IR 05000440/1985036
| ML20127H445 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/11/1985 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20127H417 | List: |
| References | |
| 50-440-85-36-MM, NUDOCS 8506260334 | |
| Download: ML20127H445 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-440/85036(DRP)
Docket No. 50-440 License No. CPPR-148 Licensee:
Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name:
Perry Nuclear Power Plant, Unit 1 Meeting At:
NRC Region III Office, Glen Ellyn, IL Meeting Conducted: June 3, 1985 Reporte* By:
J. A. Grobe I? f u) m <E): &
Approved By:
R. C. Knop, Chief (>//Mff'
Reactor Projects Section 1C Date'
Meeting Summary Meeting on June 3, 1985 (Report No. 50-440/85036(DRP))
Areas Discussed: Management meeting to discuss recent problems with implementation of the preoperational testing program and the status and results of operator ifcensing examinations.
The meeting involved a total of 28 inspector-hours by 14 NRC inspectors and regional staff.
Results:
Significant concerns were discussed in the area of test procedure adequacy, test conduct and commitment implementation.
It also was discussed that the applicant's projected fuel date may be affected if the negative preoperational testing performance trend continued.
No items of noncompliance were identified during the meeting.
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DETAILS 1.
Persons Contacted The following persons participated in the management meeting on June 3, 1985, at the NRC Region III Office in Glen Ellyn, IL.
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Cleveland Electric Illuminating Company R. M. Ginn, Chairman of the Board and Chief Executive Officer H. L. Williams, Executive Vice President M. R. Edelman, Vice President, Nuclear Group M. D. Lyster, Manager, Perry Plant Operations Department C. M. Shuster, Manager, Nuclear Quality Assurance Department G. R. Leidich, General Supervising Engineer, Nuclear Test Section b.
Nuclear Regulatory Commission J. G. Keppler, Administrator, Region III (RIII)
A. B. Davis, Deputy Administrator, RIII C. E. Norelius, Director, Division of Reactor Projects (DRP), RIII R. F. Warnick, Chief, Projects Branch 1 (PB1), DRP R. C. Knop, Chief, Projects Section IC (PSIC) PB1 J. A. Grobe, Senior Resident Operations Inspector - Perry, PSIC J. F. Streeter, Technical Assistant, Division of Reactor Safety (DRS), RIII L. A. Reyes, Chief, Operations Branch (08), DRS J. I. McMillen, Chief, Operator Licensing Section, 08 M. A. Ring, Chief, Test Programs Section (TPS), Engineering Branch R. D. Lanksbury, Lead Test Inspector - Perry, TPS D. E. Hills, Inspector, TPS G. F. O'Dwyer, Inspector, TPS J. J. Stefano, Licensing Project Manager, Division of Licensing, Office of Nuclear Reactor Regulation 2.
Management Meeting Mr. J. G. Keppler opened the meeting (Attachment 1) with a brief discussion of the problem areas in implementation of the preoperational test program and indicated that the applicant's projected fuel loading date may be affected if the negative preoperational testing performance trend continued.
Following this introduction, Mr. R. C. Knop provided an overview of the status of facility completion and NRC inspection program completion in each functional area of the physical plant and the operations, technical, and quality assurance departments.
Mr. Knop concluded his remarks with a discussion of the status of open item closeout noting that a significant workload exists for the applicant to prepare items for NRC closeout with approximately 250 items outstanding.
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A detailed discussion of preoperational testing program implementation deficiencies was then presented by Mr. M. A. Ring (Attachment 2).
Significant concerns were presented in the area of test procedure adequacy, test conduct and commitment implementation. Messrs. J. F. Streeter and L. A. Reyes then presented a synopsis of the poorer than desirable operator licensing examination results (Attachment 3) and indicated that the number of licensed operators was sufficient to operate the plant but was less than the average number of licensed operators at other Region III NT0Ls.
The applicant responded to these presentations and discussed their corrective actions. Mr. G. R. Leidich presented corrective actions responding to the deficiencies in implementation of the preoperational testing program (Attachment 4). The applicant committed to better define the review responsibilities of each Test Program Review Committee (TPRC)
member to ensure adequate review. The applicant also committed to add another level of detailed review of each procedure as defined in a Special Project Plan. Mr. M. D. Lyster presented a results evaluation and discussed program im rovements regarding success rate for license candidates (Attachment 5.
NRC Region III was satisfied that the applicant had addressed the major programmatic areas needing attention. The inspectors will continue to evaluate progress in these areas during future inspections. No
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additional items of noncompliance were identified during this meeting.
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ATTACHMENT 1 PERRY MANAGEMENT MEETING
REGION III
JUNE 3, 1985
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INTRODUCTORY REMARKS,..........
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KEPPLER
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STATUS OF INSPECTION PROGRAM.........'...
KNOP PRE 0PERATIONAL TESTING........... LANKSBURY/ RING
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OPERATOR LICENSING.............. '...
STREETER
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CLOSING REMARKS
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ATTACHMENT 2 - Page 1 PRE 0PERATIONAL TESTING PERFORMANCE
- ENFORCEMENT ACTIONS:
11 VIOLATIONS IDENTIFIED IN 5 INSPECTIONS (7 0F THE VIOLATIONS IDENTIFIED IN LAST 2 INSPECTIONS)
- INSPECTION OBSERVATIONS:
-EXCESSIVE NUMBER OF VIOLATIONS
- -VIOLATION RATE TREND NEGATIVE-PRIMARY PROBLEM INADEQUATE PROCEDURES-MISLEADING STATEMENTS / COMMITMENTS-INADEQUATE CORRECTIVE ACTIONS-UNTIMELY CORRECTIVE ACTIONS-0BSERVATIONS SIMILAR TO THOSE IDENTIFIED AT OTHER PAST CATEGORY 3 PERFORMERS WHOSE SCHEDULES WERE ADVERSELY IMPACTED BY POOR PREOPERATIONAL TESTING PERFORMANCE
- CONCLUSION:
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PERFORMANCE SALP CATEGORY 3.
PRE 0PERATIONAL TESTING CONCERNS PREVIOUSLY DISCUSSED IN MANAGEMENT MEETING WITH M. EDELMAN.
RIII LACKS CONFIDENCE IN QUALITY OF TEST PROGRAM.
IMMEDIATE MANAGEMENT ATTENTION NEEDED TO ADDRESS ADEQUACY OF PROCEDURES, TIMELINESS AND ADEQUACY OF CORRECTIVE ACTIONS, 'DEQUACY OF TEST CONDUCT, AND MISLEADING NATURE OF STATEMENTS /
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COMMITMEN 5.
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ATTACIIMENT 2 - Page 2 EXAMPLES OF INADE0VATE PROCEDURES
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(9 0F THE 15 PROCEDURES REVIEWED THUS FAR BY THE NRC WERE DEFICIENT)
1) BORON STORAGE TANK MIXING BY AIR SPARGER NOT TESTED ADEQUATELY.
2) ORIFICE FLOW NOT TESTED UNDER PROPER CONDITIONS.
3) DESIGN REQUIREMENT OF 10CFR50.62 NOT PROVEN.
INSTRUMENT AIR
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SYSTEM LEAKAGE PER REGULATORY GUIDE 1.80 NOT TESTED.
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PRESSURE DROP NOT TESTED OVER SUFFICIENT TIME.
RECIRC FLOW CONTROL
1) LOSS OF POWER TO HYDRAULIC CONTROL. UNIT NOT TESTED 2) AUTO TRANSFER OF POWER TRAINS FOR HYDRAULIC POWER UNIT NOT TESTED ANNULUS GAS TREATMENT
1) WRONG STANDARD USED
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2) SYSTEM RESTORATION MISSING
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ATTACl! MENT 2 - Page 3
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EXAMPLES OF INADEQUATE TEST CONDUCT
COORDINATION / COMMUNICATIONS BETWEEN TEST AND OPERATIONS PERSONNEL
OPERATING DG AND LPCS USE OF TEMPORARY OPERATING INSTRUCTIONS
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I 1) LED TO INADVERTANT SPRAYDOWN OF CONTAINMENT
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2) LED TO OVERPRESSURIZATION OF EDG ESW HEAT EXCHANGER NOT USING SYSTEM OPERATING INSTRUCTIONS
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INCONSISTENT WITH REGULATORY GUIDE 1.68 COMMITMENT 2) BASED ON PHILISOPHY THAT "T01s ARE BETTER"
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ATTACHMENT 2 - Page 4 EXAMPLES OF MISLEADING STATEMENTS / COMMITMENTS l
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CHANGING TPM TO CLOSE NRC ITEM THEN DELETING THE CHANGE l
C06941TMENT FOR MANAGEMENT PROCEDURE REVIEW TEAM TO
" REVIEW TEST PROCEDURES FOR ADEQUACY"
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ATTAC!! MENT 3 OPERATOR LICENSING PERFORMANCE
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- EXAMINATION RESULTS:
GROUP N0. CANDIDATES NO. PASSES (PASS RATE)
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20(77%)
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SECOND
15(58%)
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35(67%)
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'0BSERVATIONS:
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-PASS RATE TREND NEGATIVE-N0 UNUSUAL PATTERN IN FAILURE CAUSES-0VERALLPASSRATE(67%)INLOWERENDOFSPECTRUMFORRIIINT0LS (
t-NUMBEROFLICENSES(35)ADEQUATEBUTLESSTHANOTHERRIIINT0LS t
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' CONCLUSION:
PERFORMANCE BORDERLINE BETWEEN SALP CATEGORY 2 AND 3.
IMMEDIATE MANAGEMENT ATTENTION NEEDED TO DETERMINE AND CORRECT CAUSES OF LESS THAN DESIRABLE EXAMINATION PASS RATE.
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ATTACHMENT 4 - Page 1
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l PREOPERATIONAL TEST PROGRAM Testing Status (5/31)
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Preoperational Tests 59 complete out of 106 (56%)
Acceptance Tests 105 complete out of 116 (91%)
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overall 164/222.
(74%)
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ATTACitiENT 4 - Page 2
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l TEST PROCEDURES CONTENT Original sample of five procedures and resulting comments
Formation of Management Procedure ReviewTeam(MPRT)
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Improved confidence at Release for Test
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Management approach
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ATTACHMENT 4 - Page 3
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Test Procedures '- Current Enhancements I
Increased management attention /Special Project Plan e
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clarify review scope
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add Licensing to TPRC
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train review groups
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Supervisor to Engineer ratio l
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Test Procedures - Current Enhancements v
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Test Procedures-Sequence of Testing Test Program has been modified to require
specific sequence detail in procedures Tests in Progress have been reviewed / modified to
ensure level of detailis consistent The procedure backfit program willinclude
review of sequence performed for completed tests
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ATTACHMENT 4 - Page 6
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Timeliness of Corrective Actions-Test Program Organizational changes within NTS Administration
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Implementation of Perry Operations Procedures 1601,
NRC Interface During Plant Operations
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Reinforced within NTS
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adequate identification prompt / complete resolution
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ATTACHMENT 4 - Page 7
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Timeliness of Corrective Actions - Test Program
Data as of May 10 Exit Meeting:
Total Ready for Pending Review
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items of Noncompliance
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Unresolved items
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1 Total 49.
(11 tracking)*
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Data as of May 31:
Total Ready for Pending Review items of Noncompliance
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Unresolved items
3 Open items
12 Total
18 (34 Tracking)*
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- Tracking means that the NRC is waiting for an activity to be performed or condition to be attained before inspection or closecut.
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ATTACHMENT 4 - Page 8
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. Coordination / Communication between Nuclear Test Section and Operations Section Enhancements Shift Supervisors in charge of plant testing and ops e
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dual reporting to test and ops
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trained to Test Program Manual
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function as Test Coordinator Operations chairs Test Plan of Day Meeting e
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Transition of personneltest + ops e
Transition of Test Program to Operations Phase e
e.g. Alarm Reponse Instruction Tagging M & TE Calibration Procedures Performance of Surveillance Instructions underTest Program e
'I&C Operations Planning Group in place e
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ATTACHMENT 4 - Page 9
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Use of System Operating Instructions (sol's) During Testing Generally Temporary Operating Instructions (TOl's)
e have been used during testing l
Upgraded TOl program to integrate TOl's with
operations (shift supervisor approval)
Use'd sol's in simulator training - high confidence e
from control room issued directive to justify use of TOl's, o
otherwir,e use sol's
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Comments resolution - joint NTS/ ops action
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ATTACHMENT 5 - Page 1
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US NRC MEETING
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6-3-85 Chicago, Illinois a
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Examination Results
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Total Exams = 42 l
SRO Licenses = 25 of 32 = 78%
RO Licenses 6 of 10 = 60%
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INPO 1984 Survey SRO R_OO NTOL (14 locations)
75.7 %
61.1 %
All Plants (62 locations)
81.6 %
74.5%
Group Results 83-1 = 21/27 = 77%
84-1 = 13/21 = 62%
Assignment to Groups March,1983
- License Class 83-1 started 30 week program October,1983
- Simulator and written exams administered-walkthrough exams postponed.
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21 of 27 people passed both exams September,1984
- License Class 84-1 started 30 week program December,1984
_ License Class 83-1 divided into 3 groups to complete an 8-10 week training program and receive oral exams.
Exam Schedule February 7 people May 9 people April 5 people all of whom were upgrades or retakes from October,1983 exams.
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February,1985 7 persons completed walk-through exams and all 7 passed April,1985 26 people completed wntten, simulator and
walk-through exams J
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ATTACHMENT 5 - Page 2
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_ Results: S written failures (2 RO,
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3 SRO)
1 walk-through failure (RO)
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1 simulator failure (SRO)
4 double failures (1RO, 3 SRO)
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May,1985 9 people completed walk-throughs and all passed Results Analysis All written exam section failures (< 70%) were on Procedures.
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3 RO written failures did not answer last question of e
Section 4 which was on separate page None of the people retaking examin Aprilfailed.
e These were not considered especially significant nor were any other programmatic results distinguishable.
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Review of Program and improvements
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Number 1 objective was to maximize on-shift time e
to gain knowledge of Perry during testing phase.
Minimized program duration Minimized number of participants Will pay large dividends in future Have instituted a more formal structure to the in plant e
tours and observation.
Previous programs were very flexible due to varying
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backgrounds of the individuals.
e Increased use of simulator will be realized since it is now at Perry.
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More cumulative performance measures will be utilized in future
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ATTACHMENT 5 - Page 3 oift Staffin R
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FSAR - 5 shift rotation SER - 5 shift rotation + 2 extraglicensed people e
e Each shift at least 2 SRO and 2 RO licenses With 22 Operations personnellicensed the SER requirement can be met.
7 staff personnel with SRO licenses to augment as necessary.
e Generic letter 84-16 Operating Shift experience requirements will e
be met.
Shift experience may be augmented as necessary e
by plant staff personnel (4) with extensive BWR experience.
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1985 License Plans License Program will start this month and complete in December e
with 8 operators and 4 staff.
10 reapplications will be processed on or before December.
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Summary e
Exam results are not to our standards or satisfactions.
Results suffered due to our emphasis placed on plant testing
participation.
immediately implement some improvements in program.
e Enough licenses exist to adequately staff our shifts.
- well-trained motivated staff capable of accomplishing mission.
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