ML18023A070
| ML18023A070 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/30/1999 |
| From: | Kozak T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jeffery Wood CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| References | |
| NUDOCS 9910120020 | |
| Download: ML18023A070 (28) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
.RE@ION III 601 WARRENVILLEROAD LISLE. ILLINOIS60532-4351 September 30, 1999 Mr. John K. Wood Vice President - Nuclear FirstEnergy Nuclear Operating Company P. O. Box 97, A200 Perry, OH 44081
SUBJECT:
MID-CYCLEPLANT PERFORMANCE REVIEW (PPR) - PERRY
Dear Mr.'Wood:
On September 1, 1999, the NRC staff completed the mid-cycle Plant Performance Review (PPR) of Perry. The staff conducted these reviews for all operating nuclear power plants to integrate performance information and to plan for inspection activities. The focus of this performance review was to identify changes in performance over the past 6 months at your facility and to allocate inspection resources for the next 6 months.
Our 6-month review of Perry identified that your performance in certain areas warranted increased NRC attention:
Although the safety tagging program has improved from previous assessment
- periods, some tagging errors occurred during the period.
Questionable engineering judgement was occasionally used to support conclusions that Technical Specification requirements were met when system operability issues were raised.
Human performance and procedural adherence problems occasionally occurred during the assessment period.
Therefore, we plan to conduct additional resident inspections beyond the core inspection program over the next 6 months to address the questions raised by these issues..
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant Issues Matrix (PIM), that were considered during this PPR process to arrive at our integrated review of licensee performance trends.
The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and FirstEnergy Nuclear Operating Company from September 1, 1998, through August 31, 1999. As noted above, greater emphasis was placed on those issues identified'in the past 6 months during this performance review. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately.
Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance.
99iOi20020 990930 PDR ADOCK 05000400 6
0
J. Wood This letter advises you of our plans for future inspection activities at your facility so that you will have an opportunity to prepare for these inspections and to provide us with feedback on any planned inspections which may conflict with your plant activities. Enclosure 2 details our inspection plan through March 2000 to coincide 'with the scheduled implementation of the revised reactor oversight process in April2000.
Resident core and initiative inspections are not listed due to their ongoing and continuous nature.
If circumstances arise which cause us to change this inspection plan, we willcontact you to discuss the change as soon as possible.
Please contact me at (630) 829-9866 with any questions you may have.
Sincerely,
/s/ T. J.
Kozak Docket No. 50<40 License No. NPF-58 I
Enclosures:
- 1. Plant Issues Matrix
- 2. Inspection Plan Thomas J. Kozak, Chief Reactor Projects Branch 4 See Attached Distribution DOCUMENT NAME: G:iPERR>PERRY INSP PLAN9.WPD To receive e copy oi this document, indicate In the box C
~ Copy without ettechment/enclosure E
Copy with ettechmentlenclosure, N
~ Noco OFFICE NAME Rill rr Rill C
Kozak:co <~-
Grobe Rill Grant DATE 09/.=,n/99 09/V/99 09/
/99 OFFICIAL RECORD COPY cc w/encls:
H. Hegrat, Manager, Regulatory Affairs R. Schrauder, Director, Nuclear Engineering Department W. Kanda, General Manager Nuclear Power Plant Department N. Bonner, Director, Nuclear Maintenance Department H. Bergendahl, Director Nuclear Services Department State Liaison Officer, State of Ohio R. Owen, Ohio Department of Health C. Glazer, State of Ohio Public Utilities Commission N. Hofstetter, Chairman, Geauga County Board B. Jordan, Director, Department of Emergency Services D. Wedge, Assistant Director, Department of Emergency Se'rvices G. Simmons, Geauga County Sheriff R. S. Boggs, Ashtabula County Commissioner W. Johnson, Ashtabula County Sheriff E. Somppi, Emergency Management Coordinator The Honorable Robert Skilliter, Jr.
G. Adams, Genoa Village Administrator D. Fellows, Lake County Board President D. Dunlap, Lake County Sheriff R. McMahon, City Manager, Painesville K. Gauntner, Jr., County Administrator The Honorable Thomas M. Coffman The Honorable Dan Di Liberto The Honorable Julie Morales T. Neuman, President, Geneva City Council C. Zins, Geneva City Manager The Honorable Mario V. Marcopoli The Honorable Richard A. Hennig J. Suso, Mentor City Manager The Honorable John M. Rogers K. Molenaar, Administrative Director The Honorable Mort O'Ryan The Honorable David E. Anderson The Honorable Lorraine M. Fende See Continued Distribution
J. Wood The Honorable David Reed J. Sample, Administrator, Village of Madison M. L. McCracken, Chairman, Madison Board of Trustees The Honorable John Turben The Honorable Georgette Allison The Honorable Joseph Dudas The Honorable John Roskos The Honorable Alan Di Liberto INPO Distribution:
RPC (E-Mail)
G. Tracy, OEDO w/encls Chief, NRR/DISP/PIPB w/encls Chief, NRR/DIPMIIIPB T. Boyce, NRR w/encls Project Director, NRR w/encls Project Mgr., NRR w/encls J. Caldwell, Riffw/encls B. Clayton, Rill w/encls R. Lickus, Rill w/encls SRI Perry w/encls DRP w/encls DRS w/encls Rill PRR w/encls PUBLIC IE-05 w/encls Docket File w/encls GREENS
Page:
1 of 1$
09I27I1999 07:28:42 IR Report 3 Region I'l PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area ENCLOSURE 1
Functional Template Item Title Date Source Area ID Type Codes Item Description Dockets Discussed 05000440 PERRY 1
05000441 PERRY 2 08/25/ 1999 1999009 Prl: OPS NRC POS Prl: 1A Conduct of Operations was good Sec:
Sec: 3A The coilduct of operations was profess'ional.
The inspectors observed appropriate use of procedures and consistent three-part communications.
Panel walkdowns were generally completed thoroughly and consistently.
Ter: 3B 08/25/1999 1999009-01 Dockets Discussed:
05000440 PERRY 1 05000441 P ERRY 2 Pri: OPS Sec:
NRC NCY Prl: 1B Sec:
Ter:
Communication breakdown resulted In the control room not receiving a severe thunderstorm warning The inspectors conduded that a communication breakdown resulted in control room 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 appropriately addressed in the licensee's corrective action program, subsequent severe weather notifications were promptly received, and compensatory actions were taken as required.
One Nonited Violation for the failure to followthe Instructions in an offnormal Instruction was identified.
(NCY 50440/9900941(0RP))
Dockets Discussed 05000440 PERRY 1 05000441 PERRY 2 07/08/1999 1999008 Pri: OPS Licensee NEG Prl'- 3A Sec:
Sec:
Ter:
Dockets Discussed 05000440 PERRY 1
08/25/1999 1999009 Pri: OPS NRC NEG Prl: 2B Sec: MANT Sect 3A Ter.
Operations personnel did not ensure that test equi pment were properly installed and removed Operations personnel did not ensure that test equipment installa'lion 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 Inwttentlon-to<etait Inattention-tiHIetail by a non-licensed operator during restoration of a clearance resulted in an error. The operator unintentionally energized the motor control center for a normally de-energized motoiwperated valve. This error did not result in a re-positioning ofthe valve and was considered to be of minor significance.
07/08/1999 1999008 Dockets Discussed:
05000440 PERRY 1 Prl: OPS Sec:
NRC POS Pri: 1A Operator alertness was good The inspectors conduded that the overall conduct of operations continued to be professionai, viith a continuing focus on safety. Operators demonstrated good attention to panels during hourly walkdowns and promptly identified two Ter.
problems.
05/17/1999 1999003
= Prl: OPS Sec:
Dockets Discussed:
05000440 PERRY 1
NRC MISC Prl: 1A Sec: 3C Ter:
Most plant employees worked approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> each week during the refueling outage.
The plant Technical SpeciTications limitIndividual work hours to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 74ay period unless very unusual circumstances arise requiring deviation from the limit. Most plant employees worked approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> each week during the refueling outage.
Numerous deviations were processed during the outage to approve work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a week. Some of the deviations did not document specific reasons for the deviations nor did they provide any limitto the number of hours worked in a week. Plant management indicated that these deviations were for work on critlcal path activities which were considered to be very unusual circumstances.
item Type (Compliance,Followup,Other), From 08/31/1998 To 09/01/1999
Page:
2of1$
09/27/1999 07:28:42 IR Report 3 Region III PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Date Source Area ID Type Codes Dockets Discussed 05000440 PERRY 1
05/17/1999 1999003 Prl: OPS NRC POS Pri: 1A Sec:
Sec: 5C Ter:
item Title Item Description The overall conduct of operations continued to be professional with an appropriate focus on safety.
The inspectors concluded that the overall conduct of operations continued to be professional with an appropriate focus on safety. Lessons learned were applied from the previous refueling outage in the areas of procedure adherence, safety tagging, and work controL In general, the licensee effectively managed a complex refueling outage with only minor problems noted.
05/17/1999 1999003 Prl: OPS Sec:
Dockets Discussed:
05000440 PERRY 1 NRC PQS Prl: 2A Sec: 5A Ter: 5C The lIcensee was effective In Inspecting, identifying, and correcting fuel failures The inspectors conduded that the licensee was effective in inspecting, identifying, and correcbng fuel failures which occurred during the operating cycle. Although the licensee could not guarantee the removal of all foreign material from the reactor vessel, steps were taken to minimize the potential for future fuel damage.
05/17/1999 1999003-01 Prl: OPS Licensee Sec:
Dockets Discussed:
05000440 PERRY 1 NCV Pri: 1A Sec:
Ter:
Failure to Follow Procedure - Two Examples A Nonunited Violation was Identified through two examples of operations department personnel failing to follow procedures as written. The inspectors were specifically concerned that, in these cases, operations personnel exercised some latitude with the procedures that was not applicable.
Dockets Discussed 05000440 PERRY 1 04/12/1999 1999301 Prl: OPS NRC POS Prl: 3B Sec:
Sec:
Tet:
Operators responded to all sImulated events with one minor exception.
Operators assigned to validate the licensed operator dynamic simulator test accurately diagnosed and responded to all simulated events with one minor exception. A high system and plant knowledge level was evident during the operator review of the written and JPM followup questions.
04/12/1999 1999301 Prl: OPS Sec:
Dockets Discussed:
05000440 PERRY 1 NRC PQS Prl: 3B Sec:
Ter:
Allnine applicants successfully passed all portions of the examinations they were administered.
Operator initiallicense examinations were administered to nine applicants during the week of March 15, 1999. Qne reactor operator (RO) applicant failed the August 1997, examination and only took a written re-take examination. All other applicants took the operating and written examinations.
Allnine applicants successfully passed all portions of the examinations they were administered.
04/12/1999 1999301 Pri: OPS NRC POS Prt: 38 Sec:
'ec:
Ter.
Dockets Discussed 05000440 PERRY 1 Applicants were well prepared The applicants appeared to be well prepared for the licensed operator examination as evidenced by their perfonnance on all portions of the examination.
Only a few minor training and individual performance weaknesses were noted by the examination team.
Facility training personnel properly staged all portions of the examination, and examination security was well controlled. The written examination was discriminatory and was a good evaluation tool for determining applicant knowledge level.
04/08/I ggg 1999p02 Prl: QPS NRC POS Pri: 1A Sec:
Sec: 3C Ter:
Dockets Discussed 05000440 PERRY 1
The operators were welf-prepared for refueling outage 7.
The inspectors conc/uded that the operators were well-prepared for refueling outage 7. Operators performed weil and the minor equipment challenges which were encountered were effectively handled during the shutdown for the outage.
Plant management's expectation for three-way communications between operators was not consistently implemented during the shutdown; however. this did not result in any operator errors.
Item Type (Compliance,Followup,Other), From 08/31/1998 To 09/01/1999
Page:
3 of 18 09/27/1999 07:28:42 IR Report 3 Region lll PERRY Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes item Description 04/06/1999 199900241 Prt: OPS Licensee Sec:
Dockets Discussed:
05000440 PERRY 1 NCV Prl: 3B Operator isolated Hydraulic Control UnitWithout Proper Controls One Non-Cited Violation was identified when 4 supervising operator failed to obtain the required approval from a unit supervisor prior to hydraulically isolafing a hydraulic control unit which rendered the associated control rod Ter:
The licensee effectively dispositioned this item in the corrective actions program.
Dockets Discussed 05000440 PERRY 1
Ão h OPS Licensee POS Pd: 2A Operators on shift responded effectively when an Residual Heat Removal pump failed to Qrt Sec: MAINT Sec: 3B Operators on shiit responded effectively when an Residual Heat Removal pump failed to start for shutdown cooling.
Maintenance personnel provided good support and promptly repaired a failed optical isolator.
Ter.
Dockets Discussed 05000440 PERRY 1 03/05/1999 1999005 Prl: OPS Licensee NEG Pd: 1C Guidance associated with counting unavailability times per Maintenance Rule Sec:
While operators generally understood the guidance associated with counting unavailability times while using managed restoration, tighter controls were necessary to avoid misuse of the process and to ensure continuous Ter:
availability of a dedicated operator.
Dockets Discussed 05000440 PERRY 1 02/26/1999 1999001 Pri: OPS Licensee NEG Prl: 3B Sec:
Sec:
Ter:
inattention to detail by a licensed operator led to using the wrong section of an Operating Instruction inattention to detail by a licensed operator led to using the wrong section of an Operating Instruction for a system restoration activity. The operator identified hi error and appropnately notified operations management of the occurrence.
Plant management provided training to operations personnel emphasizing the importance of selfWecking and attention to detail during work activities Dockets Discussed:
05000440 PERRY 1 Sec:
Sec:
Tel.
02/26/1999 1999001 Prl: OPS NRC POS Prl: 1A The licensee effectivel replaced two circuit cards In the redundant reactivity control system The Inspectors concluded that the licensee effectively replaced two circuit cards in the redundant reactivity control system, which was categorized as a medium risk maintenance activity, through the use of good briefings, effective command and control. and dear communications between operations and maintenance personnel 01/12/1999 1998020 Pri: OPS Sec:
Dockets Discussed:
05000440 PERRY 1 POS Pri: 1A Licensee Safely and Effectively Manage the Effects ofThree Minor Fuel Leaks The licensee continued to safely and effectively manage the effects of three minor fuel leaks in the core. Operations and chemistry personnel remained focused on testing activities.
Ter.
01/12/1999 1998020 Pri: OPS NRC POS Prl: 1B Operations Took Prompt Actions In Response to Two Automatic lsolations of Feedwater He t Sec:
Operations department personnel took prompt and effective acbons in response to two automatic isoiations of feedwater heaters.
Ter:
Dockets Discussed 05000440 PERRY 1 Item Type (Compliance.Followup,Other), From 08/31/1998 To 09/01/1999
Page:
4 of 18 09/27/1999 07:28:42 IR Report 3 Region Ill PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes 12/02/1998 1998019 Prl: OPS NRC POS Prl: 1B Sec:
Sec:
Ter:
Dockets Discussed 05000440 PERRY 1 Item Title Item Description Effects of two minor fuel leaks were effectively mitigated The inspectors conduded that the licensee continued to safely and effectively mitigate the effects of two minor fuel leaks in the core. The inspectors also conduded that the operator observing and reporting the minor problem found on a panel walkdown initiated prompt corrective actions for the fuel leak 12/02/1998 1998019 Prl: OPS NRC POS Sec: MAINT Sec:
Ter:
Dockets Discussed 05000440 PERRY 1 Good attention-to4etail during routine plant operations Operators generally exhibited good attention-todetail while performing their work as evidenced by the prompt Identification and resolution of a diesel generator tachometer power supply failure 10/22/1998 1998021 Prl: OPS Sec:
Dockets Discussed:
05000440 PERRY 1
NRC NEG Prl: 1C Sec:
Ter.
Improvements needed In annual requallflcatlon examination process The annual requalification examination for licensed operators had been developed such that the minimum regulatory requirements were satisfied. However, specific weaknesses in the individual development of NRC-style performance evaluations (Job Performance Measures - JPM format) and a lack ofdocumented management validation and review demonstrated a lack of quality control.
Dockets Discussed 05000440 PERRY 1
10/22/1998 1998021 Pri: OPS NRC POS Prl: 1A Sec:
Sec:
Ter:
Operators performed well In simulator In general, licensed operators at the plant specific simulator executed their duties in a safe manner durinq abnormal and emergency conditions, and in accordance with station procedures and management expectations.
The licensee correctly identified minor deficiencies in individual performance which did not impact the crew's ability to implement necessary safeguards measures.
10/22/1998 1998021 Prl: OPS NRC POS Sec:
Dockets Discussed:
05000440 PERRY 1 Prl: 1C Sec:
Ter:
Annual requallflcation examinations were administered according to program guidance Annual requalification examinations were administered according to program guidance and consistent with regulatory guidelines.
Experienced evaluators were being used to verify operator mastery of needed skills.
Adequate evaluation means were in place to provide positive feedback into the licensed operator continuing training~
program. The variety of methods provided for operator feedback was a program enhancement, Dockets Discussed 05000440 PERRY 1 10/22/1998 1998021 Prl: OPS NRC POS Pri: 'IC Sec:
Sec:
Ter:
Remedial training completed during requal process Licensed operator performance deficiencies requiring remediation training were appropriately identified. assigned.
and completed prior to returning an operator to licensed duties.
Satisfactory operator performance with noted weaknesses was given an appropriate level of remediation training.
10/22/1998 1998021 Dockets Discussed:
05000440 PERRY 1 Prl: OPS Sec:
NRC POS Pfi:1C Sec:
Ter.
The licensee appropriately maintained individual operator licenses In an active status The licensee appropriately maintained individual operator licenses in an active status and ensured the medical fitness of each hcensed operator consistent with program guidelines and in compliance with regulatory requirements.
Item Type (Compliance,Followup,Other)
~ From 08/31/1998 To 09/01/1999
Page:
5 of 18 09/27/1999 07:28:42 IR Report 3 Region III PERRY Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description Dockets Discussed 05000440 PERRY 1 10/20/1998 1998018 Prl: OPS NRC POS Prl: 1A Sec:
Sec:
Ter:
Good command and control during fuel suppression activities The inspectors conciuded that a special evolution was effectively conducted to isolate and suppress a small fuel leak. Operations department personnel maintained a high level of reactivity control awareness during the several hundred control rod manipulations which occurred during the special evolution.
10/20/1998 1998018 Prl: OPS NRC
. POS Prl: 1B Prompt, conservative actions taken after report of seismic activity Sec:
Sec:
The licensee took prompt and conservative actions upon the report of possible seismic activity in the vicinityof the plant. Operations department personnel conducted verifications of key indicators and plant walkdowns, even though Ter:
no seismic alarm was received.
Dockets Discussed 05000440 PERRY 1 09/08/1998 1998016 Prl: OPS Sec:
Dockets Discussed:
05000440 PERRY 1 NRC POS Prl: 2A Sec: 5A Ter:
Prompt, effectiv actions taken followingfeedwater heater Isolation Operations department personnel took prompt and effective actions in response to the automatic isolation of a feedwater heater, equipment problems associated with shifting reactor recirculation system flow control valve hydraulic control subloops, and the failure ol an average power range monitor post-maintenance test. The operators effectively interacted during the events with open communications between ail levels of the on-shifl operating crews.
The operators quickly identified and responded to the situations and initiated corrective action documents in accordance with licensee management expectations.
Dockets Discussed 05000440 PERRY 1
05000441 PERRY 2 Prl: MAINT NRC POS Prl: 2B Maintenance and surveillance testing activities were property controlled Sec:
Maintenance and surveillance activities were generally properly controlled and performed per approved procedures.
There was good coordination between the control room and other work groups for these activities.
Ter:
07/08/1999 1999008 Prl: MAINT Sec:
Dockets Discussed:
05000440 PERRY 1 NRC NEG Prl: 1C Sec:
Ter.
An inadequate review prior to changing the surveillance test schedule resulted nearly missing the test While the licensee generally scheduled surveillance tests to be performed by their due date, an inadequate review prior to changing the surveillance test schedule resulted in a high pressure core spray pump and valve surv'eillance test being scheduled past its due date and the allowed 25% extension specified in Technical Specifications (TS).
The unit supervisor on shiit identified the discrepancy on the last day before the TS interval was exceeded and the test was performed satisfactorily.
07/08/1999 1999008 Prl: MAINT Sec:
Dockets Discussed:
05000440 PERRY 1 NRC POS Prl:1C Sec:
Ter:
Maintenance and surveillance activities were properly controlled Maintenance and surveillance activities were properly controlled and performed per approved procedures.
There was good coordination between the control room and other work groups for these activities. There was good preplanning for routine control rod exercise testing to address contingencies that could occur during the testing.
Item Type (Compliance,Followup.Other)
~ From 08/31/1998 To 09/01/1999
Page:
6 of 18 09/27/1999 07:28:42 IR Report 3 Region III PERRY Date Source United States Nuclear Regulatory Commission PLANT 1SSUE MATR1X By Primary Functional Area Functional Template Item Title Area ID Type Codes Item Description Dockets Discussed:
05000440 P ERRY 1 Tel". 5C 05/17/1999 1999003 Pri: MAINT Self NEG Prl: 1C Sec:
Sec: 2A A series of two surveillance failures concurrent with a scheduled maintenance activity Aseries of two surveillance failures concurrent with a scheduled maintenance activity led to a condition whese the emergency diesel generators (EDGs) for Divisions 1, 2, and 3 were inoperable at the same time during the refueling outage.
The inspectors determined that the licensee met all Technical Specification requirements associated with the scheduling of these actiyitIes and that, due to the Division 1 EQG being available, these was no increase in plant risk as a result of these activities.
Dockets Discussed 05000440 PERRY 1 Prl: MAINT NRC POS Prl: 1C The outage-related maintenance and surveillance activities were well coordinated Sec:
Sec; 3C The inspectors concluded that outage-related maintenance and surveillance activities were well coordinated and, performed properly, with few excepbons.
Management oversight of activities was good.
Ter:
05/17/1999 1999003-02 Prl: MAINT Licensee NCV Prl: 3A Test Equipment Left tn a Safety. Related Relay Sec:
A maintenance technician left test equipment in a relay following a calibration activity as a result of inattention to detail. This was identified when the Division 2 EDG Loss of Offsite Power Test failed and resulted in an Non-Cited Ter:
Violation.
Dockets Discussed 05000440 PERRY 1 04/16/1999 1999006 Pri: MAINT NRC POS Prl: 1C Sec: ENG Sec: 4B Ter.
Dockets Discussed 05000440 PERRY 1
Inservlce inspection activities were effectively implemented Inservice inspection activities were effectively implemented and in accordance with the licensee program and ASME requirements.
The insesvice Inspection program reflected a strong commitment to safety through the examinations of welds susceptible to intergranular stress corrosion cracking using procedures and personnel qualified by Performance Demonstration Initiative.
Dockets Discussed 05000440 PERRY 1 MAINT NRC POS Pri: 1C A strong lnservlce Inspection program vnth active oversight of cont ct perso I
Sec: ENG Astrong inseivice inspection program with active overs'ight of contract personnel was demonstrated by the licensee's independent evaluation of contractor-identified nondestructive examination indications and the pso-active Ter. 5C reevaluation of feedwater nozzle flaws.
Dockets Discussed 05000440 PERRY 1 Operators mlffgated two Instances of unexpected results during maintenance o
APRM.
Sec:
During maintenance on APRM power supplies, there were two instances of unexpected results.
The on-shift licensed operators held thorough pre-job briefings, properly monitored the activities, and responded promptly to Ter:
unexpected indications.
03/05/1999 1999005 Dockets Discussed:
05000440 PERRY 1 Prl: MAINT Sec:
Prl: 1C The practice of revising unavailability criteria on a recurrent basis had potential to mask degrading equipmen The licensee practice of revising unavailability criteria on a recurrent basis had the potential to mask degrading equipment performance.
Similarly, the practice of revising reliability criteria as the number of functional failures Ter:
approached limits also had the potential to mask degrading equipment performance.
Item Type (Compliance,Followup,Other). From 08/31/1998 To 09/01/1999
Page:
7 of 18 09/27/1999 07:28:42 IR Report 3 Region III PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description Dockets Discussed 05000440 PERRY 1 03/05/1999 1999005 Prl: MAINT NRC POS Prl: 1C Sec:
Sec:
Ter.
The practice of managed restoration appeared to have an acceptable risk-Informed Justification The practice of managed restoration, i.e., the discounting of maintenance rule unavailability when simple, defined operator actions can make an inoperable system available for accident mitigation within specified time periods.
appeared to have an acceptable nsk-informed justification. The acceptability of "managed restoration" as a practice is a policy matter that willbe reviewed by the Oflice of Nuclear Reactor Regulation (NRR).
02/26/1999 1999001-01 Prl: MAINT NRC Sec:
Dockets Discussed:
05000440 PERRY 1
NCV Prl: 2B Sec:
Ter.
The Unit 2, Division 3 battery surveillance test was not conducted In accordance with the procedure The inspectors identified that a surveillance test to monitor the condition of the Unit 2, Division 3 battery was not conducted in accordance with the procedure.
This failure to followan approved procedure was considered a Nonited Violation of NRC requirements 02/26/1999 1999001 02 Prl: MAINT Licensee Sec:
Dockets Discussed:
05000440 PERRY 1 NCV Prl: 2B Sec:
Ter.
plant personnel failed to adhere In all cases to plant procedures governing the storage of items near safety-r plant personnel failed to adhere in all cases to plant procedures governing the storage of items near safety-related equipment.
One Non-Cited Violation was identified concerning this issue 02/26/1999 1999001-03 Pri: MAINT Licensee Sec:
Dockets Discussed:
05000440 PERRY 1 NCV Prl:2B Sec:
Ter:
Missed hydrogen Ignlters surveillance The procedure for conducting surveillance testing of hydrogen igniters was revised to ensure that increased frequency testing would be performed in the future when necessary.
The failure to perform the increased frequency testing between March 15 and October 1, 1998, was a violation ofTS SR 3.6.3.2.2. This non-repetitive.
licensee-identified and corrected violation is being treated as an NCV, consistent with Section VII.B.1 of the NRC Enforcement Policy. (NCV55440/9900143(DRP))
Dockets Discussed 05000440 PERRY 1 01/12/1999 1998020 Prl: MAINT NRC NEG Prl: 2A Sec:
Sec:
Tel".
Emergent Equipment Problems Challenged Plant Emergent equipment problems resulted in challenges to plant operators and several entries into Technical Specification LimitingConditions for Operation, In general, the issues were resolved promptly; however, repeat problems with feedwater heater level control and control complex chillers continue to represent a challenge for plant staff Dockets Discussed 05000440 PERRY 1
~12/02/1998 1998019 Prl: MAINT NRC NFG Pri: 2B Sec:
Sec:
Ter.
Inattention-tWetall during a hydrogen Igniter surveillance test Inattention-todetail by a test performer and a unit supervisor. respectively. Ied 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 12/02/1998 1998019 I'r>>: MAINT NRC NEG Sec:
Dockets Discussed:
05000440 PERRY 1
Pri: 2B Sec:
Ter:
TS LCO entry mIssed during annulus gas treatment fan surveillance Amisinterpretation by the licensee of the Technical Specification (TS) bases regarding pressure in the secondary containment led operators to not recognize that a LimitingCondition for Operation (LCO) entry existed during surveillance testing of the annulus exhaust gas treatment system fans. The TS LCO was not exceeded in this instance Item Type (Compliance,Foilowup,Other), From 08/31/1 998 To 09/01/1999
Page:
8 of 18 09/27/1999 07:28:42 IR Report 3 Region lil PERRY United States Nuclear Regulatory Commission PLANT lSSUE MATRlX By Primary Functional Area Date Source Functional Template Area ID Type Codes Item Title Item Description Dockets Discussed 05000440 PERRY 1 12/02/1998 1998019 Pri: MAINT NRC NEG Prl: 3A Sec:
Sec:
Ter.
Incorrect chart paper Installed in the control panel suppression pool level chart recorder.
Inattention-IMetail by an instrument and control (ISC) technician led to incorrect chart paper being installed in the control panel suppression pool level charl recorder. The incorrect chart paper remained installed due to the failure of l8C technicians and operators to recognize this error during panel walkdowns until the inspectors identified it 7 days after installation Dockets Discussed 05000440 PERRY 1 12/02/1998 1998019 Pri: MAINT NRC NFG prl: 3A Sec:
Sec:
Ter:
Procedures not adhered to during HCU testing 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 not stopped to revise the procedure to reflect the way the job was planned 12/02/1998 199801941 Pri: MAINT NRC NCV Sec:
Dockets Discussed:
05000440 PERRY 1 Prl: 3A Sec: 3C Ter:
Scaffolding Blocked Operation of Vacuum Breaker Procedural instructions were not completely followed while a scaffold was erected which 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 scaffo'ld construction procedure issues Dockets Discussed 05000440 PERRY 1 12/02/1998 1998019 Prl-MAINT NRC POS Prl: 1A Sec: OPS Sec:
Ter:
Good teamwork and effective communications among work groups during routine plant operation Routine plant operations were characterized b good teamwork and effective 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.
Dockets Discussed 05000440 PERRY 1
10/20/1998 1998018 Pri: MAINT NRC POS Prl: 1A Sec:
Sec:
Ter:
Maintenance provided effectiv support in troubleshooting abnormal RC&IS Indications Operations department personnel responded appropriately to abnormal indications for the rod control and information system.
The coordination between the workgroups involved in the troubleshooting and repair was good.
distractions to the operators were kept to a minimum, and the problem was repaired in a timely manner.
10/20/1998 1998018 Dockets Discussed:
05000440 PERRY 1 Pri: MAINT Sec:
NRC POS Pri: 2A Sec:
Ter:
Control complex chill water motor replacement went well Plant management deinonstrated good involvement in the prioritization of the control complex chillwater motor replacement, the assignment of a project manager for the work activity, and during the oversight of the activity, which resulted in the motor being replaced in an efflcfent and timely manner.
10/20/1998 199801841 Dockets Discussed:
05000440 PERRY 1 Pri: MAINT Sec:
NRC VIOIV Prl-'B Sec:
Ter.
Failure to Implement Requirements of Burn Permit The inspectors concluded that a fire watch demonstrated inadequate knowledge of his fire watch responsibilities during welding activities on the Division 1 diesel generator silencer.
One violation was identified when a fire watch inappropriately allowed welders to perform hot work with a signiflcant quantity ofwood in the immediate work area.
Item Type (Compliance,Followup.Other), From 08/31/1998 To 09/01/1999
Page:
9 of 18 09/27/1999 07:28:42 IR Report 3 Region III PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Date
'ource Area ID Type Codes Item Description 10/20/1998 1998018-02 Prl: MAINT NRC Sec:
Dockets Discussed:
05000440 PERRY 1 NCV Prl: 28 Failure to Initiate Permit forTransient Combustibles After deciding to use wood, maintenance department personnel did not initiate a transient combustible permit (TCP) for the temporary staging of the wood. The tailure to generate a TCP was similar to, but not a direct repeat of, other Ter:
recent examples of problems with station personnel's awareness of when a TCP is required.
09/08/1998 1998016 Pri: MAINT Sec:
Dockets Discussed:
05000440 PERRY 1 ly P
(
) techniques into daily plant operations.
For example, a shift supervisor (SS) requested a new PRA value for the potential loss of an emergency service water isolation valve alter itwas discovered that the valve may not open due to missing gear teeth. The SS questioned the initial PRA value that was provided and a recalculation of the value resulted in the identification that the risk category was actually medium as opposed to low for this condition.
Ter:
NRC POS Prl: 28 PRA Incorporated Intgo dally plant activities Sec:
The inspectors determined that the licensee effective incorporated robabilistic risk assessment PRA Dockets Discussed 05000440 PERRY 1 09/08/1998 1998016 Prl: MAINT NRC POS Prl: 58 Sec:
Sec:28 Ter.
Good questioning attitude of hydrogen recomblners surveillance results The inspectors concluded that operations department personnel demonstrated a good questioning attitude when assessing the validity ot the surveillance data for the hydrogen recombiners (HR) when initial resistance-toground readings did not meet the acceptance criterion of the surverilance test. Also. the on-shift operating crew made the appropriate Technical Specifications entries based on their assessment of the HR test results.
Dockets Discussed 05000440 PERRY 1 09/08/1998 1998016 Pri: MAINT NRC POS Prl: 5C Sec:
Sec: 2A Ter:
The licensee was proactive In replacing a degraded emergency service water pump The inspectors concluded that the licensee was proactive in replacing a degraded emergency service water pump in a planned outage prior to its failure. While the outage was completed within the allotted time in the applicable Technical Specification limiting condition for operation, better planning for the outage could have resolved pump shaft design differences and could have reduced the on-line out-of-seivice time for safety-related equipment.
08/25/1999 1999009 Dockets Discussed:
05000440 PERRY 1 05000441 PERRY 2 Prl: ENG Sec:
NRC NEG Prl: 4A Sec: 48 Ter:
One figure In the Updated Safety Analysis Report (USAR) was not updated 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 property completed at the time and that other USAR sections containing information associated with this modification had been appropriately updated.
07/0N1999 1999008 Pri: ENG Sec:
Dockets Discussed:
05000440 PERRY 1 NRC NEG Prl: 5C Sec:
Ter:
The repeat problems with driftingsetpolnts on the Dlv 3 EDG testable rupture disc were not resolved The inspectors conduded that repeat problems with drifting setpoints on the Division 3 diesel generator testable rupture disc were not adequately resolved to prevent recurrence.
This is an unresolved item, the licensee indicated that a review was underway to determine ifthe DG was actually inoperable at the high as-tound setpoint.
Pending a review of the licensee's evaluation, this is considered an unresolved item (URI 50440/990084)1(DRP)).
Item Type (Compliance,Followup,Other). From ON31/1998 To 09/01/1999
Page:
10 of 18 09/27/1999 07:28:42 IR Report 3 Region III PERRY Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description Dockets Discussed 05000440 PERRY 1
07/08/1999 1999008 Prl: ENG NRC POS Prl: 4B Good engineering support Sec:
Sec: 5A The inspectors concluded that engineering department personnel provided good support to plant operations by promptly dispositioning emergent equipment Issues.
Operability evaluations were generally well documented and Ter: 5B engineering personnel demonstrated good understanding of plant systems.
Dockets Discussed 05000440 PERRY 1 99 999003 Pri: ENG NRC POS Prl: 4B The engineering department personnel provided timely and effective technical Sec:
The inspectors concluded that engineering department personnel provided timely and effective technical support to other departments for a variety of activities during the refueling outage.
Ter.
05/17/1999 1999003 Prl: ENG NRC POS Prl: 4B The licensee utilized effective methods to maintain fuel accountability Sec:
The licensee utilized effective methods to maintain fuel accountability and verify the proper placement of fuel bundles in the core prior to reactor vessel reassembly.
Ter: 5B Dockets Discussed 05000440 PERRY 1 Dockets Discussed 05000440 PERRY 1
04/16/1999 1999006 Pri: ENG NRC POS Pri: 3B Preparation for the weld overlay of the feedwater nozzle to safewnd weld was II do Sec:
Sec: 4B Preparation for the weld overlay ofthe N4C reactor vessel feedwater nozzle to safewnd weld was well done through the use of a weld mock-up with identical nozzle and biological shield configurations.
Ter:
04/06/1999 1999002 Prl: ENG Sec:
Dockets Discussed:
05000440 PERRY 1 NRC POS Prl: 5A Sec: 4A Ter: 4B Good use of Industry experience Through good use of industry operating experience, the licensee identified that the design of the control complex building was not sufficient to protect the interior walls in the case that a design basis tornado touched down onsite.
AlthoUgh final plans to address this issue were adequate to support continued plant operations, the inspectors determined that the licensee's initial operability evaluation did not adequately address all issues associated with this condition.
02/26/1999 1999001 Dockets Discussed:
05000440 PERRY 1 Pri: ENG Sec:
Licensee NEG Prl: 4A The Unit 2, Division 3 battery was declared Inoperable due to exceeding s i
lif The Unit 2, Division 3 battery was declared inoperable after the licensee identified that its age was greater than its rated lifetime and that increased frequency testing was required by Technical Specifications.
The battery was Ter.
subsequently successfully tested.
02/26/1999 1999001 Pri: FNG NRC POS Pri: 5C There was an appropriate amount of management Involvement In the correcgve action p Sec:
The inspectors concluded that there was generally an appropnate amount of management involvement in the corrective schon program Ter.
Dockets Discussed 05000440 PERRY 1 Item Type (Compliance,Followup.Other), From 08/31/1998 To 09/01/1999
Page:
11of18 09/27/1999 07:28:42 IR Report 3 Region III PERRY Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template Item Title ID Type Codes Item Description 02/26/1999 1999001-04 Prl: ENG NRC Sec:
Dockets Discussed:
05000440 PERRY 1
URI Prl: 5A An unresolved Item concerning the technical justification for calculating the battery age The licensee identified that 9 of 60 cells in the Unit 1 ~ Division 3 battery were beyond the rated servIce life of 20 years.
However, the battery was determined to be operable based on the average age of all of the individual battery Ter.
cells. An unresolved item concemlng the technical justification for calculating the battery age based on the average age of the individual cells was identified 01/12/1999 1998020-02 Pri: ENG NRC Sec:
Dockets Discussed:
05000440 PERRY 1
ylO Iy Prl: 5C Failure to correct the over thrust condition of the 1E12F008 valve body The inspectors concluded that not all aspects of the licensee's corrective action program guidelines were fully implemented.
The repeated extensions of a due date for actions to address a potential oyer thrust condition on a Ter:
shutdown cooling valve resulted in the failure to promptly evaluate and resolve this situation, which was a violation of NRC requirements.
Dockets Discussed 05000440 PERRY 1
1M$1998 998019 Pri: ENG NRC POS Prl: 4B The InsPectors concluded that there was an appropriate level of document tlon for e t
I Sec:
The inspectors conduded 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 Ter:
determinations provided proper justification to operations department personnel Dockets Discussed 05000440 PERRY 1 10/20/1998 1998018 Pri: ENG NRC POS Prl: 5B Sec:
Sec:
Ter:
Fuel leak promptly Identified by a chemistry technician The inspectors concluded that a chemistry technician properly analyzed a routine offgas sample which indicated a small fuel pin leak had occurred and promptly notified the appropriate station personnel.
Also, engineering department personnel provided good support for determining the location and suppressing the leak.
09/08/1998 1998016 Pri: ENG Sec:
Dockets Discussed:
05000440 PERRY 1
NRC POS Pri: 4B Sec:
Ter:
Engineering personnel support for hydrogen recombiners tesfing was good The inspectors conduded that engineering department personnel were promptly involved in the testing activities and ~
thoroughly pursued the resolution of the proper testing methodology for the HRs. The inspectors considered that there was good supervisory and senior management oversight during problem discovery. investigation, and resolution of this issue.
09/08/1998 1998016-01 Prl: ENG NRC Sec:
Dockets Discussed:
05000440 PERRY 1
NCV Prl: 5B Root cause of RCIC triPs Identified The licensee performed a comprehensive root cause evaluation of the two reactor core isolation cooling turbine tips and identified that governor valve stem binding was the root cause of the trips. The information developed through Ter:
this evaluation was appropriately disseminated to the industry.
Item Type (Compliance.Foilowup.Other). From 08/31/1998 To 09/01/1999
Page:
12 of 18 09/27/1999 07:28:42 IR Report 3 Region III PERRY Date Source United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Functional Template Item Title Area ID Type Codes Item DescrlPtlon Dockets Discussed 05000440 PERRY 1
05000441 PERRY 2 07/181999 1999012 Pri: PLTSUP NRC
.POS Prl: 1C Licensee personnel performed proper classifications during two actual actlvatlo Sec:
IJcensee personnel performed proper classifications and timely notifications during two actual activations of the emergency plan.
Ter.
Dockets Discussed 05000440 PERRY 1 08/25/1999 1999009 Pri: PLTSUP NRC POS Prl: 1C Emergency facilities were well maintained Sec:
During evaluation of a routine emergency preparedness training drillon July 21, 1999, the inspectors concluded that emergency response facilities were maintained available for emergency operations, that there was good Ter:
performance by the participants in the drill, and that the postMrill critiques were seifmitical.
07/16/1999 1999012 Pr:PLTSUP NRC POS Prl:1C TheCondltlonReportsystemwasaneffectlvemethodtotrackand close EPUI Sec:
The Condition Report system was an effective method to track and dose Emergency Planning Unit issues.
Procedures were dear and easy to use.
Ter.
Dockets Discussed 05000440 PERRY 1 Dockets Discussed 05000440 PERRY 1 07/16/1999 1999012 Pri: PLTSUP NRC POS Prl: 1C The Emergency Planning Unit training program appeared effective.
Sec:
The Emergency Planning Unit training program appeared effective. Allpersonnel reviewed were qualified for their emergency response positions.
Interviewed emergency response organization personnel successfully demonstrated Ter:
very good knowledge of their emergency roles and procedures.
Dockets Discussed 05000440 PERRY 1
6 9 0: PLTSUP NRC POS Pd: 1C Continued management support for the emergency preparedness program was i dl t d Sec:
Continued management support for the emergency preparedness program was indicated durinq discussions with site and Emergency Planning Unit (EPU) staff. The new EPU staff and management were professional and Ter:
proactive.
Dockets Discussed 05000440 PERRY 1
07/16/1999 1999012 Pri: PLTSUP NRC POS Prl: 1C Emergency response facilities, equipment, and suppges were well maint ined Sec:
Emergency response facilities, equipment, and supplies were well maintained and in a very good state of operational readiness.
Demonstration of emergency response equipment verified that the equipment was operable Ter.
and ready for use.
item Type (Compliance,Followup,Other), From 08/31/1998 To 09/01/1999
Page:
13 of 18 09/27/1999 07:28:42 IR Report 3 Region lil PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title item Description Dockets Discussed 05000440 PERRY 1 07/16/1999 1999012 Pri: PLTSUP NRC POS Prl: 1C Sec:
Sec: 5A Ter.
The licensee's 1998 and 1999 QA audits of the EP program were of good scope and depth The licensee's 1998 and 1999 Quality Assurance Section audits of the emergency preparedness program were of good scope and depth and satisfied the requirements of 10 Code of Federal Regulations 50.54(t).
Dockets Discussed 05000440 PERRY 1 05/20/1999 01012-99012 Pri: PLTSUP NRC VIOII Prl: 3C Sec:
Sec:
Ter.
Discrimination Against RP Supervisor Radiation Protection Manger counseled an RP supervisor prior to his testimony at a hearing for a different discnmination case.
Dockets Discussed 05000440 PERRY 1 04/16/1999 1999007 Pri: PLTSUP NRC POS Prl: 1B Sec:
Sec:
Ter.
The RP staff provided strong oversight of outage dose performance The radiation protection program staff provided strong oversight of outage dose performance.
The staff prepared graphical representations, which were displayed throughout the licensee's facility. In addition. the staff performed cribcal reviews ofwork in progress.
04/16/1999 1999007 Prl: PLTSUP Sec:
Dockets Discussed:
0500Q44Q PERRY 1 NRC POS Prl:1C Sec:
Ter:
The Inspectors observed effective communications and radiation protection (RP) program oversight The inspectors observed effective communications and radiation protection (RP) program oversight in removing the
]et pump mixers. Radiological conditions and Instructions were properly commumcated to the work crew. In addition, the work crew and the RP staff properly implemented the radiation work permit and AlARA (as-low-as-ls-reasonably.achievable]
review and performed necessary evaluations when unexpected radiological conditions were identified.
04/16/1999 1999007 Prl: PLTSUP NRC POS Prh 1C Sec:
Sec:
Ter.
Dockets Discussed 05000440 PERRY 1
The licensee effectivel Implemented the internal dosimetry program.
The licensee effectively Implemented the internal dosimetry program. The radiation protection program staff performed and malfltained an evaluation which concluded that formal internal monitoring was not required.
Specifically, radiation workers were effectively monitored for internal deposition of radioactive material via the passive monitoring program, with the portal contamination monitor alarm setpoints set to indicate intakes of 1 to 2 percent of an Annual Limiton Intake.
Dockets Discussed 05000440 PERRY 1 04/16/1999 1999007 Pri: PLTSUP NRC POS Prl: 1C Sec:
Sec:
Ter.
The radiation protection program staff provided strong oversight of outage activities The radiation protection program staff provided strong oversight of outage activities at radiologically controlled area access points. Technicians properly communicated radiological information to workers and monitored workers'erformance.
Radiological areas were properly posted and controlled in accordance with NRC requirements.
04/16/1999 1999007 Dockets Discussed:
05000440 PERRY 1 Pri: PLTSUP Sec:
NRC POS Prl: 1C Sec: 2A Ter:
Respiratory protection equipment was In good material condition The licensee's respiratory protection maintenance and storage program ensured the integrity of respiratory protection equipment.
The RP staff performed the required inspections and inventory of respiratory protection equipment, which was in good material condition. The inspectors also concluded that personnel issued respirators were qualified in accordance with the licensee's procedures and that training provided personnel with the necessary level of information.
Item Type (Compliance,Foliowup,Other), From 08/31/1998 To 09/01/1999
Page:
14 ot18 09/27/1999 07:28:42 IR Report 3 Region III PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Template Area
~
ID Type Codes Item Title Item Description 04/16/1999 1999007 Pri: PLTSUP NRC POS Sec:
Oockets Discussed:
05000440 PERRY 1 Prl: 1C Radiation protection personnel screening and training was thorough Radiation protection personnel screening and training was thorough and ensured that only qualified and trained personnel supplemented the radiation protection (RP) program staff. The licensee conducted comprehensive Ter. 3B training and evaluations of the contract RP staff, which prepared workers for assigned outage tasks.
Staff qualification matrices were properly maintained to ensure that personnel were qualiflied for their assignments.
04/16/1999 1999007-01 Prl: PLTSUP Licensee Sec:
Dockets Discussed:
05000440 PERRY 1 NCV Prl: 1C Sec:
Ter.
Failure to perform an adequate radiological survey to support the transfer of radioactive tank contents The licensee identified that the transfer of the contents of a radioactive tank resulted in HRAs within the Radwaste Building, which subsequently were not properly posted, in violation of 10 CFR 20.1501.
The inspectors concluded that the licensee had performed a thorough review of the incident and had planned to imp'lement corrective actions through the corrective action program which were commensurate with the error. One Severity Level IVNon-Cited Violation was identified 04/06/1999 1999002W2 Pri: PLTSUP Licensee NCV Sec:
Dockets Discussed:
05000440 PERRY 1 Prl: 1C Sec:
Ter:
Handling of Individual Fuel Rods not According to Procedure One Nonited Violation was identified concerning the failure to handle individual fuel rods in the spent fuel pool in accordance with the procedure in use for this evolution. (NCV 50-440/99002-02(DRP))
02/26/1999 1999004 Prl: PLTSUP Sec:
Oockets Discussed:
05000440 PERRY 1 NRC POS Prl:1C Sec:
Ter:
The Rp staff effectivel consIdered radiological hazards In preparing controls forthe 1999 refueling outage The Rp staff effectively considered radiological hazards in preparing controls and instructions for the 1999 refueling outage.
For example, the ALARAReviews and RWPs contained appropriate radiological hold points, anticipated radiological conditions, and provisions for engineering controls, which were routinely incorporated directly into the work orders.
Extensive system flushes and training via work site mock-ups, which included the use of the Unit2 facility,were also planned to reduce radiation dose.
02/26/1999 1999004 Oockets Discussed:
05000440 PERRY 1 Prl: PLTSUP Sec:
NRC POS Prl; 1C Sec:
Ter:
The licensee provided thorough planning and strong oversight of diving work The licensee provided thorough radiological planning and strong oversight of diving work associated with the inclined M fuel transfer system.
The work instructions and radiological planning documents contained appropriate radiological controls and lessons teamed from previous diving evolutions. The inspector observed good communications between the RP staff and the diving crew and effective control of the evolution.
02/26/1999 1999004 Pri: PLTSUP Sec:
Dockets Discussed:
05000440 PERRY 1 NRC POS Pri:1C Sec:
Ter.
The licensee's radiation worker training program was well Implemented.
The licensee's radiation worker training program was well implemented.
Training lesson plans provided an appropriate level of radiation safety instrucbon, which was consistent with NRC requirements.
In addition, the licensee conducted training exercises which effectively challenged trainees to demonstrate radiological practices and to identify work area probleins.
Dockets Discussed 05000440 PERRY 1 02/26/1999 1999004 Prl: PLTSUP NRC POS Prl: 1C Sec:
Sec: 5B Ter.
The quality assurance and RP staffs performed comprehensive reviews of the RP program.
The quality assurance and RP staffs performed comprehensive reviews of the RP program. The assessments were well planned and of approoprlate scope.
In addition, the RP staff also performed thorough evaluations of Rp performance indicators. The Inspector concluded that these assessments and evaluations were effectively used to identity and to correct performance issues.
Item Type (Compliance,Followup,Other), From 08/31/1998 To 09/01/1999
Page:
15 of 18 09I27I1999 07:28:42 IR Report 3 Region ill PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Area Template ID Type Codes Item Title Item Description Oockets Discussed 05000440 PERRY 1
11/06/1998 1998022 Pri: PLTSUP NRC NEG Prl: 1C Sec:.
Sec:
Ter.
The inspectors observed some problems concerning the content of chemistry procedures.
The inspectors observed some problems concerning the content of chemistry procedures.
For example, a note in the routine chemistry sampling procedure contained directions which the staff was not fullyimplementing. Although the chemistry staff was attemptmg to correct these issues and had performed a complete review of the department's procedures, the staff had not identified the above problem, which indicated a lack of rigor in the initial reviews.
11/06/1998 1998022 Pri: PLTSUP NRC NOEO Sec:
Dockets Discussed:
05000440 PERRY 1 Pri: 1C The licensee maintained the PASS as required by station procedures.
The Hcensee maintained the PASS as required by station procedures.
Quality control results for 1997 demonstrated that the system was obtaining representative liquid samples.
Although the testing results were not acceptable for Ter:
1998, the licensee was taking actions to resolve testing problems and system operabiTity issues.
In addition, the licensee provided PASS training to chemistry technicians which was comprehensive and included an evaluation of technician performance.
Oockets Discussed 05000440 PERRY 1
11/06/1998 1998022 Prl: PLTSUP NRC POS Pri: 1C Sec:
Sec:
Ter.
The licensee maintained a strong commitment to reducing corrosive impurities In the reactor coolant system The licensee maintained a strong commitment to reducing corrosive impurities in the reactor coolant system.
Reactor coolant sulphate and chloride concentrations were maintained at levels which were well below the industry averages.
In addition, the chemistry staff performed thorough eva!uations of chemistry trends and of the levels of zinc in the reactor coolant system to reduce radiological source tenn. The inspectors also noted effective teamwork Dockets Discussed 05000440 PERRY 1
11/06/1998 1998022 Pri: PLTSUP NRC POS Pri: 1C Sec:
Sec:
Ter:
The licensee maintained aggressive control and monitoring of accumulated personnel dose.
The licensee maintained aggressive control and monitoring of accumulated personnel dose.
For example, the RP staff prepared monthly AlARAreports which documented each p'lant department's dose performance and compared that performance to established goals.
For 1998, the licensee's annual dose perfonnance was prolected to be one of the lowest in the Industry for boiling water reactors.
11/06/1998 1998022 Pri: PLTSUP Sec:
Oockets Discussed:
05000440 PERRY 1 NRC POS Prl: 1C Sec:
Ter:
The chemistry staff implemented a sound quality control (QC) program for laboratory Instruments.
The chemistry staff implemented a sound quality control (QC) program for laboratory instruments.
The inspectors found that instrument perfonnance tests were properly performed and that control chart data generally demonstrated only statistical variations in instrument performance.
As a result of recent audit and assessment findings, the chemistry staff had also taken actions to improve QC practices concerning certain instrument calibrations and overview of long-term instrument performance trends.
Dockets Discussed 05000440 PERRY 1 11/06/1998 1998022 Prh PLTSUP NRC POS Prl: 1C Sec:
~
Sec:
Ter:
The Radiological, Environmental, and Chemistry Section staff performed effective monitoring of system oper The Radiological, Environmental, and Chemistry Section staff performed effective monitoring of system operability for the meteorological tower instrumentation.
The calibrations and surveillances for the meteorological tower were properly performed, and the licensee properly maintained the monitoring instrumentation.
The licensee thoroughly reviewed an issue related to the vendor's instrument calibration practices.
Dockets Discussed 05000440 PERRY 1 11/06/1998 1998022 Prli PLTSUP NRC POS Prl: 1C Sec:
Sec:
Ter:
Chemistry technicians demonstrated effective analytical techniques and procedure adherence.
Chemistry technicians demonstrated effective analytical techniques and procedure adherence.
For example, the technicians took steps to ensure that samples were not cross-contaminated.
With some minor exceptions. the inspectors observed proper contamination control practices and surveys of radioactive samples.
item Type (Compliance,Followup,Other), From 08/31/1998 To 09/01/1999
Page:
16 of 18 09/27/1999 07:28:42 IR Report 3 Region Iif PERRY United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Date Source Functional Template Area ID Type Codes Item Title Item Description Dockets Discussed 05000440 PERRY 1
11/06/1998 1998022 Prl: PLTSUP NRC POS Prl: 1C Sec:
Sec:
Ter:
Audits of the chemistry program were performed in good depth Audits of the chemistry program were performed In good depth, and the staff was taking aggressive actions to correct problems identified. For example, chemistry management was increasing the tine organization's involvement in the self assessment program and the supervisory staffs review of QC data results.
Generally, the inspectors found that the chemistry staff had taken appropriate actions to correct issues identified in condition reports.
10/20/1998 1998018 Pri: PLTSUP NRC NEG Sec:
Dockets Discussed:
05000440 PERRY 1
Prl: 1C Sec:
Ter.
Contamination control program not consistently understood by technicians Although the licensee's contamination control program allowed plant personnel to extend contamination area boundaries in certain situations, this policy was not consistently understood or implemented by radiation protection technicians.
Dockets Discussed 05000440 PERRY 1 09/14/1998 1998017 Pri: PLTSUP NRC NEG Prl: 1C Sec:
Sec:
Ter:
Auditof the waste management shipping programs did not provide a comprehensive review.
The inspector found that the most recent audit of the radioactive waste management and radioactive waste and material shipping programs did not provide a comprehensive review. The audit focused on the conduct of radioactive waste control room operations and system material condition but did not fullyassess the shipping program or process control program implementation.
09/14/1998 19980 I7 Prl: PLTSUP Sec:
Dockets Discussed:
05000440 PERRY 1 NRC NEG Prl:1C Sec:
Ter:
Revision of radioactive waste and material shipping procedures not timely The inspector noted slow progress in the REGS staffs revision of radioactive waste and material shipping procedures, which was started in early 1997.
In addition, the inspector observed some weaknesses in the procedures used for 10 CFR Part 61 scaling factor analyses.
The REGS staff had developed an action plan to ensure timely completion of the procedure revisions and planned to review the instructions contained in the process control program and additional procedures.
09/14/1998 1998017 Pri: PLTSUP NRC POS Prl: 1C Sec:
Sec:
Ter:
Oockets Discussed 05000440 PERRY 1 The REMP was properly Implemented The REMP was properly implemented in accordance vnth the requirements of the Offsite Dose Calculation Manual.
Airsampling equipment was calibrated at the required frequency, and the REMP technician demonstrated good analytical techniques.
The 1997 and 1998 REMP sample results were consistent with normal f!uctuations in background radioactivity.
Oockets Discussed 05000440 PERRY 1 09/14/1998 1998017 Pri: PLTSUP NRC PQS Prl: 1C Sec:
Sec:
Ter.
The licensee properly packaged and classified radioactive material and waste shipments ln general, the Radiological ~ Environmental, and Chemistry Section (REGS) staff properly packaged and classified radioactive material and waste shipments in accordance with regulatory requirements.
Although some inaccuracies were identified, the shipping documentation and fow level waste manifests contained the information required by 49 CFR Part 172 and 10 CFR Part 20.
Dockets Discussed 05000440 PERRY 1 09/14/1998 1998017 Prl: PLTSUP NRC ppS Prl: 1C Sec:
Sec:
Ter:
Personnel involved In the radioactive material shipping program were properly trained.
The inspector noted that personnel involved ln the radioactive material shipping program were properly trained. In addition, training lesson plans were coinprehensive and presented a broad review of the radioactive shipping program Item Type (Compliance,Foilowup,Other)
~ From 08/31 /1998 To 09/01/1999
Page:
17of18 09/27/1999 07:28:42 IR Report 3 Region III
'ERRY Date Source Functional Area United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Template item Title ID Type Codes Item Description 09/14/1998 1998017-01 Pri: PLTSUP NRC Sec:
Dockets Discussed:
05000440 PERRY 1
yIOly Prl: 1C Inadequate radlonucllde scaling factors used In radioactive waste characterization One violation was identified concerning the failure of the licensee to ensure that scaling factors used to determine the activity of hard to detect radionuciides in radioactive waste shipments could be correlated with actual plant Ter:
samples.
In Aprilof 1998, the licensee did not adequately evaluate a poor correlation between isotopic data reported by its chemistry laboratory and a vendor. Consequently, the licensee implemented inaccurate radionuclide scaling factors which significantly underestimated the nongamrna radionuciides in radioactive waste shipments..
09/14/1998 1998017-02 Prl: PLTSUP NRC Sec:
Dockets Discussed:
05000440 PERRY 1 NCy Prl: 1C Failure to test the hIgh alarm function of containment ventilation exhaust radiation monitor One Non-Cited Violation was ldentifIed concerning the inadequate testing of the high alarm function isolation for the containment ventilation exhaust radiation monitor. The licensee identified this problem and performed corrective Ter:
actions to ensure that the issue was corrected.
09/08/199&
19980'l6 Prl: PLTSUP Sec:
Dockets Discussed:
05000440 PERRY 1
NRC POS Prl: 1C Sec: 5C Ter:
Fire extlngulshers stored beyound allowed time; but entered into corrective action program The inspectors concluded that the fire protection supervisor implemented effective corrective actions for two fire extinguishers which had been temporarily stored beyond the guidance allowed in the station's housekeeping procedure.
However, a condition report was not initiated for this issue until the inspectors identified that licensee management's expectations were not met regarding entering this information into the corrective action program ttem Type (Compliance,Foliowup,Other). From 08/31/1998 To 09/01/1999
Page:
18of18 09/27/1999 Oy:28:42 IR Report 3 United States Nuclear Regulatory Commission PLANT ISSUE MATRIX By Primary Functional Area Legend Type Codes:
BU Bulletin CDR Construction DEV Deviation EEI Escalated Enforcement Item IFI Inspector follow.up item LER Licensee Event Report LIC Licensing Issue MISC Miscellaneous MV MinorViolation NCV NonCited Violation NEG Negative NOED Notice of Enforcement Discretion NON Notice of Non-Conformance OTHR Other P21 Part 21 POS Positive SGI Safeguard Event Report STR Strength URI Unresolved item VIO Violation WK Weakness Template Codes:
'1A Normal Operations 1B Operations During Transients 1C Programs and Processes 2A Equipment Condition 2B Programs and Processes 3A Work Performance 3B KSA 3C Work Environment 4A Design 4B Engineering Support 4C Programs and Processes 5A Identification 5B Analysis 5C Resolution ID Codes:
NRC NRC Self Selt-Revealed Licensee Licensee Functional Areas:
OPS Operations MAINT Maintenance ENG Engineering PLTSUP Plant Support OTHER Other EEls are apparent violations ot NRC Requirements that are being considered for escalated enforcement action in accordance viith the "Gene fal Statement of poli and p Enforcement Action" (Enforcement Policy), NUREG-1600.
However, the NRC has not reached its final enforcement decision on the issues identified by the EEls and lhe PIM modified when the final decisions are made.
y e
s an t e PIM entries may be URls are unfesol ed items about which more Intormation is required to determine whether the issue in question is an acceptable hem. a deviation a nonconformance or I
may also be a potential violation that is not likelyto be considered for escalated enforcement action. However, the NRC has not reached its final conctusions~o~n the issue d th 'p entries may be modified when the final conclusions are made.
Item Type (Compliance,Foliowup,Other). From 08/31/1 998 To 09/01/1 999
Page1 of1 09/30/1999 09:05:55 PERRY Inspection / ActivityPlan 09/01/1999 - 03/31/2000 ENCLOSURE 2
+n~lts nspect on ctivity IP 81700 IP 84750 IP 83750 IP 86750 Physical Security Program For Power Reactors Radioactive Waste Treatment, And ENuent And Environmental Monitoring Occupational Radiation Exposure Solid Radioactive Waste Management And Transportation Of Radioactive Mater um ero Inspectors / Individuals anne a es Start End nspec ion Type 10/25/1999 10/29/1999 Core 12/06/1999 12/10/1999 Core 03/27/2000 03/31/2000 Core 03/27/2000 03/31/2000 Core isrepo oesno in u e an a
ies.
This report shows only on-site and announced inspection procedures.