ML20247G934
| ML20247G934 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/07/1989 |
| From: | Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247G927 | List: |
| References | |
| 50-440-89-22, NUDOCS 8909190171 | |
| Download: ML20247G934 (10) | |
See also: IR 05000440/1989022
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-440/89022(DRP)
Docket No. 50-440
License No. NPF-58
Licensee: Ci reland Electric Illuminating Company
Post Office Box 5000
Cleveland, OH 44101
Facility Name: Perry Nuclear Power Plant, Unit 1
Inspection At: Perry Site, Perry, Ohio
Inspection Conducted: August 7-23, 1989
Inspector:
P. L. Hiland
W
f!7/77
Approved By:
M. A. Ring, Chief
Reactor Projects Secti n 3B
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Date
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Inspection Summary
Inspection on August 7-23,1989 (Report No. 50-440/89022(DRP))
Areas Inspected:
Routine, unannounced safety inspection by the senior resident
inspector of licensee response to the Diagnostic Evaluation Team Report of the
Perry Nuclear Power Plant dated May 1989.
The inspection performed consisted
of reviewing the licensee's response to the DET report which was provided in
letter PY-CEI/NRR-1043L, dated July 29, 1989.
Results: Of the area inspected, three violations were identified. The first
concerned the licensee's failure to take corrective action for a previous
violation involving control of unit staff overtime (paragraph 2.c).
The second
violation concerned the licensee's failure to control manual thrcttle valve
positions (paragraph 2.g).
The third violation concerned inadequate performance
of a surveillance instruction (paragraph 2.0).
Three unresolved Items were identified that require additional review to
determine if a violation existed (paragraphs 2.k, 2.n, and 2.p).
Fifteen
Open Items were identified, one of which (paragraph 2.t) required an additional
response from the licensee.
These open items were initiated to followup the
licensee's actions as stated in their response to the DET report.
All of the above items were receiving management attention; however, the
violation resulting from failure to control unit staff overtime is a repetitive
violation for which the licensee's previous corrective action was ineffective.
89o91co171 eso;jj
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DETAILS
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1.
Persons Contacted
a.
Cleveland Electric Illuminating Company (CEI)
- G. Dunn, Compliance Engineer (NSD)
- M. Gmyrek, Manager, Operations Section (PPOD)
- R. Newkirk, Manager, Licensing and Compliance Section (LCS)
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- K. Pech, Manager, Technical Section (PPTD)
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- F. Stead, Director, Nuclear Support Department (NSD)
b.
U.S. Nuclear Regulatory Commission
- P. Hiland, Senior Resident Inspector, RIII
- Denotes those attending the exit meeting held on August 23, 1989.
2.
Followup of Licensee Response to DET Report For Perry Nuclear Power Plant
(92701, 92700)
By letter dated May 30, 1989, the Executive Director for Operations,
Mr. Victor Stello, Jr., forwarded the Diagnostic Evaluation Team (DET)
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Report for the Perry Nuclear Power Plant to the licensee. That letter
requested the licensee to evaluate the report and provide a written
response.
Letter PY-CEI/NRR-1043L, dated July 29, 1989, provided the
licensee's evaluation and response to the DET report. During this
report period, the inspector reviewed the licensee's response and
identified the following items:
a.
Equipment Problem Resolution
As detailed in Sections 3.1.2, 3.2.5, and 3.6.2 of the DET inspection
report, a number of equipment problems were identified during the
licensee's first operating cycle. The licensee responded to that
issue by detailing the number of work items and design changes that
had been completed during the first operating cycle and during the
first refueling outage. The licensee stated that utilization of their
quarterly maintenance schedule would serve to maintain the backlog of
corrective maintenance items low.
The inspectors will monitor the licensee's performance to adequately
resolve equipment problems in accordance with their quarterly
maintenance schedule.
This item will be tracked as an Open Item
(440/89022-01(DRP)).
b.
Human Relations / Personnel Performance
As detailed in Sections 3.1.7 and 3.1.8 of the DET inspection report,
several issues were considered to have had a negative influence en
personnel perfortnance. The licensee responded to this issue by
stating the actions that had been tsken and were planned to be taken
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to improve personnel performance.
Those actions included a review of
job descriptions, supervisory training, development of a career
opportunities progran, and creation of a Human Resource Council.
The inspectors will review the actions taken by the licensee to
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improve human relations as an Open Item (440/89022-02(DRP)).
c.
Operator Overtime
As detailed in Section 3.2.2 of the DET inspection report, licensee
management oversight of operator overtime was ineffective. A licensee
audit identified nine instances where overtime guidelines had been
exceeded without prior approval.
The licensee's failure to comply
with Plant Administrative Procedure (PAP)-0110, " Shift Staffing and
Overtime," was the subject of a Notice of Violation (440/88012-02(DRP))
issued following an Operational Safety Team Inspection (OSTI)
conducted in March 1988.
In addition, the inspectors noted through
review of Action Request 0002 (Audit No. 89-12), dated July 13, 1989,
additional instances of failure to comply with PAP-0110. The licensee
responded to Notice of Violation 440/88012-02 via letter
PY-CEI/NRR-0926L dated October 19, 1988.
In that response the
licensee identified the cause for the violation to be personnel error
and the corrective action to prevent recurrence was to remind
supervisors of their responsibility to implement the requirements of
PAP-0110.
10 CFR 50, Appendix B, Criterion XVI, " Corrective Action,"
requires in part that measures shall be established to assure
conditions adverse to quality are promptly identified and corrected.
Failure of the licensee to correct the deficiencies identified in
the control of unit staff personnel overtime is a Violation
(440/89022-03(DRP)).
d.
Operator Aids
As detailed in Section 3.2.2 of the DET inspection report, control
of " operator aids" was found to be ineffective. The licensee's
response stated that the specific items discussed in the DET report
were corrected.
In addition, the licensee stated that a walkdown of
all in plant control panels would be completed by December 31, 1989.
The inspectors will review the results of that walkdown and perform
independent plant walkdowns to confirm the adequacy of the
licensee's actions as an Open Item (440/89022-04(DRP)).
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e.
Performance Standards of Nonlicensed Operators
As detailed in Sections 3.2.2 and 3.2.8 of the DET inspection report,
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adequate performance standards for non-licensed operators were not
established. The licensee responded to this item by providing a
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seven point Action Plan that was to address the adequacy of
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performance standards for non-licensed operators by September 1989.
The inspectors will review the actions taken by the licensee to
improve performance standards of non-licensed operators as an Open
Item (440/89022-05(DRP)).
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f.
Emergency Instructions
As detailed in Sections 3.2.2 and 3.2.4 of the DET inspection report,
the Perry Emergency Instructions were considered difficult to use.
The licensee's response to this item stated that improvements to the
Perry Emergency procedure format were ongoing and that additional
" Human Factor" improvements would be evaluated during incorporation of
the latest revision to the Emergency Procedure Guidelines scheduled
for July 1990. The inspectors will review the licensee's evaluation
of " Human Factors" after incorporation of the latest revision to the
Emergency Procedures Guidelines in July 1990 as an Open Item
(440/89022-06(DRP)).
g.
Manual Throttle Valve Positioning
As detailed in Section 3.2.3 of the DET inspection report, the
administrative control of manual throttle valve positioning was
inadequate.
10 CFR 50, Appendix B, Criterion V, requires in part
that activities affecting quality shall be prescribed by documented
instructions.
Failure of the licensee to provide adequate instructions
to assure throttle valves in the Emergency Closed Cooling, Essential
Service Water, and Residual Heat Removal systems were restored te
their required throttled position following performance of a
surveillance or test is a Violation (440/89022-07(DRP)).
The
licensee's response to this item stated that a locked throttle valve
program was implemented and that system valve lineups were revised to
identify locked throttle valves.
In addition, the licensee was to
review all Surveillance Instructions (SVIs) to verify that system
restoration lineups reflected the correct position of manual throttle
valves. The inspectors were informed by the licensee that review of
SVIs was to be completed by December 31, 1989.
The corrective actions noted above and detailed in the licensee's
response to the DET inspection report were adequate to address the
subject violation of 10 CFR 50, Appendix B, Criterion V, and a
further response is not required.
However, this item will remain
open pending the inspector's review of completed corrective actions.
h.
Implementation of Corrective Actions
As detailed in Section 3.2.8 of the DET inspection report, not all
of the licensee's recommended corrective actions following a 1988
"special evaluation" were implemented.
The licensee's response
stated that a re-evaluation of their recommended corrective actions
from that "special evaluation" would be performed and any new items
would be implemented by December 31, 1989. The subject of the
licensee's re-evaluatice ind implementation of any additional
corrective actions to their "special evaluation" is considered an
Open Item (440/89022-08(DRf)) pending the inspector review of
completed licensee action.
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i.
Manual Valve Testing and Preventive Maintenance
As detailed in Sections 3.3.3 and 3.4.1 of the DET inspection report,
several manual valves which provided an accident mitigation function,
were not tested nor were adequate preventive maintenance requirements
imposed. The licensee's response stated that a review of their
manual valve preventive maintenance program was performed. The
results of that review were to be entered into the licensee's scope
for preventive maintenance activities.
In addition, the licensee
stated that manual valves manipulated within the Plant Emergency
Instructions were incorporated into their Pump and Valve Inservice
Testing Program Plan. The subject of testing and performance of
preventive maintenance on manual valves is considered an Open Item
(440/89022-09(CRD)) pending the inspector's review of the licensee's
completed actt'a,
j.
Equipment Tret< Enalysis
As detailed in Section 3.3.6 of the DET inspection report, the
effectiveness of equipment trend analysis based on maintenance
history was diminished due to incomplete maintenance history records.
The licensee's response stated that their reliability information
tracking system (RITS) would improve equipment trending.
The RITS
program was to be operational during the fourth quarter of 1989. The
subject of equipment trend analysis is considered an Open Item
(440/89022-10(DRP)) pending the inspector's review of the
implementation of the RITS.
k.
Post Maintenance Testing of SLC System
As detailed in Section 3.3.' of the DET inspection report, the post
maintenance test of Standby Liquid Control (SLC) system valve F001A
was inadequate.
The licensee's response stated that adequate
administrative controls existed to assure the proper review of post
maintenance testing prior to returning the SLC system to service.
The subject of adequate post maintenance testing on SLC valve F001A
is considered an Unresolved Item (440/89022-11(DRP)) pending the
inspector's review of the administrative controls that were in place.
1.
Check Valve Testing
As detailed in Section 3.4.1 of the DET inspection report, closure
testing of various check valves was not specified by current
administrative procedures. The licensee's response stated that
their Inservice Test Program (as noted by the DET) was undergoing
revision at the time of the DET inspection. The revised test program
added additional requirements to 189 check valves.
However, the
inspectors noted that check valve E51-F011 was not required to be
tested for Alternate Position Verification (AP). The subject of
check valve E51-F011 not required to be AP tested is considered an
Open Item (440/89022-12(DRP)) pending the inspector's review of the
licensee's testing criteria.
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' Guidance on Erratic or Abnormal Valve Actions
As detailed in Section 3.4.1 of the DET inspection . report, no written
guidance or criteria existed'for identifying erratic or abnormal
valve action. The licensee's response to this item incorporated a
note in their IST Administrative procedure to_ notify the Lead ISI
Engineer of erratic or abnormal valve operation. However, it was' not
clear to the inspectors that adequate and specific criteria had been
established. The subject of guidance on Erratic or Abnormal Valve
Actions during testing is considered an Open Item (440/89022-13(DRP))
pending the inspector's review of the licensee's implementation of-
the revised guidance.
n.
Pump Test Criteria
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As detailed in Section 3.4.1 of the DET inspection report, the
licensee revised ESW pump test criteria less conservative than
required by ASME Section.XI. The licensee's response stated that
revised pump test criteria were performed under.a formal documented
program as permitted by ASME Code Interpretation XI-1-79-19. ..However,
the inspectors were not provided with adequate technical justification
to revise pump test criteria. The subject of revising pump test
criteria based on an adequate and documented basis is considered an
Unresolved Item (440/89022-14(DRP)) pending the inspector's further
review of the licensee's documented basis for revising pump test
criteria.
o.
Inadequate Surveillance Test
As detailed in Section 3.4.1 of the DET inspection report, position
indicator testing required for vacuum breaker valves '1M16-F020A and
' F020B was not performed properly on February 20, 1989. The licensee's
response stated that the test was correctly reperformed.
Appendix B, Criterion'V, requires that activities affecting quality
shall be accomplished in accordance with instructions.
Sailure of
the licensee to accomplish drywell vacuum breaker testing in
accordance with Surveillance Instruction (SVI)-M16-T2001 is a
Violation (440/89022-15(DRP)).
p.
Vacuum Breaker Surveillance Test
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As detailed in Section 3.4.2 of the DET inspection report, the
inspectors concluded that Surveillance Instruction (SVI)-M16-T0414
was technically deficient. That surveillance instruction directed
that drywell vacuum breaker relief valves be opened first with their
power operators before relief settings were measured and verified.
Opening the drywell vacuum breakers prior to collecting "as-found"
data appeared to invalidate the test. The licensee's response to
this item stated that the "as-found" setpoint of the drywell vacuum
breakers was not adversely impacted by first opening the valves with
their power operators. The inspectors will review the licensee's
response with the staff to evaluate its acceptability. The subject
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. of adequate' testing of drywell ' vacuum breakers is considered an
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Unresolved Item (440/89022-16(DRP)) pending further review of the
. licensee's response.
q.
Work Package Rejection Rate
As detailed in Section 3.5.4 of the DET inspection report, the
inspectors concluded that the continued large. rejection rate in
final work packages was due.to a lack of management attention. The
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inspectors will continue to monitor the licensee'sl action with regard
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to improving' final work order packages.
The subject of final work
order package rejection rate is an Open Item (440/89022-17(DRP))
pending the. inspectors review of licensee actions.
r.
Root Cause Analysis Program
As detailed in Sections 3.5.7 and 3.6.8 of the DET inspection report,
.the inspectors concluded that several weaknesses in the licensee's
root cause analysis program existed. The licensee's response to this
item detailed their initiatives to assure better root cause. analysis.
The subject of.the licensee's initiatives to improve their root cause
analysis program is considered an Open Item (440/89022-18(DRP))
pending the inspector's review of the effectiveness of implementing
those initiatives.
s.
Independent Safety Engineering Group (ISEG)
As detailed in Section 3.5.8 of the DET inspection report, the
inspectors concluded that the ISEG had limited effectiveness due to
a lack of adequate management attention and support. The licensee's
response-to this item stated that a revised ISEG charter was developed
'to correct problems noted with management support of the ISEG. .The
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licensee stated that their revised ISEG charter would be in place in
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1989. The subject of ISEG effectiveness is considered an Open Item
(440/89022-19(DRP)) pending the inspector's review of actions taken
by the. licensee.
t.
Contractor Support
As detailed in Section 3.6.1.3 of the DET inspection report, the
inspectors expressed a concern that, since selected areas in the
Nuclear Engineering and Plant Technical departments relied heavily
on contractor support, a rapid reduction .in contractor support could
adversely impact the licensee's ability to accomplish engineering
support tasks. The licensee's response to this item stated that a
five year plan was under development and that any reductions in
staffing size would be consistent with the goals of that five year
plan. The inspectors advised the licensee that their response to
this item was general in nature and did not explicitly discuss
actions that would be taken to minimize the impact of rapid contractor
support reduction.
The inspectors requested and the licensee agreed
to provide an additional response to this item. The subject of
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contractor support is considered an Open Item (440/89022-20(DRP))
pending receipt and the inspector's review of the requested additional
information,
u.
Design Change Packages
As detailed in Section 3.6.4.1 of the DET inspection report, the
inspectors estimated that about 500 Design Change Packages (DCPs)
would be outstanding at the beginning of the second cycle. The
inspectors noted that the licensee did not have a long range
implementation schedule to reduce the number of DCPs.
The licensee's
response to this item stated that a DCP review committee had been
created and that priorities had been established on issued DCPs as
well as those under development. The licensee further stated that
the results of that effort would be factored into their'five year
plan scheduled to be issued in September 1989.
The subject of DCP
implementation schedule is considered an Open Item (440/89022-21(DRP))
pending the inspectors review of the licensee's plan for implementation.
3.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether it is an acceptable item, a violation or a
deviation.
Three unresolved items were identified in Paragraphs 2.k.,
2.n., and 2.p.
4.
Open Inspection Items
Open inspection items are matters which have been discussed with the
licensee, which will be reviewed further by the inspector, and which
involve some action on the part of the NRC or licensee or both.
Fifteen
(15) open inspection items disclosed during the inspection are discussed
in Paragraph 2.
5.
Exit Interviews (30703)
The inspectors met with the licensee representatives denoted in Paragraph 1
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throughout the inspection period and on August 23, 1989,
The inspector
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summarized the scope and results of the inspection and discussed the
likely content of the inspection report. The licensee did not indicate
that any of the information disclosed during the inspection could be
considered proprietary in nature.
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Inspection Report 50-440/89022
Appendix
OET Eval.
OET
RIII
Results
Details
Followup
Paragraph
Paragraph
Action Items
2.1.1.1
3.1
None
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3.1.2
01 89022-01
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3.1.3
None
.4
3.1.4
None
.5
3.1.5 (3.2.2)
01 89022-04
.6
3.1.5
None
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3.1.7
01 89022-02
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3.1.7 (3.1.8)
OI 89022-02
2.1.2.1
3.2.2
NOV 89022-03
OI 89022-04
.2
3.2.2 (3.2.8)
01 89022-05
.3
3.2.2
None
.4
3.2.2
01 89022-04
.5
3.2.2 (3.2.4)
OI 89022-06
.6
3.2.3
NOV 89022-07
.7
3.2.5
OI 89022-01
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3.2.6
None
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3.2.7
None
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.10
3.2.8
OI 89022-08
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3.2.9
None
2.1.3.1
3.3.1
None
.2
3.3.3 (3.4.1)
01 89022-09
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3.3.3
None
.4
3.3.4
None
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3.3.5 (3.6.5.3)
None
.6
3.3.6
OI 89022-10
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3.3.7
UI 89022-11
2.1.4.1
3.4
None
.2 (1-6)
3.4.1
01 89022-12
01 89022-13
UI 89022-14
.3 (1-4)
3.4.1
NOV 89022-07
NOV 89022-15
.4
3.4.1
None
.5
3.4.1
None
.6
3.4.1
NOV 89022-15
.7
3.4.2
UI 89022-16
.8
3.4.3
None
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Inspection Report 50-440/89022
Appendix (Continued)
DET
DET
RIII
Eval.
Details
Followup
Paragraph
Paragraph
Action Items
2.1.5.1
3.5.1
None
.2
3.5.2
None
.3
3.5.3
None
.4
3.5.4
OI 89022-17
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3.5.5
None
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3.5.6
None
.7
3.5.7
01 89022-18
.8
3.5.8
OI 89022-19
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3.5.8
None
2.1.6.1
3.6
01 89022-18
.2
3.6.1
01 89022-20
.3
3.6.1
None
.4
3.6.1
None
.5
3.6.2
None
.6
3.6.2
OI 89022-01
.7
3.6.2
None
.8
3.6.2
None
.9
3.6.3
None
.10
3.6.4.1
OI 89022-21
.11
3.6.5
None
.12
3.6.6 (3.6.7)
None
.13
3.6.8
OI 89022-18
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