IR 05000440/1998019
| ML20198N358 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198N356 | List: |
| References | |
| 50-440-98-19, NUDOCS 9901060108 | |
| Download: ML20198N358 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lli
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Docket No:
50-440 License No:
NPF-58 Report No:
50-440/98019(DRP)
Licensee:
Centerior Service Company P.O. Box 97 A200 Perry, OH 44081 Facility:
Perry Nuclear Power Plant Location:
Pr,rry, OH -
Dates:
October 21 through December 2,1998 Inspectors:
C. Lipa, Senior Resident inspector J. Clark, Resident Inspector Approved by:
Thomas J. Kozak, Chief Reactor Projects Branch 4
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EXECUTIVE SUMMARY Perry Nuclear Power Plant NRC Inspection Report 50-440/98019(DRP)
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This inspection report included resident inspectors' evaluation of aspects of licensee operations, engineering, and maintenance.
l Operations l
Routine plant operations were characterized by good teamwork and effective e
communications among work groups which resulted in the resolution of a moisture separator / reheater drain tank drain leak and the proper performance of the high pressure core spray system room cooler surveillance test. Operators generally exhibited good attention-to-detail while performing their work as evidenced by the prompt identification and resolution of a diesel generator tachometer power supply l
failure (Section 01.1).
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The inspectors concluded that the licensee continued to safely and effectively mitigate e
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operator observing and reporting the minor problem found on a panel walkdown initiated
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prompt corrective actions for the fuel leak (Section 01.2).
Maintenance
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I Procedural instructions were not completely followed while a scaffold was erected which e
resulted in the scaffold interfering with the operation of a safety-related containment vacuum breaker. This was similar to, but not a direct repeat of, previously identified
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scaffold construction procedure issues (Section M1.2).
Inattention-to-detail by an instrument and control (l&C) technician led to incorrect chart e
paper being installed in the control panel suppression pool level chart recorder. The incorrect chart paper remained installed due to the failure of l&C technicians and
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operators to recognize this error during panel walkdowns until the inspectors identified it 7 days after installation (Section M1.3).
inattention-to-detail by a test performer and a unit supervisor, respectively, led to a data e
entry error during a hydrogen igniter surveillance test and a failure to identify the error
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during a review of the test results (Section M1.4).
e A misinterpretation by the licensee of the Technical Specification (TS) bases regarding pressure in the secondary containment led operators to not recognize that a Limiting Condition for Operation (LCO) entry existed during surveillance testing of the annulus l
exhaust gas treatment system fans. The TS LCO was not exceeded in this instance j
(Section M1.5).
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i Although licensee management has recently taken actions to improve procedure e
adherence at the Perry Plant, the actions were not effective in ensuring personnel
adhered to the procedural requirement that the supervising operator manipulate control
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panel pushbuttons during hydraulic control unit testing activities. Although a number of different supervisors and workers were aware of the procedural requirement, work was not stopped to revise the procedure to reflect the way the job was planned
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(Section M1.6).
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Enoineerina The inspectors concluded that there was an appropriate level of documentation for e
emergent equipment issues, that the process for requiring and documenting the need for an operability evaluation was formalized, and that operability determinations provided properjustification to operations department personnel (Section E1.1).
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Report Details Summary of Plant Status The plant was being operated at 100 percent power at the beginning of the inspection period.
The licensee continued fuel leak suppression activities for one small fuel pin leak. Periodic control rod surveillance testing activities were conducted at 90 percent instead of 100 percent power, and power changes were limited to 1 percent per hour. A second, small fuel pin leak was deteded during the inspection period and on November 7, plant power was reduced to 60 percent to determine its ' location. The two small fuel pin leaks were suppressed by the full insertion of four control rods. The plant was returned to full power over the next week following
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the suppression activities. The licensee developed a rod pattern to allow continued operation at full power for the remainder of the inspection period, except for periodic rod testing and
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adjustments.
I 1. Operations
Conduct of Operations
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01.1 Review of Routine Plant Operations a.-
Insoection Scope (71707)
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l The inspectors followed the guidant.e of Inspection Procedure (IP) 71707 and conducted frequent reviews of plant operations. This included observing routine control
- room activities, reviewing system tagouts, attending shift turnovers and crew briefings, and performing panel walkdowns. The inspectors also observed operators performing routine equipment line-ups.
b.
Observations and Findinas On October 28,1998, the inspectors observed a high pressure core spray (HPCS)
system room cooler test evolution. There was good coordination between engineering personnel and control room operators during the test. The supervising operator (SO)
used the appropriate procedures to line-up emergency service water and HPCS components to support the test.
On October 31,1998, an SO identified a discrepancy with an emergency diesel generator (DG) tachometer indicator while conducting a panel walkdown. The unit supervisor immediately declared the Division 1 DG inoperable and troubleshooting was expedited on the tachometer. It was determined that a power supply for the tachometer failed. The power supply was replaced and, following satisfactory post maintenance testing, the DG was declared operable on November 1,1998.
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On November 17,1998, the inspectors observed good teamwork among operations, maintenance, and engineering department personnel while they developed and implernented a plan to inspect and repair a leak on a moisture separator reheater (MSR)
drain tank drain. The inspectors observed portions of the activities on November 18 when control room operators removed the MSR from service and then later returned it to service. The operators appropriately followed procedures and effectively communicated with in-plant operators during these activities.
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. Conclusions Routine plant operations were characterized by good teamwork and effective communications among work groups which resulted in the resolution of a MSR drain tank drain leak and the proper performance of the HPCS system room cooler surveillance test. Operators generally exhibited good attention-to-detail while performing their work as evidenced by the prompt identification and resolution of a DG tachometer power supply failure.
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01.2 Testina and Sucoression of identified Second Pin-Hole Fuel Leak a.
Inspection Scope (71707)
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The inspectors followed the guidance of IP 71707 in assessing the licensee's performance in detecting, isolating, and suppressing a second pin-hole fuel leak.
b.
Observations and Findinas On October 28,1998, an operator noted a small increase in the off-gas pretreatment radiation monitor reading during a panel walkdown and took prompt action to inform the I
shift supervisor and chemistry department personnel of this observation. Through a subsequent chemistry analysis, the licensee determined that there was either an increase in the known fuel leak (see Inspection Report 50-440/98018), or a second
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minor fuel leak. Operations, engineering, and chemistry department personnel l
conducted testing during the weekend of November 7 which identified a second pin-hole l
fuelleak near the middle of the core. Engineering department personnel worked with General Electric Company personnel to develop a new suppression pattern for the control rods.
I The inspectors observed a continuation of the effective command and control, three-way communications, and safety focus that was observed during the similar evolution in the last inspection period.
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Conclusions The inspectors concluded that the licensee continued to safely and effectively mitigate the effects of two minor fuel leaks in the core. The inspectors also concluded that the operator observing and reporting the minor problem found on a panel walkdown initiated prompt corrective actions for the fuel leak.
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O2 Operational Status of Facilities and Equipment O2.1 General Plant Tours and System Walkdowns (71707_1 The inspectors followed the guidance of IP 71707 in walking down accessible portions of several systems and areas including:
annulus exhaust gas treatment system (AEGTS)
e high pressure core spray system i
e emergency diesel generators (DG)
e Equipment operability, material condition, and housekeeping were acceptable in all cases. Minor discrepancies were brought to the licensee's attention and were corrected.
The inspectors identified no substantive concerns as a result of these walkdowns, ll. Maintenance M1 Conduct of Maintenance M1.1 General Comments The inspectors observed or reviewed all or portions of the following work activities:
SVI-M15-T1239, Annulus exhaust gas treatment system operability test
SVI-M17-T2002, Containment vacuum breaker and isolation valve operability
PTI-M39-P0002, HPCS pump room cooler performance test
SVI-C11-T0009, Control rod scram accumulator pressure / leak detection e
function / calibration SVI-M56-T5417, Hydrogen igniter current check e
SVI-M16-T0414, Drywell vacuum breaker relief setpoint test e
SVI-E51-T2001, Reactor core isolation cooling system operability
SVI-G41-T2001, Fuel pool cooling and cleanup system pump and valve e
operability SVI-R43-T1317, Division 3 diesel generator start and load e
e SVI-C11-T1003A, Control rod exercise PTI-E12-P0002, RHR heat exchanger A and C performance testing o
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l Work Order (WO) 982286, Breaker EH1201 minimum voltage testing e
j WO 980092, Replace diesel generator air start solenoid valve e
in general, the inspectors observed appropriate controls and procedure adherence for the activRies listed. There was good coordination between and among work groups.
However, the inspectors iaentified instances where workers did not employ strict procedural adherence and sufficient attention-to-detail during activities and subsequent reviews as discussed in the sections below.
M1.2 Scaffoldina Blocked Operation of Containment Vacuum Relief Valve
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Inspection Scope (61726. 62707)
The inspectors reviewed the results of a failed surveillance test on containment vacuum breakers. The inspectors interviewed operations and maintenance department personnel and walked down the system.
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Observations and Findinos
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l On November 4,1998, during the routine performance of SVI-M17-T2002, " Containment Vacuum Breaker and Isolation Valve Operability Test," vacuum breaker valve M17-F020
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failed to fully stroke open. The licensee subsequently identified that a scaffold located in front of the valve prevented the disc from fully opening.
The licensee declared valve M17-F020 inoperable and tested the other three containment vacuum breakers to ensure the system was operable. Technical Specification 3.6.1.11 requires three out of four vacuum breakers to be operable. This specification was met even though the safety-related function of valve M17-F020 was impaired by the scaffold; therefore, this did not result in a TS violation.
In inspection Report 50-440/98013, the inspectors identified four examples where scaffolding was erected in close proximity to safety-related equipment. In those cases, the procedurally required 3-inch minimum clearance was not maintained. In this case, the scaffold near valve M17-F020 met the 3-inch clearance requirement; however, Procedure GCl-0016, " Scaffolding Erection, Modification, or Dismantling Guidelines,"
Revision 1 (June 29,1998), Section 10.c, also required that scaffolds not impair the operation of plant equipment.
The licensee took corrective actions for this issue which included: (1) initiating condition report (CR) 98-2341 to document the condition, (2) modifying the scaffolding to allow proper operation of the vacuum breaker, (3) successfully testing all four vacuum breakers, and (4) initiating CR 98-2493 to perform a more extensive review of the scaffolding issues at the facility.
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Perry Nuclear Power Plant Unit 1 Technical Specification (TS) 5.4.1.a., requires that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978.
Appendix A of RG 1.33, includes maintenance procedures affecting safety-related
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equipment. The failure to follow GCl-0016 was a violation of TS 5.4.1.a. This non-repetitive, licensee-identified and corrected violation is being treated as a non-cited e violation consistent with Section Vll.B.1 of the NRC Enforcement Policy.
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' Conclusions
Procedural instructions were not completely followed while a scaffold was erected which h
resulted in the scaffold interfering with the operation of a safety-related containment
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vacuum breaker. This was similar to, but not a direct repeat of, previously identified L
scaffold construction procedure issues.
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M1.3 : Wrona Chart Paoer installed in Control Panel Chart Recorder
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Inspection Scope (62707)
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During control panel walkdowns, the inspectors identified that incorrect chart paper had L
been installed in a safety-related control panel chart recorder. The inspectors
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interviewed operations and maintenance department personnel and reviewed records
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associated with this issue.
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Observations and Findinas During control room panel walkdowns on November 9,1998,' the inspectors identified that the wrong chart paper was installed in recorder G43-R073B for suppression pool level. The incorrect paper, which was installed on November 2,1998, had a range of 2 ft. to 24 ft. The actual range of the recorder was 16 ft. to 96 ft. The inspectors
reviewed TS requirements to determine if data from this recorder was used during the
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performance of recent surveillances. The inspectors determined that there were no TS required readings taken from this recorder while the incorrect paper was installed and that there were no violations associated with this issue.
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' The instrumentation and controls (l&C) technician did not apply adequate attention-to-L detail when obtaining and installing the new paper. Also, opportunities to identify that
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the incorrect pape was installed were missed during shiftly operator panel walkdowns over a 7-day period and during an l&C technician walkdown of control room recorders on November 9,1998.'
The licensee installed the correct paper and initiated CR 98-2337 to investigate the issue and take further actions. Also, at the exit meeting held on December 2,1998, plant management indicated that they planned to consider the need for a check list to follow when recorder paper is replaced.
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Conclusions inattention-to-detail by an I&C technician led to incorrect chart paper being installed in
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the control panel suppression pool level chart recorder. The incorrect chart paper remained installed due to the failure of l&C technicians and operators to recognize this error during panel walkdowns until the inspectors identified it 7 days after installation.
M1.4 Missina Data in Hydroaen laniter Surveillance
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Inspection Scope (61726)
i The inspectors used IP 61726 to review the results of a surveillance test on hydrogen igniters. When the inspectors identified missing data within the completed procedure, they reviewed the applicable TSs and discussed this issue with plant personnel.
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Observations and Findinas On November 24,1998, during a review of SVI-M56-T5417, ' Hydrogen Igniter Current Check," Revision 3, that had been completed on October 1,1998, the inspectors identified missing data. The data sheet on page 12 for hydrogen igniter 1M56-S102 did not have data filled in for " actual voltage" as required by step 5.1.1.16. Also, step 5.3, which required verification that all ste r een satisi1ctorily completed, was signed
r off despite the missing data on page 11. In addition, the missing data was not identified during the unit supervisor's (US) review of the test results. When the inspectors informed the licensee of the error, hydrogen igniter 1M56-S102 was declared inoperable and the error was corrected.
Technical Specification 3.6.3.2, required that 90 percent of the 52 hydrogen igniters in each Division be operable. The missing data affected only one of the hydrogen igniters and the Division remained operable. The failure to record data for 1M56-S102 is a violation of TS 5.4.1.a, which requires that surveillance procedures be followed.
However, this failure constitutes a violation of minor significance and is not subject to formal enforcement action.
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Conclusions Inattention-to-detail by a test performer and a US, respectively, led to a data entry error during a hydrogen igniter surveillance test and a failure to identify the error during a review of the test results.
M1.5 Secc.,dary Containment Temporarily lnocerable Durina AEGTS Testina a.
Insoection Scope (61726)
The inspectors followed the guidance of IP 61726 while observing and reviewing a routine surveillance test of the AEGTS system. The inspectors questioned the operability of secondary containment when TS vacuum requirements were not met during the test for short periods of time. The inspectors reviewed TS requirements and conducted interviews with operations and engineering department personnel.
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Observations and Findinas On November 14,1998, the inspectors observed the performance of surveillance test SVI-M15-T1239, " Annulus Exhaust Gas Treatment System Operability Test." When the licensed operator shifted from operation with AEGTS train A to train B, for approximately 40 seconds, the secondary containment vacuum dropped below the 0.66 inch vacuum water gauge pressure requirement of TS SR 3.6.4.1.1. Control room annunciators alarmed as expected and operators responded appropriately. Operations department personnel explained that the pressure changes in the secondary containment were l
typical when shifting AEGTS fans due to the slow response of the dampers.
The inspectors asked the US whether the 4-hour Limiting Condition for Operation (LCO)
of TS 3.6.4.1.A should be entered. The US indicated that the LCO for this condition was not usually entered and referred the inspectors to TS bases discussions regarding pressure in the secondary containment during entry and exit to the annulus. The inspectors determined that the TS bases only addressed annulus entries and not pressure changes due to testing.
The inspectors questioned operations management on the need to formally recognize and enter the 4-hour LCO. Subsequently, operations management initiated a Standing instruction to invoke existing guidance regarding logging short entries into LCOs. The inspectors verified that AEGTS fan shifts after the date of the Standing Instruction were appropriately logged in the operators' logs. The licensee also planned to clarify the TS bases description to address changes in pressure due to testing. The inspectors determined that there was no violation of TS because the LCO time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was not exceeded.
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Conclusions A misinterpretation by the licensee of the TS bases regarding pressure in the secondary containment led operators to not recognize that an LCO existed during surveillance testing of the annulus exhaust gas treatment system fans.
M1.6 Policy for Performino Hydraulic Control Unit Testina Did Not Match Procedure a.
Inspection Scope (61726)
The inspectors followed the guidance of IP 61726 while observing a cyclic surveillance test of the control rod scram accumulator pressure and leak detection instrumentation.
The inspectors reviewed surveillance procedure requirements and conducted interviews with operations and maintenance department personnel.
b.
Observations and Findinas On November 17 and 18,1998, the inspectors observed the performance of surveillance test SVI-C11-T0009, " Control Rod Scram Accumulator Pressure / Leak Detection Functional / Calibration for Hydraulic Control Unit Accumulators," Revision 4.
The inspectors observed that l&C technicians were pressing pushbuttons on the control room horseshoe panel during the test. Step 5.1.3 of SVI-C11-T0009 stated, " Request
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Supervising Operator press ACCUM FAULT pushbutton (P680-05C)." TNs step was performM several times for each control rod in the plant.
Tt.e inspectors questioned the US about the discrepancy between the procedure (which required a licensed operator to perform the step) and the practice (allowing an I&C technician to perform the step). The US immediately reviewed the procedure and testing was suspended until the procedure was changed. When the inspectors
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questioned the l&C technicians, they were told that the testing " policy" had been agreed upon by I&C and operations management before the testing was commenced.
Subsequent discussion with operations management indicated that the Plant Administrative Procedure, PAP-0528, " Procedure Use and Adherence," may allow this type of activity to be performed without a change to the procedure. The inspectors reviewed the procedure and concluded that section 10 of PAP-0528 only addressed a situation when the procedure could not be performed as written and did not address a situation where the licensee chooses to perform steps in a different manner.
The failure to follow the surveillance procedure as written is a violation of TS 5.4.1.a, which requires that surveillance procedures be followed. However, this failure constitutes a violation of minor significance and is not subject to formal enforcement action.
Although there was minor safety significance with this example, the testing was performed over several weeks involving several personnel on different crews. Because of the number of operations and I&C department personnelinvolved, there were numerous opportunities for the question of strict procedure adherence to have been raised.
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Conclusions Although licensee management has recently taken actions to improve procedure adherence at the Perry Plant, the actions were not effective in ensuring personnel adhered to the procedural requirement that the supervising operator manipulate control panel pushbuttons during hydraulic control unit testing activities. Although a number of different supervisors and workers were aware of the procedural requirement, work was
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not stopped to revise the procedure to reflect the way the job was planned.
Ill. Enaineerina E1 Conduct of Engineering E1.1 Review of Corrective Action Proaram for Emeraent Eauipment issues a.
, Inspection Scope (37551)
The inspectors followed the guidance of IP 37551 and evaluated engineering personnel's involvement in the resolution of emergent equipment issues and other routine activities. The inspectors reviewed areas such as operability evaluations and
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root cause analyses. The effectiveness of the licensee's controls for the identification, resolution, and prevention of problems was also examined.
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Observations and Findinas The inspectors reviewed several condition reports (CR) which documented emergent equipment issues and several operability evaluations performed by engineering department personnel. The inspectors noted that equipment problems were promptly documented in the CR program. For issues that operators considered to be potential operability issues, there was a formal process to involve engineering personnelin a timely manner. On the front of the CR form, there was a block for operations department personnel to indicate the need for an operability determination or an immediate investigation. The inspectors reviewed several operability determinations performed during the inspection period. Specific observations included:
CR 98-2331 - On November 5,1998, as a result of special HPCS pump room
cooler performance testing, the licensee identified that the cooler would not be capable of meeting design basis requirements. Engineering department personnel performed an interim operability determination and concluded that the cooler was fully capable of removing the minimum heat load, provided emergency service water inlet temperature remained less than 60 F. The lake temperature was approximately 55 F on November 5 and was not expected to exceed 60 F until June 1999. Long-term actions were being evaluated for completion during the next refueling outage in March 1999.
- CR 98-2451 - On November 24,1998, the licensee identified that the data base for tracking replacements of agastat relays in safety-related equipment contained an error. There was only one affected component, which was a relay in the containment vacuum relief system. This relay was incorrectly listed in the data base as having been replaced according to program requirements.
Engineering department personnel provided an operability evaluation to operations department personnel, which contained the basis for continued operability until relay replacement.
- CR 98-2166 - On October 14,1998, during the performance of routine surveillance test SVI-M16-T0414, the breakaway torque for one drywell vacuum i
breaker exceeded the acceptance criteria in the surveillance. The licensee
declared the component inoperable and initiated a CR and a work order.
Following further testing of the vacuum breaker and the review of test results by
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engineering department personnel, an operability determination was provided to q
operations department personnel and the vacuum breaker was declared
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operable. The operability determination provided appropriate justification that the vacuum breaker was operable based on the results of additional testing.
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Conclusions i
- The inspectors concluded that there was an appropriate level of documentation for emergent equipment issues, that the process for requiring and documenting the need for an operability evaluation was formalized, and that operability determinations provided
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properjustification to operations department personnel.
E8 Miscellaneous Engineering lasues (92903)
E8.1 (Closed) Violation 50-440/98007-02: The inspectors identified that the TS requirement for Division 3 diesel generator fuel oil level was incorrect. The licensee submitted a TS amendment request, which was approved by NRC on November 23,1998, as Amendment No. 94. The inspectors determined that the corrective actions were appropriate. This item is closed.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on December 2,1998. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
- Licensee L. Myers, Vice President, Nuclear H. Bergendahl, Director, Nuclear Services Department N. Bonner, Director, Nuclear Maintenance Department W. Kanda, General Manager, Nuclear Power Plant Department F. Kearney, Superintendent, Plant Operations T. Rausch, Operations Manager R. Schrauder, Director, Nuclear Engineering Department
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INSPECTION PROCEDURES USED
. IP 37551:
.Onsite Engineering IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726:
Surveillance Observation IP 62707:
Maintenance Observation IP 71707:
Plant Operations IP 71750:
Plar,t Support -
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Onsite Followup of Written Reports of Nonroutine Events at Power Reactor -
Facil; ties IP 92901:
Followup - Operations IP 92902:
Foliowup - Maintenance IP 92903:
Followup - Engineering ITEMS OPENED AND CLOSED Opened 50-440/98019-01 NCV Scaffolding Blocked Operation of Vacuum Breaker Closed -
50-440/98007-02 VIO _ TS Requirement for Division 3 DG Fuel Oil 50-440/98019-01 NCV Scaffolding Blocked Operation of Vacuum Breaker
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I l-LIST OF ACRONYMS USED
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h AEGTS
- Annulus Exhaust Gas Treatment System CFR
. Code of Federal Regulations
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E CR Condition Report.
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DG :-
Diesel Generators
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Division of Reactor Projects HPCS.
l&C.
Instrumentation and Controls t
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IPL Inspection Procedure j
'LCO Limiting Condition for Operation j
~MSR'
Moisture Separator Reheater-NCV.
Non-cited Violation
.NRC
' Nuclear Regulatory Commission l PAP Plant Administrative Procedure
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.RG-Regulatory Guide
RHR Residual Heat Removal-SO~
Supervising Operator
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Surveillance instruction TSL
. Technical Specification US.
Unit Supervisor
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