ML20217M131

Insp Rept 50-440/98-07 on 980223-0305.Violations Noted. Major Areas Inspected:Operations,Engineering & Maintenance

ML20217M131
Person / Time
Site:	Perry
Issue date:	04/29/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217M101	List: ML20217M096 ML20217M114 ML20217M131
References
50-440-98-07, 50-440-98-7, NUDOCS 9805040443
Download: ML20217M131 (20)

See also: IR 05000440/1998007

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

Docket No: 50-440

License No: NPF-58

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Report No: 50-440/98007(DRS)

Licensee: Centerior Service Company

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Facility: Perry Nuclear Power Plant

Location: P. O. Box 97, A200

Perry, OH 44081

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Dates: February 23 to March 5,1998

Inspectors

R. Bailey, Reactor Inspector

l M. Bielby, Reactor inspector

i J. Clark, Resident inspector

! C. Lipa, Senior Resident inspector

Approved by: M. Leach, Chief, Operator Licensing Branch

Division of Reactor Safety

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9905040443 990429

PDR ADOCK 05000440

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! EXECUTIVE SUMMARY

Perry Nuclear Power Plant

! NRC Inspection Report 50-440/98007

This operational assessment team inspection (OATI) included aspects of licensee operations,

engineering, and maintenance. The report covers a 2-week period of on site inspection of the

conduct of operations which included a continuous 72-hour period of control room observation.

The conduct of operation's activities at the Perry facility were good; however, the

communication of management expectations was not always clear. The NRC observations

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noted inconsistencies during operator panel walkdowns and control panel deficiency tagging.

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The following specific observations were made:

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Operations

e Shift crew briefings and tumovers were consistent and effective sources of information

to ensure continued safe operations. However, special evolution briefings and turnovers

l were not always conducted in accordance with program guidance. (Section O1.2)

* A wide diversity in time intervals between panel walkdowns and the quality of panel

l monitoring raised a concern that operators were indifferent to indication problems and,

in some cases, lacked a questioning attitude. (Section 01.3)

e Formal communications resulted in an effective exchange of information among

i operators and other plant personnel. Generally, commands and directions were clear

and concise with repeat backs being expected. (Section 01.4)

e Control room operators effectively coordinated plant personnel during maintenance and

testing evolutions to identify expected plant response and annunciator alarms. (Section

O1.5)

• Work control pre-job briefings emphasized procedure compliance, contingency action

plan, and termination criteria with attention on self checking and personal safety.

However, the pre-job briefing for a reactor core isolation cooling post-maintenance test

failed to include quality control personnel which resulted in an unnecessary challenge to ,

plant operators when an unanticipated heatup of the suppression pool above an I

administrative limit occurred. (Sections 01.6 & M1.1)

e Control room deficiency identification and tagging guidelines were not clearly

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established and communicated through procedures and instructions. (Section 01.7)

• During the performance of work under a safety tagout, an operator removed the wrong

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safety tag and installed a fuse in the wrong panel which energized a system tagged out

l for maintenance and jeopardized personnel safety. (Section 01.8)

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Maintenance

e A reactor core isolation cooling system testing evolution was conducted within

procedural guidelines. However, a number of deficiencies had been identified in the

planning and implementation of the testing process.' (Section M1.1)

e- Prior to reactor core isolation cooling system maintenance, a pre-job walkdown failed to I

identify the inaccessibility of several steam Jet plugs.' Additionally, maintenance

personnel failed to document management's action to correct work procedure problem. l

(Section M3.1)

Engineering

e A calculation deficiency existed in the licensee's determination of the 7-day diesel

generator (DG) fuel oil supply quantity for division-3. The calculation revealed a

required amount that was not consistent with TS and no corrective action had been

implemented for almost two years. The calculated difference required a TS change to 4

address a non-conservative requirement which constituted a violation of regulatory

requirements. (Section E1.1)

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Report Details

Summary of Plant Status

The Unit operated at or near full power for the duration of the inspection period. '

l. Operations

01 Conduct of Operations

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01.1 General Comments

The inspectors conducted an observation of routina control room activities during a

continuous 72-hour period using Inspection Procedures (IP) 93802 and 71707 as -

guidance. Additionally, the inspectors assessed the licensee's ability to control

maintenance activities and surveillance testing, and provide technical staff support

during routine plant operations. In general, conduct of operations was professional and

focused on operational safety. Specific observations and findings are listed in the

following sections.

01.2 Shift Mannina and Relief Tumovers

a. Insoection Scoce (71707. 93802)

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The inspectors assessed the licensee's operating shift tumovers and briefings

conducted during the continuous 72-hour monitoring period. The inspectors also

assessed the licensee's effectiveness to control plant operations and coordinate support

activities with the current shift manning. The following procedures were considered in

the process:

• PAP-0126," Shift Relief and Tumover," Revision 0

v PAP-0201," Conduct of Operations," Revision 9

b. Observations and Findinas

Each control room crew consisted of two licensed senior reactor operator positions, Shift

Supervisor (SS) and Unit Supervisor (US); and three licensed reactor operator positions,

Supervisory Operator /At-The-Controls (SO-ATC), Supervisory Operator / Extra (SO-E),

and Operations Foreman (OF). Additionally, each crew consisted of two non-licensed

operator positions: Perry Plant Operators (PPO) and Perry Plant Attendants (PPA), who

performed rounds and system alignments outside of the control room. The inspectors

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determined that an appropriate level of manning had been maintained.

Shift relief personnel were generally observed arriving early and performing a detailed i

discussion and panel review of plant and equipment status, log entries, planned work,

and operating priorities from their counterparts. During the on-coming shift briefings, the

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inspectors observed a reaffirmation of turnover information with emphasis on personal

safety awareness. An open dialog was normally observed at the briefings, versus

simple dissemination of information from supervision. Although operations personnel

did not express a difficulty in hearing others that spoke, the inspectors had difficulty

hearing all of the brief at varied positions on the edge of the briefing area.

The inspectors also observed some special evolution briefings and subsequent task

performances with noted differences in personnel performance. During a post-

maintenance run of the reactor core isolation cooling (RCIC) turbine, the dedicated

control operator was directed to establish suppression pool cooling. Following initiation

of the task, a shift relief operator was requested to relieve the on-shift control operator

and finish establishing suppression pool cooling. Although the relief operator had

conducted a pre-shift walkdown, no special evolution briefing or detailed tumover was

observed which deviated from program guidance The inspectors noted that an extra on-

shift control operator, who had participated in the evolution briefing, was available but

was not asked to perform the evolution.

c. Conclusions

Shift briefings and turnovers were consistent and effective sources of information to

ensure continued safe operations. However, special evolution briefings and turnovers

performance were not always conducted in accordance with program guidance and

lacked formality.

O1.3 Ooerator Attentiveness to Duty and Panet Monitorina

a. Insoection Scoce (71707. 93802)

The inspectors assessed the licensee's ability to monitor control panel indications during

routine operator walkdowns and to determine all conditions adverse to continued

operations. These observations were conducted during the continuous 72-hour

monitoring period. The following procedures were considered in the process:

o PAP-0201, " Conduct of Operations," Revision 9

e Operations Policy item 1-6, " Control Room Monitoring," dated August 15,1996

b. Observations and Findings

The inspectors observed control room operators during the performance of panel

walkdowns both inside and outside of the horse-shoe control area. The inspectors ,

noted the following regarding the effectiveness to perform horse-shoe panel walkdowns: 1

(1) Each SO-ATC was expected to conduct a panel walkdown inside the horse-shoe

control area approximately once every hour. However, the inspectors noted that

the time between each panel walkdown varied from approximately 30-minutes to

90-minute intervals, with the longest period observed being almost 180 minutes.

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(2) In general, each SO-ATC was attentive to plant status as evidenced by routine

reviews of each panel's indications and controls. As a follow-up, the inspectors

questioned selected operators about system status and specific panel indication

or control status. The inspectors determined that the operators were

knowledgeable of the items in question. However, the inspectors observed that

a few operators would routinely perform a general scan of the entire control

panel area while sitting / standing in one chosen position. The inspectors had

difficulty determining the status of some major equipment while performing a

similar panel review.

(3) On more than one occasion, the inspectors observed the SO-E position

performing a temporary relief of the SO-ATC position. The inspectors were

informed that operators routinely performed interim reliefs to allow for an

independent review of panelindications and controls.

Each SO-E performed a walkdown of the panels located outside of the horse-shoe area

twice a shift or about once every four hours. At the beginning of each shift, the first

panel walkdown included taking a set of required Technical Specification logs.

Sometime during the middle of shift, the same operator would perform a second

walkdown of the same control panels. The inspectors also observed that the SS and

US made an independent tour of the same panels at least once during the shift which

usually occurrad at the middle of each shift. However, the inspectors noted that the time

between panel walkdowns varied widely from about 2-hours to 4-hours.

A number of deficiencies on the control panels located outside of the horse-shoe area

were not addressed in a timely manner. One of these deficiencies became readily

obvious during an operator's panel walkdown prior to shift tumover. The following items

were noted:

e The inspectors identified an off gas post treatment recorder (D17-R601) with one

of two channels not indicating (ink pen failure) for approximately three hours.

!' The licensee promptly replaced the non-inking pen which corrected the problem.

However, the positioning of the replacement pen caused the other channel's pen

l to stick such that it stopped inking for approximately three hours, until identified

and corrected.

! * The inspectors identified indications for a reactor recirculation flow control valve

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hydraulic power unit subloop fan had a very dimly illuminated indication (bulb lit

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on only one of a four-bulb group). The inspectors had a difficult time in

determining whether the bulb was illuminated or not. The inspectors discussed

the observation with the control operators, who verified the indication was dim

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and replaced the bulb once management concurrence was received. Other

dimly illuminated indication bulbs were observed on various control panels.

e The inspectors identified a reactor head vent valve (B21-F005) with intermediate

position indication (both the open and closed indicating lights were illuminated) at

a time when plant operations required the valve to be open. The SO-ATC was

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questioned as to the valve's position for which he responded "The valve is open."

! After repeated questioning, the licensee determined that the closed indicator

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bulb was grounded causing it to be illuminated. The indicator bulb was replaced

and the valve position was verified to be full open, as expected.

l * The licensee identified an equipment area 6T recorder (E31-R611) which printed

for over 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> at below scale reading before being noticed by an oncoming

operator. The licensee promptly corrected the deficiency with no other problems

noted.

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Operations personnel were generally attentive to the control room panels. However,

inconsistencies in panel walkdown frequencies and level of deta:1 were noted, as

discussed above. These inconsistencies were considered a negative finding by the

inspectors.

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A wide diversity in the frequency of panel walkdown and quality of panel monitoring

raised a concern that operators were not consistently implementing management

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expectations. Also, an indifferent atmosphere was noted during monitoring of plant

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conditions and, in some cases, a questioning attitude toward equipment status was not

evident.

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01.4 Control Room Communications

a. Insoection Scoce (71707. 93802)

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f The inspectors observed the licensee's communications among various control room

l operators and between plant personnel located outside the control room. Additionally,

l the inspectors observed communications between the various departments during

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maintenance and testing evolutions. The following procedure was considered in the

process:

l e Operations Policy item 1-2, " Operations Section Communications Policy," dated

February 18,1997

b. Observations and Findinas

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, in general, good verbal commun. cations were being consistently used by the control

l room operators during all plant evolutions. Management's expectation of using 3-way

j communication skills (i.e. sender's statement - receiver's repeat back - sender's

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acknowledgment) during all forms of verbal communication was being implemented. A

few instances of improper 3-way communications were promptly corrected by another

operator or the supervisor. The inspectors observed that inplant operators and

attendants used 3-way communications when discussing rounds and when performing

equipment manipulations.

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. The inspectors observed that support personnel (i.e. maintenance or engineering) were i

also required to use 3-way communication skills when discussing work activities with the

control room operators. On r,everal occasions, the US or SS would require

maintenance personnel to repeat-back directions or action commands during testing.

These discussions also required the use of an approved phonetic alphabet.

During the performance of post-maintenance testing on the RCIC turbine (See Section

M1.1 discussion), the inspectors noted a decline in formal communications during

unanticipated plant changes, such as, increasing suppression pool temperature with

suppression pool cooling required.

c. Conclusions

Formal communications resulted in an effective exchange of information and

understanding between operators and other plant personnel. Generally, commands and

directions were clear and concise, and easily repeatable. Additionally, the timely

correction of improper communications by other operators was consistent with

management's expectation.

01.5 Ooerator Resoonse to Alarms and Annunciators

a. Insoection Scone (71707. 93802)

The inspectors assessed the control room operators' ability to respond to expected and I

unexpected control panel annunciator alarms during the continuous 72-hour monitoring

period. The following procedure was considered in the process:

e . Operations Policy item 2-4, " Control Room Response to Annunciators," dated j

August 15,1996  ;

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b. Observations and Findinas j

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A majority of the annunciator alarms received during surveillance or testing evolutions

were identified as " expected." Operators were observed discussing planned work

evolutions with plant personnel to establish which annunciators would be received for a  !

given activity.- For unexpected annunciator alarms, in general, the SO-ATCs would

acknowledge and announce each alarm to the US or SS, reference the appropriate

Alarm Response Instruction, and dispatch appropriate personnel to investigate the j

problem. Both the US and SS remained in a position of command and control, and l

periodically provided guidance to the Supervisory Operator who was addressing the

event.

c. Conclusions

Control room operators effectively coordinated with maintenance and testing personnel

to identify expected plant responses and annunciator alarms requiring operator

response. Appropriate responses were noted during abnormal situations.

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01.6 Work Control and Evolution Briefinos

a. Insoection Scooe (93802)

The inspectors assessed the licensee's effectiveness at conducting pre-job briefings and

controlling work in progress during the continuous 72-hour monitoring period. The

following procedures were considered in the process:

• PAP-0201, " Conduct of Operations," Revision 9

e PAP-1121, " Conduct of Infrequently Performed Tests or Evolutions," Revision 1

e SOI R42 (Div 2),"Div 2 DC Distribution, Buses ED-1-B and ED-2-B: Batteries,

Chargers, and Switchgear," Revision 0

e sol B33, " Reactor Recirculation Flow Control Valve Hydraulic Power Unit

Subloop A-1," Revision 6

• Policy item 2-9, " Operational Activity Evaluation," dated February 24,1997

b. Observations and Findings

A pre-job brief was held on February 20,1998, for the post maintenance testing of the

RCIC turbine. Each step of the procedure was reviewed, including notes and cautions.

Actions and required communications were clarified with emphasis on self checking and

personal safety. However, quality control personnel needed to verify the post

maintenance work were not included in the briefing. (See Section M1.1 for more details)

A pre-job brief was held on February 23,1998, for restoration of the Unit 2, Division 1

batteries to a float charge which followed an equalizing charge evolution. The OF led the

brief and referenced guidance in a prepared Pre-Job Checklist. Appropriate personnel

were in attendance which included two PPOs and one PPA assigned to perform the sol

procedure. Each step of the procedure was reviewed, including notes and cautions.

Actions and required communications were clarified. Related industry and Perry specific

events were discussed. The OF emphasized the importance of self checking and

verification in reference to manipulation of equipment effecting both units. Termination

criteria were established as any unexpected or misunderstood events that may occur

during the evolution.

A pre-job brief was held on the February 24,1998, for restoration of the reactor

recirculation flow control valve hydraulic power unit subloop A-1 to service after

replacement of filter elements that had been leaking. The US led the briefing and

reviewed procedure steps, notes and cautions. Safety precautions and their importance

were emphasized. Contingency actions for an unexplained change in reactor power and

an unexpected or unisolable fluid leak were reviewed and clarified. Additionally, the

licensee stationed an extra licensed operator at the recirculation control panel for

monitoring of the flow control valve operation during restoration.

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The related work activities were completed satisfactorily with no problems identified. I

Control operators maintained a positive control over the evolution with emphasis on  !

proper communications. I

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c. Conclusions  !

In general, pre-job briefings were conducted in a formal manner and contained an

appropriate level of information. Procedural steps, notes and cautions were thoroughly

reviewed with contingency actions being clarified, and attention to self checking and

personal safety were emphasized. However, necessary personnel were not always in

attendance during the briefing process.

01.7 Eauioment Deficiencv Identification i

a. Insoection Scoce (93802)

The inspectors assessed the licensee's awareness of component and system status

which included the identification and tagging of system deficiencies that affected control

room operations. Additionally, the inspectors questioned selected operators about the

process for identifying and tracking control room deficiencies. The following procedure

was considered in the process:

o PAP-0902, " Work Request System," Revision 9

b. Observations and Findinas

The operators demonstrated appropriate knowledgeable of the process and were able

to identify deficient equipment located on the control room panels which affected remote

operations capability. The US was observed performing routine updates to the Rolodex

file, at or near the end of each shift. However, a disparity was noted among the control

room operators as to the minimum threshold to tag a component and the type or level of

deficiency needed to be maintained in the control room Rolodex file.

The inspectors were informed that management expectations had been discussed in an

operations department memorandum, dated January 18,1998, which implemented the

use of a Rolodex filing system to track each deficiency. The management directive

emphasized a reduction in the multiplicity of tags on the control panels to reduce the

distraction associated with redundant tag information The control operators were

aware of the management directive but a copy was not available in the control room.

Management expectations were unclear as to the tagging of deficient control room

equipment.

Additionally, section 6.1 of PAP-0902 provided some guidance on when to place a

deficiency tag / sticker on a faulty piece of equipment and how to write a work order once

it had been identified. However, the inspectors expressed a concern that the procedure

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judgement evaluation as to whether a deficiency sticker would be needed or was

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Conclusions

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The process of identifying and labeling deficient equipment was not being implemented

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l through procedures and instructions as to the proper method of identifying and tagging

l deficient equipment.

01.8 Safety System Tagaing

a. Insoection Scoce

The inspectors assessed the licensee's safety system tagg;ng and isolation program

during the continuous 72-hour monitoring period. This included the review of a

clearance package and a Potential Issue Form (PlF 98-377) associated with safety

system tagging removal activity. The following procedure was considered in the

process:

! * PAP-1401, " Safety Tagging," Revision 8

b. Observations and Findinas

(1) Two PPAs were observed performing a clearance package which required the

removal of safety tags and the restoration of the Feedwater Booster Pump "C"

system alignment. The safety tag removal was performed in accordance with

the prescribed procedure and the PPAs used good self checking techniques (i.e.

verified each tag matched the clearance sheet and component labeling prior to

sign off and removal of the tag). Additionally, the PPAs used the appropriate

tools and safety precautions during the electrical equipment restoration.

(2) On February 27,1998, the inspectors were informed that while performing a

temporary lift evolution, a licensed operator removed an incorrect tag and

inserted a fuse for an incorrect system component. The operator error became

immediately apparent when an unexpected annunciator alarm occurred on the

control panel for the annulus exhaust gas treatment system (AEGTS). The

licensee identified that no work had been in progress on the AEGTS system at

the time the fuse was installed. The licensee documented the occurrence on PlF

98-377. The incorrectly removed tag was promptly restored and verified. The

operator acknowledged in a written statement that he failed to properly verify the

panel and tag numbers matched the temporary lift document before performing

the evolution.

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Immediately following the event, the licensee initiated corrective actions to suspend all

tagging activities and have all operational personnel receive training on safety tagging.

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The inspectors noted that a similar personnel error occurred on August 19,1997, as

discussed in Inspection Report 50-440/97012 (DRP). In that case, a non-licensed

operator had removed fuses from a wrong cubicle, which resulted in a loss of power to a

safety-related bus and actuation of several containment isolation valves.

TS 5.4.1.a specified, in part, that written procedures shall be implemented covering the

applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision

2, February 1978, which specified equipment control activities, such as tagging. Section

6.11.8 of PAP-1401 specified that the operating representative assigned to remove tags

shall verify the tag to be the correct one by comparison of its tagout number and MPL

number with the listed information on the temporary lift form. The licensed operator's

failure to comply with the requirements in PAP-1401 was a violation of the licensee's

technical specifications. (VIO 50-440/98007-01(DRS))

c. Conclusions

A licensed operator's incorrect action to remove the safety tag and replace a fuse on a

wrong component was contrary to the licensee's procedure and a violation of the

licensee's technical specifications. The inspectors were made aware that a similar

occurrence had been identified by the licensee during another implementation of the

safety tagging program. The licensee's management response was timely and

appropriate.

03 Operations Procedures and Documentation

O3.1 Procedure Revision and Format

a. Insoection Scoce (71707)

The inspectors reviewed operational and administrative procedures during the course of

the 72-hour observation. This review included an assessment of each procedure's

adequacy. The foliowing procedures were considered in the process:

• PAP-0201, " Conduct of Operations," Revision 9

• PAP-0507," Preparation, Review, and Approval of Procedures and instructions,"

Revision 12

• PAP-0522, " Changes to Procedures and Instructions," Revision 9

e SOI-R45/E22B, " Division 3 Diesel Generator Fuel Oil System," Revision 5

b. Observations and Findinas

The control room operators consistently referenced current System Operating

Instructions (sol) and Annunciator Response Instructions (ARI), when required.

However, the inspectors identified one concem regarding the clarity of instructions in

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Section 2.0.2 of SC;-R45/E228. The instruction specified that when the fuel oil storage

tank level decreased to 95% then order more fuel oil. The inspectors determined that

tank level had been 94% or less between January 21 and February 25,1998, and fuel

had not been ordered as of February 25,1998. Operations Department Management

informed the inspectors that a note in the procedure made a clarification that

engineering would be consulted to determine when to add additional fuel oil. The

inspectors determined that the procedure's intent was vague because it clearly stated

the expectations for ordering fuel oil but did not specify when to refill the tank. The

licensee noted the problem and agreed to review and revise the procedure, as needed.

The inspectors were able to verify that the existing tank volume had met TS

requirements during the time in question.

c. Conclusions

The licensee's procedures were written consistent with program guidelines and provided

the appropriate level of direction, with one exception as noted above.

II. Maintenance

M1 Conduct of Maintenance

M1.1 Post-Maintenance Testino and Surveillances

a. Insoection Scoce (61276)

The inspectors observed the post maintenance run and surveillance testing of the RCIC

pump turbine. The following procedure was considered in the process:

e PAP-0201, " Conduct of Operations," Revision 9

The following post maintenance and TS surveillance tests were reviewed:

• TS Rounds for Modes 1,2, & 3; week of February 16,1998, and week of

February 23,1998.

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e SVI-E51-T2001, "RCIC Pump and Valve Operability Test," Revision 10 l

e SVI-M16-T2001, "Drywell Vacuum Breaker and Isolation Valve Operability Test,"

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e SVI-M45-T1323, " Remove Water From Fuel Storage Tanks," Revision 3.

e SVI-R43-T1318," Diesel Generator Start and Load Division 2," Revision 6.

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b. Observations and Findinas

The inspectors identified a number of concerns during the conduct of the RCIC turbine

post maintenance testing on February 20,1998, including: (1) lack of coordination j

among support groups; (2) complex sequencing of multiple tests; (3) decline in three- I

way communications during unexpected evolutions; and (4) poor evolution turnover

during suppression pool cooling setup.

(1) Post maintenance testing of the RCIC turbine required a quality control (QC)

inspector to verify that steam leak reduction work activities had been properly

performed. The QC inspector was not included in the pre-job briefing, but had

been made aware that testing would be going on sometime that day. The QC

inspector was not contacted until approximately 25-minutes into the RCIC turbine j

run, when he was directed to begin a system walkdown. The QC inspector

began a system walkdown approximately 55-minutes into the planned 1-hour

run. The inspectors expressed a concern that the pre-evolution briefing had not

incorporated all key personnel. l

(2) The pre-job briefing by an operations supervisor had included a direction that

suppression pool temperature should be allowed to increase to approximately

90 F. The purpose was to allow subsequent testing of the combustible gas

compressors which resulted in a cooling of the suppression pool. Operations

management considered the evolution to run the RCIC turbine for 1-hour as a

normal event. Also, the licensee noted that performing a follow on test activity

was a routine evolution. However, the inspectors questioned the management's

reasoning that scheduling two complex evolutions back-to-back should not be

considered an infrequently performed test or evolution (IPTE) as discussed in

Section 6.3 of PAP-0201. The inspectors expressed a concern following a

critique of operator performance that non-routine evolutions were considered

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(3) During surveillance testing of the RCIC turbine, the licensee acknowledged that {

suppression pool cooling would normally be started early in the evolution to I

minimize any temperature rise as a result of the turbine run, in this case,

however, the licensee had pre-established suppression pool temperature at

approximately 70*F, such that the planned one hour run would not increase pool

temperature above 90*F. An administrative limit of 95'F was established for

starting suppression pool cooling, if needed, but was not anticipated.

The QC inspector's untimely inspection of the RCIC system caused the required

run time to be extend beyond the 1-hour anticipated run period. Suppression

pool temperature was allowed to rise to 93*F before direction was given to place

I suppression pool cooling in service. The pool temperature exceeded 95"F

before pool cooling was initiated, and increased to 97*F before pool temperature

was stabilized. The inspectors observed a decline in 3-way communications

during this period and expressed a concern that performance had deviated from

those observed during stable plant conditions. j

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(4) Following the need to place suppression pool cooling in service, the dedicated

RCIC turbine control operator was directed to place the residual heat removal

(RHR) system into suppression pool cooling mode. While establishing the

system lineup, the US directed an on-coming shift relief operator to place the

RHR system in service. The inspectors observed the relief operator look at the

procedure, then perform equipment realignment, as required. Section A.3 of

Attachment 1 in PAP-0201 specified that during equipment manipulations or

activities, if personnel positions change, then the following items shall be

discussed: (1) status of the activity in progress; (2) changes since last worked

on equipment; and (3) present condition of out-of-position components. The

inspectors were informed that the relief operator had reviewed the procedure

and discussed where the control operator had stopped. However, the inspectors

expressed a concern that an incomplete evolution brief and turnover had taken

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place.

The inspectors determined that no primary containment challenge had occurred during

the pool temperature rise. However, the inspectors noted an indifferent attitude toward

the implementation of multiple planned evolutions.

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c. Conclusions l

Although the RCIC turbine testing had been conducted within procedural guidelines, the

inspectors were concerned that a number of deficiencies had been identified in the

planning and implementation of the testing process.

M3 Maintenance Procedures and Documentation

M3.1 Work Package Documentation

a. Insoection Scoce (62707. 93802)

The inspectors reviewed the maintenance work package for the RCIC turbine to assess

work control effectiveness. The following procedures were considered in the process:

o PAP-0905, " Work Order Process," Revision 15, dated July 31,1996

• W.O.# 970002020," Identify Leaks on the RCIC Turbine, Tighten Casing Bolts

and Jet Plugs," dated February 10,1998

b. Observations and Findinas

The work package was reviewed and approved in accordance with program guidance.

The work package procedure included a step to tighten seven steam jet plugs.

However, four of the seven plugs were not accessible to the workers which left only

three plugs available. The workers tightened the three accessible plugs and placed a

note in the progress description log confirming the non-conformance action taken. The

inspectors noted the following deviations from program guidance:

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(1) Section 6.3.4 of PAP-0905 specified that the work group supervisor was

responsible to ensure the work to be performed could be done as written. The

inspectors expressed a concern that the work package had been approved for

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implementation without a clear understanding of the work conditions or

limitations.

(2) Section 6.4.1.5 of PAP-0905 specified that the worker was responsible to

perform the work as identified on the work instruction. However, the inspectors

expressed a concern that no procedural guidance existed to address or

, document a deviation from the work procedure. Additionally, no documentation

of the management concurrence had been noted. The inspectors were informed

that the workers had contacted their work supervisor and the control room

supervisor to inform each of the problem encountered.

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The licensee acknowledged the inspectors' concems. The licensee agreed to review

the concems for possible revision to the process. The inspectors were informed by the

licensee that management expectations had not been satisfied when the workers failed

to document the supervisor's concurrence.

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c. Conclusions

The RCIC turbine maintenance had not been completed in accordance with approved

work instructions. The work package documentation of a change to the work performed

was not consistent with management expectations in that maintenance personnel failed

to note management concurrence with actions taken.

Ill. Enaineedng

E3 Engineering Procedures and Documentation

E3.1 Desian Basis Review of Emeraency Diesel Generator (D6) Fuel Oil Reauirements

a. Insoection Scooe

The inspectors reviewed surveillance test data for the emergency diesel generators

(DG). This included a review of past surveillance tests on the diesel generators and the

fuel oil storage tank levels. The inspectors also reviewed and compared related

Technical Specifications, Sys.am Operating Instructions, and the Updated Final Safety

Analysis Report to supporting calculations.

b. Observations and Findinas

The inspectors identified two discrepancies between the calculated and TS values for

emergency DG fuel oil storage tank requirements on all three divisions. The following

concern was noted during a review of the engineering calculation R45-9, Revision 4,  ;

dated January 26,1996:

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e The minimum required fuel oil volume for 7-days of continuous operation for the

! division-3 DG was determined to be 36,700 gallons. The calculated volume was

! greater than the TS 3.8.3 minimum requirement of 36,100 gallons. The

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inspectors noted that the system engineer had rounded the value down to agree

with the TS value and were concerned that a non-conservative approach to safe

operations had been applied to the TS value.

• The minimum required fuel oil volume for 6-days of continuous operation for the

Division 1 and 2 DGs was determined to be 62,400 gallons. The calculated

l volume was less than the TS 3.8.3 minimum requirement of 65,100 gallons.

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The inspectors expressed a concern that the licensee needed to address the design

calculation and TS difference to ensure continued safe operations. The licensee

acknowledged that a TS change was required and initiated PlF 98-496, A prompt

operability determination was made which determined that an adequate amount had

i existed in the tank. The licensee had put administrative controls in place to ensure tank

levels remained above the calculated minimum value.

Criterion lil of 10 CFR 50, Appendix B, states, in part, that measures shall be

established to assure the applicable regulatory requirements and design basis for

structures, systems, and components are correctly translated into specifications,

drawings, procedures, and instructions. The failure to translate division-3 emergency

DG fuel oil tank quantity into the technical specifications resulted in a violation of

Criterion lil in Appendix B of 10 CFR 50. (VIO 50-440/98007-02(DRS))

c. Conclusions _

l The licensee's calculation for determining the minimum 7-day and 6-day diesel

generator fuel oil tank quantities showed a difference from the TS values with no

corrective action being taken by the licensee. In the case of the division-3 DG, a TS

change was required to resolve this issue which was a violation of regulatory

requirements.

V. Management Meetings

X1 Exit Meeting Summary

On March 5,1998, the preliminary results of the team inspection were presented to the licensee

at an exit meeting. The licensee did not identify any material provided during the inspection

report period as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee  !

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P. Arthur Perry Operations Supervisor - US

N. Bonner Director - Perry Nuclear Maintenance Department l

R. Collings Quality Assurance Manager

T. Henderson Compliance Supervisor

H. Hegrat Regulatory Affairs Manager - g

W. Kanda General Manager - Perry Nuclear Power Plant Department

R. Keamy Operations Superintendent

H. Kelly Perry Operations Supervisor- SS ,

J. Kloosterman Corrective Action Program Supervisor

J. Lausberg Senior Engineer

K. Meade Training Instructor >

S. Moffitt Plant Engineering Manager

L. Myers Site Vice-President Nuclear

J. Powers Design Engineering Manager

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R. Schrauder Director- Perry Nuclear Engineering Department i

J. Sipp RECS Manager

L. Zerr Quality Assurance

MB.C

M. Dapas Deputy Director, DRP

D. Kosloff Senior Resident inspector

M. Leach Chief, Operator Licensing Branch, DRS

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! INSPECTION PROCEDURE USED

IP 61276 Surveillance Observations

l lP 62707 Maintenance Observations

l lP 71707 Conduct of Operations

l IP 93802 Operational Safety Team Inspection (OSTI)

ITEMS OPENED, CLOSED, AND DISCUSSED

Ooened

50-440/98007-01 VIO Incorrect removal of safety tag and installation of fuse

50-440/98007-02 VIO Tech Spec requirement for division-3 DG Fuel Oil was non- j

conservative

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Closed

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None )

Discussed ,

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LIST OF ACRONYMS USED

AEGTS Annulus Exhaust Gas Treatment System

ARI Annunciator Response instruction

DG Emergency Diesel Generators

dPCS High P essure Core Spray

IP inspection Procedure

M&TE Measurement and Testing Equipment

OATI Operations Assessment Team inspection

OF Operations Foremen

PAP Perry Administrative Procedure

PIF Problem identification Form

PPA Perry Plant Attendant

PPO Perry Plant Operator

QC Quality Control

RCIC Reactor Core Isolation Cooling

RHR Residual Heat Removal

SO-ATC Supervising Operator- At The Contr< !s

SO-E Supervising Operator- Extra

SOI System Operating Instructions

SS Shift Supervisor

TS Technical Specifications

UFSAR Updated Final Safety Analysis Report

US Unit Supervisor

VIO Violation

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