ML20203D824

Insp Rept 50-440/97-21 on 971202-980127.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20203D824
Person / Time
Site:	Perry
Issue date:	02/20/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203D810	List: ML20203D806 ML20203D821 ML20203D824
References
50-440-97-21, NUDOCS 9802260157
Download: ML20203D824 (14)

See also: IR 05000440/1997021

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U. S. NUCLEAR REGULATORY COMMISSION l

REGION lil

Docket No: 50-440

License No: NPF 58

Report No- 50-440/97021(DRP)

Licensee: Centerior Service Company

Facility: Perry Nuclear Power Plant

Location: P. O. Box 97 200

Perry, OH 44edi

Dates: December 2,1997, to January 27,1998

Inspectors: D. Kosloff, Senior Resident laspector (SRI)

J. Clark, Resident inspector (RI)

S, Campbell, SRI, Davis-Besse

K. Zellers, RI, Davis Besse

Approved by: Thomas J. Kozak, Chief

Reactor Projects Branch 4

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PDR ADOCK 05000440

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EXECUTIVE SUMMARY

Perry Nuclear Power Plant

NRC inspection Report No. 50-440/97021(DRP)

This inspection included a review of tespects 9l licensee operations, maintenance, engineering,

and plant support. The report covers aneight week period of resident inspection. Three

violations of NRC requirements were identified.

Operations

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The conduct of operations was generally effective and professional. Communications I

among operators and within the operations department were not as effective as had been

observed during previous inspection periods (Section 01.1).

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Good preparations for activities associated wah unusual plant conditions and the

relatively good material condition of the plant, notwithstanding the electro-hydraulic

control system and off gas cooling syt. tem problems, led to effective operator responses

to the automatic reactor scram and the chemical spill during this inspection period

(Section 01,3).

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The inspectors concluded that the guidelines and expectations for the change in the

equipment tagging policy were not initially clearly communicated to the operators which

resulted in some degraded equipment not being tagged as expected by operations

management (Section O2.1).

Maintenance

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Effective preparations led to the completion of a number of maintenance activities during

an unanticipated two day reactor shutdown which resulted in the resolution of several

outstanding material condition deficiencies. Effective planning and work execution led to

a relatively low corrective and preventative maintenance item backlog (Section M7,1).

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The licensee inadvertently allowed the degradation of required raceway markings over

time to the extent that some were either i!!egible or missing, which was a violation of NRC -

requirements (Section M7.2).

Enaineerina

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Aninadequate evaluation of a design change to the electro-hydraulic control system

contributed to an automatic scram (Section E2.2).

Plant Support

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Actions to verify fire doors were closed on a daily basis were generally effective.

However, the licensee failed to recognize that a floor sealant applied in the EDG rooms

introduced the possibility for fire doors to stick open, which resulted in a violation of NRC

requirements when a fire door was identified by an inspector to be stuck open

(Section P1.1).

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.+ Combustible materials were generally well controlled,- However, the inspectors identified

a violation involving the placement of excess combustible material in ars ESW pump

house combustible free zone (Section P1.2).

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Report Details

Symmary of Plant 'Jiatus

The unit continued full power operation from the beginning of the report period until an automatic j

scram occurred due to an EHC leak and turbine trip on December 18,1997. Recovery from the

scram was completed on December 21,1997. Full power operation continued throughout the

remainder of the period, with the exception of normal power reductions for periodic valve testing

and control rod manipulations,

l. Operations

01 Conduct of Operations

01.1 General Comments

The inspectors observed numerous pre-job briefings, shift turnover briefings, and

operations activities that had been discussed at pre-job briefings. The inspectors

observed the response to an automatic scram, and the subsequent recovery and plant

startup activities. The inspectors also monitored the actions associated with the

emergency response to a trichloroethylene leak. While the conduct of operations was

generally effective and professional, communications among operators and within the

operations department were not as effective as had been observed during previous

inspection periods, Specific observations and conclusions are listed in the following

sections.

01.2 Communications

a. Inspection Scope (71707)

The inspectors conducted several periods of continuous control room observation to

f assess command and control activities, and operator communications.

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b. Observations and Findinos

The inspectors obsented that three-way communications and repeat back

communications for alarm responses were not consistently or effectively utilized by some

operating crews, and some crew members, near the end of December. This was in

contrast to the excellent communications and alarm response detailed in several

preceding inspection reports. Specific observations were discussed with operations

management. Subsequent briefings and training was conducted by operations

management with their operating cmws. No further lapses in communications were

noted for the remainder of the inspection period.

c. Conclusions

The inspectors concluded that a lack of formality during the conduct of operations by

certain crews resulted in their failure to use effective communication techniques such as

three legged communications and repeat back of alarm acknowledgments in the middle

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of this inspection period. Operations management responded quickly and effectively to

correct this failure to meet management expectations.

01.3 Abnormal Plant Operations

a. Inspection Scope (71707. 92901. and 93702)

The inspectors responded to an automatic reactor scram and to a declaration of an

unusual event (UE). The inspectors assessed the effectiveness of operator responses,

communications, and use of plant procedures.

b. Observations and Findinas

Automatic Reactor Scram Due to Electro-Hydraulic Leak (EHC)

On December 18,1997, the plant automatically scrammed due to an EHC leak and

subsequent turbine trip. An inspector responded to the control room to monitor operator

actions. The inspector observed clear and concise orders and communications being

used. The operators effectively used plant procedures. The generally good material

condition of the plant, notwithstanding this equipment failure, resulted in no other safety

feature actuations or unanticipated challenges to the operators.

Unusual Event Due to Spill of Trichloroethylene (TCE)

On January 23,1998, approximately 275 gallons of TCE leaked fron, the off gas (OG)

brine system into the OG building. Since TCE is a mildly toxic gas, which required

restricted access to areas of the OG building and the use of forced air breathing devices

for entry, a UE was declared at approximately 3:10 a.m. The inspectors monitored the

emergency response actions and efforts to isolate and repair the OG system. Good

coordination was observed between responding groups. Personnel displayed a cautious

and thoughtful approach to handling the problems associated with the leak and the

system recovery. However, the inspectors questioned the timeliness of the initial UE

! declaration, and the notifications of offsite personnel required by Plant Administrative

l Procedure (PAP) 806, " Oil / Chemical Release Contingency Plan," Revision 2

) (November 1994). This issue will require furtt er discussion between NRC Region lll

emergency preparedness personnel and Perry staff. Therefore, this is an Unresolved

item (50440/97021-01(DRS)) to be evaluated in a future inspection.

c. Conclusions

Good preparations for activities associated with unusual plant conditions and the

relatively good material condition of the plant, notwithstanding the EHC and OG Cooling

system problems, led to effective operator responses to the automatic reactor scram and

the chemical spill during this inspection period.

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O2 Operational Status of Facilities and Equipment

O2.1 Control Room Eauipment Taaoina

a. Inspection Scope (71707 and 92901)

The inspectors assessed the implementation of a change to the licensee's policy for

tagging control room deficiencies,

b. Observations and Findinas

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Several different methods were used to tag control room devices and indicators that

required supplementalinstructions for operation or that were degraded in some way.

Overlapping requirements for the various tagging methods resulted in some control room

devices or indicators being marked with multiple tags (e.g., danger tags, operations

administrative tags, material deficiency tags (MDT), and/or information tags). Operations

management noted that this condition could unnecessarily distract or confuse operators.

Therefore, after bench marking trips to other power plants, in November 1997, a new

policy was formv5ted to modify control room equipment tagging requirements which

resulted in the removal of many tags from the panels. The guidelines provided to the

operators for the implementation of this policy included that redundant tags be removed,

that control room MDTs be stored in a ROLODEX file in the control room if not placed on

the equipment, and that operators evaluate which tag would be appropriate for the

condition of the equipment to be tagged.

During control room observations, the inspectors identified several out-of service or

degraded equipment controllers or indicators that were not marked. During a subsequent

walkdown of the control panels with the operations manager, he indicated that two meters

( should have been tagged per the new policy and promptly ensured they were

acropriately taggeo - While the operators and other personnel were aware of the

equipment that was out of service, discussions with operations personnel revealed

various levels of understanding and differences in interpretations of the new policy.

These interpretation differences were apparent during the walkdown with the operations

manager, in response, on January 18,1998, operations management issued a -

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memorandum to operations personnel which more clearly defined the guidelines and

expectations for the new policy. Based on follow up ooservations and discussions with

control room personnel, the inspectors concluded that the policy was more clearly-

understood.

. c. Conclusions

The inspectors concluded that the guidelines and expectations for the control room

equipment tagging policy change were not initially clearly communicated to the operators

which resulted in some degraded equipment not being tagged as expected by operations

management. Effor;s to reduce operator distractions are considered positive initiatives.

However, the net effect of reducing the amount of tags in the control room (i.e., less

information provided on the control panels for the operators' use versus less distractions)

can not be immediately assessed.

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08 Miscellaneous Operations issues

08.1 (Closed) LER 50-44019717 00: *High Suppression Pool Level Signal Results in

Engineerad Safety Feature Actuation." This event involved actuation of the logic to

transfer the suction of the high pressure core spray pump due to a minor level change in

the suppression pool. There was no actual equipment actuation. This event was

discussed in Inspection Report No. 50-440/97009(DRP) and was the subject of a violation

(50 440/97009-01) for failure to submit a licensee event report (LER). The logic actuation

had no safety consequences and no corrective actions were necessary.

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08.2 (Closed) VIO 50-440/97009-01(DRP): Failure to submit an LER for high suppression pool

level signal. The LER closed in Section 08.1 of this report was submitted in response to

this violation. The corrective actions for this violation appest adequate and this item is

considered closed.

11. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments

a. Inspection Scope (61726. 62707. 71500. and 92902)

The inspectors used Inspection Procedures 61726 and 62707 to evaluate several work

activities and surveillance tests. The inspectors observed emergent work as well as

planned maintenance conducted during the forced outage, plant startup, and normal

operations,

b. Observations and Findinas

The activities observed were generally accomplished effectively with appropriate use of

drawings and written instructions. Licensee personnel continued to maintain a low

threshold in using the corrective action process and material deficiency tags to identify

issues and potential equipment problems. Effective preparations for a forced outage

enabled the licensee to resolve several previously identified material condition

deficiencies during an unexpected plant shutdown. The overall maintenance backlog was

, at 414 items for combined corrective and general maintenance (CM/GM) as of

f January 26,1998. Licensee management established a new, lower backlog goal of

250 CM/GM items by December,31,1998. A Division 3 equipment outage was well

planned and executed, with safety equipment made available within the schedule despite

emergent work.

The inspectors performed a detailed review of Surveillance instruction (SVI) C71-TS232,

" Reactor Protection System - Electrical Power Monitoring Calibration / Functional for

1C71-S003B and 1C71-S003D." This included a review of the technical specificG-

basis, the Updated Safety Analysis Report (USAR), and associated drawings. The

instruction was clearly written and contained appropriate guidance and instructions. The

instrumentation and controls personnel who conducted the test were knowledgeable and

the responsible system engineer provided appropriate technical support.

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c. Conclusig_nm r

The inspectors concluded that effective preparations led to the completion of a number of

maintenance activities during an unanticipated two day reactor shutdown which resulted

in the resolution of several outstanding material condition deficiencies. Effective planning

and work execution led to a relatively low corrective and preventative maintenance item

backlog.

M7 Quality Assurance in Maintenance Activities

M7.'1 Measurina and Test Eauipmenj

a. Inspection Scope (61726. 62707. 71500. and 92902)

The inspectors assessed the effectiveness of various calibration activities for measuring

and test equipment (M&TE). A number of surveillance procedures were reviewed to

determine what M&TE was used, what the accuracy requirements were, and the

calibration methods that were used.

b. Observations and Findinas

The licensee's procedures for control and calibration of M&TE were detailed and

thorough. The licensee used a common corporate calibration facility with personnel from

the Davis Besse Nuclear Power Plant (Beta Labs). Except for contaminated devices,

M&TE are sent to Beta Labs (in Cleveland) for periodic checks.

The inspectors observed that more state-of-the art M&TE was t.eing used at Perry than in

the past. Although this provides technicians with better M&TE, the licensee was not

ensuring that the reference standaids were stik appropriate for the upgraded M&TE. The

licensee is committed to Institute of Electrical and Electronics Engineers (IEEE)

Standard 498, "lEEE Standard Requirements for the Calibration and Control of Measuring

l and Test Equipment Used in the Construction and Maintenance of Nuclear Power

l Generating Stations"(1977). This standard specifies that reference standards, used to

calibrate M&TE, must be at least four times as accurate as the M&TE. While several

years ago the reference standards were up to ten times more accurate than the M&TE,

the inspectors determined that some reference standards were exactly four times the

accuracy of the M&TE Deing used. The inspectors reviewed USAR Section 7.0,

" Instrumentation and Controls Systems," which included information related to this issue,

c. Conclusions

The inspectors concluded that administrative procedures and quality essurance programs

did not verify that calibration reference standards met accuracy requirements when the

M&TE was upgraded and therefore, that it was fortuitous that the standards used met the

IEEE requirements.

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M7.2 Divisional Raceway Markinos

. a. Inspection Scope (61726. 62707. 71500. and 92902)

The inspectors toured the emergency diesel generator (EDG) rooms to assess

maintenance activities and the general material condition of the equipment in the rooms,

b. Observations and Findinas

On January 7,1998, the inspectors observed nurr erous raceways in the EDG rooms that

did nnt have divisional markings on them. The markings are used to provide a visual  !

methr.d to ensure proper separation of cables is maintained. The licensee concluded that

thn recewsys had been marked at one time, but that the markings had deteriorated over

tir, an1 had not been maintained.

Appendix B,Section V of 10 CFR Part 50 requires, in part, that activities affecting quality

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shall be prescribed by documented instructions, procedures, or drawings, of a type

appropriate to the circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings. Perry Drawing Number D215001, Sheet 1,

Revision HH, dated May 3,1995, prescribed the marking requirements for Class 1E

raceways to ensure proper separation of cables is maintained. The marking of Class 1E

raceways is an ectivity affecting quahty. The failure to follow the prescribed drawing

requirements was a Violation (50-440/97021-02(DRP)) of NRC requirements.

c. . Conclusions

The inspectors concluded that the licensee inadvertently allowed the degradation of

required raceway markings over time to the extent that some were either illegible or

missing which was a violation of NRC requirements.

111. Enaineerina

.E2 Engineering Support of Facilities and Equipment

E2.1 Seismic Tubina Supcorts

a Inspection Scope (37551. and 92903)

The inspectors assessed the adequacy of maintaining seismic supports in the EDG

rooms and on EDG equipment.

b. - Observations and Findinas

On January 7,1998, the inspectors identified numerous STAUFF clamps on all three

divisional EDGs that did not appear to meet seismic qualification criteria. Many clamps

were loose, possibly cf the wrong type (2 dimensionalir: stead of 3 dimensional, or vice

versa), or had physicalimpairments that prevented them from operating correctly. These

issues were reviewed in two subsequent walkdowns with licensee engineering personnel.

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The engineering personnel stated that some of the physicalimpairments had probably

existed since the tubing was installed.

A potential issue form (PlF) was generated for this issue on January 20,1998,13 days

after the initialidentification. The preliminary indication on the PlF was that an operability

determination was not naeded for this condition. However, in parallel with the generation

of the PlF, engineering personnel were performing a review to determine if the EDGs

were operable. Once this review was completed, the licensee stated that, based on

engineering judgement, the EDGs were operable. A full technical review of the seismic

qualifications was in progress at the end of the inspection period to assess the

qualification and operability of the EDGs. In addition, work was initiated to correct the

deficiencies that had been identified. This issue is an Unresolved item

(50-440/9702103(DRP)) based on the completion and inspector review of the licensee's

engineering evaluations.

c. Conclusions

The inspectors questioned the operability of the EDGs based on numerous identified

differences in clamps provided for seismic qualifications. This item remained open at the

end of the inspection period.

E2.2 Desion Chanoe Causes Scram

a. Insoection Scope (37551 and 92903)

The inspectors assessed the adequacy of a change in the design of nonsafety-related

electro-hydraulic control oil tubing connections. Failure of one of the tubing connections

caused a reactor scram on December 19,1997 (see Section 01.3).

b. Observations and Findinas

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The licensee formed an incident response team to determine the causes of the scram.

l The team included vendor representatives in addition to licensee personnel frora

appropriate disciplines. The team's report included documentation of a systematic

approach to identifying the root and contributing causes of the Scram. The team also

systematically evaluated various options for correcting the causes. The team concluded

that the failure of the tubing connection was caused by hydraulically induced vibrations of

the tubing. The vibration coricem had been identified prior to the recently completed

refueling outage and the design of the tubing was changed during the outage through the

use of a specification change. The change consisted of replacing flared connections with

compression fitting connections. The compression fittings weie superior in preventing

leakage. The engineers who had initiated the change had evaluated the compression

fittings for use with vibration. However, their evaluation had not considered the increased

stress in the tubing at the compression fitting. The increased stress combined with the

tubing vibration caused high cycle fatigue failure of the tubing. The licensee's senior

management team accepted the incident response team's recommendation to install

flared tubing connections and accelerate preparation of the tubing design modification to

allow it to be installed if another forced outage occurs.

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c. Conclusions

The incident response team's evaluation of the scram was thorough and the conclusions

were well supported. However, the toam identified that an eariier change from flared tc

compression tubing connections had not been adequately evaluated prior to completion.

As a result, the tubing failed which caused a plant scram. The inspectors concluded that

a violation of NRC requirements did not occur in this case because the inadequate

evaluation occurred on a non safety related component and the maintenance rule

requirements were tatisfied.

lyafjant Support

F2 Status of Fire Protection Facilities and Equipment

F2.1 Fire Barriers

a. {rupection S_ cope (71707)

Using inspection Procedure 71707, the inspectors reviewed conditions affecting safety.

related equipment, including fire barriers required by Appendix R of 10 CFR Part 50.

b. Observations ansl Findinas

During an inspection of the Division 2 and 3 Emergency Diesel Generator (EDG) rooms

on December 8,1997, the inspectors noted that the fire door batween the rooms was

stuck open. This type of door was designed to close automatically, with no hold-open

mechanism. The inspectors reported the door's condition to plant opatakons staff, and

the door was reclosed. The licensee reviewed security recoms to identify who had been

in the rooms shortly before the inspectors. The licenseo concluded through interviews

that the door had most likely been inadvertently left open when a cart was taken through

the door several minutes before the inspector saw the door open. Yne licensee

determined that a floor sealant, which had been applied in the rooms many rnonths

earlier, had caused the door to stick on the door stop. This condition had not been

noticed because the door would stick open only if it was taken fully open or 90 degrees

open, as when the closing mechanism was tested. The inspectors did not observe

similar flaws in 20 additional doors inspected.

Appendix R, Section lit.N.4 of 10 CFR Part 50 f eeires, in part, that fire doors shall De

kept closei and inspected daily to verify that they w in the closed position. This NRC

identified failure to keep a required fire door closed is evnsidered a Violation

(50 440/9702144(DRP)) of Appendix R.

c. Conclusions

The inspectors concluded that actions to verify fire doors were closed on a daily basis

were generally effective. However, the licensee failed to recognize that a floor sealant

applied in the EDG rooms introduced the possibility for fire doors to stick open which

resulted in a violation of NRC requirer..ents when a fire door was identified by an

inspector to be stuck open.

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F2.2 Combustible Materials

a. Inspection _ Scope (62707. 71750. and 92902)

The inspecPars toured areas of the plant with safety related equipment to assess the

effectiveness of 10 CFR Pari 50, Appendix R fire prevention measures associated with

ongoing maintenance activities.

b. Observations and Findinot

On January 6,1998, the inspectors informed the shift supervisor that various items of

combustible matenal were in an area that was posted as a combustible free zone of the

emergency service water (ESW) pump house. The licensee promptly inspected the area

and temoved the combustible material. The licensee also initiated a PlF to enter the

issue h1 the corrective action system. The fire protection technician who inspected the

area stated that when he had inspected the area a few days earlier, the combustible

material had not been present. The combustible material appeared to be from a recently

completed maintenance activity The inspectors did not observe combustible materials in

other combustible free zones The inspectors reviewed USAR Section 9A.7, * Deviations

to Appendix R," which included information related to this issue.

Appendix R, Section ill G.2.b of 10 CFR Part 50 requires, in part, separation of cables

and equipment and associated non safety circuits of redundant trains by a horizontal

distance of move than 20 feet with no intervening combustibles or fire hazards, The

combustible free zone in the ESW pump house had oeen established to comply with

Appendix R, Administrative controls, postings, and boundary markings were in place to

ensure compliance with Appendix R. However, the failure to follow the posted

requirement was a Violation (50 440/9702105(DRP)) of NRC requirements.

c. Conclusions

The inspectors concluded that,in general, combustible materials were appropriately

controlled, However, a violation involving the placement of excess combustible material

originating from a maintenance work activity had been placed in an ESW pump house

combustibo free zone was identified by the inspectors,

X, Mananement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at

the conclusion of the inspection on January 27,1998. The licensee acknowledged the

findings presented. The inspectors asked the licensee whether any materials examined

during the inspection should be considered proprietary, No proprietary information was

identified.

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PARTIAL LIST OF PERSONS CONTACTED

L W. Myers, Vice President, Nuclear

W. R. Kanda, General Manager Nuclear Power Plant Department

T. S. Rausch, Director, Quality and Personnel Development Department ,

N. L Bonner, Director, Nuclear Maintenance Dyartment I

R. W. Schrauder, Director, Nuclear Engineering Department

H. W. Bergendahl, Director, Nuclear Services Department

J. Messina, Operations Manager

J. T. Sears, Radiation Protection Manager

F. A. Kearney, Superintendent Plant Operations

INSPECTION PROCEDURES USED

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lP 37551: Onsite Engineering

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IP 61726: Surveillance Observations ,

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IP 62707: Maintenance Observation

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IP 71500 Batance of Plant

IP 71707: Plant Operations

IP 71714: Cold Weather Preparations

IP 71750: Plant Support Activities

IP 92700: Onsite Follow up of Written Reports of Non routine Events at Power Reactor

Facilities

IP 92901: Follow up Plant Operations

IP 92902: Follow up Maintenance

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IP 92903: Follow-up Engineering

IP 92904 Follow up Plant Support

ITEMS OPENED OR CLOSED (NONE DISCUSSED)

Qpened

50-440/9702101(DRP) URI Timeliness of Emergency Declaration and Notifications

50 440/9702102(DRP) VIO Class 1E Raceway Markings

50-440/9702103(DRP) URI Seismic Tubing Supports for EDGs

50 440/9702104(DRP) VIO Failure to Keep Fire Door Closed

50-440/9702105(DRP) VIO Corrbustibles in Combustible Free Zone

Closed

50 440/97 17 00 LER High Suppression Pool Level Signal Results in Engineered

Safety Feature Actuation

50-440/97009-01 VIO Failure to submit and LER for High Suppression Pool Level

Signat

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LIST OF ACRONYMS ANDINITIALISMS

CFR Code of Federal Regulations

CM/GM Corrective Maintenance / General Maintenance

EDG Emergency Diesel Generator

EHC Electro Hydraulic Controls

ESW Emergency Service Water

IEEE Institute of Electrical and Electronics Engineers

IR inspection Poport

LCO Limiting Condition for Operation

LER Licensee Event Report

MDT Material Deficiency Tag

M&TE Measuring and Test Equipment

NRC Nuclear Regulatory Commission

OG Off Gas

PAP Plant Administrative Procedure

POR Public Document Room

PlF Potantialissue Form

PLCO Potential Limiting Condition for Operation

PSIG Pounds per Square Inch, Gage

RFO6 Refueling Outage 6

RG Regulatory Guide

RI Resident inspector

RO Reactor Operator

RPS Reactor Protection System

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SRI Senior Resident inspector

SRO Senior Reactor Operator

SVI Surveillance instruction

TCE Trichloroethylene

TS Technical Specification

UE Unusual Event

URI Unresolved item

USAR Updated Safety Analysis Report

VIO Violation

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