ML20135H673
| ML20135H673 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/18/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20135H668 | List: |
| References | |
| 50-440-85-01, 50-440-85-1, NUDOCS 8509240120 | |
| Download: ML20135H673 (38) | |
See also: IR 05000440/1985001
Text
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SALP 5
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
.
REGION-III '
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-440/85001
Inspection Report
Cleveland Electric Illuminating Company
Name of Licensee
Perry Nuclear Power Plant Unit 1
Name of Facility
January 1, 1984 - June 30, 1985
Assessment Period-
.
8509240120 850918
gDR
ADOCK O j
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
~
periodic basis and to evaluate licensee performance based upon this infor-
mation. SALP is supplemental to normal regulatory processes used to ensure
compliance.with NRC rules and regulations. SALP is intended to be sufficiently
diagnostic to provide a rational basis for allocating NRC resources and to
provide meaningful guidance to the licensee's management to promote quality
and safety of plant construction and operation.
An NRC SALP Board, ccmposed of the staff members listed below, met on
! August 15, 1985, to review the collection of performance observations and -
data to assess the licensee's performance in accordance with the guidance
in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary.of the guidance and evaluation criteria is provided in Section II
of this report.
This report is the SALP Board's assessment of the licensee's safety perfor-
mance at Perry Nuclear Power Plant Unit 1 for the period January 1,1984,
through June 30, 1985.
Personnel attending the SALP Board for Perry Nuclear Power Plant:
Name Title
J. G. Keppler Regional Administrator
A. B. Davis Deputy Regional Administrator
C. E. Norelius Director, DRP
C. J. Paperiello Director, DRS
J. F. Streeter Technical Assistant, DRS
L. A. Reyes Branch Chief, DRS
W. D. Shafer Branch Chief, DRSS
J. J. Harrison Branch Chief, DRS
R. F. Warnick- Branch Chief, DRP
B. J. Youngblood Branch Chief, NRR
R. C. Knop Section Chief, DRP
M. A. Ring Section Chief, DRS
C. C. Williams Section Chief, DRS
F. C. Hawkins Section Chief, DRS
J. J. Stefano Project Manager, NRR
J. A. Grobe Senior Resident Inspector, DRP
J. W. McCormick-Barger Project Manager / Inspector, DRP
R. A. Westberg Reactor Inspector, DRS
W. G. Snell Emergency Preparedness
Analyst, DRSS
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- II. CRITERIA
)
The licensee's performance is assessed in selected functional areas i
depending on whether the facility is in a construction,. pre-operational,
or operating phase. Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
programmatic areas. Some functional areas may not be assessed because
of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess
each functional area.
1. Management involvement in assuring quality.
2. Approach to resolution of technical issues from a safety standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Reporting and analysis of events.
6. Staffing (including management).
7. Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate. .
Based upon the SALP Board's assessment, each functional area evaluated is
classified into one of three performance categories. The definition of
these performance categories is:
Category 1: Reduced NRC attention may be appropriate. Licensee manage-
ment attention and involvement are aggressive and oriented toward nuclear
safety. Licensee resources are ample and effectively used so that a high
level of performance with respect to operational safety or construction
is being achieved.
Category 2: NRC attention sho~uld be maintained at normal levels. Licen-
see management attention and involvement are evident and management is
concerned with nuclear safety. Licensee resources are adequate and are
reasonably effective such that satisfactory performance with respect to
operational safety or-construction is being achieved.
Category 3: Both NRC and licensee attention should be increased. Licen- ,
see management attention and involvement is acceptable and considers l
nuclear safety, but weaknesses are' evident. Licensee resources appear to
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety or construction is being
achieved.
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' Trend: -.The"SALP' Board has also categorized the performance trend in each
functional area rated over the course'of the SALP assessment period. The-
. categorization describes the general .or prevailing tendency (the perfor-
mance gradient) during the SALP period.
'
The performance trends are
defined as follows:
Improved: Licensee performance has generally-improved over the course
of the SALP assessment period.
Same: Licensee performance has remained essentially constant over
the course of the SALP assessment period.
Declined: Licensee performance has generally declined over the course
of the SALP assessment period.
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III. SU N RY OF RESULTS
The licensee's performance was found to be acceptable. The licensee was
found to exhibit an aggressive management attitude and demonstrated a high
level of performance in the (1) Containment and Other Safety-Related Struc-
tures, (2) Safety-Related Components, (3) Instrument and Control Systems,
and (4) Emergency Preparedness functional areas. Performance in the
Preoperational Testing area was found to need increased management atten-
tion. Particular attention to Preoperational Quality Assurance is needed
to help reverse the negative trend in performance in this area. Perfor-
mance in.the Licensing. area would also be. enhanced by increased management
involvement and increased staffing. Increased management responsiveness
to operational needs has been apparent during the latter part of the
assessment period. With the exception of the Preoperational Testing area,
management has been responsive to NRC findings and concerns and enforcement
history has been good during the SALP period.
Rating Rating
Last This
Functional Area Period Period Trend
A. Containment and Other 1 1 Same
Safety-Related
Structures
B. Piping Systems and Supports 2 2 Improved
C. Safety-Related Components 2 1 Same
D. Electrical. Power Supply 2 2 Improved
and Distribution
E. Instrument and Control 2 1 Same
Systems
F. Quality Programs and 2 2 Same
Administrative Controls
Affecting Quality
G. Licensing Activities 2. 2 Declined
H. Preoperational Testing NR 3 Declined
I. Radiological Controls 2 2 Improved
J. Fire Protection NR 2 Not Rated
-- K. . Emergency Preparedness NR 1 Same
L. Security NR 2 Improved
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Rating _
Rating !
-Last
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This-
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Functional-Area Period Period Trend
Operational Readiness'
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M. NR 2 Same
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.NR = not rated.
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b IV.' PERFORMANCE ANALYSIS
i
A. 'C_ontainment and other Safety-Related Structures
-1. Analysis
4- Examination of this functional area consisted of three inspec-
1L tions by regional based-inspectors and portions of seven
, inspections by the resident inspection staff. . Areas examined
4- included (1) walkdown of the containment and auxiliary building;
!' (2) observation of installed penetrations in containment; (3)
!
concrete drilling and coring; (4): review of the results of a
- limited re-inspection.of structural steel; connections; (5)
reworked safety-related.HVAC support structure welds and asso-
}- ciated ~ documentation; (6) documentation concerning control rod
guide tube welds.to-stub tubes.in the bottom head of the reactor ,
i vessel;:(7) observation of placement of portions of concrete;
- and (8) previous inspection findings and 10 CFR 50.55(e) items.
4
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One; violation was_ identified relative to the control over
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structural steel installation:
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Severity Level IV - Failure to implement corrective- -
- . action to prevent recurrence of-improper reinstallation -
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of structural steel bolting (50 440/84022).
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- The licensee took corre'ctive action including revision of
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procedures governing the issuance and review of nonconformance
t
reports and training personnel responsible for disposition,
review,'and approval-of nonconformance reports.to_the new
j- requirements of the project procedures. The-licensee also ,
- reviewed all nonconformance. reports for'an approximate one'
year period to ensure that the probles was not; generic.
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The bolting problem indicated a programmatic weakness in the '
- removal and re-installation of: structural steel. As a~ result,-
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a limited re-inspection of bolted connections.was performed in
? .the Auxiliary, Reactor, and.Radwaste Buildings by the licensee.
E Although some bolted connections were found to be inadequate,
the bolting problem did not appear.to be widespread.
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Licensee resources? appeared to'be appropriate for the activities
being performed in this-area. Records. reviewed during these
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i . inspections were foundLto be complete, well maintained; and
- . easily retrievable. Observations' indicate l personnel have an
-adequate understanding of work practices and that procedures
, . were adhered to. Deficiencies, when identified,'were-promptly.
reported to. the staff.'and the analyses of these reported defi-
ciencies were consistently found to be adequate. Management >
1showed aggressive involvement in the resolution of identified
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deficiencies. -
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2. Conclusion
. . The'l_icensee is rated Category 1 in this area. This'is the same
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rating as the previous assessment period. Licensee performance
- has remained essentially constant over the course of the SALP
i- assessment period.
,
3. Board Recommendations
None.
~B. Piping Systems and Supports
l 1. Analysis -
Construction was essentially complete. Examination of this
functional area consisted of nin<! inspections by regional based
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inspectors and one inspection by the resident inspection staff.
Areas examined for reactor coolant pressure boundary and other
safety related piping included (1) observation of inprocess
. welding; (2) visual examination of completed welds and weld
repairs; (3) selected review of procedures and documentation
related to fabrication, installation, welding, and heat treat-
ment; (4) review of the applicability to the Perry plant of
- deficiencies identified at the'Vogtle plant concerning shop
, welds in spool pieces fabricated by Pullman Power Products;.
I
(5) review of.ASME Code N-5 Data Reports; (G) review of ultra-
sonic examinations performed on recirculation system piping
welds susceptible to intergranular stress' corrosion cracking,
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and piping welds prepared with corrosion resistant cladding;
! (7) review of licensee actions related to previous inspection
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findings; (8) review of Reactor Coolant System, hydrostatic test
procedure and.results; (9) observation'of.the-iteactor Coolant
' System hydrostatic test; and (10) examination of allegations
brought to the attention of the NRC. 'No violations or devia-
tions were identified.
For the areas examined, the inspectors determinsd that the
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.ranagement control systems aggressively addressed nuclear
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' safety and the personnel and material. certifications were
current and, complete. Records were found to be complete,.well
maintained,.and easily retrievable. Discussions-with licensee
3 and contractor personnel-indicatedithat they were; knowledgeable
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in their- job. 2The two violations' identified 'during. th'e last
r. - assessment period by the Construction Appraisal-Team were
promptly corrected during that assessment period and no
recurrence has been'found.
$ iA11egation'sreviewed'relatedprimarilyto(i)theus'eofthe 1
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wrong diameter weld rod on piping hangers; (2) the accuracy of '
assumptions and' calculations by Gilbert Associates staff during
othe' design and verification of pipe-supports; and (3) pipe-
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. support 2G42H001 n'ot being installed as required. LAllegations
(1) and (2) above could not be substantiated. Allegation (3).
was partially substantiated; however, the allegation concerned
a non-safety related pipe support.
The NRC's Integrated Design Inspection (IDI) team found some
weaknesses in the design process in this assessment area which
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included: (1) piping stress analyses for the faulted conditions
~
did not always consider piping thermal stress in nozzle loadings
on NSSS equipment, as required by-licensing commitments; and (2)
piping stress analysis modeled equipment as rigid when the equip-
ment had a frequency more appropriate to dynamic modeling.
These weaknesses should have been identified through licensee
audits and reflects upon management involvement and control in
assuring ~ quality. Licensee's responsiveness in correcting the
problems identified by the IDI and expanding the scope to include
systems not reviewed by the IDI, indicated an aggressive
approach to resolution of technical issues from a safety stand-
point. All findings were resolved to the satisfaction of the
IDI team by the end of the assessment period.
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same rating as in the previous assessment period. Licensee
performance has generally improved over the course of the SALP
assessment period.
3. Board Recommendations
None.
C. Safety Related Components
1. Analysis
Construction was essentially complete prior to the assessment
period, and examination of this functional area was somewhat
limited. It_ consisted of one inspection by regional based
inspectors and portions of three inspections by the. resident
inspection staff. Areas examined included (1) observation of
4- completed work; (2) review of selected quality records related
to material certification, installation and cleanliness of
installed components; (3) observation of inspection and test
activities associated with the quality revalidation program .
for the Division I and II standby power source Transamerica
Delaval Inc. (TDI) diesel engines; (4) review of test proce-
dures and results of the TDI diesel engine-testing; and (5)
review of test procedures, observation of testing, and review
of results for testing of the Division III High Pressure Core
Spray System General Motors Electromotive Division diesel
engine. No violations or deviations were identified,
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In addition to regional inspections, the integrated design
inspection team performed an evaluation of the design adequacy
of specific Seismic Category 1 components. Although minor
deficiencies concerning ball joints and pump qualifications
were identified, the licensee / Architect Engineer took prompt
corrective action in-resolving these concerns. Reviews of
safety-related component seismic and environmental qualifica-
tions were also performed and found to be well documented
and adequate.
Problems identified during the previous SALP assessment period
were adequately resolved by the licensee and not found to have
recurred during this assessment period. Licensee management
was aggressive in identifying and resolving deficiencies during
the assessment period. This was particularly evident by the
prompt reporting of vendor identified material / component dis-
crepancies and the high quality of the analysis and approach to
resolving these problems. The prompt and adequate resolution of
the TDI diesel engine concerns was another example of the licen-
see's high level of involvement and commitment to assuring a
quality plant.' Staffing in this area was ample and effective
in achieving well documented sound resolutions to identified
deficiencies.
2. Conclusion
The licensee is rated Category 1 in this area. The licensee
was rated a Category 2 during the last assessment period.
Licensee performance has remained essentially constant over
the course of the SALP assessment period.
3. Board Recommendations
None.
D. Electrical Power Supply and Distribution
1. Analysis
Portions of fourteen inspections were performed by region based
inspectors and the resident inspection staff of activities in
this functional area. These inspections included (1) examination
.of cable tray and conduit installations; (2) review of welding
processes; (3) examination of cable installation and termina-
tion;'(4) review of quality assurance implementing procedures;
(5) review of equipment and materials qualification; and. (6)
.
' review of. quality assurance documentation.
Also, due to problems with L. K. Comstock welding procedures
identified at another site, a comprehensive review of the
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control of welding ~ processes for electrical cable trays and
supports was performed. All welding procedures were reviewed
and approximately'300 welds were visually examined. 'The general ] ,
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workmanship of all welds appeared'to be acceptable.
Three-violations were' identified:
, (a) Severity Level,V - Inadequate' documentation of electrical
insoections (50-440/84007).
t (b); Severity Level..IV - Inadequate design-review and veri-
fication of safety-related schematic and wiring diagrams
(50-440/84007).
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- (c) Severity' Level IV - Programmatic violation with four
- examples of a failure ~to control the welding process'
(50-440/85043). '
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The first two violations were isolated and the-licensee took. 4
l prompt and effective corrective action to resolve the'defici- !
E encies. The licensee's corrective action on the third violation-
- will be reviewed'during a' subsequent. inspection prior to fuel
1- - load. This violation was not repetitive of violations-identi-
fied during the previous assessment period and the licensee
has initiated corrective action.
i Additionally, an Integrated Design Inspection was conducted
- - during the SALP. period. The IDI included an examination of.
licensee activities in design, design bases, design procedures,
records, and as-installed systems to determine whether regulatory
- - requirements and design bases specifiedein~the li. cense applica--
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, tion had' been correctly translated into 'as-built. design, correct -
i design.information had been provided to the responsible design
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. organizations, and sufficient technical' guidance to perform
- assigned engineering functions.and design controls equivalent to- ;
- original design processes was-available for design changes
including field changes. Issues identified by;the integrated
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design inspection were promptly. resolved to the satisfaction '
of the team inspectors with the exception'of!the' voltage drop
, issue'which resulted in'the initiation of seve'ral-construction
L deficiency reports pursuant to 10'CFR 50.55(e). The voltage
drop issue concerned long cable-length and the.effect of asso-
ciated equipment'during: degraded supply voltage conditions.
, --After.an extensive ~ eval.uation by theilicensee, components in-
j- three systems'were found to require wiring'modificationssto-
- preclude possible adverse.a'ffects'~on the' operation of certain
Region based ~ inspections confirmed,the pre L i
- plant equipment.
- existence of a program implemented by the licensee intended to
- Lidentify .these conditions l prior to reactor operation. Further
i' NRC;reviewlof these' construction deficiency reports are
required prior to fuel load. '
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In general the licensee and contractor staffs appeared to be
adequate during the SALP period in this functional area. -At
~the end of the appraisal period electrical installation activity '
was virtually complete.
]
2. Conclusion
The licensee is rated Category 2 in this area. This is the
same. rating as the previous assessment period. Licensee
i performance has generally improved over the course of the SALP
,
assessment period.
,
- _ 3. Board Recommendations
. 'None.
l E. Instrument and Control Systems
! l'. -Analysis;
- .~
Examination.of this functional' area included eight inspections
L 'by-reofonal based inspectors. The inspections included (1) the-
examination of the licensee's control of activities involving
4
installation of materials.and components including direct in' spec-
,
tion of in process and. completed work; (2) system walkdowns;
i. (3) examination of quality assurance records including equipment-
- qualification documentation; and (4) review of quality control
activities.
.In addition to the regional inspections, an Integrated Design
i. ' Inspection (IDI) was performed during this appraisal period.
The integrated design inspection examined (1) design control
'
procedures; (2) general and.' specific. design criteria; (3) func-
tional" system requirements;--(4) logic. diagrams; (5)~ piping and
instrument. system diagrams; (6)-instrument procurement specifica-
- .tionst and (7) instrument qualification reports. One weakness
- . identified during the IDI team inspection was the unavailability
l- of-calculations and supporting documentation for instrument' set -
point values. Instrument setpoint.value validation, following
the-General Electric-Instrument Setpoint Methodology,.isLa
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generic ~ problem at General Electric facilities and has been an
Longoing process which is currently being reviewed by the NRC.
- All issues raised by the' team were promptly resolved to the;
1- satisfaction'of the team members.-
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- No violations of.NRC: requirements or deviations from commitments
- . ' were identified in this functional. area. - In addition; procedural
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- weaknesses identified during the previous assessment period have
l' not recurred indicating'that the licensee's correctiva actions
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, were adequate and lasting... ,
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The licensee was found to have an adequate and well trained
staff in this assessment area. -Management involvement par-
ticularly in the prompt resolution of construction deficiencies
and IDI-findings has indicated an aggressive and high level
of performance with respect to construction of the plant and
. assuring quality.
2. Conclusions
The licensee is rated Category 1 in this functional area.
The licensee was rated a Category 2 during the last assess-
ment period. Licensee performance has remained essentially
constant over.the course of the SALP assessment period.
3. Board Recommendations
None.
F. Quality Programs and Administrative Controls Affecting Quality
'
1. Analysis
In this functional area, four inspections were conducted by
regional based personnel and portions of nine inspections were
conducted by the resident inspection staff during the assessment
period. These inspections were performed to determine the ade-
.quacy.of the written operational Quality Assurance Program in
the following areas: (1).preoperational testing; (2) audits;
~(3) QA/QC administration; (4) document control; (5) maintenance;
(6) design changes and modifications; (7) surveillance testing;
(8) procurement; (9) receipt, storage, and handling of equipment
and materials; (10) records; (11) test and measuring equipment;
(12) operating staff training; and (13) onsite review committee
activities,
c One violation was identified:
Severity Level V - Failure to perform procurement activi-
- ties in accordance with procedures and failure to-include
appropriate quantitative or qualitative acceptance criteria
in procurement procedures (50-440/85014).
- -This item did have some significance, in that commercial grade
hardware of-indeterminate quality could have been installed in
safety-related systems. The licensee's' proposed corrective
action on this-item involving procedural changes,-audits of'
vendors, and inspection and testing of comme'rcial grade hardware ,
should resolve this issue.
'
.The promptness and extent of licensee corrective action in
resolving NRC- open and unresolved items Lidentified prior to -
and during the assessment period, generally indicated appro -
priate management involvement. However, problems identified
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.in the'preoperational-testing assessment area (Section H)
were not adequately addressed when initially identified in
- that measures.taken to preclude recurrence were not adequate.
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This indicated a weakness _in the preoperational quality-
assurance implementation. '
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+ The written quality-programs were found to be well defined and
stated; however, it is too early to fully assess the implemen-
-tation of the QA program for operations. This functional ~ area
is well staffed by knowledgeable, dedicated personnel.
In addition to the regional inspections, an Integrated Design
?
Inspection (IDI) was performed during the appraisal period.
?
Activities included examination of (1) design bases; (2) design
. procedures; (3) records; and (4) systems as installed in the
_
i
r plant. Emphasis was placed on reviewing the-adequacy of-design-
{ details as a means of measuring how well the design process had
! functioned for the selected samples.
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Although no violations of NRC requirements were identified from
- the IDI, technical issues were found which' indicated a weakness
in the. licensee's management involvement and control in assuring
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quality design, particularly concerning the audit program. The
responsiveness of the licensee and Gilbert Associates Inc. in
taking broad corrective actions to address the problems identi-
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fied by the IDI reflects favorably upon the licensee's approach.
to resol.ution of technical issues from a safety standpoint.
-2. Conclusion-
The licensee is rated Category 2 in-this area. This is the same
rating as'in the previous assessment period. Licensee perfor-
i mance has generally remained constant over the course of the
j iSALP. assessment period.
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-3. Board Recommendations
The Board. recommends that I the licensee. review the adequacy of
its quality assurance and management systems to promptly
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identify and correct problems such as those found in the-
preoperational" testing assessment area.
G. Licensing Activities
1. Analysis
Evaluation of the licensee's performance for this rating period
involvedLthe areas of-(1)~ management involvement and control in
-assuring quality;-(2) licensee's approach.to the resolution of
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technical issues; (3) licensee's responsiveness ~to NRC initia-
tives; (4)' projected staffing in the emergency planning'and
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- licensing organizations; and (5) training of plant operators
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in-accordance'with the guidance in NRC Generic Letter 84-16. .i
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With respect to approach to resolving technical issues, the
licensee was found to be thoroughly competent and understanding
- ~o f technical issues to be resolved in obtaining an operating
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license. The performance of the technical staff was better.than- ,
2 average in addressing difficult open licensing issues, such as: l
' reliability of TDI diesel' engines; hydrogen control system.
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design; qualification of safety-related mechani_ cal and-elec-
- trical equipment; containment purge; suppression pool dynamic
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loads; and emergency plans. The results of_the licensee's
, resolution were documented in Supplemental Safety Evaluation
Report Nos. 4, 5 and 6 issued during the assessment period. The
licensee's technical competence was also quite evident and
{ instrumental ir.~the timely litigation of contention issues at
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the licensing board hearings in April and May 1985. Responsive-
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ness to NRC_ initiatives has~been most satisfactory in that-the
licens~ee is always ready to meet with the staff', often generating
. meetings themselves, to ensure a correct response to NRC needs.
! Examples of this were most evident'in the preparation of the
- NRC staff's equipment qualification files which resulted in a
relatively deficiency-freeiequipment qualification audit.
)' Assessments of the licensee's staffing and training were limited
, to plant operators' conformance with the guidelines of NRC
Generic Letter 84-16,-and the-licensing organization.~ Perfor-
mance.in these areas was-~found to'be acceptable. =However, '
F
contrary to past performance ~, the CEI licensing organization
missed several~ commitments in providing information required by
- the NRR staff for. completing their reviews. This occurred
1 during the.last three months of this assessment period. We
? believe that this1is attributable to.the increased ~ activities
, and often concurrent and-conflicting _ matters which can be
experienced when a plant is to receiv'e an operating license.
< While this has:not had a significant impact on the NRR staff's
-ability to support project schedules, failure to reverse this
condition could impact fuel load schedules.-. Additional =
, resources are needed to mitigate peaking workloads through
,
compl.etion of the Perry project.
t
. The primary weakness was found to be in the area.of management
control to ensure quality. While the licensee.has demonstrated
strong participation in. licensing ~ activities and is abreast of'
~
4 current and anticipated licensing actions, there has been some-
. inconsistency in~ documenting commitments to the NRC. This- -
'
Lincludes Regulatory Guides in the FSAR,-numerous _ deficiencies
.found during the;NRC ' Integrated Design Inspection, :and problems
with_the FSAR description of the preoperational test program.
The ' staff' believes that' errors- could have been avoided with'a
- ' ore vigorous control _by manageme t to assure quality of FSAR
m _
. commitments.
l
.
+
l _
, 14; , ,
. , .
-w,- V t T * *'e -
T '-* b& '-*v - y e 3w v r4< - ~ =hw mr-a F - ' + e rm e v-d m * 'e -
.
One Severity Level IV violation was issued as a result of a ,
motion,-dated ~ April 28, 1983, filed before the Atomic Safety 1
and Licensing Board concerning a material false statement that
had.been made in the licensee's application concerning the use
of herbicides to control vegetation along. transmission lines
(50-440/84006). The licensee's initial incomplete statement
.and its failure to correct the staff's use of the licensee's
statement in the Final Environmental Statement, did not have
significant regulatory impact. -This was considered to be an
isolated occurrence.
2. Conclusion
An overall Category.2 rating is assigned the licensee for this
rating period. Thi's is the same rating as the previous assess-
ment period. Licensee performance has generally declined during
the SALP assessment period.
3. Board Recommendations
The licensee should enhance its management control of the Perry
project to ensure quality in addressing licensing issues to
attain a higher performance rating. Assurance of appropric.te
resources in the licensing organization is also recommended
during the time remaining for licensing of the plant.
H. .P_reoperational Testing
1. Analysis
'
During this assessment period region based inspectors performed
five inspections and resident inspectors performed portions of
nine inspections in this functional area. The inspection effort
included (1) review of administrative controls and implementing
._
procedures; (2) detailed reviews of preoperational test proce-
dures and results; (3) preoperational test witnessing; (4)
independent inspection; and (5) followup 'of previous inspection
items.
Thirteen violations were identified as follows:
a. Severity Level IV - Failure to properly implement the
- test program by not properly ver.ifying instrument air
cleanliness specification:; (50-440/84015).
b. Severity Level V - Failure to properly implement juris-
dictional tagging controls in the installation of juris-
.dictional tags and dots on thirteen safety-related 480
volt motor control center compartments (50-440/84022).
15
.- - _ ._ _ _ _ _ - _ - - _ - _ - _
_
.
c. Severity Level IV - Test program not properly identified
and documented to facilitate tracking. The containment I
atmosphere monitoring system, motor control centers and
120, 240, and 480 distribution systems, seismic monitoring
system, and feedwater leakage control system were not
included on the preoperational test program " Software
Status Report"~as requiring preoperational tests
(50-440/84022).
d. Severity Level-IV - Preoperational test procedures
1821B-P001, " Automatic Depressurization System / Safety
Relief Valves",.and 1P57-P001, " Safety Related Instrument
Air System", were determined to be inadequate to properly
test system design requirements (50-440/85002).
e. Severity Level V - Failure to implement program require-
ments pertaining to Alarm Response Instructions (50-440/
85013).
f. Severity Level V - Failure to adhere to jurisdictional
program controls with regard to tagging for the hydrogen
recombiner system and emergency closed cooling water
system. In addition, jurisdictional controls were violated
when a recirculation flow control valve cable was discon-
nected without the knowledge of the_ Nuclear Test Section
(50-440/85013).
g. Severity Level IV - Failure to implement applicable regu-
latory requirements in preoperational test procedures
OM25/26-P001, " Control Room Heating, Ventilation and Air
Conditioning and Emergency Recirculation System", IM98-P001,
" Supplementary Charcoal and HEPA Filter Ef'iciency Test",
and generic test procedure GEN-M-016, " Test Balancing (Air)"
(50-440/85013). Further examples of this violation were
delineated in a subsequent inspection (50-440/85017) in
that test precedures 1833-P001, " Recirculation Flow Control
Valves", and 1E12-P001 " Residual Heat Removal System", were
also determined to be inadequate.
h. Severity' Level V - Administrative controls were inadequate
to control test performance sequence of testing (50-440/
85017).
i. Severity Level V - Required pre-test check list verifica-
tions were inadequately accomplished to ensure design-
changes were incorporated into test procedure 1E12-P001,
" Residual Heat Removal System" and to ensure that lifted
leads and jumpers had been reviewed for impact on testing
of procedure 1R43-P001, " Division I_ Standby Diesel
Generator",~(50-440/85017).
j. Severity Level IV - The Low Pressure Core Spray Sys'. . was
not operated in accordance with procedures (50-440/6.,a 7).
16
L
y ._
,
1
-k. Severity Level IV - Inadequate adsinistrative controls
.for. integrated run in testing activities-performed under
control of Temporary Operating Instructions. This-was
exemplified by two events which occurred under this type
of testing: (1).an inadvertent containment spray actua-
tion, and (2) exceeding the design. pressure of the Emer-
gency Service Water Heat Exchangers (50-440/85017).
1. Severity Level V - Failure to adhere to program. require-
ments for conducting annual evaluations to. determine
continued individual certifications (50-440/85029).
' m. Severity Level V - Preoperational~ test procedure 1M15-P001,
" Annulus Exhaust Gas Treatment System", was determined to-
be inadequate.in that it did.not include a section for
system restoration (50-440/85029).
These violations.can be' categorized into three general areas of
-(1) inadequate. administrative controls; (2)' failure to adhere to
program requirements'and controls; and (3) inadequate preopera-
tional test procedures. The identified violations encompass a-
wide range of program areas representing fundamental aspects of
the. test program and signify a serious concern pertaining to
overall program implementation'.
As a result of these problems,.a management meeting (Inspection
Report No,. 50-440/8f,036) was conducted'on June'3, 1985, to'
discuss the excessive number of violations, the. increasing rate
of violation _of regulatory requirements, the major concern of
inadequate procedures, misleading licensee statements / commit-
ments, inadequate or minimal corrective' actions, untimely
corrective actions, and non-responsiveness to NRC concerns. The
licensee has implemented aggressive corrective actions.to address
the concerns presented at the management meeting.' Corrective
actions include a detailed search ofzlicensing documentation to
identify commitments and their basis,La detailed re-review of
all preoperational test procedures and'other procedures affecting
test results, formalization'of-onsite verbal communication with
written followup, and restructuring test management to ens'ure-
timely'and thorough corrective action in response to NRC'
findings. An overview of this' corrective' action is included.in
Inspection Report ~No. 50-440/85036. The' effectiveness of.these.
actions will be evaluated during the next assessment period.
~
' Staffing including management'at the end of.the assessment-
- period appeared to be adequate. Training effectiveness:and
qualification:of test personnel was.the subject'of Violation 1-
and may have contributed to Violations f, j, and k. These areas
.are.also expected to be more closely examined'during the next'
assessment' period.
17
s..
r
- _
e
i
i
2. Conclusion
The licensee is rated Category 3-in this area due to the number
of violations, the majority of which were issued in the latter
half of the assessment period, and the wide range of fundamental !
program aspects t.hese violations represent which indicates a
basic weakness in the preoperational test program implementation.
The licensee was not rated in this area in the previous assess-
ment because no inspections were performed. Licensee perfor-
'mance has generally declined over the' course of the SALP assess-
ment period.
3. Board Recommendations
The. board recommends that the licensee continue the high level
of management attention developed as a result of the June 3,
1985, management meeting to ensure responsiveness to NRC
concerns and proper and continued implementation of corrective
measures pertaining to the test program. In consideration of
the rapid and intense testing schedule the licensee has
implemented, the current high level of NRC attention should be
maintained.
I. Radiological Controls
1. Analysis '
Five preoperational inspections of-this functional area by
regional specialists and portions of one inspection by the '
resident inspection staff were conducted during the assessment
period. The inspections covered (1) radiation protection; (2)
radiological environmental monitoring Program (REMP); (3) con-
firmatory measurements' programs; and (4) implementation of
radiological protection measures during initial fuel receipt.
No violations were identified.
Since the last assessment period, continued management attention
to the staffing and development of the radiation protection
program has resulted in significant progress-in program develop-
ment. Staffing of the health physics unit is nearly completed-
as is procedure development-and equipment readiness.' Health
physics unit personnel are adequately experienced and. trained.
Health physics related training programs have been developed
and implemented, and appear good. INP0 accreditation of train-
ing programs is being sought. The licensee has demonstrated a
willingness to correct identified problems and to perform
reviews necessary to determine and demonstrate compliance with-
requirements. -Adequate manpower is being~ utilized to perform
the necessary tasks and reviews.
18
o )
l
.
,
Office. space for health physics and chemistry personnel is tight.
Additional space is being made available by alteration of space
adjacent _to the health physics and chemistry facilities.
Organization,-training, an'd staffing of.the chemistry group
appear adequate to meet FSAR requirements'. Two supervisors
for the chemistry laboratories and counting room meet ANSI /ANS
3.1 qualifications. They-are supported by_two chemists with-
Bachelors' degrees and twelve technicians,~mostly with nuclear
navy experience. A satisfactory formal training program on
-chemistry and technical systems is underway along with on-the-
job qualifications in performing required analyses. This group
was augmented by;six new technicians.
Chemistry laboratories and equipment are adequate. Gross alpha
and gross beta _ counting capability ~in the counting room was
limited _but the licensee indicated that a_ backup counter used
by the radiation protection group would be available if needed.
Instruments were_being calibrated in accordance with procedures
and quality controls were being maintained on all counting
equipment. However,_ implementation of a'QC program to test
technician proficiency by..using blind or spiked samples, estab-
lished in May 1984, was. delayed until the second quarter of
1985 and will be reviewed subsequent to the assessment period.
-
The licensee has demonstrated capability at performing satis-
factory analyses of radiological samples. Twelve agreements
in-twelve confirmatory measurement comparisons on spiked air
particulates and charcoal filters, and five. agreements in five
comparisons for tritium,. strontium, and gamma emitters on a
spiked liquid sample were achi.eved by the licensee.
~
Licensee implementation of the pre-operational radiological
environmental monitoring program (REMP) has generally been
adequate. Responsibility for.. implementation.and review are
defined in licensee procedures and audits are being perfotaed
of the REMP contractor. Sampling procedures ~ exist in draft
form and were awaiting final management approval. A replacement
REMP contractor was engaged when the original contractor
discontinued providing laboratory analytical-services in
August 1984. The.riew contractor,' Applied Sciencs Laboratory
(ASL), had submitted QA plans and procedures to meet Regulatory
-Guide-4.15 in response to_a licensee pre-acceptance audit. A
followup audit was performed in March 1985 to close out' audit-
findings prior to putting' ASL on the approved vendors list.
~
, .
2. Conclusion
The; licensee is rated Category 2 in this area. This~is the
_
,
- same rating as-the previous' assessment period. ' Licensee per-
formance has generally improved' aver.the course of the'SALP~
assessment. period. ,
i
(191
E
.
3. Board Recommendations
None.
J. ' Fire Protection
1. Analysis
During this assessment ~ period, one inspection by Region III I
based inspectors and their consultants was performed to deter- l
mine the licensee's progress in implementing the applicable I
requirements of 10 CFR 50, Appendix R, and their fire protection
pre-operational test program and a review of allegations received
by the NRC relative to fire barrier seals. In addition, the
resident inspector reviewed preparations for department fire
brigade training including the training program and equipment
to be used which was generally found to be acceptable. No vio-
lations were identified.
Based on the regional inspection, it was determined that the
licensee was making satisfactory progress in implementing the
applicable sections of 10 CFR 50, Appendix R, and the fire
protection pre-operational test program. Licensee management
was involved in fire protection, and adequate staffing including
a fire protection engineer, was assigned. Numerous items remain
to be completed. Items to be completed include installation of
certain fire barriers, installation of automatic sprinklers in
areas containing safe shutdown equipment; rerouting of cables
and instruments to achieve twenty feet of separation between
redundant components; installation of penetration seals,
installation of emergency lighting; verification that fire
dampers function properly, verification that certain gypsum
board wall designs, which deviate from SER descriptions, will
withstand postulated fire exposures; verification of fire alarm
system design and installation, and verification that all
required fire door _ assemblies are labeled, listed, or tested
in accordance with NFPA 252.
Three allegations were reviewed relative to penetration seals.
They were closed based on supporting test data and the technical
adequacy of procedures.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
was not rated in this category during the previous assess-
ment period. . A performance trend is not assessed during this
evaluation due to the limited inspection performed.
3. Board Recommendations
None.
>
20
l
. . _ . . - - . _ _ . . . . _. _ _ _ . _ _ _
,
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' '
. .
f
!
'
1. Analysis '
, Three-inspections were conducted during the assessment period
- by region based inspectors to evaluate the licensee's perfor-
3
'mance with regard to emergency preparedness. These included
e (1) a-pre-emergency preparedness implementation appraisal
ll to assess the applicant's progress in emergency preparedness
[ activities; (2) observation of the applicant's first full-scale
j' emergency exercise; and (3) a two-week in-depth examination of
the licensee's entire emergency preparedness implementation
appraisal-(EPIA).
Although no violations or deviations were identified during
'
, the SALP period,-seven weaknesses were identified during the
,
exercise and 25 incomplete items were identified during the:
EPIA. Many of the items identified were the result of
.
. incomplete construction activities, and not a failure.to
4 raddress items due to'an oversite or lack of knowledge of
! regulatory requirements. For all.of these items the licensee ;
has been responsive to NRC concerns by providing viable and
~
!
'
- generally sound and thorough responses in a-timely manner.
The seven weaknesses were corrected.and from a safety ,
- . standpoint,ithe licensee has demonstrated a clear
- understanding of the issues involved.
i.
i Management involvement in emergency preparedness has been very
strong as evidenced by their participation in the exit meetings
i following each inspection. One NRC concern identified during
- the EPIA involved the. licensee's ability to maintain an accept-
! able level,of emergency preparedness based on the existing
organizational structure and assigned' duties and responsibilities
! of emergency preparedness personnel and their associated review.
. These concerns were quickly and adequately addressed through a
j reorganization that changed the chain of management review and
- responsibility for emergency preparedness activities'.
i - Staffing of key emergency response positions has been adequate
with the authorities and responsibilities of personnel identi-
fied. . An.in-depth review of the: licensee's emergency' prepared-
ness training ~ program was conducted during the EPIA and.it was
,
determined to be a well defined program that provided an adequate
level'of material-and understanding to the staff. In addition,
i the NRC conducted extensive walkthroughs with plant personnel to
- test their knowledge and understanding in the area of emergency'
,
response. -Overall,.it was determined-that personnel were well
.
trained'and, knowledgeable of their emergency response. duties and
- . responsibilities. ~This was also supported by a good demonstra-
'
. tion of the licensee's capabilities during the emergency
-exercise. .
l.
!:
-
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'
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e ? M - N 5'eiW 'i,,.4'- ?r cer- (% e @- -- -
J? '4' e P g --MMe **Wy- g ---++"stTt 7aw w= -NE'*Pbe * *W M$" )
. _. ,
.
2. Conclusion-
The licensee is rated Category 1 in this area. The licensee
was not rated in this category in the last SALP period. The
licensee's performance.during the assessment period has remained
essentially constant.
3. -Board Recommendations I
None.
l
L. Security
1. Analysis
, Three safeguards inspections by regional based specialists and
one inspection by.the resident inspection staff were conducted
during the assessment period. The inspections addressed
1 (1) security measures for onsite receipt and protection of new
fuel; (2) observation of fuel receipt activities; (3) material
control and accountability requirements for stored fuel; and
(4) preoperational inspections to determine the licensee's
progress in the implementation of the security program.
The licensee's Physical Security Plan, Safeguards Contingency
Plan, and Training and Qualification Plan become effective upon
, issuance of an operating license. Therefore, no violations
were cited during the preoperational security inspections.
Additionally, no violations were identified during the new fuel
receipt, storage, and material control and accountability
, inspections. During the preoperational security inspection,
numerous items were identified which must be corrected or
resolved before issuance of an operating license. The licensee
has been very responsive to the concerns identified by the NRC.
-The security. force appears to be of sufficient size, supervision
and administrative support appears adequate, and the licensee is
aware of all major elements necessary to implement the security
program. . The senior security personnel represent broad technical
disciplines, have a high degree of expertise, and have been
effective in identifying problem areas and recommending solutions.
Adherence to the current' security program implementation
schedule is essential so full implementation of the program
can be initiated so as not to impact the licensee prior to
licensing. The necessary resources are available to ensure
and assist in the implementation of the security program.
Essential security equipment acceptance testing by the licensee
is scheduled to be completed early during the next assessment
period. Although notable. progress has been made,.the implemen-
tation and completion of the security system will require a
22
. . -
.
' major effort and the licensee's current completion schedule
appears optimistic. The licensee indicated that the necessary
resources will be available with continuous management overview
to assure schedule completion.
Due to a lack of security experience in the licensee's Quality
Assurance staff, the licensee is having experienced represen-
tatives of another utility conduct a comprehensive audit of
the security program prior to licensing. The licensee's QA
department needs to gain experience in the security audit area
so they can effectively audit and identify program deficiencies
to meet regulatory requirements.
In summary, the. licensee's staff has been effective in planning
for implementation of the security program and in identifying
problem areas during implementation of the program. Senior
site management personnel appear willing to commit the necessary
resources to ensure timely implementation as indicated by the
upgrading and expansion of the access facility. The licensee
management's ability to resolve identified problems and imple-
ment major. elements of the security program, such as personnel
screening, badging, and integration of the computerized security
program will extend into the next assessment period.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
was not rated.in this area during the previous assessment
period. Licensee performance has generally improved over the
course of the SALP assessment period.
3. Board Recommendations ,
None.
M. Operational Readiness
1. Analysis
During this assessment. period, the resident inspection staff
performed portions of nine inspections to assess the licensee's
readiness for operation. The inspectors followed program and
procedure development and implementation for operational
related activities. This' analysis extends beyond the assess-
ment period to the date that the Board convened, August 15, 1985.
'
Three violations were identified in the operations area which
do not pertain to a specific rated functional area:
23
.
a. Severity level V - The licensee failed to properly imple-
ment the administrative program controlling temporary
mechanical alterations to equipment (440/84009).
b. Severity level IV - The licensee failed to properly
establish and implement housekeeping and equipment
cleanliness controls to ensure prevention of equipment
degradation (440/85010).
c. Severity level V - The licensee failed to properly
document foreign material control in the reactor vessel
and reactor well area (440/85033).
The last two items are repetitive in nature in that they address
implementation of equipment protection measures and reflect poor
facility housekeeping conditions. Since those violations were
identified, the licensee has taken effective action to ensure
housekeeping prntices are appropriate and equipment integrity
is not compromised, including additional staffing, supervision,
and implementation of the " call for cleanup" program.
At the beginning of the assessment period, Unit 1 construction
was 92 percent complete, 52 percent of all Unit 1 required
systems were turned over for preoperational or acceptance
testing, 11 percent of all tests had been field completed and
fifteen percent of all Unit I required systems were turned over
.to operations. At that time, the Nuclear Test Section (NTS)
reported to the Manager, Nuclear Construction Department, and
all operations functions reported to the Manager, Perry Plant
Department.
In April 1984, the Superintendent of Operati.ons, Perry Plant
Department, was temporarily detailed to the Nuclear Operations
Division (N0D) and reported directly to the Vice President, N0D.
The Neclear Test Section was transferred from construction to
operations under the Superintendent of Operations. This was
considered by Region III to be a positive move with the
beginning of the transition from construction to operations.
In October 1984, the Perry Plant Department was split into' the
Perry Plant Operations Department (PP00), containing the opera-
tions, maintenance, outage planning and nuclear test sections,
and the Perry Plant Technical Department (PPTD), containing the
technical, health physics, training, sesrity, and the adminis-
trative unit. The managers of those departments report to the
Vice President, N00. This move strengthened the alignment
between test and operations activities, but fragmented these
activities into two separate departments under separate managers
who' report to an executive. The technical supervision and
management in PPTD has very little actual applicable operating
nuclear plant experience. Also reportir.g to that executive
24
L'
.. .- - . . ~ . - - . - - - . - - -.- -- . - - . - .-
r .
- ..
- -
i
,
is the Nuclear Engineering Department which provides licensing, '
- modification design, and engineering review support to the Perry
4
Plant: Departments. These three departments and the Vice
l President, N00,-are onsite.and will remain onsite following ;
[ Unit 1 licensing.
E At the end of the assessment period, fuel-load was predicted to
, be September 27, 1985. This completion schedule was optimistic.
Unit 1 construction was essentially complete with no systems
.under construction jurisdiction. Approximately 62 percent of.
2
the preoperationalitests and 93 percent of the acceptance tests-
were field complete-and 61 percent of all systems were turned
j. over for operations. .
1
i During the assessment period, the licensee undertook several
-major activities to prepare for operation:
[ The licensee obtained sufficient operating experience
!- through experience and training.at other BWR operating ,
- plants for individual shift members to enable plant
l licensing and startup without dependence on contract
experienced shift personnel.
The licensee successfully licensed 24 personnel as reactor
- operators.or senior reactor operators. This.is sufficient
i ~for five fully. qualified and certified rotating shifts.
i. . The licensee: expects sufficient reactor licenses during
i
December 1985: examinations to staff a sixth shift. The
i licensee examination pass rate-to date has;been'approxi-
mately 68%, which is below the industry average of approxi-
.mately 74%. The licensee is undertaking efforts to improve
the pass rate for the December 1985 examinations.
~
!
- The licensee implemented access control to the control room
i complex limiting persons not' required for plant operating
- and testing activities, and moved all non-operations per-
l sonnel-out ofJthe control room. The licensee-also imple- ;
i mented strict access control to the control room " horseshoe" '
,
-area requiring operator approval for entry.
!
} The' licensee prepared ~ facility technical specifications
F which are scheduled to be issued in final draft on August
! 30,~1985. The technical specifications, with few excep-
tions, have been. complete and accurate.
-
. The licensee completed an FSAR verification program on-
l." -July 19,:1985, with FSAR Amendment No. 20,.to ensure that
adequate.; basis exists for statements in the FSAR. :This
-
was a Perry-unique activity which was 'self initiated.
'
[
c
$ ;
i I
- ~
25:
j
,
n ,
-
- -
_ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
.
4
The licensee has a continuing effort to complete the opera-
tions procedures of which 68 percent of the procedures have
been finalized. The NRC procedures inspection effort in
this area was underway when the licensee initiated a
reanalysis of their licensing commitments in the operations
area to ensure that their procedures addressed all appli-
cable commitments and requirements. This effort was preci-
pitated from the procedural difficulties encountered in the
i preoperational testing area and minor preliminary inspection
findings regarding operations procedures.
The licensee is " dry running" mechanical and instrument and
control system surveillance test instructions and revising
them as necessary. Following an NRC management meeting on
June 3, 1985, the licensee has increased the use of system
operating instructions during test activities to ensure
procedure accuracy. Maintenance and instrument calibration
is performed routinely using the operations program from
the time each system is turned over to the test section.
The licensee has been preparing packages addressing each
inspection finding, generic notification, and construction
deficiency report. With very few exceptions, these
packages have been comprehensive and technically adequate.
At the end of the assessment period the licensee had underway
development and implementation of all major programmatic
aspects necessary for operation of the unit. Management was
properly focusing efforts to achieve operational readiness.-
2. :onclusion
The licensee is rated Category 2 in this area. The licensee
was not rated in this category during the previous assessment
period. The level of activity has increased during the assess-
i
ment period, and licensee performance has remained essentially I
constant over the SALP assessment period.
3. Board Recommendations
The licensee should consider taking steps to bolster the commer-
cial nuclear power plant experience level of the technical
department supervision and management.
26
_- _ _ _ _ _ _ _ _ _ _ - _ __ _ _ _ _ . _ _ .-
.
3 1 ,
..
,
V. SUPPORTING DATA AND SUMARIES
-
A. ' Licensee Activities
- The' construction of Perry Unit 1 at the close of this assessment
period was essentially 100% complete. . Major activities performed
E during the assessment period were related to the completion ~of
. construction, construction test (initial checkout and run test),
operator training, completion of Reactor Vessel Internals
installation, receipt of fuel, preoperational and acceptance testing,
system' turnovers, and completion of licensing board hearings.
Specific' activities are listed below.
Date. Selected Perry Milestones / Activities
Jan. 17-19, 1984 NRR Site Audit of Environmental
. Qualification of Electrical. Equipment
February 1,1984 ~Vice President of Nuclear Operations
? Division established to direct Perry Plant
. Department (PPD), Nuclear Engineering
Department-(NED), and Nuclear Training
Section
February 17 1984 Perry Supplemental Safety Evaluation Report
(SSER) No. 4 Issued
March 1984 . Resolution of ASLB;Iss'ue:No. 9 Polymer
Degradation
March 8, 1984 Operational Quality Assurance (0QA) Plan
Approved by NRC
May 26, 1984 Start Nuclear Steam Supply System (NSSS)
Flushing'
'
June 12, 1984 .First Safety Related System turned over
to Operations (Emergency-Service Water
Screen Wash System)
-June'26, 1984 " Call for Quality" instituted to address
allegations.
'
July 19, 1984 - National, Board of Boiler and Pressure-
Vessel Inspectors: issued NR: Certificate
' July 27, 1984 Initial Draft Perry. Technical. Specifications
submitted
July 29, 1984 _ National ~ Board cf Boiler and Pressure
-
Vessel Inspectors issued R Certificate
27
- , <
.
July 30, 1984 Consolidation of test procedures into Test
Program Manual
August, 1984 - Conducted the NRC Integrated Design
October, 1984 Inspection (IDI)
August 14-17, 1984 NRR Site Audit of Seismic Qualification and
Pump Valve Operability
August 31, 1984 Completed Reactor Vessel Construction
September 11, 1984 Completed NSSS Flushing
September 17, 1984 Completed Integrated Flush and Outflush
September 26, 1984 Completed Reactor Pressure Vessel Hydro
October 1, 1984 Reorganization of PPD into Perry Plant
Operation Department and Perry Plant
Technical Department under Vice President -
Nuclear Operations Division
October 6, 1984 ASLB Issue No. 6, Anticipated Transient
Without Scram (ATWS)/ Standby Liquid Control
' System (SLCS), dismissed
November, 1984 Initial Nuclear Safety Review Committee
(NSRC) Meeting held
November 3, 1984 Completed Reactor Vessel Internals to
support Control Rod Drive System Preopera-
tional Test
November 28, 1984 Completed Reactor Recirculation System
Construction
November 28, 1984 Conducted NRC/ FEMA Emergency Plan Evaluation
Exercise
December 2, 1984 Initial Control Rod Motion test completed
February 2, 1985 Established Independent Safety Engineering
Group
February 21, 1985 Steam Bypass and Electrical Hydraulic
Control (EHC) Systems operational
February 26, 1985 Perry SSER No. 5 issued
February 27, 1985 ASLB Issue No. 14, In-Core Thermo Couples,
dismissed
28
L _ _ _____
.
March 7, 1985 NRC Appraisal of the PNPP Onsite Emergency
Preparedness Program l
March 7, 1985 NRC Special Nuclear Material (SNM) License
issued
March 10-22, 1985 RIII/NRR Appendix R Audit
March 12, 1985 Completed Diesel Generator (D/G) Division I
and II Revalidation, Flush, Rework, and
Restoration
March 13, 1985 ASLB Issue No. 15, Steam Erosion, dismissed
March 15, 1985 Completed Condenser Vacuum Pull
March 15, 1985 Security Building turned over to Operations
March 17, 1985 Arrival of first shipment of fuel
May 13-17, 1985 NRC First Preoperational Security Inspection
April 3, 1985 PNPP Mechanical Equipment Qualification
Program submitted
April 8, 1985 Proof and Review copy of Perry 1 Technical
Specifications issued
April 9-12, 1985 NRR Detailed Control Room Design Review
Implementation Audit (DCRDR)
April 10, 1985 Hearing on Issue No. 16, Diesel Generator
Reliability, completed
April 12, 1985 Hearing on Issue No. 1, Emergency Planning,
completed
April 19, 1985 Perry SSER No. 6 issued
April 23-25, 1985 NRR Instrumentation and Control Systems
Branch Design and Verification Audit
April 27, 1985 Completed Re' circulation System Slow Speed
Preoperational Test
April 30, 1985 Completed Control Room HVAC Testing
May 3, 1985 Hearing on Issue No. 8, Hydrogen Control,
completed
June 5, 1985 Completed D/G Division I, II, and III
Preoperational Test
29
.
June 7, 1985 Completed Closure of IDI Findings ;
l
June 12, 1985 Completed Reactor Recirculation Fast Speed l
Tests
June 13, 1985 All Systems turned over to Test Section
June 21, 1985 Completed Fuel Receipt
June 30, 1985 24 NRC Licensed PNPP Personnel (22 Operators)
B. Inspection Activities
1. Inspection Data
Facility Name: Perry Nuclear Docket No. 50-440
Power Plant
Unit 1
Inspections: No. 50-440/84001 through 50-440/84013,
50-440/84015 through 50-440/84018, 50-440/84020 through
50-440/84024, 50-440/84026 through 50-440/84030, 50-440/85001
through 50-440/85003, 50-440/85006 through 50-440/85015,
50-440/85017 through 50-440/85020, 50-440/85022 through
50-440/85024, 50-440/85026, 50-440/85028 through 50-440/85030,
50-440/85032, 50-440/85033*, 50-440/85035 through 50-440/85045,
and 50-440/85046*.
- Inspections performed subsequent to this assessment period,
but included in the assessment.
Violations and Severity Levels
Functional Areas Assessed I II III IV V
A. Containment and Other
Safety-Related Structures 1
B. Piping Systems and Supports
C. Safety-Related Components
D. Electrical Power Supply and
Distribution 2 1
E. Instrumentation and Control
Systems
F. Quality Programs and
Administrative Controls
Affecting Quality 1 )
'
G. Licensing Activities 1
l
1
l
30
L
'
.
.
Violations and Severity Levels
Functional Areas Assessed I II III. IV V
H. Preoperational Testing 6 7
I. Radiological Controls
,
J. Fire Protection
L. Security
M. Operational Readiness 1 2
11 11
2. Inspection Summary
Fifty eight inspections were performed at Perry during the
assessment period, two subsequent to the assessment period,
and five NRR audits. Team inspections included'the integrated
design inspection, fire protection, emergency preparedness,
environmental qualification of electrical equipment audit,
seismic qualification and pump valve operability audit,
security, control room design review implementation audit, and
Instrumentation and Control Systems Branch design and verifica-
tion audit. Portions of the inspection effort were dedicated
to allegation inspections.
C. Investigations and Allegations Review
A formal investigation involving potential wrongdoing, was initiated
during the assessment period and should be completed in the next
assessment period. . Thirteen allegations concerning Perry and relating
to deficient construction and. Quality Assurance practices were also
received by the NRC during the assessment period. Region III has
inspected, dispositioned, and documented 10 of the thirteen allega-
tions. No violations were identified. The inspection of the
remaining three allegations had not been completed by the end of the
assessment period.
The licensee has a program called " Call for Quality" which provides
personnel at the plant a means to contact CEI Quality Control with
plant. safety or quality concerns. In addition, the licensee performs
mandatory. interviews with all quality control personnel'and all CEI
personnel that are departing the plant. .These interviews are
reportedly designed to give the departing employee the opportunity
to state any concerns they may have regarding the plant. Concerns
.are investigated by the CEI QA organization and results relayed to
the departing employee. Feedback from the departing employee is
encouraged and' followup.on feedback initiated-if deemed necessary.
Results of the investigation's are available to the NRC.
'
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. s
D. Escalated Enforcement Action-
There were no escalated enforcement actions during this assessment
period.-
E. Management Conferences
Thefollowingmanagementmeetingswerecon'dUctedduringthisperiod:
April 10, 1984
.
A management meeting to present and
~
discuss the results of the SALP 4
evaluation.
October 30, 1984 The "Second Corporate Management
Meeting" was~ held by Region III at
Perry to discuss with licensee
management their preoperational test '
program and lessons learned from
preoperational tests at other plants.
March 21, 1985 A management meeting was held to dis-
cuss matters relating to Perry schedule
and performance. The meeting was
requested by CEI.
June 3, 1985 A management meeting was. held to discuss
the status and recent inspection-findings
of the Perry Preoperational Test Pro- '
'
gram, including failure to properly
implement the Test' Program.
F. ' Licensee Report Data
Construction Deficiency Reports (CDRs)
During this SALP period, seventy 10'CFR 50.55(e) items were reported
-by the licensee. Eighteen were vendor related.~Of the' seventy
- reported, seventeen were . subsequently withdrawn prior to the end of
the thirty day reporting period. -Corrective-actions were initiated
by the licensee on the remaining 53 reportable; items and'all but 22'
were reviewed and documented as closed in Region III inspection -
reports. Below is a list of the fifty-three 50.55(e) items:
. Licensee's ..
-DAR No. .' Description'
153 Borg Warner MOV shaft keys too long
154 ASME' Class 1, 2 and 3. material installed on
ASME Class 1 piping supports
155' Pullman (site contractor) accepted materials
that were not manufactured to NA-3700
.
32 -
W-____--__-___- . __-__ - __ = __-_ _ _ _ _ ___ = _ _ _ _ _ _ _ _ _ _ _
_
.
Licensee's
DAR No. Description l
156 Problems with Diesel Generator flexible coupling
drive hubs !
158 Surface cracks found on actuator mounting
brackets for 24 motor operated exhaust louvers
associated with diesel room HVAC system
159 Pacific Air Products Part 21 - Linear converters
may wear excessively (HVAC)
160 Disagreement between logic and FSAR drawing for
the Standby Diesel Generator
161 Problems with synchronizing the standby diesel
generator from the diesel generator room
162 HPCS System - No power monitor downstream of the
fuses that supply some control relays
163 HPCS System - MOV E-22-F001 shuts before
E-22-F015 is fully open, which could result in
less than specified flow
164 HPCS System - Suppression pool cleanup suction
does not isolate between reactor levels 1 and 2
which could result in less than specified flow
171 ASME Code Class I pipe tees were found to have
discontinuity in thickness
172 HPCS power supply - drawings do not indicate
FSAR required logic for switch S-26
175 Transamerica Delaval Part 21 potential problem
with 2 spare piston skirt castings
178 Licensee discovered that failure of a K-70 relay
contact could result in both the inboard and
outboard Main Steam Isolation Valves not closing
182 . Inadequate weld documentation and questionable
welds on equipment hatch of drywell
183 During loss of critical 120 VAC and 24 VDC
systems, the systems would not annunciate in the
control room
185 MCC units 1 and 2 R4250015 were found missing 12
rear bracing panels rendering the seismic
qualification of the MCCs indeterminate
33
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,
.
Licensee's
DAR No. Description
186 Brown Boveri Part 21 - 480 voit circuit on R23
system may contain silicon controlled rectifiers
which exhibit excessive leakage that would
result in false circuit breaker trips
189 Incorrect electrical design, which if it had gone
uncorrected, would not have allowed the diesel
generators to synchronize to the grid in certain
switch positions
190 Johnson Controls 3/4" socket welds were found to
have improper welds
194 Lack of leakage acceptance criteria in fuel pool
gate testing specification
197 Emergency service water pump will start with
either LOCA or loss of offsite power signal but
not both
200 Carrier fans for the control complex auxiliary
building vent system may have error in seismic
report due to the use of wrong natural frequency
data
201 Conex Part 21 concerning 821 defective power
lead gland sealing assemblies at Perry Units 1
and 2
202 Rosemount Part 21 - Rosemount transmitters Model
1153 Series B have a potential environmental
leakage into transmitters which could result in
an electrical failure
203 Delaval Standby Diesel Generators could have
field resistors overheat during coastdown
204 FSAR design evaluation revealed that a
non-safety related moisture detector was used in
the HVAC for the control complex
209 Incorrectly installed Hilti drop in anchors by
fire protection system contractor
34
_
.
Licensee's
DAR No. Description
211 General Electric Part 21 - Class 1E inverters
were not supplied with proper low voltage cutoff
adjustment.
212 Containment isolation valves stick closed when
they should be wide open
~213 Borg Warner Part 21 - 20" Class 1 gate. valve
would not fully open due to gate binding on body
mounted guide rails
216 Gilbert Part 21 - Jet impingement design for
~feedwater system was nonconservative
218 Overpressurization of some isolated pipe systems
during a LOCA inside drywell
220 Two locations were found where condensate can
collect in the RCIC steam supply line and
potentially disable the system
221 Ruskin Part 21 - Concerning fire dampers
supplied to Perry that are unable to function
properly under normal duct pressure er operating
conditions
222 Concerns starting voltage drops in the power.
feeder cables for motor operated valves
associated with the RCIC system
223 Concerns voltage drops in control circuits (M32
system) that may be large enough to result in
the loss of Division I and II pump ventilation
fans-
224 The voltage drops in some P45 power and control
circuits may cause loss of. Division I, II'and
III emergency-service water pumps and/or
discharge valves
225 Delaval Part 21 - Filter on'TDI diesels not
rated for pressure ~used in service
,
35'
_.
,_ _
e
Licensee's
DAR No. Description
226 Perry may not be in compliance with Appendix R
due to lack of adequate separation of associated
Division I and II circuitry,
230 A review of the 4160 and 480 volt power systems
indicated that a LOCA in combination with a
degraded off-site power supply condition could
result in a loss of starting voltage to motors
232 Brown Boveri Part 21 - Concerns ,480 volt circuit
breakers that may have damaged control wire
insulation
234 Gilbert Part 21 - Design error where the floor
response spectra was not considered'during the
design of the diesel generator building-
238 Tubing clamps made_by Basic Engineering do not
provide enough seismic restraint to meet
specification
239 Gilbert Part 21 - Potential flooding of the
turbine building due to design problem of under
drain system I.in the-turbine building
240 Licensee unable to identify the seismic
qualification of the emergency service water
backwash strainers
241 Potential excess off-site releases due to single
isolation valve between post accident sample
system and primary containment
242 Brown Boveri Part 21 - Low voltage (480V) K-line
circuit breakers potentially have incorrect
'short time delay band levers installed in
electro-mechanical overcurrent trip devices
243 During a review of as-built seismic support
spacing criteria for instrument and control
piping, the AE noted that spacing criteria had
not always been properly interpreted by the
installation contractor
36
_
'
c
Licensee's
OAR No. Description
244 Level detector transmitter output had an error
band above that allowed by G.E. specification
for the standby liquid control system tank
245 Incorrect logic for the vacuum relief valves
between containment and the suppression pool
246 Approximately fifty components and five motor
operated valves may have inadequate voltages
under certain conditions such as degraded grid
voltage
The number of CDRs identified during the assessment period was
approximately 250% of of the number identified during the previou's
SALP period. This rise was in part a result of the IDI and licensee
initiated pre-IDI review of Perry's design. Increased activities in
the preoperational testing area.have also resulted in increased
identification of construction deficiencies. A review of the nature
and details of the items reported and the timeliness of the reporting
indicates that the licensee maintains a proper reporting threshold
and is responsive to the 10 CFR 50.55(e) reporting requirements. The
quality of the written reports and associated analysis and relative
ease with which Region III staff have been able to review and close
these construction Deficiency Reports reflects favorably on the
licensee's management and staff.
37
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