PY-CEI-NRR-1416, Responds to Open/Unresolved Items Noted in Insp Rept 50-440/91-13 on 910819-30.Corrective Actions:Labeling Issue Will Be Resolved Via Rev to OAP-0507 & Design Change Will Be Pursued to Install Permanent Storage for Ladders

Responds to Open/Unresolved Items Noted in Insp Rept 50-440/91-13 on 910819-30.Corrective Actions:Labeling Issue Will Be Resolved Via Rev to OAP-0507 & Design Change Will Be Pursued to Install Permanent Storage for Ladders

ML20086E010
Person / Time
Site:	Perry
Issue date:	11/22/1991
From:	Lyster M CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1416, NUDOCS 9111270025
Download: ML20086E010 (12)

Text

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PERRY NUCLEAR POWER PLANT d oe Michael D. Lyster

'f fER ( 10 4 081 PERRY, OHIO 44001 VICE PRESIDENT . NUCLEAR (216) 259-3737 November 22, 1991 PY-CEI/NRR-1416 L U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Response to Open and Unresolved Items Gentlemen:

This letter acknowledges receipt of the Open and Unresolved Items contained within Inspection Report 50-440/91013 dated September 23, 1991. The report documented the results of the Emergency Operating Procedures (EOP) inspection led by Hs. P.'Rescheske on August 19 - 30, 1991.

Many of the NRC identified discrepancies were resolved prior to the Enforcement Conference held on September 30, 1991. However, the inspection report contains numerous specific discrepancies that vill require additional time and effort and additional. procedural changes to resolve. In accordance with the Operations Administrative Procedure, (OAP-0507) " Development of Plant Emergency Instructions", verification and validation vill be required. This detailed program requires an extensive commitment of resources and time for revisions to the procedures. -Therefore, the resolution of the specific discrepancy items identified in the inspection report vill be completed concurrently with the current procedure rewrite effort. Several of the items are scheduled.for near term completion. . The remaining items are expected to be complete by December, 1992.

l Our response to each of the Open Items and the Unresolved Item discussed in the.

inspection report is provided in the Attachment.- Additionally, our current schedule for simulator activities is included in the response to Open Item 91013-09b. -It-is our understanding the.NRC will be on site the veek of l :- December 2, 1991 to' develop scenarios and observe operator use of the PEIs on

i. the simulator. Although we understand the NRC's desire to close the open items

generated by this inspection, it is our expressed opinion that the m e t

appropriate time to observe-the PEI use on the new simulator vould be the'end L

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. Document Control Desk PY-CEI/NRR-1416 L November 22, 1991 ,

of February or early March. Because of the recent delivery and installation of ,

a new simulator the operators must become acclimated to its greatly expanded ,

capabilities. Although we have every confidence in these instructions, we are concerned that the "nevness" of the simulator vill prevent recognition of our ability to demonstrate the quality and usability of the PEls.

If you have questions or comments concerning this matter, please contact Mr. K. P. Donovan, Licensing and compliance Manager, at (216) 259-3737 extension 5606.

Sincerely,

) 1 .

Michael D. Lyster HDL TSHisc +

Attachment

- cc: NRR Project Manager 4 Sr. Resident Inspector >

USNRC Region'III ,

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Attachment PY-CEI/NRR-1416 L Page 1 of 10 50-440/91013-01 Restatement of Open Item The Team identified several procedures which required clarification or enhancements to be accomplished effectively. The Team also identified several procedures which either vould not accomplish their intended function or did not exist. Several of the deficiencies involved missing or ambiguous references to supporting procedures, incorrect or missing procedures, or undocumented / unjustified deviations from the EPGs or PSTG. In addition, the Team identified several areas which need further review by the licensee. The i examples which are considered apparent violations are discussed in Paragraph 4 4.C. Other examples vere as follovs, with additional examples detailed in '

Appendix B and Paragraph 5 (Valkthroughs): 1 (1) PEI-SPI 1.0, " Control Rod' insertion." Step 3d, directed the operator to start and run in tandem a second CRD pump to increase CRD pressure; however, no instructions vere provided to perform this task. The Draft Revision 1 SPI 1.0 referred to SPI 4.1 to accomplish the start of the  !

second pumps however, the steps referenced increased flow to the RPV, while the intent of SDI 1.0 was to increase CRD drive pressure.

(2) PEI-SPI 1.0 did not provide a method for individually scramming rods. l This was required by EPG Step RC/0-7.2 and the PSTG.

(3) A procedure did not exist to de-energize electrical equipment in containment (to an elevation of 61 feet), when vater is added to containment during flooding.  :

Resolution of these three issues, as well as related examples in Appendix B, vill be tracked as an Open Item (440/91013-01(DRS)).

Corrective Actions Completed and Planned All of the items identified in this Open Item have been evaluated. The actions to be accomplished for the three items detailed above are included below. Specific recommendations from the related examples in Appendix B have either been incorporated into the current revision of the PEI-3PIs, vill be incorporated into the next revision, or have justifications provided for those which vill not be incorporated.

(1) Issue one vill be resolved by revising SPI section 1.3 to include details for runnirig a second pump to increase CRD pressure to drive control rods.

This will be accomplished when the SPIs are revised.

(2) Issue two has been evaluated by the Engineering department and it was determined that this method is effectively accomplished in SPI 1.1, 1.2, and 1.4. A deviation from the EPG vill be developed and included in the-revision to the PSTG.

(3) Issue three is currently being evaluated by the Engineering department.

Actions to address this issue vill be incorporated into the SPIs, 12 it >

is deemed appropriate.

1 Attachment PY-CEI/NRR-1416 L Page 2 of 10 50-440/91013-04 Restatement of Open Item The NRC's conditional exemption to not have a secondary containment control guideline required that the licensee consider incorporating the applicable portions of the guideline in other procedures (e.g., guidelines covering events which involve leakage outside both containment structures). In letters to the NRC dated June 26, 1989, and October 11, 1990, the licenser committed to complete the conversion to Revision 4 of the EPGs, including the development of procedures related to secondary containment control, by October 1991. During the inspection, the Team tound no evidence that the licensee had modified procedures to meet the intent of the guideline. For example, the licensee had not enhanced the Radioactivity Release Control PEI to encompass the control cf releases from locations other than the turbine building.

Therefore, the Perry PEls do not contain provisions for monitoring and controlling the release of radioactive materials in the Auxiliary, Inter nediate, or Fuel llandling Buildings in the main sequence of the PEls.

This is considered an Open Item (440/91013-04(DRS)), pending completion of licensee action and further review by the NRC.

Action Completed As stated in our October 31, 1991 response on the Secondary Containment Control issue (PY-CEI/NRR-1405 L), ve have reviewed our response from October 11, 1990 and the recommended action in the generic EPGs. Detailed reviews by Operations / Engineering staff have determined that the current guidance in the Off-Normal Instructions (ONIs) and Alarm Response Instructions (ARIs) provides monitoring of the appropriate parameters (area temperatures, radiation and water level), and also provides the appropriata operator actions. It was therefore determined that the intent of the secondary containment control guideline has been incorporated into plant instructions. The reviews that provided the basis for this conclusion are being maintained as on-site records.

4 4 Attachment PY-CEl/NRR-1416 L Page 3 of 10 50-440/91013-05 Restatement of Unresolved Item In a deviation from the RPV Control EPG (Revision 4), the licensee chose not to develop any alternate boron injection procedures. EPG Step RC/0-6 states that if boron cannot be injected with SLC, then inject boron into the RPV by one or mote of the following alternate methods: CRD, HPCS, MVCU, feedvater, HPCI, RCIC, and Hydro Pump. The licensee's documented " technical" just3fication for this deviation from the EPGs discussed expense, necessary complexity, time frame required to place in service, and licensing considerations. According to the licensee, there was a risk that several of the methods (e.g., HPCS, RClC, CRD , or RVCU) could render those systems inoperable for other functions and therefore the risk was greater than the ATVS they would be attempting to mitigate. The licensee provided no justification for this position. The Team did not consider this adequate technical justification for deviating from the EPG.

The SLC system at Perry is not significantly different than that of other BVRs (and is less reduadant than some plants which have three trains of SLC). Most other BVRs have developed multiple alternate SLC injection procedures.

Because the major components of the SLC at Perry are within the Mark III

--i ma r' containment (versus external to containment as in the Mark I design),

la the event of an ATVS, the Perry SLC is far more likely to become inaccesslble than the SLC sys. ems at Mark I and II containment sites, thus potentially precluding any emergency repair activities on the system. The fact that Perry had installed a SLC heated mixing tank outside containment (in addition to the SLC storage tank within containment) would probably make the developm(nt of alternate SLC procedures easier than for those developed at other BVR plants. The philosophy of the EPPs is to plan for anticipated problems in the SLC system. The licensee appears not to have planned for potential problems even thouGh their SLC system is less accessible for repcirs.

The acceptability of the license's exemption in this area is considered an Unresolved Item (440/91013-05(DRS)), pending receipt of licensee technical justification and subsequent review by NRR.

Technical Analysis Engineering evaluate' this issue based on probability of a SLC failure and its

-contribution to core Jamage and on the probability of successfully mitigating an ATVS with an alternate SLC injection. A preliminary PRA analysis determined that an ATVS vith SLC failure event contributes 0.6% to the core damage probability and has a frequency of 1.01E-06 per reactor year. Because the time to add boron to the water source for the proposed alternate systems is large, the efficacy of this step is questionable. This is acknowledged in the NRC's Safety Evaluation on alternate SLC injection in EPG Revision 4:

"This step is a 'last ditch' effort with a low probability of success."

However, a detailed analyris vill be performed to illustrate the relative probabilities for success using the alternate SLC injection methods proposed in Revision 4 *- the EPG. A procedure incorporating the methodology with the highest probability for success vill be developed if appropriate. If not, adequate technical jm:tification vill be documented and submitted to NRR for review.

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l Attachment PY-CE1/NRR-1416 L Page 4 of 10 50-440/91013-06 Restatement of Open Item The results from the walkthroughs were as follows, with additional detailed comments relating to specific procedures provided in Appendix B:

(a) In general, the operators had little difficulty locating in-plant or control room components required for accomplishing PEI tasks. The licensee had special PEI-related labeling both in the control room and the plant; however, the labeling did not extend to all PEI-related components. Further the Team noted that this labeling effort was not a documented or controlled program, and implementation was left to the discretion of the PEI Coordinator. The licensee has drafted a plan to control and maintain PEI component labeling.

(b) The Team determined that several in-plant actions vould only be accomplished after ; me time delay, due to the lack of required tools and equipment; specific y pe/ size of screwdriver, vrench, " cheater bar,"

etc., may be requireu and not readily available. For example, the recirculation line stop valve, 1P81-F553, required a three foot long cheater bar to overcome the torque, however, the cheater bar was not located. The licensee has drafted a plan to contrcl and maintain an additional PEI toolbox (in SBill), along with the existing toolbox in the control room. The Team noted that the Draft Revision 1 SPIs included a tool list; however, the procedures did not identify type, size and other specific requirements, and not all required tools / equipment vere listed.

Several valves which must be operated during performance of the SPIs are located high above the floor (e.g. 15-20 feet), with no dedicated or prestaged ladders. For example, the following valves vould not be accessible without a ladder or scaffolding: 1E12-F552B, 1E12-F099B, 1P45-F572, 1P45-F573, 1P45-F593, 1P45-F632, 1G42-F509, 1E12-F552, and 1E12-F099A. The Team also noted that the condensate pump discharge valves ('N21-F513A/B/C) require about 2-3 hours to open manually. The licensee should evaluate the time required to take the action and its impact on success of the evolution. Motor assists may be effective in reducing times. The Team also noted that the handvheel had fallen off the 1N21F513B valve.

(ci The Team identified other areas of potential time delays, which the licensees V&V program failed to consider, such as: The time constraints associated with the PEI action, adequacy of normal and emergency lighting in proximity of the PEI component, and accessibility problems related to post-accident radiological and environmental hazards.

(d) Valkthrough of some SPIs and S0Is revealed the need for more definitive guidance as to which sections of procedurec should be performed. As an example, some SOIs contain two or more options for accomplishing the task (e.g., Sections 4.9 and 7.1 of the Backup Hydrogen Purge System procedure SOI H51/56). While operators could usually determine which operation within a procedure was the more appropriate for a given situation, they expressed a desire for more definitive guidance to eliminate these decision-making processes.

1

Attachment PY-CEI/NRR-1416 L Page 5 of 10 (e) The Team identified several potential training deficiencies during the walkthrough, which are discussed in Paragraph 8.

(f) Many of the SPIs for the defeats and bypasses of interlocks and isolations require the lifting and relanding of leads within panels (at terminal strips and relay blocks). The licensee should check logic diagrams to see if some of these SPIs could be performed with jumpers, instead of the present practice of using lifted and landed leads (a very risky evolution under accident conditions).

(g) The Perry design afforded the convenience of having most instrumentation panels required for performance of SPIs located within the control room.

The posting of accurate panel location drawings throughout the control room was a positi7e feature in using the SPIs.

(h) The licensee had not included the curves developed to support PEI Caution 1 (Level Indication Temperature Affects) in the caution notes on the PEI flovcharts. Interviews with several operators indicated that they know where to find the curves within the Special Plant Instructions SPI 9.0.

Operators further pointed out that the curves had been reproduced as an operator aid and posted on the center concrete column in the control room. The Team noted that the operator aid appeared to be uncontrolled, lacking standard industry controls for such aids, including copy number, date, revision number, and approval for posting by operations management.

The licensee explained that operator aids are controlled, but do not contain any of these typical indications of control at Perry. The Team questioned how control could be maintained in the absence of any inventory or audit markings on the aids (i.e., hov is control maintained if the number of copies of an aid and their location is unknovn). This point was clearly reinforced when the licensee stated that only one of the SPI 9.0 aids existed, followed by the Team noting that there vas one in the control room and another in the simulator. The licensee should consider implementing industry standard quality control practices for operator aids.

Resolution of the above weaknesses identified during the walkthroughs, and the related examples in Appendix B, vill be tracked as an Open Item (440/91013-06(DRS)).

Corrective Actions Completed and Planned (a) The labeling issue vill be resolved by a revision to 0AP-0507 to incorporate a documented program for installation and control of PEI labels. PEI specific equipment / components are currently being labeled.

(b) The current SPI revision includes a listing of the tools required. Type and size of tools are not included since components manipulated are of common size and type. Plans are being made to provide a dedicated container, with the required tools, for each section of the SPIs.

A design change is being pursued to install permanent storage for ladders near the components that require one. As an interim solution the labels of the affected equipment have been modified, directing the operators to the proper storage location for a dedicated PEI ladder.

Attachment PY-CE1/NRR-1416 L Page 6 of 10 A design change is being evaluated to change slov opening valves to motor operated valves. A dedicated air operated vrench for operation of the major valves is staged for ure.

(c) The factors of time, lighting, and radiological and environmental hazards during the V6V process were evaluated.

Time requirements derived from validation data for Alternate Injection System line-ups vill be included in the flow charts when they are revised so operators can make an informed choice. Other SPI sections are unique, and their time requirements vill be evaluated on a case-by-case basis for addition to the flow charts.

Flashlights and batteries (checked quarterly) are located in the PEI toolbox. Because Operation's philosophy is that during accident conditions, operators vill work in teams, not individually, the use of flashlights vill not encumber the operators ability to properly complete the action.

Upon entry to the PEIs, operators vill enter the Radiological Restricted Area with radiological monitoring equipment, which vill provide the operators with indication of abnormal radiation levels. If the condition further degrades, entry into the Emergency Plan vill be required, and operations are then accomplished with teams that include llealth Physics personnel.

(d) Specific sections of SOIs/SPIs vill be referenced for ease of location and simplification for operator use when the SPI's and flow charts are revised. (See open item 50-440/91013-08)

(e) Training improvements are discussed under open item 50-440/91013-08.

(f) Engineering vill evaluate possible improvements in the use of lifted leads in the SPIs. Changes will be implemented with the SPI revision, if appropriate.

(g) No response required.

(h) PAP-0507 addresses the issue of operator aids. The current program has the operator aid listed in the procedure along with a location of posting. The program governing the control of operator aids was reviewed with respect to the team's concern on control of these aids. The administrative restraints prescribed by the current procedure vere determined to be sufficient to maintain current and controlled operator aids.

Completion of the remaining activities referenced above is scheduled concurret.tly with the revision to the PEIs. Activities for the related items from Appendix B have been completed.

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i Attachment PY-CEI/NRR-1416 L Page 7 of 10 I t: ,

50-440/91013-08 Restatement of Open Item The Vriter's Guide and PEls were reviewed for ccnformance with accepted human factors' principles as described in NUREG-0899, NUREG-1358, and NUREG/CR-5228.

Veaknesses in areas considered strongly related to potential human error vere identified in the Vriter's Guide and both the flowcharts and SPIs. These veaknesses are described below. Detailed findings specific to individual procedures are provided in Appendix C (and also supported by examples in Appendix B). Resolution of the weaknesses identified during the human factors review and the related examples (below) and la Appendix C, vill be tracked as an Open Item (440/91013-08(DRS)).

Corrective Actions Planned-The next revision to 0AP-0507 vill resolve the Human Factors comments concerning the Writer's Guide. The flow-charts vill also be revised to incorporate the more detailed guidance given in the new Vriter's Guide revision. 1oth of these revisions vill be made with direct guidance from Human Factors specialists.

Specific items to be evaluated during the revision to 0AP-0507 include conversion of a conditional action step in the EPG into flow chart steps, flow chart movement control,. standardization of procedure referencing, control of paraseology, placement of notes and cautions, caution format, use of concurrent steps, use of. action verbs, consistent use of symbols, use of qualifiers, and.the adequacy of the PEI-SPI Vriter's Guide.

Specific items to be evaluated during the revision to the flow charts include relocating "dryvell pressure > 1.68" step to agree with the PSTG, removal of embedded decision steps, simplification of overly complex steps, inclusion of

_. a procedure reference for RPV depressurization using the main condenser, inclusion of reference (s) for determining if level indication has been restored, and all of_the specific examples referenced in Appendix C.

Justification for non-technical deviations between the PSTG and the flov

- charts will be documented and: justified in the cross reference document.

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Attachment PY-CEI/NRR-1416 L

Page 8 of 10 l 50-440/91013-09a Restatement of Open Item The Team could not determine the effectiveness of training and usability of the PEIs without the use of the simulator. However, during the inspection several areas, described above, were identified which may require additional emphasis during training. Further, the Team identified two general areas which need resolution by the licensee

a. The rules of usage (" philosophy of use" document ) for the PEI flovcharts and SPIs was not complete. Some aspects of procedure use were included in 0AP-0507; others were found in the draft PEI Basis Document. However a number of issues regarding how to use the procedures were not yet defined. As a result, the effectiveness of training on the procedures was reduced. Some variation in operator interpretation of the procedures was identified during the walkthroughs and during interviews. In addition, operator confusion was observed regarding when you can exit the procedure; can you return to action steps or decision steps if moving backvard in a flovchart; and determination of top of active fuel. The need for clarifying information in some parts of the flovcharts was noted in the interviews with operations and training staff. The Team's understanding was that the licensee had identified this weakness, however, this does not change the fact that Perry PEIs, for which operators vere not completely clear on usage, vere currently approved and available in the control room.

b. There was no formal method in place by which the operations staff could maintain an accurate status of abnormal system line-ups (e.g., bypasses of interlocks, cross-connects of systems, etc.). Each operator had developed an individual preference for annotating PEI flovcharts as they were accomplished. The licensee should consider standardizing methods for tracking plant system status and for place-keeping in the PEI flowcharts.

Resolution of the above training related weaknesses (including the potential training deficiencies identified during the walkthroughs), vill be tracked as an Open Item (440/91013-09a(DRS)).

Corrective Actions Completed and Planned

a. A memo was issued by the Operations Section Manager to address the

" philosophy of use" of the PEI flowcharts and SPIs. This information was included in the licensed operator requal training course and was completed on November 1, 1991. Additionally, this information vill be added to the Basis document.

b. An evaluation vill be performed on the methods to status abnormal system line-ups during training sessions on the simulator. If it is determined to be beneficial, an appropriate method will be incorporated into the PEIs as part of the Basis document or flow charts. A statement concerning Perry's philosophy will he included in a revision to 0AP-0507.

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4 i Attachment PY-CEI/NRR-1416 L Pt.ge 9 of 10 The potential. training deficiencies identified during the walkthroughs dealt

- vith label location, the operation of relays and sliding links, and specific PEI-definitions. The general use and understanding of PEI red labels, the removal process for relays and the use of sliding links vill be covered during the licensed operator requalification training. Training vill reemphasize the definitions for the criteria to determine its (1) the reactor was shutdovn

- vith boron,-(2) emergency depressurization was anticipated, and (3) core cooling was adequate.

Inspectors felt the logic used in PEI-M51/56, Dyrvell and containment hydrogen

-control with no method to determine hydrogen concentration was contrary to the symptomatic approach. An engineering evaluation, of the training given with respect to'the RPV vater level and the generation of hydrogen, confirmed that the present training guidance for determining when to turn on the hydrogen ignitors was correct.

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50-440/91013-09b-Restatement of Open Item Further assessment by the NRC of the effectiveness of training and usability of the PEIs utilizing the Perry simulator is required, and vill be tracked as an.Open Item (440/91013-09b(DRS)).

Response

The-following is a schedule of simulator activity. This should assist you with scheduling any planned NRC activities.

Requal Cycle 8- . November 11 - December 20 ,

Requal Cycle 9 January 6 - February 14 Annual Exam Cycle February 17 - March 27

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