in this section.

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2.1 (Closed) Violation (440/90012-01 A(DRS))

t Inadequate procedures for the removal of main steam isolation valve (M51V) air packs.

The licensee's response, dated December 14, 1990, statec that additional instructions for the removal of MSIV air packs had been provided to maintenance personnel. The inspectors reviewed procedure GMI-0056, "MSIV

Disassembly, Repair, and Reassembly Instructions," Revision 2, with Temporary i

Change f40tice (TCf4)-4, and noted that the procedure described acequate methods i

for the removal of the MSIV air packs.

fio other problems were r.oted with removal of the MSIV air packs after the initial problem documented in the violation. The actions taken to correct this problem were apprc:riate.

This item is closed.

j 2.2 (Closed) Violation (440/90012-OlB(DRS))

Failure to verify that required inspections were performed prior to sign off on burn permit. The licensee's response, dated December 14, 1990, stated that additional training had been provided to responsible individuals and procedural requirements had been clarified.

The Fire and Security Inspection Unit increased the number of field inspections of hot work activities during

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the outage.

In addition, the Quality Assurance Section conducted an ongoing field surveillance of plant hot work performed during the outage. No problems

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were noted with these additional inspections' and surveillances. The actions taken to correct this problem were appropriate. This item is closed.

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2.3 (Closed) Violation (440/90012-02(DRS))

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Failure to separate non-conforming fuses from conforming fuses. The licensee's response, dated December 14, 1990, stated that all non-conforming items would be physically separated and tagged. The inspectors observed several fuse storage bins in the warehouse and concluded that non-conforming fuses were stored separately from conforming fuses. The non-conforming items

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were segregated upon receipt and held in a separate holding area. The actions taken to correct the problem were adequate. This item is closed.

3.0 Evaluation and Assessment of Maintenance

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The purpose of this inspection was to evaluate and assess maintenance at the i

Perry Nuclear Power Plant (Unit 1). The inspection concentrated on the RHR

system, which removes heat from the reactor and suppression pool under normal

and accident conditions, restores and maintains the desired water level in the reactor vessel after a loss of coolant accident (LOCA), and controls or

reduces primary containment pressure and temperature following a LOCA.

The inspectors reviewed past performance of the RHR system, reported events, observed materiel condition and ongoing maintenance activities, and reviewed

completed maintenance work packages.

3.1 Materiel Condition and Housekeepina The inspectors performed a general walk down and inspection of the plant, with particular emphasis on the electrical, mechanical and instrumentation areas of the RHR system.

Systems, structures, and components in the plant were observed for proper identification, accessibility, scaffolding, radiological controls, and unusual conditions. Unusual conditions included but were not limited to water, oil or other liquids on the floor or equipment; indications of leakage through ceilings, walls or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting.

The inspectors also verified that work requests had been initiated for broken or defective equipment.

Housekeeping in the areas around and adjacent to RHR equipment was good.

RHR equipment identification was satisfactory and no problems were noted. Other areas of the plant observed were generally clean and well kept. A program hac

l been implemented to upgrade painting and lighting.

For example, the newly painted diesel generator rooms were well lit and clean.

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3.2 Maintenance Work in Proaress The plant was in a forced outage due to a se'r'vice water pipe rupture. The RHR suction strainers were inspected by divers, samples of the buildup on the strainers were taken, and preparations were made to replace the strainers; however, none of this work was observable.

No other maintenance was performed on the RHR system or any other safety-related system during the inspection.

The inspectors observed work in progress on a modification to the radwaste building crane controls to provide better crane control and faster crane operation in limited areas. The work was documented in maintenance work order (MWO) 92000860. The work was adequate and all personnel involved were experienced and knowledgeable.

The maintenance supervisor and the assigned engineer were present and involved in the activity. No problems were noted.

The inspectors also observed the repacking of an extraction steam non-return check valve. The work was documented in MWO 930001085. The inspectors concluded that the maintenance activity was adequate and was accomplished by skilled maintenance personnel.

Parts and materiels were available and work instructions were used at the job site.

3.3 RHR Maintenance Work Order Packaoes The inspectors reviewed completed MWO packages for mechanical, electrical, and instrumentation and controls (I&C) systems in the RHR system.

The review was done to determine if the packages were complete and adequate.

Packages reviewed were as follows:

Mechanical MWO 910002858, MWO 910003587, MWO 920000363, MWO 920001323, MWO 920001540, MWO 920002483, and MWO 930000574

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Instrument ation and Controls MWO 920000835, MWO 920001073. MWO 920001156, MWO 920001168, MWO 920001880, MWO 920001899, MWO 920002484, MWO 920004491, and MWO 930000409 Electrical MWO 920001182, MWO 920001881. MWO 920002194, and MWO 920005269

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The work performed in MWO 930000574 for the RHR pump suction strainer l

replacement was acceptable; however, subsequent to the replacement, the

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strainer again became plugged due to debris buildup. This matter was under investigation by the licensee and will be the subject of a special inspection by the NRC.

The inspectors determined that some 1&C MWO's assigned a priority of "2" were worked and documented in a troubleshooting log before the work package was released.

Plant procedure PAP-0905, " Work Order Process," Revision 12, i

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allowed the control room unit supervisor to authorize and start work before issuance of the work package if "immediate corrective action is required."

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The requirement for immediate corrective action, such as maintaining plant l

control or possible danger to plant personnel or the public, was not l

applicable for the MW0's examined. The licensee agreed to discuss this matter

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thoroughly with operations personnel to minimize the starting of work prior to the issuance of the MWO package.

Except as noted, the MW0s were complete and acceptable with appropriate work instructions and proper approvals.

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3.4 Maintenance Backloos l

The inspectors reviewed the overall maintenance backlogs during the last two l

years. The backlog in the RHR system was low.

During Refueling Outage 3 (RF03), the licensee made a conscious decision to defer cleanup of the suppression pool until a later date.

Subsequent to that decision, the RHR suction strainers became plugged. The prioritization of this issue was inappropriate and is considered a weakness. Other problems with the RHR system were prioritized appropriately and did not affect operability of the

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i system. The non-outage related backlogs in electrical and mechanical maintenance have been reduced during the last two years, although the backlog

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stands at approximately five months. The backlog in the I&C area is currently l

about two months work. This is " W.ively unchanged from the Maintenance Team

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Inspection (MTI) report issued No' ember 1990.

The inspectors noted that the current backlogs were manageoole with the available plant maintenance i

staff.

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3.5 Maintenance Staff Levels

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l The licensee had a total staff of 212 in electrical maintenance and mechanical maintenance. This included one manager and 23 supervisors.

In addition, 28 contract personnel were available. The instrumentation and controls (1&C)

t group had 84 persons, inchding 20 supervisors.

As a result of a recent j

reorganization of plant groups, eight reguiar staff and some contractor

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j positions from the I&C group were eliminated. The current maintenance staff l

levels were effective in regulating the backlog of maintenance work.

3.6 Maintenance Trainino The inspectors reviewed the qualifications and training provided to the maintenance and I&C staffs. A Training Review Committee, composed of j

representatives from the maintenance, I&C, and training staffs, provided recommendations on training. The licensee's accredited training program, staffed by a manager and 35 instructors, provided classroom, laboratory and on-the-job training.

In accition to craft instruction, training was provided

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in the human performance ernancement system, root cause analysis and corrective action. Trainir>g was provided on mock-ups or on spare equipment, l

when available, prior to tre start of maintenance activities in an effort to maintain doses as low as reasonably achievable.

The inspectors concluded that the maintenance and 1&C staff were appropriately trained and qualified.

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3.7 System Enaineerina The licensee's engineering staff of 240 incTuded 33 system engineers. The RHR system engineer was actively involved with the maintenance and operations staff, including the activities in progress on the strainers.

The RHR system engineer was aware of activities affecting the RHR system and industry experience. The system engineers were required to walk down systems once a week and remain cognizant of the system status. The work planners effectively utilized the system engineers in the work planning stages to develop acceptance criteria and ensure procedural adequacy. The system engineers reviewed the maintenance work orders upon completion.

3.8 Repetitive Eauipment failures The inspectors reviewed the licensee's corrective action program and actions taken in response to repetitive failures. The inspectors reviewed the licensee's reliability information tracking system, Perry plant maintenance information system, and Perry equipment master file system to determine their individual roles in the identification of repetitive failures. The inspectors also reviewed component failure analysis reports, Reliability Information Tracking System (RITS) high frequency failure reports, condition reports (CR),

licensee event reports (LERS), CR/LER trend reports and Quality Assurance (QA)

audit reports on the effectiveness of corrective action.

Weaknesses in root cause evaluation were evident in the evaluations of the RHR suction strainer plugging and corrective actions were inadequate to prevent recurrence. Other than this, the inspectors determined that the licensee's identification of repetitive equipment failures, dissemination of pertinent equipment failure information through various reporting mechaniscs, and the resolution of these failures were effective in meeting the safety objectives of the program.

3.9 Followuo on Industrv identified Problems The inspectors examined the licensee's evaluation of industry information through the evaluation of several completed reviews related to the RHR system.

The inspectors reviewed the evaluations of Information Notice (IN) 92-71, Technical Support Information 4637, Services Information Letter 106-2, and Operating Experience Report (0E) 4758.

The inspectors noted that, in one of the reviews, a contradiction existed in the 0;arating Experience Review Request Cover sheet.

In the evaluation of OE

4758, an Operating Experience Review Request sheet identified that no

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commitments or procedural changes were being made as a result of the review even though an internal commitment was made to initiate the necessary revisions to procedures. This contradiction did not result in any problems, but such inconsistencies could affect the tracking of reviews.

l IN 92-71 was issued to alert addressees to an incident at the Barseback nuclear power plant. An open safety valve impinged on thermally insulated equipment, dislodging the insulation.

This insulating material was washed into the suppression pool, where it partially plugged two of five emergency

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core cooling system suction strainers. Although the licensee evaluated this event and determined that the Perry Plant is,not susceptible to the same event, the licensee failed to evaluate the g'eneric ramifications of foreign matter in the suppression pool and take appropriate actions when confronted with cleanliness concerns of the suppression pool. Consequently, the RHR suction strainers became plugged.

Except as noted, the evaluations of industry information reviewed were acceptable.

3.10 Ouality Assurance Audits l

The inspectors reviewed several Quality Assurance (QA) audit reports conducted l

by the licensee's QA department in the areas of maintenance, control of M&TE,

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receipt inspection and control of parts, materiel / fuse control and work order l

implementation. The documents were reviewed to assess the identification of l

significant safety issues and to determine overall adequacy and completeness.

The inspectors concluded that the QA audits were thorough and effective in the identification of problem areas, issuance of Action Requests (ARs) and provision of recommendations. A sample of ARs were reviewed and the recommended corrective actions were verified to be complete or in progress.

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3.11 Dedication of Commercial Grade Fuses

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The inspectors identified a batch of 100 fuses, for which the dedication tests lacked acceptance criteria. The fuses were procured as commercial grade and dedicated as safety grade level Ill.

In this batch, 31 fuses were tested for

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resistance homogeneity. Clearing time tests were conducted at 135% of rated current on one low resistance fuse and one high end fuse. The low resistance

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fuse did not blow in the specified time period of 400 to 3600 seconds.

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Another low end fuse was satisfactorily testeu, and the batch was accepted.

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non-conformance report was not issued. As a result of the inspectors'

concerns, the licensee conducted over current tests on four additional fuses,

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with satisfactory results.

The licensee stated that the dedication test

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procedures would be revised to verify the actual current / time at which the fuse blows, in case the fuse failed an initial test.

The licensee also stated that a non-conformance report would be issued and an evaluation performed for each failure in a dedication test.

4.0 Exit Meetina An exit meeting was held at the Perry Nuclear Power Plant on April 23, 1993, with the licensee representatives denoted in Section 1.0, to summarize the purpose, scope, and findings of the inspection.

The inspectors discussed the likely informational content of the inspection report with regard to documents and processes reviewed by the inspectors during the inspection. Licensee personnel were requested to identify any proprietary statements or material.

The licensee did not identify any information presented during the discussion as proprietary.

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