IR 05000440/1998002
| ML20248L575 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/12/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248L570 | List: |
| References | |
| 50-440-98-02, 50-440-98-2, NUDOCS 9803230212 | |
| Download: ML20248L575 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
REGIONlli i
i Docket No:
50-440 l
License No:
NPF-58 l
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Rr; port No:
50-440/98002(DRS)
l Licensee:
Centerior Service Company Facility:
Perry Nuclear Power Plant Location:
P. O. Box 97, A200 Perry, OH 44081 Dates:
January 12 - 16 and 26 - 30,1998 Inspectors:
R.A. Westberg, Reactor Engineer M. Miller, Reactor Engineer G. O'Dwyer, Reactor Engineer R A. Winter, Reactor Engineer Approved by:
John Jacobson, Chief,
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Lead Engineers Branch Division of Reactor Safety l'
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EXECUTIVE SUMMARY l
Perry Nuclear Power Plant NRC Inspection Report 50-440/98002 This announced inspection reviewed the effectiveness of the corrective action program. In addition, a sample of current short term corrective actions and long term corrective actions as well as a sample of engineering items were reviewed.
Ooerations
The team concluded that the corrective action program at Perry had shown
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improvement in the past year. Improvements were noted in identification, resolution, and prevention of problems. However, continued attention will be required for effective resolution of ongoing personnel error and corrective action timeliness problems (Section 07.1).
Effective correction actions since Refueling outage (RFO)5 resulted in improvements in
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leak reduction and equipment availability (Section O7.1).
The licensee's tracking and trending of personnel errors was good and showed a slight
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reduction in the personnel error rate over the past year (Section 07.1.1).
Personnel errors remained a problem; however, programs had been set in place to
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mitigate the errors and both management and the staff were aware of and accept the use of those tools. The team concluded that the licensee had taken reasonable measures to reduce the errors and that continued efforts would be necessary to resolve this issue (Section O7.1.1).
The Operating Experience Report program effectively assessed operating experience
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originating from both inside and outside the licensee's organization, informed the proper personnel of the assessments, generated technically sound corrective actions when appropriate, and correctly implemented these actions (Section 07.2).
The team concluded that appropriate mechanisms were in place for self-assessment
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j and quality assurance activities and that a number of plant and organizational problems were being identified (Section 07.3).
Plant problems not always fixed in a timely manner or on first try and a lack of diligence
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in problem analysis were two areas of corrective action that will require continued effort for their resolution (Section 07.3).
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The team concluded that the Company Nuclear Review Board and the Plant Operations
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Review Committee were effectively identifying areas of weakness in the corrective action program. The committees gave good attention to issues, promoted free discussion, and focused appropriately on safety and effective corrective action (Section 07.4).
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Engineering
. Implementation of effective corrective actions by Engineering, since RFO5, led to
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l improvements in conduct of engineedng and plant material condition (Section E1,1).
Engineering too narrowly focused on upper reservoir alarm actuations from the Reactor
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Recirculation (RR) Pump oil level switches, despite clear vendor recommendation regarding separation of the upper and lower oil reservoir signals. An opportunity was missed to definitively bound the problem because insufficient emphasis was placed on running the RR pump in fast speed during the hydrostatic test considering the limited opportunities to run the pump in this configuration and to troubleshoot the alarms. This
demonstrated an inability to see the big picture or stand back and consider all possibilities when planning a corrective action (Section E2.1).
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l Report Details Operations
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07.1 Corrective Action Proaram a.
Insoection Scone (40500)
The team assessed the Corrective Action Program through review of implementing procedures, Potential Issue Forms (PIFs), corrective action management reports, section "binning" reports, corrective action effectiveness reviews, Corrective Action Review Board (CARB) minutes, Collective Significance Process quarterly analyses, and action taken for previously identified trends. The team also attended two CARB meetings during the on-site inspection period and interviewed cognizant personnel relative to corrective action and the PlF process. In addition, the team assessed corrective actions taken for problems previously identified in resident reports and the NRC Architect / Engineer design inspection.
b, Observations and Findinas A review of the past two years indicated that corrective actions at Perry have historically been a problem. Inspection Report NOS. 50-440/96008,50-440/97007, and 50-440/97008 all documented failures of the corrective action program that resulted in violations of NRC requirements. The team used this information as a benchmark to assess the current status of the corrective action program.
The team observed that the corrective action program at Perry had shown improvement in most aspects of corrective action. Problems were identified via the PlF process, the more significant issues were investigated for root causes, trends were identified and tracked, significant corrective actions received interdisciplinary review through the CARB, observations were made in the field to improve problem prevention, and overall collective significance of issues and trends was assessed quarterly.
The threshold for identifying problems via PIFs appeared to be low and the number of PlFs generated was high. PersonnelInterviewed appeared willing to identify problems, thought the process to be owned equally by all plant staff, and did not consider PIFs written against themselves to be negative.
Of the sample cf PIFs reviewed by the team, categorized for investigation at Category 3 or higher, root cause analyses appeared to be thorough and effective. Corrective actions reviewed with due dates extended appeared to be extended appropriately.
However, the team noted that the 12 month average age of open corrective action documents had a upward slope, even though the current trend was down. In addition, the average closure time for corrective action documents was increasing. The team i
considered this worthy of additional management attention.
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The CARB was effective in its oversight of PIF investigations and corrective actions. It did not appear to be a rubber stamp for corrective actions. In fact, the team observed that a PlF related to welding was rejected at both CARB meetings attended during the inspection. The effectiveness reviews provided good feedback for redirection of corrective actions and resources.
Trending was employed at all levels as evidenced by section binning reports, monthly corrective action manegement reports, and quarterly Quality Assurance (QA)
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effectiveness of corrective action audits. Although the section binning reports were still l
being developed and differed in content and quality between sections, they appeared to l
be an effective tool for trending.
Stop Think Act Review (STAR) cards were being used by supervisory personnelin the plant to monitor performance and reinforce positive behaviors. The team considered their use a proactive method for problem prevention (see section 7.1.1).
The team also observed several noteworthy practices relative to the corrective action l
program. Examples included daily review of new PIFs, significant PIFs, and the " Issues List", at the managers' communications and teamwork daily meeting (8:00 meeting);
discussion of the top 10 oldest PlFs every Tuesday at the 8:00 meeting; development of leading indicators and assessment of collective significance quarterly; discussion of the 20 oldest PIFs, corrective actions to prevent recurrence, and PIF remedial actions at the CARB; and senior management review of all Category 1 and 2 PlFs.
Several examples of effective corrective actions were noted. For example, improvements made in the valve packing program and conversion of valves with silver plated stainless steel pressure seal rings to graphite seal rings resulted in significant leak reductions in the plant. Also, corrective actions taken to improve availability of
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Feed Water booster pumps resulted in the plant's running with the fourth booster pump as a spare, as originally designed.
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Two areas where continued attention will be required for effective resolution of corrective actions were also noted. The first area was personnel errors (see Section 07.1.1). The second area was timeliness of corrective actions. This was a theme in Inspection Report Nos. 50-440/96008,50-440/97007, and 50-440/97008. It was also recognized by your self assessment program (see Section 07.3)
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Conclusions The team concluded that the corrective action program at Perry had shown improvement in the past year, improvements were noted in identification. resolution, I
and prevention of problems. However, continued attention will be required for effective
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resolution of ongoing personnel error and corrective action timeliness problems.
Effectivo correction actions since Refueling outage RFO 5 resulted in improvements in leak reduction and equipment availability.
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07.11 Corrective Action Associated with Personnel Errors a.
Insoection Scoos (40500)
The team noted a significant number of Licensee Event Reports (LERs) were attributed to personnel errors. The licensee acknowledged a problem with personnel errors and had taken actions to address the problem. The team reviewed the corrective actions taken by the licensee and interviewed personnel to determine the staff's understanding
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Observations During 1996 and 1997,8 LERS out of 23 were the direct result of personnel errors. The LERs represented the more significant personnel error events; however, PlFs also captured additional problems with personnel errors. The licensee first identified the l
personnel error problem in mid 1996 and started a program to improve performance and track the results.
To address the problem the licensee first defined a personnel error as a " human performance problem that is specific to one individual. The appropriate depth of barriers L
(procedures, training, supervision, and plant design) to the error are already in place l
sufficiently to preclude the error from recurring with any other individual." With this l
definition, the licensee could track actual personnel errors that were documented in PIFs more definitively. Trending was based on a 12 month rolling average, with the data l
normalized to every 10,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> worked. The normalization removed spikes due to increased work periods such as outages. Based on this data, slightly more than three l
personnel errors occurred per month and with a slight decline indicated over the last year. The licensee considered that the recent refueling outage skewed the data and
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limited the magnitude of overall improvement due to an influx of first time workers at the site during that outage.
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The team noted that supervisors were appropriately monitoring their workers for l
indications of personal performance problems which could result in errors. To ensure this barrier remained consistent, the licensee provided supervisors additional training on human performance fundamentals and provided them with quick reference cards which identified the common error precursors to look for. During interviews with su,or visors i
this card was often referenced as a useful tool.
L The STAR card was one method the licensee used to improve supervision's presence in l
the plant and at the same time obtain real time feedback of emerging problems. The I
card contained several job attributes with specific items to observe for each attribute.
- The attributes included: personal safety, radiation protection, communications, and several human performance attributes. The card also contained an area for general comments or observations. Management's expectation was that these cards would be used on a periodic basis.
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The team noted that the overall STAR card program had a direct effect on occupational safety incidents. Over the last six quarters, licensee data demonstrated that as supervisor observations increased, occupational safety incidents decreased and as the observations decreased, the incidents increased. At the time of the inspection, STAR card usage had decreased and the licensee was in the process of revising the card and changing the name to a Field Observation Card before re-emphasizing the program.
The Radiation Protection Section and the Radwaste, Environmental, and Chemistry i
Section were using the STAR card for prompt assessment of work activities. These
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all supervisors, direct reports, and specialists. Both sections expected use of the card's comment parts to denote specific observations made in the work place. The
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observations were not limited to individuals associated to those work sections but were l
of anyone working at the site.
l The STAR cards for these two sections were reviewed by the respective manager to identify any issues. Both managers indicated that this process had allowed early l
detection and correction of minor issues before they became problems. For example,
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one observation identified that a few workers were using the electronic dosimeters as survey meters. The practice was quickly identified and corrected, issues identified outside these two sections were communicated to the appropriate section manager. In
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addition, positive observations where an individual performed exceptionally well, were l
brought to the attention of the appropriate supervisor and the Individual on a written i
form. This positive feedback to the workers appeared to be appreciated by the l
recipients.
l The STAR card was used by Operations but was not as useful for this workgroup.
Operations used peer reviews to identify weaknesses and better ways of performing tasks. For example, reactor operators (ROs) reviewed other ROs or Shift Technical Advisors (STAS) reviewed other STAS. The important findings were complied and made required reading for the operating crews. Based on interviews, the team found the process had a positive effect on crew performance.
Further efforts to improve human performance in Operations were through the documentation of management expectation in the form of Operation Section Policies.
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i One policy, the Assessment of Piant Problems (Item 2-1 dated 1/23/98) included removing crew members from duty that were involved in the personnel error to prevent l
the individual or individuals from making further errors. The theory was that once an error was made, they would not be as focused on work activities and the probability of-further errors increased. This policy appeared to apply equally to all members of the crew and was recognized by the crew as the appropriate action to take. Specific steps were required prior to retuming involved individuals to full duty. This policy was new and subject to change as feedback was obtained from the crews. Due to the limited time the policy was in place, the team drew no conclusions as to its effectiveness.
Another policy, Operational Activity Evaluation (item 2-9 dated 2/26/97) focused on minimizing error by specifying what level of crew briefing, oversight, and contingency
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plan would be required before a specific activity would be initiated. The level was l
based on risk significance of the activity and the operationalimpact. The policy included a table of specific systems which were risk significant and expectation for pre and post job briefings.- Briefing papers were available in electronic form to improve consistency for repeated activities and the electronic files were revised with any lessons learned from the activity, in addition to the licensee's direct corrective actions, two independent groups were invited to the site (one in July and one in December of 1997) to assess the licensee's efforts. Insights provided by these assessments were incorporated into the new Perry Mant Human Performance Improvement Plan which was waiting final approval before implementation. Many of the actions in the plan had already been taken (such as the actions described above); however, the plan included further short term and long term items to be implemented.
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Conclusions The licensee's tracking and trending of personnel errors was good and showed a slight reduction in the personnel error rate over the past year. Programs had been set in place to mitigate the errors and both management and the staff were aware of and accepted the use of those tools. The site acknowledged that personnel errors remained i.
a problem at the site. The team concluded that the licensee had taken reasonable
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measures to reduce the errors and that continued efforts would be necessary to resolve this issue.
l 07.2 Ooeratina Exoerience Feedback i
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Insoection Scoce (40500)
The team evaluated the adequacy of the licensee's program that implemented operational experience feedback, in part, by reviewing administrative procedures and dispositioned operation feedback reports (OERs). The team also reviewed the Operating Experience Reference Guide, issued June 26,1996, and attended plant meetings and shift briefings.
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Observations and Findinos
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The team determined that PAP-1607, Revision 1, " Operating Experience Report (OER)
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Program" specified a thorough and technically sound program to review operating experience reports, including for example, significant event reports, significant operating event reports and significant event notifications generated by the Institute of Nuclear Power Operations, NRC notifications,10 CFR 21 reports, vendor reports, and reports from similar facilities. The procedure also included directions for site personnel to generate and properly disseminate OERs to other sites. The team noted that Electric Power Research Institute (EPRI) reports were not included in the OER program but -
were obtained and utilized by the appropriate plant personnel on a case-by-case basis and plant staff were well aware of EPRI reports since a signiftant number of the plant
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management and staff were members of EPRI Committees. The team observed that the EPRI reports were adequately reviewed and utilized. At the end of the inspection period the licensee was considering including the EPRI reports ;n the OER program.
The team determined that the OER reviews generated technically sound corrective actions, when appropriate, which were properly implemented. Personnel were observed to be appropriately trained on lessons leamed from OERs and the information was properly disseminated and appropriately emphasized by plant management and staff.
Procedures were noted to have been revised to incorporate lessons learned from OERs.
l The Operating Experience Guide was a thorough and useful tool for personnel to search for appropriate onsite and offsite OERs.
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Conclusion
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l-The team concluded that the OER program effectively assessed operating experience originating from both inside and outside the licensee's organization, informed the proper personnel of the assessments, generated technically sound corrective actions when necessary, and correctly implemented these actions.
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07.3 Self Assessment Activities
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Insoection Scone (40500)
The team evaluated the effectiveness of the licensee's self-assessment capability by reviewing department self-assessment reports, QA quarterly self-assessment reports, and QA audits. In addition, the team interviewed cognizant personnel.
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Observations and Findings Although self-assessments appeared to be sufficient in number with 28 performed in 1997 and most organizations committed to the program, the process was not fully utilized as yet. There were some good recommendations made by the self assessments; however, there was no mechanism to track all recommendations. The licensee has discussed adopting a consistent tracking method such as using the Perry l
Master Actions Tracking System. This appeared to be necessary to reach a well j
l managed program with management overview of all self-assessment action items.
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There was also a lack of schedule integration between self-assessments and audits to j
best position the time frame for self-assessment improvement to an area before a critical audit evaluation when the self-assessment and the audit covered similar areas.
The value-added concept for self-assessments had not been recognized in all departments, in part because presently no measurement by some performance criteria existed for the effectiveness of self-assessments within each organization.
An example of a recommendation that management initially downplayed; which management eventually resolved similar to the original recommendation, concerned PIF No. 97-1024 which addressed the difficulty engineers were having in obtaining j
design bases information. Occasionally, this resulted in ineffective first fixes to
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problems. NED originally tumed down the recommendation for Design Bases Documents (DBDs) as not being cost effective. Subsequently, the licensee began investigating the best methods of other utilities and is currently in the process of l
developing some DBDs.
Sufficient audits were being performed to cover required areas. The licensee appeared to be making efforts to improve the QA programs. For example, QA audits and self-assessments covering similar areas were starting to be coordinated, but there was currently no c.:mpehensive schedule to cover the next two years.
From its review of self assessment recommendations and audit findings, the team noted some general themes that reflect on corrective actions: plant problems not always fixed in a timely manner or on first try; and a lack of diligence discovering the fundamental reason why in the problem analysis. These are two areas that will require continued effort for their resolution.
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Conclusion The team concluded that appropriate mechanisms were in place for self-assessment and quality assurance activities and that a number of plant and organizational problems were being identified. However, plant problems not always fixed in a timely manner or on first try and a lack of diligence in problem analysis were two areas of corrective action that will require continued effor' for their resolution.
07.4 Onsite and Offsite Safety RevieMatWht Activities a.
Insoection Scoce (40500)
The team evaluated the Company Nuclear Review Board (CNRB) and the Plant Operations Review Committee (PORC) through review of implementing procedures, meeting minutes, and actions taken for previous review items. The team also attended PORC meetings that occurred during the inspection period and interviewed cognizant personnel to assess the committee's work load, abilities, and management support for the committee's initiatives.
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Observations and Findinas The PORC met or exceeded the Updated Final Safety Analysis Report (UFSAR)
requirements for committee make-up, qualifications, frequency, attendance, review scope, and reporting. Meeting agendas and supporting documentation were distributed prior to the meeting, meetings were crisp and business-like, there was critical discussion and participation by committee members, preecusly opened action items were reviewed, items tabled during previous meetings did not appear to be languishing, and the committee had an appropriate focus on safety and effective corrective action. The PORC chairman kept the committee from digressing from the subject matter while promoting free discussion of the issues.
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The CNRB met the UFSAR requirements for board membership, qualifications,
frequency, attendance, review scope, and reporting. Although no meetings occurred l'
during the inspection period, board meeting minutes were reviewed and one board l
member was interviewed relative to the board's activities. The CNRB appeared to be appropriately focused on safety and corrective action.
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Conclusion The team concluded that the PORC and CNRB were effectively identifying areas of weakness in the corrective action program. The committees gave good attention to
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issues, promoted free discussion, and focused appropriately on safety and effective corrective action.
Engineering l
E1 Conduct of Engineering a.
Insoection Scoce (40500)
The team discussed corrective action and how it related to programs and initiatives in the design and system engineering departments.
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Observations and Findings l
There was a significant improvement in the quality of design change packages (DCPs)
since RFOS. This was the result of effective corrective actions relative to expectations, lessons learned from the PIF binning process, and increased ownership by engineering personnel. As a result, there was a 75 percent decrease in PlFS written against DCPs during RFO6 when compared to the previous refueling outage.
Improvements were made in the plant's balance of plant material condition over the past
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year, which was due in part, to a lower threshold for writing PlFs before material condition issues became more significant. This resulted in a positive impact on plant
thermal performance. This coupled with efforts during RFO6 to improve relief vawes, l
condenser, cooling tower, and air operated valves, resulted in a net increase in plant
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output of 16 MW.
In response to 50.54(f), the UFSAR was sampled to determine its fidelity. As a result of l
the findings from this sample, a dedicated project was set up to validate all 28 volumes of the UFSAR which is expected to be completed by October of 1998. In addition, the i
engineering department formed a Configuration Management and Information
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Technology Section to follow up on commitments in the 50.54(f) letter response on design basis maintenance, design basis document development, and a calculation improvement program.
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During RFO6, a major restoration project was completed to rectify construction damage and in service degradation issues in both the service water and circulating water systems which resulted in the correction of long standing material condition issues.
J Aggressive implementation of the maintenance rule, resulted in a decrease in systems classified as A(1) from 17 to 5 in 1997. Again, this was due, in part, to a lower threshold for initiating PIFs to address system material condition before it became more i
significant.
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Conclusions implementation of effective corrective actions by Engineering, since RFOS, led to improvements in conduct of engineering and plant mate;ial condition.
E2 Engineering Support of Facilities and Equipment E2.1 Corrective Action Associated with Reactor Recirculation (RR) Pumo Annunciator a.
Insoection Scoce (40500)
The licensee has reduced the number of lit control room annunciators to a relative low
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number. However, the team noted that both reactor recirculation pump motor high oil level annunciators were lit during a tour of the control room. The team reviewed the j
corrective action history associated with these annunciators, b.
Observations A 1981, General Electric Service Information Letter (SIL) Number 361, contained several recommendations to identify and prevent the false alarms from the RR pump motor oil level switenes. Since the upper and lower oil reservoir alarm circuits for each pump were wired in parallel, the SIL recommended separating the circuits by using separate wiring. This would allow identification of the reservoir causing the alarm.
The resolution of the problem was complex. Changes in the high level alarm affected the lower alarm and adjustments in oil level were limited. The licensee did attempt to manually measure the maximum oil levels in the upper and lower reservoirs that occur during operation. The results of the measurements focused the activities to the upper reservoir, which appeared to coincide with industry data.
in RFOS (early 1996), the licensee had the opportunity to operate a RR pump in fast speed for less than 10 minutes during the reactor vessel hydrostatic test which allowed l
personnel access to the pump. The information gathered during this effort was used to modify the upper oil reservoir detector piping in hopes of eliminating the false alarm.
Modification for the alarm circuit to verify if the alarm was the sole result of the upper oil reservoir was prepared by Engineering.
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The modifications were installed in RFO6 (late 1997). During the hydrostatic test, the starting temperature of the reactor coolant was sufficiently high that operation of a fast speed pump was not possible. Although fast speed operation of the RR pump had been i
scheduled, greater emphasis was placed on completing the test. Had the reactor coolant temperature been lowered prior to starting the test, a short run of the RR pump in fast speed would have been possible. When the plant was restarted and the RR pumps taken to fast speed the alarms returned. Engineering attempted to verify the alarms were from the upper oil reservoirs; however, the lower oil reservoir alarms were activated and the status of the upper oil reservoir high level alarm could not be determined.
When engineering designed the change to the alarm circuit they were focused on the upper reservoir. The modification could have easily been changed to differentiate between the two alarms which would have met the intent of the S!L. In addition, had the RR pump been run in fast speed during the hydrostatic test, the alarm would have come in and data from a sightglass on the new level detector could have been obtained.
Additional trouble shooting may have been possible before the reactor startup.
Following RFO6, the licensee could not determine if the upper oil reservoir alarm was actuated and therefore the licensee did not know if the modification to the detector piping was successful or not.
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Conclusions Engineering too narrowly focused on upper reservoir alarm actuations from the RR pump motor oil level switches, despite clear vendor recommendation regarding separation of the upper and lower oil reservoir signals. An opportunity was missed to definitively bound the problem because insufficient emphasis was placed on running the RR pump in fast speed during the hydrostatic test, considering the limited opportunities to run the pump in this configuration and to troubleshoot the alarms. This demonstrated an inability to see the big picture or stand back and consider all possibilities when planning a corrective action.
E8 Miscellaneous Engineering issues (40500)
E8.1 (Closed) Insoection Followuo item 50-440/93019-05: The engineering staff did not conduct a detailed review of the available information which was relevant to corrective actions associated with gradual galling of fan shafts and corrective actions associated with preventing water hammers. During the Design inspection ( Inspection Report (IR)
50-440/97-201) conducted in February and March of 1997, similar issues were identified in several engineering evaluations and corrective actions. The Design Inspection issues were dispositioned as violations in IR 97008. The corrective actions for the violations addressed the issues identified in this inspection followup item. This item is closed.
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E8.2 (Closed) Insoection Followuo Item 50/440-94010-08: DCP 92-0097 changed the l
intemal trim in the residual heat removal (RHR) heat exchanger discharge and bypass valves and resized several restricting orifices to resolve significant valve degradation caused by unsuitable throttling characteristics of the o-iginal valves. After several
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changes were required, weaknesses associated with the design process were noted, including a weak safety evaluation that did not discuss system resistance changes due to orifice resizing (removal), weak design basis understanding of the impact on the RHR and interfacing systems, apparently no involvement by operations or maintenance in the design process, and the DCP revisions were made on a rush basis leading to an erroneous redesign of the control circuit for the suppression pool test return valve. The licensee reexamined whether the modification process was effective through the RF04 DCP Re-evaluation program. The licensee worked to resolve a number of issues including design control measures, weak safety evaluations, poorly documented calculations, inadequately addressed system interactions and weaknesses in the rigor of design verification. The licensee has taken sufficient action to resolve this issue. This item is closed.
E8.3 (Closed) Insoection Followuo Item 50/440-94010-11: After several failures to meet the local leak rate test (LLRT) over an 8 year period, the licensee replaced the existing Target Rock containment isolation valves (CIVs) with Valcor valves. A concern was raised about the lack of root cause analys and the lack of formal evaluation of numerous occurances of cavitation in the adjacent piping after preliminary conclusion of the cause of valve failure was cav% tion. The licensee subsequently performed a calculation to determine the cavitation poter,tial around the CIVs. The results of the calculation were that valves Nos.1P87-F049 and 1P87-F055 were not predicted to cavitate at the normal sample flowrate of 1400 cc/ min. Subsequent licensee action clarified that cavitation was not the root cause. This item is closed.
E8.4 (Closed) Insoection Followuo item 50/440-94010-12: During a review of various DCPs, the NRC identified weaknesses in specific calculations concerning completeness, accuracy, and compliance with regulatory requirements. A general concern developed on the design modification process adequacy. The licensee has taken actions on five specific calculations to correct weaknesses. There was a thorough review of the design changes packages completed in that period which included review for completeness of required dmmentation. The updated guidelines of Nuclear Engineering Department Policy Manual, section IV, NEDP-13, Rev.1, March 3,1995 and NEl-0341, Rev. 5, 6/15/1995, " Calculations" provided some improvements in the guidelines. The licensee has taken sufficient action on this issue. This item is closed.
I E8.5 (Closed) Unresolved item 50-440/96005-04: Calculated values for valve operating differentlal pressures were different than the values listed in the UFSAR. Inspection report 97008 identified several similar discrepancies between calculated values and the values listed in the UFSAR. A violation was issued in IR 97008 for failure to update the UFSAR. The scope of corrective actions for the IR 97008 violation addressed the issues identified in this URI. This item is closed.
E8.6 (Closed) Violation 50-440/96008-01: Failure of LER 93-021. Revision 0, to contain an adequate assessment of the safety consequences and implications of the December 1993 loss of the Emergency Closed Cooling (ECC) System. The LER only discussed the loss of Train A and did not report that Train B had also been simultaneously out of service resulting in a complete loss of the ECC safety function.
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The licensee conducted an investigation to determine the root cause and any other related conditions. In response to the violation the licensee stated: (1) the cause of the inadequate evaluation was personnel error, i.e., oversight by the Compliance engineer who prepared the LER; (2) the preparer was new to the Regulatory Affairs Section and was overburdened and under time pressure; and (3) contributing factors were inadequate supervision of work and control of work assignments, and personnel were not held accountable for the accuracy and completeness of the LER information. The licensee effected the following corrective actions: (1) revision 1 of LER 93-021 was issued and adequately described the event; (2) procedure changes have assigned the root cause investigation to the appropriate plant staff which have allowed the LER preparer to concentrate on LER preparation; (3) the procedure changes have also more clearly delineated responsibilities and accountability in the LER review process; and (4)
LER preparers and their supervisors have been trained on this violation. The team
reviewed the licensee's followup investigation and immediate and long-term corrective actions and found them to be thorough and adequate. Since LER 93-021, Revision 0 was written, the team did not detect any other LERs that did not meet NRC documentation requirements and LER documentation has improved. This violation is closed.
E8.7 (Closed) EA 96-367. 01013. 01023: The loss of the ECC system safety function because of excessive system leakage through an ECC boundary isolation valve due to maintenance incorrectly setting the limit switch. The valve did not receive an adequate Post-maintenance Test (PMT) because the valve had been classified as ASME Boiler and Pressure Vessel Code, section XI, Category B in the licensee's Pump and Valve Inservice Testing Program Plan (ISTP), Revision 3.
The team verified that among other corrective actions, the licensee recategorized the ECC boundary valves as Category A in Table 3.4 of the ISTP and note 10 of the table required a system leak test as PMT for Category A valves having a system leakrate requirement. The licensee informed the team that the valves would remain Category A.
The licensee confirmed that the boundary valves for other systems were properly categorized. The team verified that Fuel and Technical Instruction FTI-36, Revision 2,
"PMT Program Matrix," Table 2.0, required an ECC system leak test as PMT after any maintenance that might affect the leakage prevention capabilities of the ECC boundary valves regardless of ISTP categorization. This item is closed.
E8.8 (Closed) EA 96-367. 02024: The failure to reclassify the ECC boundary valves as category A in a timely manner.
As discussed in paragraph E.8.7, the team verified that the ECC boundary valves had been reclassified as Category A in Table 3.4 of the ISTP. The licensee assured the team the valves would remain Category A. The licensee confirmed the boundary valves for other systems were properly classified. This item is closed.
E8.9 (Closed) Violation 50/440-97006-01: Licensee personnel completed two surveillance l
tests before the procedure / instruction changes (PICS) were reviewed and approved.
PAP -0522 required the unit's supervisor's signature and date on PICS before the
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surveillance were performed. Although, this violated procedural requirements and technical specifications, there were minimal safety consequences since the voltages observed were acceptable. To resolve this problem the licensee revised procedure PAP-1105 (on 9/12/97) to reference (Ref 15) the governing procedure PAP-0522 for PICS so future surveillance performers would not repeat this error. This item is closed.
E8.10 (Closed) Violation 50-440/97008-01: Several examples were cited where calculations or analyses were not verified or controlled adequately. This included open assumptions that were not closed in a timely manner. The licensee determined the discrepancies were the result of inattention to detail which was addressed during the Design Engineering staff during the September 1997 section meeting.
The specific issues were appropriately revised which included the calculation for level setpoint in the condensate storage tank. In this case, the revised calculation was found l
to provide sufficient margin to maintain the minimum net positive suction head to the high pressure core spray pump (HPCS). The licensee was planning to implement a set point change later in 1998 to improve this margin.
An engineering improvement plan was developed late in 1997 which incorporated the lessons learned from the Design inspection Team findings. The computerized tracking system for calculations was expanded to include calculations that occurred before the data base was started. The expansion of the data base was to improve the ability to identify and close calculation assumptions in a timely manner. This item is closed.
E8.11 (Closed) Violation 50-440/97008-02: Several examples of untimely or ineffective corrective actions were identified. The licensee attributed the violations as a work management issue combined with insufficient management attention. Following the identification of these issues, section managers were required to maintain an engineering issues lists that establish priorities to ensure timely and effective resolution of issues.
Each specific issue was appropriately addressed by the licensee. In the case of the over
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frequency protection relay for HPCS, the revised calculation demonstrated the relay was not required. The original consideration for incorporating the relay was to account for a pump with a potentially higher shut off head. The pump selected for the application did not require the additional over pressure protection. This item is closed.
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E8.12 (Closed) Violation 50-440/97008-03: Safety related piping was not protected against missiles generated by natural phenomena as described in the UFSAR. Prior to
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issuance of an operating licensee, the architect engineer changed the methodology for protecting the equipment to a probabilistic approach; however, the UFSAR did not support that methodology. The licensee took immediate actions to erect temporary physical barriers and to change procedures. A license amendment was submitted and
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approved that permitted the probabilistic approach. This item is closed.
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E8.13 (Closed) Violation 50-440/97008-04: The licensee failed to perform a 10 CFR 50.59 safety evaluation for operating the suppression pool cleanup (SPCU) system differently
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than described in the UFSAR. The operation of the SPCU was promptly placed under
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administrative controls. Safety evaluation 98-0006 was approved February 3,1998, and l
the following day the associated UFSAR change request (97-0111) was approved. The review included a discussion of NPSH to HPCS during the period when the SPCU isolation valves transitioned to a closed position. Based on UFSAR Section 3.6.2.1.3,
" Postulated Pipe Breaks and Cracks," the team agreed that pipe breaks or cracks outside containment are not postulated to occur concurrently with a postulated break inside containment. Therefore, the use of SPCU normal flow in the calculation was appropriate. This item is closed.
E8.14 (Closed) Deviation 50-440/97008-05: A commitment was made to clean and inspect the HPCS system room coolers on a periodic basis; however, the coolers were only inspected. The licensee then documented that the coolers had been cleaned and inspected.
Plant management identified that expectations for literal compliance required strengthening. Continuing training for the engineering support personnel addressed this expectation during the second calendar quarter of 1997. The licensee revised the j
commitment to clarify the specific intentions concerning the cooler inspections. This
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item is closed.
E8.15 (Closed) Deviation 50-440/97008-06: The licensee failed to meet a commitment to test the HPCS room coolers on a periodic basis until the testing results demonstrated that a reduced frequency was warranted. This item was closely tied to the deviation above.
The issue of management expectation for literal compliance was the same. This commitment was also revised to clarify the specific intent of the licensee. This item is closed.
E8.16 (Closed) Unresolved Item 50-440/97201-07: Treatment of droop bias for the emergency diesel generator governor with respect to technical specification acceptance criteria for HPCS flow. The revised calculation demonstrated that the HPCS pump would perform
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its design function as long as it delivered 6110 gpm with 524.8 psid head. The licensee revised the surveillance procedures to include the new values as the acceptance criteria. This item is closed.
E8.17 (Ocen) EA 96-367. 02014: The loss of both trains of the Control Room Emergency Recirculation System (CRERS) due to failure of the licensee to prevent the ECC system water from dropping below 55*F and tripping off the control complex chillers.
One of the corrective actions was a design modification which installed Temperature Control Valves (TCVs) and associated bypass lines around the ECC heat exchangers.
In a docketed letter from the licensee to the NRC on October 22,1998, the licerisee requested NRC approval pursuant to 10 CFR 50.59 and 10 CFR 50.90 for a UFSAR change to incorporate the TCV design modification. Pending NRC determination of the acceptability of the TCV design modification UFSAR change, this item remains open.
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V. Manaamment Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to licensee representatives during an exit meeting on January 30,1998. The licensee acknowledged the findings and did not indicate that any materials examined during the inspection should be considered proprietary.
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PARTIAL LIST OF PERSONS CONTACTED Licensee
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L. Myers, Vice President - Nuclear H. Hegrat, Regulatory Affairs Manager W. Kanda, General Manager Nuclear Power Plant Department J. Messina, Operations Manager T. Rausch, Director, Quality and Personnel Development Department R. Schrauder, Director, Nuclear Engineering Department J. Kloosterman, Corrective Action Regulatory issues Unit Supervisor D. Saven, Regulatory Affairs A. Okorn, Operating Experience - Independent Safety Engineering Group R. Collings, Quality Assurance Section Manager NRG D. Kosloff, Senior Resident inspector, Perry 1 J. Clark, Resident inspector, Perry 1 INSPECTION PROCEDURES USED IP 40500, Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems
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ITEMS OPENED, CLOSED, AND DISCUSSED Closed 50-440/93019-05 IFl Engineering staff did not review available Information relevant to corrective actions associated with gradual galling of fan shafts and corrective actions associated with preventing water hammers.
50/440-94010-08 IFl Weaknesses in the design control process caused several changes to the modification.
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50/440-94010-11 IFl Inconclusive assumptions and follow through prior to replacing Target Rock containment isolation valves with Valcor valves.
50/440-94010-12 IFl Weaknesses in completeness, accuracy and regulatory requirements compliance on specific design modification calculations.
50-440/96005-04 URI Calculated values for valve operating differential pressures were different than values listed in the UFSAR.
50-440/96008-01 VIO Failure of LER 93-021, Revision 0, to contain an adequate assessment of the safety consequences and implications of the l
December 1993 loss of the ECC System. The LER only l
discussed the loss of Train A and did not report that Train B had also been simultaneously out of service resulting in a complete loss of the ECC safety function.
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EA 96-367,01013 eel Loss of the ECC system safety function because of excessive system leakage through an ECC boundary isolation valve due to maintenance incorrectly setting the limit switch.
EA 96-367,01023 eel Loss of the ECC system safety function because of excessive system leakage through an ECC boundary isolation valve due to
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maintenance incorrectly setting the limit switch, t
EA 96-367,02024 eel The failure to reclassify the ECC boundary valves as category A in
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a timely manner.
i 50/440-97006-01 VIO Two surveillance tests were completed before the procedure
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instruction changes (PICS) were reviewed and approved.-
50-440/97008-01 VIO Several examples were cited where calculations or analyses were not verified or controlled adequately, 50-440/97008-02 VIO Several examples of untimely or ineffective corrective actions were identified, including HPCS overfrequency protection relay.
50-440/97008-03 VIO Safety related piping was not protected against missiles generated by natural phenomena as described in the UFSAR.
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50-440/97008-04 VIO Failure to perform a 10 CFR 50.59 safety evaluation for operating
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the suppression pool cleanup (SPCU) system differently than described in the UFSAR.
50-440/97008-05 DEV A commitment was made to clean and inspect the HPCS system room coolers on a periodic basis; however, the coolers were only inspected.
50-440/97008-06 DEV The licensee failed to meet a commitment to test the HPCS room coolers on a periodic basis until the testing results demonstrated that a reduced frequency was warranted.
50-440/97201-07 URI Droop bias for the emergency diesel generator governor with respect to technical specification acceptance criteria for HPCS flow demonstrated in the revised calculation.
Discussed (Ocen) EA 96-367. 02014:
The loss of both trains of the CRERS due to failure of the licensee to prevent the ECC system water from dropping below 55"F and tripping off the control complex chillers. This violation cannot be considered for closure until the NRC determines if the TCV design modification UFSAR change is acceptable.
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f LIST OF ACRONYMS AND INITIALISMS ASME American Society of Mechanical Engineers l
CARB Corrective Action Review Board CFR Code of Federal Regulations CIV Containment Isolation Valves CNRB Company Nuclear Review Board CRERS Control Room Emergency Recirculation System DBD Design Bases Document l
DCP Design Change Package l
ECC Emergency Core Cooling System
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EPRI Electrical power Research Institute GE General Electric HPCS High Pressure Core Spray IFl Inspector Followup Item
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IR
Inspection Report
Local Leak Rate Test
Pump and Valve Inservice Testing Program Plan
LER
Licensee Event Report
NED
Nuclear Engineering Department
NRC
Nuclear Regulatory Commission
Operational Experience Report
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Perry Administrative Procedure
Procedure / instruction Change
Potential issue Form
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Post-maintenance Test
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PMATS
Perry Master Actions Tracking System
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Plant Operations Review Committee
Quality Assurance
Refueling Outage
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Temperature Control Valve
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Unresolved item
Violation
Reactor Recirculation
Reactor Operator
Service Information Letter
SPCU
Suppression Pool Cleanup
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Stop Think Act Review
Updated Final Safety Analysis Report
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LIST OF DOCUMENTS REVIEWED
The following is a list of licensee documents reviewed during the inspection, including
documents prepared by others for the licensee. Inclusion on this list does not imply that NRC
inspectors reviewed the documents in their entirety, but, rather that selected sections or
portions of the documents were evaluated as part of the overallinspection effort. Inclusion of a
document in this list does not imply NRC acceptance of the document, unless specifically stated
in the body of the inspection report.
Items Reviewed
PlFs
PJER
Date Discoverv
94-2140
11/15/94
95-1670
08/24/95
95-2296
11/12/95
96-3767
12/16/96
97-0768
05/06/97
97-0833
05/18/97
97-1024
06/23/97
97-1279
08/05/97
97-1552
09/17/97
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97-1712
09/23/97
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97/2085
10/11/97
97-2245
10/22/97
97-2272
10/23/97
97-2322
11/11/97
98-0101
01/20/98
98-0182
01/30/98
98-0183
01/30/98
98-0184
01/30/98
98-0185
01/30/98
Procedures
Procedure #
Revision #
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PAP-1607
Operating Experience Report (OER) Program
PAP-1608
Corrective Action Program
Operations Section Policies
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2-1
1/23/98
Assessment of Plant Problems
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2-9
2/26/97
Operational Activity Evaluation
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Safety Evaluations
Number
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Description
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97-0110
1/14/98
Clarification of design requirements for ECCS keep-fill pump
98-0006
2/2/98
Suppression pool cleanup continuous operation
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Audits
Number
Qala.
Description
96-07
4/10/96
Effectiveness of Corrective Actions.
96-16
10/17/96
Effectiveness of Corrective Action
97-05
5/22/97
Effectiveness of Corrective Action
97-14
1/15/98
Effectiveness of Corrective Action
independent Safety Group Evaluations
Number
Qala.
Description
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97-112
2/10/97
Independent Review of 50.54(f) Letter
97-115
7/30/97
Independent Assessment of Electrical Events
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Self Assessments
Number
Data.
Description
017SE96
3/20/96
Maintenance Rule Self-Assessment Report
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E-SO-16936
12/15/95
MOV Self-Assessment Final Report
015-DES-95
4/22/96
EART Self-Assessment Final Report
12/17/96
PNED Cycle 5/RF05 DCP Product Quality Report
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Reports
Description
Report on Self-Assessments Third Quarter 1997
Collective Significance Process Second Quarter Analysis
Collective Significance Process Third Quarter Analysis
Trend Analysis
Description
Perry Nuclear Plant 1997 Radiological Trend Analysis
Radwaste Environmental Chemistry Section Bin Results 3rd Quarter 1997
Design Engineering Section 3rd Quarter 1997 PlF Trend Analysisi Report
Corrective Action Process Trend Report Perry Nuclear Services Department 1997
Corrective Action Management Report January 1997
Corrective Action Management Report December 1997
Corrective Action SiteTrend Report Regulatory Affairs Section June 30,1997
Significant Event Reports
Description
SEN 0172, "Through Wall Crack in Core Spray injection Line Weld"
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Operating Experience Reports from other Plants
Description
OE 8568, * Maximum Linear Heat Generation Rate (MLHGR) Limits for GE11 Fuel not included
in Grand Gulf Core Operating Limits Report";
institute for Nuclear Power Operations (INPO)
Description
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Operations and Maintenance Reminder OMR 0422," Freezing of safety related process piping
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and systems"
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Other and Vendor Letters, Part 21
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Description
OV 970924, *Part 21 on Electromotive Division Air Start Motors #40047506 and 40047507;
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NRC Information Bulletin IEB 97-02," Puncture Testing of Shipping Packages Under 10 CFR 71"
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NRC Generic Letter 97-04, " Assuring Sufficient Net Positive Suction Head for Emergency Core
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Cooling System and Containment Heat Removal Pumps"
NRC Administrative Letter NAL 97-04, "NRC Staff Approval for Changes to 10 CFR 50,
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Appendix H"
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General Electric Rapid Information Letter SIL 0613, "Feedwater Level 8 Trip inoperable"
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NRC Daily Plant Status Report PS 7048," Potential for inadequate Residual Heat Removal
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Service Water System flow Due to Instrument Uncertainties".
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