IR 05000212/2004029

Insp Repts 50-440/85-10 & 50-441/85-05 on 850212-0429. Noncompliance Noted:Failure to Develop & Implement Equipment Protection & Housekeeping Procedures

ML20127D139
Person / Time
Site:	Perry, 05000212
Issue date:	05/23/1985
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20127D106	List: IR 05000212/2004029 ML20127D102 ML20127D117
References
50--441-85-5, 50-440-85-10, 50-441-85-05, 50-441-85-5, IEB-79-08, IEB-79-8, IEB-80-17, NUDOCS 8506240135
Download: ML20127D139 (14)

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-440/85010(DRP); 50-441/85005(DRP)

Docket Nos. 50-440; 50-441 Licenses No. CPPR-148; CPPR-149 Licansee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Units 1 and 2 Inspection At: Perry Site, Perry, OH

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Inspection Conducted: February 12 through April 29, 1985 Inspectors: J. A. Grobe J. W. McCormick-Barger G. F. O'Dwyer R FlNau'd= k Approved By: R. C. Knop, Chief Reactor Projects Section 10 T/23/W

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Date Inspection Summary Inspection on February 12 through April 29, 1985 (Report No. 50-440/85010(DRP);

50-441/85005(DRP)

Areas Inspected: Routine, unannounced inspection by resident inspectors of previous inspection findings, a 10 CFR Part 21 item, IE Bulletins and Circulars, an allegation, preoperational test program implementation, operating procedures, emergency procedures, safety committee activity, operating staff training, fuel receipt and storage, containment spray event review and followup. The inspec-tion involved a total of 309 inspector-hours onsite by three NRC inspectors including 46 inspector hours onsite during off-shift Results: Of the eleven areas inspected, no items of noncompliance were identified in eight areas; one item of noncompliance was identified with examples in the remaining three areas (failure to develop and implement equipment protection and housekeeping procedures, Paragraphs 5, 6.b and 11). l l

8506240135 850524  !

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DETAILS 1 Persons Contacted ,

• D. Lyster, Manager, Perry Plant Operations Department

• J. J. Waldron, Manager, Perry Plant Technical Department

• C. M. Shuster, Manager, Quality Assurance Department

• F. R. Stead, Manager, Nuclear Engineering Department

• W. R. Kanda, General Supervising Engineer, Technical Section

• G. R. Leidich, General Supervising Engineer, Nuclear Test Section

• R. P. Jadgchew, General Supervising Engineer, Nuclear Construction l Administration Section

! *B. D. Walrath, General Supervising Engineer, Operational Quality Section

• P. P. Martin, General Supervising Engineer, Procurement and Administrative Quality Section The inspectors also contacted and interviewed other licensee and contractor personnel during the course of this inspection.

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• Denotes those persons attending one or more of the exit interviews

! conducted on March 12 and 26 and April 30, 198 . Applicant Action on Previous Inspection Tindings l

• . (Closed) Noncompliance Item (440/83027-01(DRP); 441/83026-01(DRP)):

Timeliness of reports made pursuant to 10 CFR 50.55(e). The inspector reviewed the applicant's response to this item of noncompliance dated October 21, 1983, as supplemented on February 17, 1984 The noncompliance was caused by a delay

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in the initiation of the onsite review process to determine I if a design deficiency was reportable under 10 CFR 50.55(e).

Pursuant to their response, the applicant revised Nuclear Design

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Instruction No. 35-1501, " Engineering Design Deficiencies," to require a review for reportability within ten working days of identification of the deficiency. The inspector routinely reviews 10 CFR 50.55(e) reports initiated by the applicant and has observed that they have been timely. The inspector also verified that the current revision of Instruction 35-1501 contained simila reportability review requirements. The inspector has no further concerns in this area.

I (Closed)UnresolvedItem(440/83034-01(DRP);441/83033-01(DRP)):

l Inadequate implementation of equipment protection requirements.

! Equipment protection was examined during routine tours of the l facility and additional discrepancies were noted. These

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discrepancies are discussed in Paragraphs 5, 6.b, and 11, of this report and represent examples of an item of noncompliance.

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l (Closed) Open Inspection Item (440/84009-01(DRP); 441/84009-01(DRP)):

l Concerns regarding the Plant Operations Review Committee (PORC)-

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procedure, PAP 0103, Revision 1. Revision 2 to PAP 0103 was issued effective April 5~, 1985, which resolved the inspector's concerns as described in Inspection Report No.- 440/84015; 441/84014, Paragraph . .

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e4 (Closed)UnresolvedItem(440/84015-01(DRP)): Jurisdictional tagging concerns following turnover from Nuclear Test Section (NTS)

to Perry Plant Operations Department (PP00). The inspector was concerned that an insufficient number of green tags, PP00 jurisdictional tags, were being hung to positively identify equipment jurisdiction in : light of the fact that the absence of a jurisdictional tag is indicative of construction jurisdictio Plant Administrative Procedure (PAP) 1401, " Equipment Tagging," is being revised to provide more specific guidance on the scope of equipment to be tagged. The proposed revision, which the turnover group has been implementing for the past several months, specifies

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that all valves, pumps, heat exchangers, tanks and spectacle flanges

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shown on the piping and instrumentation diagram shall be tagged to r

indicate PP0D jurisdictional control. The hspector walked down l M28, Emergency Pump Area Cooling System, turned over on February 19,

1985, and 2P42B, a subscope of the Emergency Closed Cooling System I (ECCS) including the Unit 1/ Unit 2 ECCS crosstie, turned over on November 13, 1984. One minor discrepancy was noted on 2P42B, an untagged drain valve, which was promptly rectified by the applican The inspector has no further concerns in this are (Closed) Open Item (440/84015-03(DRP))

Plant Operations Review Committee (PORC) scope of review responsibilities. The inspector was concerned with the applicant's original submittal of technical l specifications 6.5.1.6.a and 6.8.2, which limited the scope of PORC l . required procedure reviews to administrative procedures. The l applicant revised those technical specification sections as l

described in the second draft issued Mcrch 6,1985. The inspector L

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has no further concerns in this area.

, (Closed)NoncomplianceItem(440/84022-04(DRP)): Failure to take

appropriate steps to prevent recurrence of nonconforming condition l The inspector examined the applicant's response to this item of noncompliance contained in a letter dated January 24, 1985. The inspector also examined the applicant's internal documentation regarding this violation. Routine reviews of nonconfomance reports i by the inspector has not shown recurrence of a significant nonconforming condition without appropriate corrective action to prevent recurrence. The-inspector has no further concerns in this are (Closed) Open Inspection Item (440/84022-06(DRP)): Safety relief

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valve (SRV) position indication technical specification. The inspector-was concerned with the minimum number of SRV position indication instruments required to be operable by technical- .

l specification section 3.3.7.5 and table 3.3.7.5-1. The applicant revised those specifications as reflected in the second draft issued

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March 6, 1985. . The inspector has no further concerns in this area.

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! (0 pen)OpenInspectionItem(440/84028-04(DRP);441/84025-03(DRP)):

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Lifted lead. jumper and electrical device administrative control

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deficiencies. The inspector examined the applicant's engineering

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evaluation of the identified improperly controlled lifted leads and jumpers. The results of that analysis are contained in an internal applicant memorandum dated January 22, 1985, from A. G. Migas to G. Hicks. Of the deficiencies identified, the applicant concluded that none would have gone uncorrected prior to operation or if they had gone uncorrected would either have operable redundant components or alanns/ annunciators which would have alerted the operators to the deficient condition. The applicant used this conclusion to justify not examining the remaining 35 percent of field electrical panel The inspector concurs with the applicant's analysis in each individual case, however, the justification for not performing inspection of the remaining field panels will be examined further by regional electrical specialist . Applicant Action on 10 CFR Part 21 Reports (Closed) 10 CFR Part 21 Report (440/82004-PP; 441/82004-PP): Deficiency in the Class 1E Low Voltage switchgear furnished by Brown Boveri. This 10 CFR Part 21 report was filed by Brown Boveri Company on December 22, 1982. The applicant reported this deficiency in accordance with 10 CFR 50.55(e)(440/83006-EE;441/83006-EE). The reported 10 CFR 50.55(e) item was reviewed and closed in Inspection Report No. 50-440/84015(DRP);

50-441/84014(DRP). Based on the closure of the 10 CFR 50.55(e) report, this item is close . Applicant Action on I.E. Bulletins and Circulars (Closed) I.E. Circular 81-10 (440/81-10-CC; 441/81-10-CC): Steam voiding in the reactor coolant system during decay heat removal cooldown. The applicant reviewed this Circular during a review comittee meeting (as documented in minutes reported July 5,1983)

and concluded this item to be not applicable to PNP Based on the fact that the Circular concerns Pressurized Water Reactor (PWR) reactor coolant system steam voiding and PNPP is a Boiling Water Reactor (BWR), this Circular is closed, (Closed) I.E. Circular 80-15 (440/80-15-CC; 441/80-15-CC): Loss of reactor coolant pump cooling and natural circulation cooldown. This Circular describes the events that occurred at a PWR after losing component cooling water flow to reactor coolant pumps and the

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resulting steam void that occurred during the natural circulation cooldown. This Circular recommended that " Power Reactor Licensee's" perform certain action to inform reactor operators of the incident and preclude recurrenc The applicant performed a review of the Circular and concluded that the formation of a steam bubble in a BWR reactor pressure vessel is not a concern. The applicant stated that the system which supplies cooling water to the recirculation pump seals consists of a single line penetrating containment with motor-operated isolation valves which should not be susceptible to inadvertent closure (the valve

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that closed inadvertently in the Circular report was a solenoid operated air valve that closed due to a short in the solenoid caused by a steam leak in the immediate vicinity of the valve). The applicant also reported that reactor recirculation pump seal leakage is directed to the drywell equipment drain sump, and that indefinite operation of the pumps after loss of seal cooling is possible if warrante Based on the applicant's review of the Circular which appears to be adequate considering the circumstances of the Circular (PWR steam void), this item is close c. (Closed) I.E. Circular 80-12 (440/80-12-CC; 441/80-12-CC):

Valve-shaft-to-actuator key may fall out of place when mounted below horizontal axis. This Circular requested that the applicant inspect all valve-shaft-to-actuator key connections that are similar to the connection described in the Circular whether or not supplied by the particular manufacturers identifie A review of the applicant's actions taken on Circular 80-12 indicated that an engineering review of similar valve connections was made and, when found, inspections of those valves were conducted to assure that the valves were not mounted below horizontal. The applicant concluded that no incident was found where a valve of similar design was mounted below horizonta This item is considered close (Closed) I.E.Bulletin 80-17, Supplements 3 and 4 (440/8C-17-3B; 440/80-17-4B;441/80-17-3B;441/80-17-48): Failure of control rods to insert during a scram at a BWR. These supplements were sent to the applicant for information and no response was require Supplements 3 and 4 of Bulletin 80-17 were provided to operating BWRs to require operational actions required pending the incorporation of changes requested per Supplements 1 and 2. The PNPP design for the scram discharge volume and associated vent and drain systems were approved by the NRC in Section 4.6 of Perry Safety Evaluation Report (SER) issued May 198 The applicant's review and determination that no response to Supplements 3 and 4 was required, was found to be adequat These Bulletin supplements are considered closed, (Closed) I.E.Bulletin 79-08 (440/79-08BB; 441/79-08-8B): Events relevant to boiling water power reactors identified during Three Mile Island incident. This Bulletin was sent to the applicant for information only. No written response by the applicant was require _-.

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A review of this Bulletin was documented in Inspection Report 50-440/84015(DRP)and 50-441/84014(DRP) and found to be inadequate

.in that documentation was.not provided which could show the inspector what specific actions were taken by the applicant in regard to this Bulleti In response to the findings reported in Inspection Report 50-440/84015(DRP)and 50-441/84014(DRP) the applicant prepared a matrix of the required actions of Bulletin 79-08 and_the appropriate response. The applicant's response to the Bulletin was addressed in Appendix 1A to the Perry FSAR. Appendix 1A specifically addresses 4 the applicant's responses to NUREG 0737 " Clarification of TMI Action Plan Requirements" and was found to include the necessary responses to Bulletin 79-08. Review of actions required by NUREG 0737 will be addressed in subsequent inspection This Bulletin is considered close (Closed) I.E.Bulletin 80-01(440/80-01-BB;441/80-01-BB):

Operability of ADS Valve Pneumatic Supply. This Bulletin was not :

, initially sent to the applicant and was applicable to General Electric BWR facilities with an operating license which use a pneumatic operator for ADS function. The applicant obtained a copy of the Bulletin in December 1983 and performed a review of the proposed action '

The inspector reviewed the applicant's response which reported the following information: Check valves F039 installed for isolation of the ADS accumulators were supplied with soft (resilient) seats and also spring loaded to (11;ninate leakag . Periodic leak test of the supply line check valves are conducted every 2 years in operational condition 4 and . The ADS supply line was built to ASME Section 3 and seismically qualifie The applicant's response to the required actions (for operating plants) have been found to be adequate. This Bulletin is close . Allegation Followup (Closed) Allegation (RIII-85-0080): Structural steel cleanliness over the fuel storage pools. On April 11, 1985, an allegation was received from contractor employee "A" that the structural steel supporting the roof over the new fuel preparation pool, the incline fuel transfer canal and the spent. fuel pool in the fuel handling building had not been cleaned as required due to employee safety concerns regarding the height of the work location. Contractor employee "A" had been told that another

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contractor (Kelly Steel) accomplished the work. Contractor employee "A" indicated that contractor employee "B" had examined the structural steel and it was not cleane It was not possible for the NRC inspector to examine the structural steel over the fuel pool area without having the licensee erect extensive scaffolding. On April 12, 1985, the inspector did examine a section of the structural steel over the high bay in the fuel handling building. That structural steel had not been cleaned for a lengthy period of time was evidenced by one-sixteenth to one-eighth inch deep dust, a one inch metal disk and other debris found on the beams. Based on this visual observation, further inspection of the fuel pool area was unnecessar The inspector discussed the lack of cleanliness with the applicant. The applicant indicated that there had been a work authorization issued in January 1985 for the cleaning of all the structural steel in the fuel handling building. The steel over the pools was not cleaned at that time due to personnel safety concerns, and the steel over the high bay was not cleaned because it was deemed unnecessary. The inspector could not locate that work authorizatio The applicant also indicated that a technical section engineer had also discovered the uncleaned steel above the storage pools and reported his observation to his supervisor. The applicant told the inspector that the steel had then been cleaned by Kelly Steel, the structural steel erection contractor. To support this claim, the applicant presented time cards for six Kelly Steel employees showing two hours of overtime each on February 28, 1985, from 4 to 6 p.m., with the annotation, " Fuel Handling Building - Clean Girders." The inspector also examined the entry / exit logbook for the fuel handling building access security checkpoint which documented that those individuals had entered the fuel handling building at approximately 3:40 p.m. and exited at approximately 5:05 p.m. on February 28, 1985, to clean structural steel. -The inspector _ interviewed two technical section engineers who asserted that they examined the area before and after the cleaning activity to verify adequate cleanlines No procedure was used for controlling the cleaning activity. .Following the inspector's discussion with the licensee, the applicant also decided to clean the steel over the fuel handling building high bay. This was accomplished on April 12 and 13,1985, while fuel was not being handle The inspector verified the clean up and the adequacy of housekeeping in this area. The cleaning activity was also accomplished without a procedur The applicant indicated that no housekeeping or cleaning activities are accomplished using procedures. The lack of records and failure to have procedures for cleaning activities is a violation of 10 CFR 50, Appendix B, Criterion V, which requires that activities affecting quality be accomplished in accordance with written procedures (440/85010-01(a)). .

The allegation was substantiated in part and one example of an item of noncompliance was identified in this area. No deviations were identifie The inspector considers the allegation close . .__ - . . - -. - . - -

. . Preoperational Test Program Implementation Verification 1 The inspector observed control room operation and test coordination, reviewed applicable logbooks and conducted discussions with control room operators and test personnel during the inspection period to

- ensure that test activities were being conducted in accordance with regulatory requirements and facility procedures. Tours of the Unit I reactor building, intermediate building, Unit 1 auxiliary building, fuel handling building, control complex and diesel generator building were conducted to observe test and maintenance work in progress, area housekeeping, equipment condition and system cleanliness. The inspector also reviewed the minutes from Test Program Review Committee (TPRC) meetings No. 345 through 372, 377 through 382, 388, 391, 392 and 393 conducted during this inspection period to verify conformance with Nuclear Test Section procedure During routine tours of the facility, the inspector paid particular N _ attention to the protection of equipment under NTS and PPOD jurisdiction to address a previous NRC concern over equipment protection (440/83034-01(DRP); 441/83033-01(DRP)). The PNPP procedures governing housekeeping and equipment protection are listed below:

. ProjectAdministrationProcedure(PA)-0206, Revision 5,

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" Housekeeping"

. Test Program Instruction (TPI)-10, Revision 1, " Housekeeping and Equipment Protection"

. Plant Administrative Procedure (PAP)-0204, Revision 0,

" Housekeeping / Cleanliness Control Program"

. General Electric Procedure GEP-AP-0011, Revision 1, " Vessel

! Access Control", as modified by letters dated November'17 and 26 and December 3, 1984, and March 9, 1985.

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These procedures implement the requirements of Regulatory Guide 1.39, Revision 2, " Housekeeping Requirements for Water Cooled Nuclear Power Plants," and ANSI N45.2.3-1973, " Housekeeping During the Construction Phasa of Nuclear Power Plants," as committed in Final Safety Analysis Report (FSAR), Section The inspector observed many areas with proper equipment protection including hard clear plastic gage face covers, instrument and instrument rack wooden housings, instrument rack heavy plastic

. . protective coverings and equipment wire cages. However, several pieces of equipment were observed without adequate protection:

. Three Residual Heat Removal-(RHR)-System and Reactor Core Isolation Cooling (RCIC) System instrument racks were observed ;

in a high construction traffic area without protection.for instrument lines and instrument I l

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. The nonsafety instrument, air compressor control panel was observed without protection and was covered with dirt and grim . Six Control Complex Chilled Water System pressure gauges were observed unprotected in high construction activity areas (R135B, R115B, R115C, R115A, R100A and R110A).

The inspector also examined the housekeeping zone designation floor plans which are required pursuant to PA-0206, Section 1.2.1. A number of inconsistencies existed between the floor plans, the implementing procedures and actual field practice . The control room was designated as Zone IV which prohibits eating and use of tobacco. This requirement is not being implemented. The inspector observed individuals eating, drinking and smoking in the Unit 1 control roo . The reactor vessel was categorized as Zone II requiring gloves, shoe covers, head covers, material and personnel accountability and prohibiting eating and tobacco use. The inspector reviewed GEP-AP-0011, as modified, which required a change of clothes (not a Zone II requirement), but did not require gloves and head covering. The inspector observed individuals entering and working in the reactor well over the edge of the open reactor vessel during removal of the reactor vessel tarp on March 8, 1985, without clothing change or head covering. In some cases, paper coveralls were worn over the street clothing,sbut the coveralls were torn and unzipped. The inspectors did not observe any signs near the reactor well indicating the area cleanliness requirements. The applicant was unable to locate the entry logs for March 8, 1985. Those records are required to be initiated pursuant to GEP-AP-0011, Sections 5, 6 and . The areas above the 687' elevation in the reactor building were categorized as a Zone IV with personnel accountability. This classification without material accountability is unacceptable over the open reactor vessel and reactor wel . The reactor well ("B" pool) was only categorized as Zone IV while an appropriate classification would be equivalent to the reactor vessel classificatio The applicant indicated that the control room designation on the floor plans was incorrect and should have been Zone V. The inspector acknowledges that eating and smoking may be appropriate for the horseshoe control panel area, but would not be appropriate for back panel areas. The applicant also indicated that the reactor vessel had been miscategorized as Zone II and should have been Zone III with additional requirements of shoe covering and clothing change. These changes would make the floor plans and procedures internally consistent. The floor plans had been inaccurate since their last updating on October 26, 198 .- .

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' The inspector examined PAP 0204 using the requirements of ANSI N45.2.3-1973 as modified by FSAR Section 1.8. The inspector is concerned that both the exceptions documented.in the FSAR and the

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procedure are too vague to ensure implementation of equivalent requirements'as those in ANSI N45.2.3-1973. This concern will be examined during a future inspection and will be tracked as an open item (440/85010-02(DRP)).

o The equipment protection program and procedure implementation deficiencies are examples of an item of noncompliance (440/85010-01(b)(DRP)).

Several examples of an item of. noncompliance were identified in this area. No deviations were identifie . Operating Procedures The inspectors' reviewed Perry Administrative Procedure (PAP-1105)

" Surveillance Test Control," Revision 1, dated 5-1-85. A major purpose-of Revision 1 to PAP-1105 was to provide a controlled means of evaluating to what extent the Nuclear Test Section (NTS) testing (Preop Testing) can be used to satisfy surveillance program requirements, and to establish a program for reviewing, documenting and taking credit for the NTS test results as satisfying Technical Specification surveillance requirement In addition, a review of procedures PAP-1201, " Control and Calibration of Measuring and Test Equipment," Test Program Instruction (TPI) No. 31,

" Measuring and Test Equipment Control and Calibration," PAP-0212,

" Technical Specification Surveillance Program," and PAP-0507,

" Preparation, Review,- Approval and Cancellation of Instructions," were made to ensure that the NTS program and the Surveillance Test Program were sufficiently compatibl The inspectors have concluded that the program established by the licensee to take credit for_'NTS testiresults as Technical Specification Surveillance requirements appears to be adequate. -The inspector will examine a sample of the NTS test procedure sections approved _for surveillance procedure credit during a future inspection _to verify proper implementation of this program. This is an openl item

.(440/85010-03(DRP)).

No items of noncompliance of deviations were identified in this are i Emergency Procedures l During review of the Standby Liquid Control System (SLCS) preoperational test, the inspector reviewed the alarm response instruction (ARI) for SLCS alarm Four procedures,.ARI-C41-2, ARI-C41-3, ARI-C41-4, and ,

ARI-C41-5, identified an improper annunciator location. One SLCS annunciator, "SLC Pump Trip. Storage Tank' Level Low" had no AR Additionally, there was inconsistency between the FSAR, Technical y-Specifications, preoperational. test. procedure and ARI-C41-4 with respect i j

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to the high and low storage. tank' level setpoints. Resolution of these ARI discrepancies will be followed as an unresolved item *

(440/85010-04(DRP)).

No items of noncompliance or deviations were identified in this are +

. Safety Committee Activity The inspector attended Plant Operations Review Committee (PORC) meetings No. 85-19, 85-21 and 85-22, and reviewed the minutes of meetings N through 85-27, 85-29 and 85-30, conducted during the inspection period to verify conformance with PNPP procedures and. regulatory requirements. The observations and examinations. included PORC membership and qualifications, quorum'at PORC meetings and PORC activities. The -

inspector noted an increased level of detail in the meeting minutes documenting changes which PORC makes to procMures during the meeting ,

prior to approval of those procedures. .This increased. detail should help t to ensure that any PORC required changes will be incorporated into the j final-procedur t During PORC Meeting No'. 85-19, PORC recommended for approval three security implementing procedures which were written to implement a ,

revision'of the security plan that was not on the applicant's shelves, '

had.not been printed and was:not submitted to or approved by NR The inspector is concerned that when the revised security plan is approved, it may differ from the submitted plan invalidating the implementing

. procedures. The' applicant does not have a formal mechanism to identify '

this sort of discrepancy. This concern will be handled as.an open item *

(440/85010-05(DRP)). j During-PORC Meeting No. 85-22, PORC recommended for approval PAP-1917, Revision 2, " Fire Protection Training Programs".- Branch Technical Position CMEB 9.5-1, " Guidelines for Fire Protection at Nuclear Power .

Plants," Sections C.1.a(4)(d)v. and'vi. recommends the implementation of '

training programs for indoctrination of personnel in appropriate '

administrative controls implementing the fire protection program and emergency-procedures relative to fire protection. PAP 1917, Revision 2, ;

only requires General Employee Training to include response to a fire i emergency. This training program deficiency will-be tracked as an open I

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ites.(440/85010-06(DRP)).

No items of noncompliance or deviations were identified in this are . Operating Staff Train _ing The inspector participated in General Employee Training (GET) and Radiological Controls Training (RCT)-on March 11_and 12, 1985. -The inspector verified that a documented program exists for training

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applicant personnel in' administrative controls and organizational ..

structure, security'and controlled access, emergency plan, industrial safety, fire protection, quality assurance, radiological controls and prenatal radiation exposur . .

After observing GET,.the inspector is concerned with the scope and number of ' inadequacies in the GET program and the lack of a formal mechanism to retrain persons after rectification of those inadequacie The inspector noted the following deficiencies in the GET:

. Sirens for fire and evacuation emergency situations were not included in the trainin .

Special fire fire discharge, protection alarms detector (Halonetc.)

actuation, system discharge, were CO,d. system not discussE

. Administrative controls over handling and storage of combustible and flammable materials / liquids were not include . Administrative controls over welding, grinding, cutting, and other

" hot work" were not discusse .

. Immediate response actions for a~ flammable liquid spill were not discusse . The organizational charts for Perry Plant Operations Department and Perry Plant Technical Department were out of dat . During a discussion of the purpose and function of electrical grounding tags, the slide showed an information ta . The purpose and function of information tags were not discusse . n discussion was presented on initiating work on an RHR system globe valve using a work request, but the slide showed an action reques . The slides of NRC forms 3 and 4 showed out of date form The inspector will follow up on this concern during a future inspectio This concern will be tracked as an open item (440/85010-07(DRP)).

No items of noncompliance or deviations were identified in this are . Fuel Receipt and Storage The inspector reviewed the following Plant Administrative Procedures (PAP), Fuel and Technical Instructions (FTI) and Health Physics Instructions (HPI) which relate to new fuel. receipt and storage:

PAP-0802, " Control of Special Nuclear Material," Revision 0, with Temporary Change Notice (TCN) #1 PAP-1303, " Fuel Receipt, Handling, Storage and Shipment," Revision 1, with TCN #2,'3 and 4 FTI-E13, "New Fuel Receipt and Storage," Revision 0, with TCH #1 and 2

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o o FTI-E14, "New Fuel Inspection and Channeling in the New Fuel Inspection Stand," Revision 0, with TCN #1 and 2 FTI-E15, "Unirradiated Channel and Channel Fastener Inspection and Cleaning," Revision 2 FTI-E29, " Fuel Receipt Emergency Procedure," Revision 0 HPI-H2, " Receipt of Special Nuclear Material," Revision 0 The inspector also reviewed Special Nuclear Materials License N SNM-1928 issued March 7, 1985. The inspector verified that license conditions 16, 17, 18, 21.b, 22 and 23.b had been incorporated into procedures and instructions.

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During routine tours of the Fuel Handling Building (FHB), the inspector examined the integrity of the security barriers and access control for the controlled area. The inspector also examined the storage pools and racks and observed area cleanliness, housekeeping and fire protection measure On March 17, 1985, at approximately 1:30 a.m. , PNPP received the first shipment of new fuel onsite. The inspector witnessed the receipt of fuel onsite and the unloading and storage of the shipping containers in the FH The inspector verified that applicant personnel inspected the shipping containers and tamper seals for damage, examined the material for radioactive contamination, reviewed the shipping papers to ensure receipt of proper containers and established augmented security measures during necessary breach of the security barrie The inspector observed inspection, channeling and movement of new fuel bundles on numerous occasions during the inspection period. The inspection personnel appeared to be well trained. The inspector noted that the fuel storage map utilized magnetized labels approximately one half inch square to show graphically the location of each stored bundl The magnets could be easily displaced and no barriers were provided to prevent personnel from inadvertently disrupting the map. 'After the inspector brought this concern to the applicant's attention, barriers were erected to preclude this type of proble !

The inspector also noted that controls were.not established to prevent damage of inspected fuel by inadvertent incorporation of foreign -

materials. Administrative controls did not control materials used by personnel working near or over the fuel storage pools such as nuts, bolts, pens, pencils and other materials which could restrict flow through a fuel bundle. This is contrary to Regulatory Guide 1.39, Revision 2, and ANSI N45.2.3-1973, Section 3.2, " Control of Facilities",

which states that, "The control of all tools, equipment, materials and supplies that are used in Zones I, II, and III [ equivalent to PNPP Zone A], shall be maintained to prevent.the inadvertent inclusion of deleterious materials or objects in critical systems. Appropriate

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control measures shall be-provided through' utilization of such items as log books:and tethered' tools.." The inspector observed individuals with loose materials on the fuel handling machine bridge moving a fuel bundle ,

, over the fuel storage area. This is an example of an item of noncompliance (440/85010-01(c)(DRP)).

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One example of an item of noncompliance was identified in this area.

No deviations were identified.

l 12. Containment Spray Event Review and Followup - Independent Inspection i

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During conduct of interlock testing .of the containment spray system ,

injection valves, an inadvertent spraydown of containment occurred at

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approximately 10:00 a.m. on March 14, 1985. Approximately 1500 gallons i of water was_ spray onto the 689 foot, elevation of.the Reactor Building i

! ~ and washed down through the other elevations inside containment. 'An NRC -

inspector was in the control room observing testing .t the time of the- ,

event and remained.in the control room monitoring operator' response '

i activities. Another inspector immediately toured the reactor building inside and outside the drywell' examining equipment for water damage. The applicant initiated inspection activities by operational and construction

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i quality and nuclear test sections to' examine all equipment in the reactor '

building. The applicant also initiated the condition report proces The followup of programmatic aspects contributing to this event will be ,

, handled by the test inspection staff under unresolved ites

440/85013-08(DRS). The followup of equipment' deficiencies resulting from '

the event will be reviewed by the resident inspection staff:as an open item (440/85010-08(DRP)).

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i-i No items of noncompliance or. deviations were identified in this are , . Open and Unresolved Inspection Items .i

! Open and unresolved inspection items are matters which have'been

! discussed with the applicant, which will be reviewed further by the

.; inspector, and which involve some action on the part of the NRC or the j applicant or both. Open and unresolved inspection items disclosed during l the inspection are discussed in Paragraphs 2.h, 6, 7, 8, 9, 10 and'1 I 1 Exit Interviews

- The inspectors met with applicant representatives denoted in Paragraph 1 throughout the inspection and at the conclusion of the inspection period on March 121and 26, and April 30, 1985. The inspectors summarized the j-  ; scope and results of the inspection and discussed the likely content of

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this inspection report. 'The applicant did not indicate-that'any of the information disclosed ~during the inspection could be considered proprietary in nature.

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