IR 05000440/1999009

Insp Rept 50-440/99-09 on 990709-0825.One Violation Occurred & Being Treated as Ncv.Major Areas Inspected:Aspects of Licensee Operations,Engineering,Maint & Plant Support

ML20217A909
Person / Time
Site:	Perry
Issue date:	09/09/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217A901	List: IR 05000440/1999009 ML20217A897
References
50-440-99-09, NUDOCS 9910120107
Download: ML20217A909 (11)

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U. S NUCLEAR REGULATORY COMMISSION

REGIONlli k-Docket No

50-440-License No: NPF-58 i

Report No: 50-440/99009(DRP)

l Licensee: FirstEnergy Nuclear Operating Company l P.O. Box 97 A200 l Perry, OH 44081 Facility: Perry Nuclear Power Plant Location: Perry, OH Dates: July 9 through August 25,1999 in pectors: C. Lipa, Senior Resident inspector J. Clark, Resident inspector R. Vogt-Lowell, Resident inspector P. Louden, Senior Resident inspector i

Approved by: Thomas J.- Kozak, Chief .

Reactor Projects Branch 4 Division of Reactor Projects DR D 0 '

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EXECUTIVE SUMMARY Perry Nuclear Power Plant NRC Inspection Report 50-440/99009(DRP)

This inspection report included resident inspectors' evaluations of aspects of licensee operations, engineering, maintenance, and plant support activitie Operations

• The conduct of operations was professional. The inspectors observed appropriate use of procedures and consistent three-part communications. Panel walkdowns were generally completed thoroughly and consistently (Section 01.1).

• The inspectors concluded that a communication breakdown resulted in control rocm operators not receiving notification of a severe thunderstorm warning for the county. As a result, the necessary compensatory measures were not taken. This issue was 4 appropriately addressed in the licensee's corrective action program, subsequent severe weather notifications were promptly received, and compensatory actions were taken as required. One Non-Cited Violation for the failure to follow the instructions in an off normal instruction was identified (Section O1.2).

Maintenance

• Maintenance and surveillance activities were generally properly enntrolled and performed per approved procedures. There was good coordination between the control room and other work groups for these activities (Section M1.1). I i

• Operations personnel did not ensure that test equipment installation and removal was properly controlled during a surveillance test. Specifically, operators failed to remove a meter from an electrical panel following completion of a high pressure core spray system pump and valve operability test. There was no impact on system operability as a result of this event (Section M1.2). i Enaineerino

• One figure in the Updated Safety Analysis Report (USAR) was not updated when the reactor core isolation cooling system was modified in 1987. When this was identified by the inspectors, a condition report was initiated to investigate this discrepancy and correct the USAR. The inspectors concluded that the modification and safety evaluation were properly completed at the time and that other USAR sections containing information associated with this modification had been appropriate;y updated (Section E3.1). '

Plant Suocort

• During evaluation of a routine emergency preparedness training drill on July 21,1999, the inspectors concluded that emergency response facilities were maintained available for emergency operations, that there was good performance by the participants in the drill, and that the post-drill critiques were self-critical (Section P2.1).

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REDort Details Summarv of Plant Status l

The plant was operated at approximately 100 percent power throughout the inspection period.

l The licensee conducted a downpower es ,ation for a rod pattern sequence exchange on July 11,1999. No other significant downpower activities or plant transients occurred this perio l. ODerations 01 Conduct of Operations 01.1 Review of Routine Plant Operations (71707)

The inspectors followed the guidance of Inspection Procedure (IP) 71707 and conducted frequent reviews of plant operations including observing routine control room activities, performing panel walkdowns, reviewing system tagouts, accompanying plant operators on rounds, and attending crew briefings. The conduct of oper:tions was professional with appropriate use of procedures and consistent three-part communications. Panel walkdowns were generally completed thoroughly ared consistentl .2 Ooerators Missed an Entry into a Severe Weather Off-Normal Instruction (ONI) Insoection Scope (71707)

The inspectors reviewed the circumstances surrounding the licensee's identification that operators failed to enter ONI-ZZZ-1, " Tornado or High Winds," when its entry conditions existed, Observations and Findinas On July 10,1999, an encoming Shift Supervisor (SS) identified that a previous crew had failed to enter ONI-ZZZ-1 when a severe thunderstorm waming was issued the previous day. The warning had been issued for Lake County by the National Weather Service at 5:42 p.m. on July 9 and lasted until 6:45 p.m. the same day. Section 4.0 of ONI-ZZZ-1 requires certain compensatory actions to be taken upon receipt of a severe thunderstorm warning, tornado watch, or tornado warning in order to protect plant equipment from the possibility of damage that could affect the safety of the plant. The required actions for a severe thunderstorm waming were the repositioning of certain doors within the control complex building and closing ventilation louvers on the top floor of that buildin On July 9, the primary method for notification of severe weather was a weather radio in the Security SS office that would alarm when a severe waather report was received. No report was received on the radio on July 9. The licensee's investigation determined that the location of the radio inside the office may have caused poor reception. Other sources of notification included Internet radar maps, television news channel reports, and the system control center. None of the other sources identified the severe

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thunderstorm waming on that day. The inspectors, held discussions with the Control Room SS earlier in the day on July 9 and he indicated that he was checking the sources

' of information because severe weather had been forecaste ' The licensee initiated CR 99-1774 to investigate the issue. Corrective actions included

' moving the weather radio to an area with better reception and procuring dedicated weather pagers for the Control Room SS and Security SS, which alarm when weather advisories are issued. The inspectors have observed two instances since the corrective actions were implemented where a severe thunderstorm waming was issued for the county and plant personnel took the appropriate actions per the ONI in a timely manne ^

Technical Specification 5.4.1 requires that procedures listed in Regulatory Guide (RG) 1.33, Appendix A, be implemented. Procedures for off normal conditions

. are listed in this Appendix. The failure to properly implement ONI-ZZZ-1 on July 9,1999, is a violation of TS 5.4.1.a. This Severity Level IV violation M Ning treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Polic This violation is in the licensee's corrective action program as CR 99-177 (NCV 60 440/99009-01(DRP)) . Conclusions The inspectors concluded that a communication breakdown resulted in control room operators not receiving notification of a severe thunderstorm warning for the county. As a resuit, the necessary compensatory measures were not taken. This issue was appropriately addressed in the licensee's corrective action program and subsequent severe weather notifications were promptly received. One Non-Cited Violation for the failure to follow the instructions in an off normal instruction was identifie Operational Status of Facilities and Equipment O General Plant Tours and System Walkdowns (71707)

The inspectors followed the guidance of IP 71707 in walking down accessible portions of several systems and areas, including:

o Controlcomplex e Emergency diesel generators e Emergency closed cooling system o Emergency service water pump house o High pressure core spray system (HPCS)

e Reactor core isolation cooling system (RCIC)

e. Switchgear and station battery rooms

~ Equipment operability and material condition were acceptable. The inspectors identified a discrepancy in the Updated Safety Analysis Report (USAR) for the RCIC system, which is discussed in Section E ,

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II Maintenance

.M1 Conduct of Maintenance

M1.1' Review of Routine Maintenance and Surveillance Activities The inspectors reviswed applicable calculations, applicable sections of the Technical Specifications (TSs) and the USAR, and observed portions of the work activities listed below:

e SVI-E31-T53118, " Turbine Building Main Steam Line Temperature High Channel Functional"

.o SVI-M26-T1259,'" Control Room Emergency Recirculation Operability Test"

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e Control Complex Chilled Water "A" Overhaul

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• SVI-R42-T5228, " Unit 1 Division 1 Battery Charger Load Test"

' e' Work Order 39-12227, "Setpoint Change for Main Steam Isolation" e- SVl-E12-T2001, "RHR System'"A" Pump and Valve OperaMiity" e SVI-E22-T5214, " Service Test of Battery Capacity Division 3 Unit 2" e: Work Order 99-13598, " Troubleshoot Cause of RHR "A" Out of Service Annunciator" Maintenance ar.d surveillance test activities were generally completed properly, with j satisfacto y results. There was good coordination between the control room and in-field i personnel during the activities. In general, procedures were appropriate for the activities and were followed. One example of inadequate control of test equipment is discussed in Section M M1.2 Test Eauioment Left Installed After Surveillance Testina . Insoection Scope (61726. 62707)

The inspectors reviewed the circumstances involved with the improper control of test

. equipment associated with a HPCS surveillance test. The inspectors interviewed operations and maintenance department personnel, and reviewed the completed surveillance test and the operability determinatio ,

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b. - Qhgervations and Findinas -

On June 7,1999, operations personnel connected a Fluke digital multi meter to terminals in panel 1H13-P601-168 as part of surveillance test SVI-E22-T2001, "HPCS .

' Pump and Valve Operability. Test." The installation of the me'.er was optional because l

'. the plant computer data was usually available. The test was turned over to the !

oncoming crew, who used the plant computer for the data and did not realize that the ;

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. 1 Fluke had been installed. When the SVI was completed, operations personnel failed to remove the instrument as require On August 11,1999, operations personnel discovered that the Fluke digital mu!ti meter was still connected to the h?CS terminals while chec' .1g inside the panel for an unrelated pre-job walkdown. The inspectors reviewed the documentation for the June 7,1999, performance of the SVI and noted that removal of the meter was marked as "N/A" in the restoration checklist. The system restoration checklist of the SV1 called for removal of the meter; however, this block could be marked "N/A" if the meter was not previously installed. The personnel completing the test did not verify if a meter had been installed during the tes The inspectors reviewed the licensee's past operability evaluation, which covered the

, time period between June 7 and August 11,1999. The licensee concluded that with the instrumentation installed, there was no impact on system operability. The inspectors determined that sufficient basis was provided for this conclusio Technical Specification 5.4.1 requires that procedures listed in RG 1.33, Appendix A, be implemented. Surveillance testing is one of the listed procedures. The faihre to properly control test equipment installation and removal during SVI-E22-T2001 is a violation of TS 5.4.1. However, this failure constitutes a violation of minor significance and is not subject to formal enforcement actio c, Conclusions Operations personnel did not ensure that test equipment installation and removal was properly controlled during a surveillance test. Specifically, operators failed to remove a meter from an electrical panel following completion of a HPCS pump and valve operability test. There was no impact on system operability as a result of this even Ill. Enaineerina E1 Conduct of Engineering E1.1 Review of Routine Enair.eerina Activities Engineering personnel were actively involved in the resolution of emergent material l condition problems and other routine activities. When requested by operations personnel, engineering personnel promptly evaluated and documented the basis for system operability. Engineering personnel also assisted in troubleshooting efforts for several activities. The inspectors determined that engineering department personnel provided good support to plant operation E1.2 Ultimate Heat Sink Desian Basis Inspection Scope (37551)

The inspectors reviewed the response of engineering and operations personnel to increasing lake temperatures during a period of high ambient temperatures. The

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inspectors also interviewed engineering personnel and reviewed applicable sections of

- the USA Observations and Findinas'

During the week of July 25,1999, the ambient air temperature in the vicinity of the Perry plant remained in the upper 80 to 90 degree Fahrenheit range. The temperature of

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Lake Erie, which is the ultimate heat sink (UHS) for the Perry plant and is the water supply for the emergency service water (ESW) system, increased to a maximum value of 84.7_ degrees on July 31 (based on the service water system inlet temperature as measured by the plant process computer). As the lake temperature rose, engineering and operations personnel became concerned with the operability of the ESW syste The inspectors noted that no specific limit for maximum UHS or ESW temperature was given in the TSs or in the applicable design basis sections of the USA.R. However, an

- ESW temperature of 85 degrees was listed in the USAR as one of three inputs to the calculation used for determining the ESW system net positive suction head (NPSH).

The other two inputs to the calculation were minimum design !ake level and maximum design heat exchanger flow rate. Should one of these input values not be met, the ESW

. system would be considered degraded and a sys'am operability evaluation would need '

to be conducted. Plant management informed the inspectors that engineering

. personnel were evaluating the ESW system NPSH calculation to determine if a temperature input above 85 degrees could be used without degrading the NPS Per the USAR, the licensee committed to fo!Iow the recommendations in RG 1.27,

" Ultimate Heat Sink for Nuclear Fewer Plants," Revision 2, January 1976. The RG addresses, in part, heat sinks wl;ere the supply and/or temperature of plant intake water may become critical. The RG recommends that sufficient conservatism be used to ensure that a 30-day supply of water be available so that the design basis temperatures of safety-related equipment not be exceeded following an accident. It also recommends that transient analysis of supply and/or temperatures should be performed and that the TS should include provisions for actions to be taken in the event that conditions threaten a partialloss of UHS capability. However, a statement in the USAR indicated that the TSs do not address the loss of UHS capability since, "there is no single active or passive failure which would preclude the ultimate heat sink from' meeting its design criteria". The inspectors noted that this statement appeared to be inconsistent with the fact that actual lake temperatures approached the limits used in the licensee's design calculations

- which demonstrated that high ambient air temperature has the potential to predude the ultimate heat sink from meeting its design criteria. The inspectors asked the licensee for m. ore information on how this RG was implemented at Pwy and how the muirements of 10 CFR Appendix A, General Design Criterion (GDC) 44, " Cooling E.M" and GDC 2, " Design Bases for Protection Against Natural Phenomena," were met. The inspectors will continue to review this issue to determine if the UHS design bases were properly considered in accordance with the licensee's commitment to Regulatory Guide 1.27. This is considered an unresolved ite (URl 50-440/99009-02(DRP)) Conclusions The inspectors will review the licensee's commitments to Regulatory Guide 1.27 to determine if the ultimate heat sink design bases were properly considere .

E3 Engineering Procedures and Documentation E3.1 Lncorrect Descriotion of Reactor Core Isolation Coolina (RCIC) System initiation in

.t)SAR Inspection Scope (71707. 37551)

The inspectors followed the guidance of IP 37551 and 71707 in walking down and reviewing system operability for the RCIC system. This included a walkdown of control room panels and accessible plant equipment, and a review of system drawings and applicable USAR section ! Observations and Findinas '

The inspectors identified that Figure 5.4-10 in the USAR incorrectly described that the standby lineup for the RCIC system had the inboard steam supply isolation valve 4 (E51-F063) in the normally closed position, with the valve opening on a RCIC system initiation. This was incorrect in that the F063 valve is normally maintained in the open position. The normal position for this valve was changed in 1987 as part of a system modification. The inspectors reviewed the Safety Evaluations associated with this modification (EDCR # 870123) and determined that relevant aspects of the modification had been appropriately reviewed. Part of the modification package contained a list of drawings and figures that needed to be updated as part of the modification. However, ;

the modification package failed to identify Figure 5.4-10 as one of the items that was ,

required to be updated as part of the modification. The licensee initiated CR 99-1885 to

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investigate this issue and correct the USA l 10 CFR 50.71(e) requires that the USAR be revised to include all changes made in the facility and that the revisions must be filed 6 months after each refueling outage. The failure to update USAR Figure 5.4-10 following modification EDCR #870123 is a violation of this requirement. However, this failure constitutes a violation of minor 3 significance and is not subject to formal enforcement actio I Conclusions

One figure in the USAR was not updated when the RCIC system was modified in 198 When this was identified by the inspectors, a Condition Report was initiated to investigate this discrepancy and correct the USAR. The inspectors concluded that the mod;fication and safety evaluation were properly completed at the time and that other ,

USAR sections had been appropriately update E8 Miscellaneous Engineering issues E Year 2000 (Y2K) Comoliance Review I l

On July 26,1999, the licensee informed the inspectors that the last remaining item for {

remediation under the Y2K Readiness Pian was complete. This item consisted of the i removal of two non-compliant computers for the meteorological tower data, and l installation of software in the new plant computers to process the data. The inspectors Q reviewed the licensee's closecut paperwork and observed that the meteorological tower {

data appeared to be properly displayed by the plant process compute i i

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, IV. Plant Suppoit r

P2 Status of Emergency Preparedness (EP) Facilities, Equipment, and Resources P Evaluation of EP Trainino Drill (7175Q The inspectors followed the guidance of IP 71750 and observed and evaluated a routine EP Training Drill on July 21,1999. The emergency response facilities were maintained available for emergency operations. The inspectors observed good performance by the participants in the Technical Support Center, Operations Support Center, and the Emergency Operations Facility. Post-drill critiques were self-critical and a summary report was prepared, which provided opportunities for enhancements to the program and facilitie 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 August 25,1999. 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 identifie X3 Management Meeting Summary On July 29,1999, the NRC Region ll! Administrator toured the plant and met with licensee management individuals. Topics discussed included the licensce's corrective action program and initiatives the licensee is implementing as part of its business pla i l

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u PARTIAL LIST OF PERSONS CONTACTED l.-

.- Licensee >

H. Bergendahl, Director, Nuclear Services Department '

. B. Boles, Manager, Plant Engineering -

N. Bonner, Director, Nuclear Maintenance Department H. Hegrat, Manager, Regulatory Affairs T. Henderson, Supervisor, Compliance

'W. Kanda, General Manager, Nuclear Power Plant Department J.' Kloosterman, Supervisor, Corrective Actions Program B. Luthanen, Compliance Engineer-J. Powers, Manger, Design Engineering -

' T. Rausch, Operations Manager .

S. Sanford, Senior Compliance Engineer 3 R. Schrauder, Director, Nuclear Engineering Department J. Sears, Manager, Radiation Protection

- J. Sipp, Manager, Radwaste, Environmental, and Chemistry J. Wood, Vice President, Nuclear INSPECTION PROCEDURES USED L

IP 37551: Onsite Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: - Plant Operations IP 71750: Plant Support IP 92901: Followup.- Operations IP 92902: Followup - Maintenance -

IP 92903: Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-440/99009-01 NCV : - missed entry into ONI for severe weather 50-440/99009-02 URI conformance to RG 1.27 for ultimate heat sink Qlosed 50-440/99009-01- NCV missed entry into ONI for severe weather Discussed flone

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F LIST OF ACRONYMS USED CFR- Code of Federal Regulations CR Condition Report DG . Diesel Generators -

ESW: Emergency Service Water HPCS High Pressure Core Spray

~IP Inspection Procedure NC Non-Cited Violation .

NPSH' Net Positive Suction Head NRC Nuclear Regulatory Commission -

ONI Off-NormalInstruction RCIC - Reactor Core isolation Cooling l RG . - Regulatory Guide RHR Residual Heat Removal SVI Surveillance Instruction TS- Technical Specification URI Unrs.olved item j USAR Updated Safety Analysis Report

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Y2K Year 2000

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