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{{Adams | |||
| number = ML20203D824 | |||
| issue date = 02/20/1998 | |||
| title = Insp Rept 50-440/97-21 on 971202-980127.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support | |||
| author name = | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000440 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-440-97-21, NUDOCS 9802260157 | |||
| package number = ML20203D810 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 14 | |||
}} | |||
See also: [[see also::IR 05000440/1997021]] | |||
=Text= | |||
{{#Wiki_filter:_ _ _ _ . _______- -_ | |||
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U. S. NUCLEAR REGULATORY COMMISSION l | |||
REGION lil | |||
Docket No: 50-440 | |||
License No: NPF 58 | |||
Report No- 50-440/97021(DRP) | |||
Licensee: Centerior Service Company | |||
Facility: Perry Nuclear Power Plant | |||
Location: P. O. Box 97 200 | |||
Perry, OH 44edi | |||
Dates: December 2,1997, to January 27,1998 | |||
Inspectors: D. Kosloff, Senior Resident laspector (SRI) | |||
J. Clark, Resident inspector (RI) | |||
S, Campbell, SRI, Davis-Besse | |||
K. Zellers, RI, Davis Besse | |||
Approved by: Thomas J. Kozak, Chief | |||
Reactor Projects Branch 4 | |||
' | |||
, | |||
, | |||
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9002260157 900220 | |||
PDR ADOCK 05000440 | |||
0 FDR | |||
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EXECUTIVE SUMMARY | |||
Perry Nuclear Power Plant | |||
NRC inspection Report No. 50-440/97021(DRP) | |||
This inspection included a review of tespects 9l licensee operations, maintenance, engineering, | |||
and plant support. The report covers aneight week period of resident inspection. Three | |||
violations of NRC requirements were identified. | |||
Operations | |||
. | |||
The conduct of operations was generally effective and professional. Communications I | |||
among operators and within the operations department were not as effective as had been | |||
observed during previous inspection periods (Section 01.1). | |||
. | |||
Good preparations for activities associated wah unusual plant conditions and the | |||
relatively good material condition of the plant, notwithstanding the electro-hydraulic | |||
control system and off gas cooling syt. tem problems, led to effective operator responses | |||
to the automatic reactor scram and the chemical spill during this inspection period | |||
(Section 01,3). | |||
. | |||
The inspectors concluded that the guidelines and expectations for the change in the | |||
equipment tagging policy were not initially clearly communicated to the operators which | |||
resulted in some degraded equipment not being tagged as expected by operations | |||
management (Section O2.1). | |||
Maintenance | |||
. | |||
Effective preparations led to the completion of a number of maintenance activities during | |||
an unanticipated two day reactor shutdown which resulted in the resolution of several | |||
outstanding material condition deficiencies. Effective planning and work execution led to | |||
a relatively low corrective and preventative maintenance item backlog (Section M7,1). | |||
. | |||
The licensee inadvertently allowed the degradation of required raceway markings over | |||
time to the extent that some were either i!!egible or missing, which was a violation of NRC - | |||
requirements (Section M7.2). | |||
Enaineerina | |||
. | |||
Aninadequate evaluation of a design change to the electro-hydraulic control system | |||
contributed to an automatic scram (Section E2.2). | |||
Plant Support | |||
. | |||
Actions to verify fire doors were closed on a daily basis were generally effective. | |||
However, the licensee failed to recognize that a floor sealant applied in the EDG rooms | |||
introduced the possibility for fire doors to stick open, which resulted in a violation of NRC | |||
requirements when a fire door was identified by an inspector to be stuck open | |||
(Section P1.1). | |||
2 | |||
. . _ _ . _ _ _ . _ _ _ . - _ _ _ . _ - .. . . . _ _ _ . _ . _ . . . _ . _ . _ . _ - _ _ _ . _ _ . . . _ _ , . _ _ _ _ . _ | |||
,- - | |||
, | |||
h | |||
.+ Combustible materials were generally well controlled,- However, the inspectors identified | |||
a violation involving the placement of excess combustible material in ars ESW pump | |||
house combustible free zone (Section P1.2). | |||
3 | |||
.- | |||
. | |||
* | |||
. | |||
Report Details | |||
Symmary of Plant 'Jiatus | |||
The unit continued full power operation from the beginning of the report period until an automatic j | |||
scram occurred due to an EHC leak and turbine trip on December 18,1997. Recovery from the | |||
scram was completed on December 21,1997. Full power operation continued throughout the | |||
remainder of the period, with the exception of normal power reductions for periodic valve testing | |||
and control rod manipulations, | |||
l. Operations | |||
01 Conduct of Operations | |||
01.1 General Comments | |||
The inspectors observed numerous pre-job briefings, shift turnover briefings, and | |||
operations activities that had been discussed at pre-job briefings. The inspectors | |||
observed the response to an automatic scram, and the subsequent recovery and plant | |||
startup activities. The inspectors also monitored the actions associated with the | |||
emergency response to a trichloroethylene leak. While the conduct of operations was | |||
generally effective and professional, communications among operators and within the | |||
operations department were not as effective as had been observed during previous | |||
inspection periods, Specific observations and conclusions are listed in the following | |||
sections. | |||
01.2 Communications | |||
a. Inspection Scope (71707) | |||
The inspectors conducted several periods of continuous control room observation to | |||
f assess command and control activities, and operator communications. | |||
l | |||
b. Observations and Findinos | |||
The inspectors obsented that three-way communications and repeat back | |||
communications for alarm responses were not consistently or effectively utilized by some | |||
operating crews, and some crew members, near the end of December. This was in | |||
contrast to the excellent communications and alarm response detailed in several | |||
preceding inspection reports. Specific observations were discussed with operations | |||
management. Subsequent briefings and training was conducted by operations | |||
management with their operating cmws. No further lapses in communications were | |||
noted for the remainder of the inspection period. | |||
c. Conclusions | |||
The inspectors concluded that a lack of formality during the conduct of operations by | |||
certain crews resulted in their failure to use effective communication techniques such as | |||
three legged communications and repeat back of alarm acknowledgments in the middle | |||
4 | |||
. .. .. .. . | |||
. | |||
.. . | |||
.. | |||
_ _ - _ _ _ _ _ _ _ | |||
, ______ _ _ _ _ _ | |||
of this inspection period. Operations management responded quickly and effectively to | |||
correct this failure to meet management expectations. | |||
01.3 Abnormal Plant Operations | |||
a. Inspection Scope (71707. 92901. and 93702) | |||
The inspectors responded to an automatic reactor scram and to a declaration of an | |||
unusual event (UE). The inspectors assessed the effectiveness of operator responses, | |||
communications, and use of plant procedures. | |||
b. Observations and Findinas | |||
Automatic Reactor Scram Due to Electro-Hydraulic Leak (EHC) | |||
On December 18,1997, the plant automatically scrammed due to an EHC leak and | |||
subsequent turbine trip. An inspector responded to the control room to monitor operator | |||
actions. The inspector observed clear and concise orders and communications being | |||
used. The operators effectively used plant procedures. The generally good material | |||
condition of the plant, notwithstanding this equipment failure, resulted in no other safety | |||
feature actuations or unanticipated challenges to the operators. | |||
Unusual Event Due to Spill of Trichloroethylene (TCE) | |||
On January 23,1998, approximately 275 gallons of TCE leaked fron, the off gas (OG) | |||
brine system into the OG building. Since TCE is a mildly toxic gas, which required | |||
restricted access to areas of the OG building and the use of forced air breathing devices | |||
for entry, a UE was declared at approximately 3:10 a.m. The inspectors monitored the | |||
emergency response actions and efforts to isolate and repair the OG system. Good | |||
coordination was observed between responding groups. Personnel displayed a cautious | |||
and thoughtful approach to handling the problems associated with the leak and the | |||
system recovery. However, the inspectors questioned the timeliness of the initial UE | |||
! declaration, and the notifications of offsite personnel required by Plant Administrative | |||
l Procedure (PAP) 806, " Oil / Chemical Release Contingency Plan," Revision 2 | |||
) (November 1994). This issue will require furtt er discussion between NRC Region lll | |||
emergency preparedness personnel and Perry staff. Therefore, this is an Unresolved | |||
item (50440/97021-01(DRS)) to be evaluated in a future inspection. | |||
c. Conclusions | |||
Good preparations for activities associated with unusual plant conditions and the | |||
relatively good material condition of the plant, notwithstanding the EHC and OG Cooling | |||
system problems, led to effective operator responses to the automatic reactor scram and | |||
the chemical spill during this inspection period. | |||
5 | |||
____ | |||
,_ -- ___ _ -_- _ - | |||
.. . - | |||
, | |||
O2 Operational Status of Facilities and Equipment | |||
O2.1 Control Room Eauipment Taaoina | |||
a. Inspection Scope (71707 and 92901) | |||
The inspectors assessed the implementation of a change to the licensee's policy for | |||
tagging control room deficiencies, | |||
b. Observations and Findinas | |||
s | |||
Several different methods were used to tag control room devices and indicators that | |||
required supplementalinstructions for operation or that were degraded in some way. | |||
Overlapping requirements for the various tagging methods resulted in some control room | |||
devices or indicators being marked with multiple tags (e.g., danger tags, operations | |||
administrative tags, material deficiency tags (MDT), and/or information tags). Operations | |||
management noted that this condition could unnecessarily distract or confuse operators. | |||
Therefore, after bench marking trips to other power plants, in November 1997, a new | |||
policy was formv5ted to modify control room equipment tagging requirements which | |||
resulted in the removal of many tags from the panels. The guidelines provided to the | |||
operators for the implementation of this policy included that redundant tags be removed, | |||
that control room MDTs be stored in a ROLODEX file in the control room if not placed on | |||
the equipment, and that operators evaluate which tag would be appropriate for the | |||
condition of the equipment to be tagged. | |||
During control room observations, the inspectors identified several out-of service or | |||
degraded equipment controllers or indicators that were not marked. During a subsequent | |||
walkdown of the control panels with the operations manager, he indicated that two meters | |||
( should have been tagged per the new policy and promptly ensured they were | |||
acropriately taggeo - While the operators and other personnel were aware of the | |||
equipment that was out of service, discussions with operations personnel revealed | |||
various levels of understanding and differences in interpretations of the new policy. | |||
These interpretation differences were apparent during the walkdown with the operations | |||
manager, in response, on January 18,1998, operations management issued a - | |||
. | |||
memorandum to operations personnel which more clearly defined the guidelines and | |||
expectations for the new policy. Based on follow up ooservations and discussions with | |||
control room personnel, the inspectors concluded that the policy was more clearly- | |||
understood. | |||
. c. Conclusions | |||
The inspectors concluded that the guidelines and expectations for the control room | |||
equipment tagging policy change were not initially clearly communicated to the operators | |||
which resulted in some degraded equipment not being tagged as expected by operations | |||
management. Effor;s to reduce operator distractions are considered positive initiatives. | |||
However, the net effect of reducing the amount of tags in the control room (i.e., less | |||
information provided on the control panels for the operators' use versus less distractions) | |||
can not be immediately assessed. | |||
6 | |||
_ - . _ _ _ | |||
_ . . . - . - _ _ . | |||
, | |||
. | |||
( | |||
i | |||
08 Miscellaneous Operations issues | |||
08.1 (Closed) LER 50-44019717 00: *High Suppression Pool Level Signal Results in | |||
Engineerad Safety Feature Actuation." This event involved actuation of the logic to | |||
transfer the suction of the high pressure core spray pump due to a minor level change in | |||
the suppression pool. There was no actual equipment actuation. This event was | |||
discussed in Inspection Report No. 50-440/97009(DRP) and was the subject of a violation | |||
(50 440/97009-01) for failure to submit a licensee event report (LER). The logic actuation | |||
had no safety consequences and no corrective actions were necessary. | |||
' | |||
08.2 (Closed) VIO 50-440/97009-01(DRP): Failure to submit an LER for high suppression pool | |||
level signal. The LER closed in Section 08.1 of this report was submitted in response to | |||
this violation. The corrective actions for this violation appest adequate and this item is | |||
considered closed. | |||
11. Maintenance | |||
M1 Conduct of Maintenance | |||
M1.1 General Comments | |||
a. Inspection Scope (61726. 62707. 71500. and 92902) | |||
The inspectors used Inspection Procedures 61726 and 62707 to evaluate several work | |||
activities and surveillance tests. The inspectors observed emergent work as well as | |||
planned maintenance conducted during the forced outage, plant startup, and normal | |||
operations, | |||
b. Observations and Findinas | |||
The activities observed were generally accomplished effectively with appropriate use of | |||
drawings and written instructions. Licensee personnel continued to maintain a low | |||
threshold in using the corrective action process and material deficiency tags to identify | |||
issues and potential equipment problems. Effective preparations for a forced outage | |||
enabled the licensee to resolve several previously identified material condition | |||
deficiencies during an unexpected plant shutdown. The overall maintenance backlog was | |||
, at 414 items for combined corrective and general maintenance (CM/GM) as of | |||
f January 26,1998. Licensee management established a new, lower backlog goal of | |||
250 CM/GM items by December,31,1998. A Division 3 equipment outage was well | |||
planned and executed, with safety equipment made available within the schedule despite | |||
emergent work. | |||
The inspectors performed a detailed review of Surveillance instruction (SVI) C71-TS232, | |||
" Reactor Protection System - Electrical Power Monitoring Calibration / Functional for | |||
1C71-S003B and 1C71-S003D." This included a review of the technical specificG- | |||
basis, the Updated Safety Analysis Report (USAR), and associated drawings. The | |||
instruction was clearly written and contained appropriate guidance and instructions. The | |||
instrumentation and controls personnel who conducted the test were knowledgeable and | |||
the responsible system engineer provided appropriate technical support. | |||
7 | |||
_ ____ | |||
, _ . . _ _ _ | |||
-____ _-_- - _ ___ - - | |||
. | |||
c. Conclusig_nm r | |||
The inspectors concluded that effective preparations led to the completion of a number of | |||
maintenance activities during an unanticipated two day reactor shutdown which resulted | |||
in the resolution of several outstanding material condition deficiencies. Effective planning | |||
and work execution led to a relatively low corrective and preventative maintenance item | |||
backlog. | |||
M7 Quality Assurance in Maintenance Activities | |||
M7.'1 Measurina and Test Eauipmenj | |||
a. Inspection Scope (61726. 62707. 71500. and 92902) | |||
The inspectors assessed the effectiveness of various calibration activities for measuring | |||
and test equipment (M&TE). A number of surveillance procedures were reviewed to | |||
determine what M&TE was used, what the accuracy requirements were, and the | |||
calibration methods that were used. | |||
b. Observations and Findinas | |||
The licensee's procedures for control and calibration of M&TE were detailed and | |||
thorough. The licensee used a common corporate calibration facility with personnel from | |||
the Davis Besse Nuclear Power Plant (Beta Labs). Except for contaminated devices, | |||
M&TE are sent to Beta Labs (in Cleveland) for periodic checks. | |||
The inspectors observed that more state-of-the art M&TE was t.eing used at Perry than in | |||
the past. Although this provides technicians with better M&TE, the licensee was not | |||
ensuring that the reference standaids were stik appropriate for the upgraded M&TE. The | |||
licensee is committed to Institute of Electrical and Electronics Engineers (IEEE) | |||
Standard 498, "lEEE Standard Requirements for the Calibration and Control of Measuring | |||
l and Test Equipment Used in the Construction and Maintenance of Nuclear Power | |||
l Generating Stations"(1977). This standard specifies that reference standards, used to | |||
calibrate M&TE, must be at least four times as accurate as the M&TE. While several | |||
years ago the reference standards were up to ten times more accurate than the M&TE, | |||
the inspectors determined that some reference standards were exactly four times the | |||
accuracy of the M&TE Deing used. The inspectors reviewed USAR Section 7.0, | |||
" Instrumentation and Controls Systems," which included information related to this issue, | |||
c. Conclusions | |||
The inspectors concluded that administrative procedures and quality essurance programs | |||
did not verify that calibration reference standards met accuracy requirements when the | |||
M&TE was upgraded and therefore, that it was fortuitous that the standards used met the | |||
IEEE requirements. | |||
8 | |||
,- -- -- ------- - . | |||
- | |||
- -- . | |||
. . . - .. - | |||
.. | |||
M7.2 Divisional Raceway Markinos | |||
. a. Inspection Scope (61726. 62707. 71500. and 92902) | |||
The inspectors toured the emergency diesel generator (EDG) rooms to assess | |||
maintenance activities and the general material condition of the equipment in the rooms, | |||
b. Observations and Findinas | |||
On January 7,1998, the inspectors observed nurr erous raceways in the EDG rooms that | |||
did nnt have divisional markings on them. The markings are used to provide a visual ! | |||
methr.d to ensure proper separation of cables is maintained. The licensee concluded that | |||
thn recewsys had been marked at one time, but that the markings had deteriorated over | |||
tir, an1 had not been maintained. | |||
Appendix B, Section V of 10 CFR Part 50 requires, in part, that activities affecting quality | |||
, | |||
shall be prescribed by documented instructions, procedures, or drawings, of a type | |||
appropriate to the circumstances and shall be accomplished in accordance with these | |||
instructions, procedures, or drawings. Perry Drawing Number D215001, Sheet 1, | |||
Revision HH, dated May 3,1995, prescribed the marking requirements for Class 1E | |||
raceways to ensure proper separation of cables is maintained. The marking of Class 1E | |||
raceways is an ectivity affecting quahty. The failure to follow the prescribed drawing | |||
requirements was a Violation (50-440/97021-02(DRP)) of NRC requirements. | |||
c. . Conclusions | |||
The inspectors concluded that the licensee inadvertently allowed the degradation of | |||
required raceway markings over time to the extent that some were either illegible or | |||
missing which was a violation of NRC requirements. | |||
111. Enaineerina | |||
.E2 Engineering Support of Facilities and Equipment | |||
E2.1 Seismic Tubina Supcorts | |||
a Inspection Scope (37551. and 92903) | |||
The inspectors assessed the adequacy of maintaining seismic supports in the EDG | |||
rooms and on EDG equipment. | |||
b. - Observations and Findinas | |||
On January 7,1998, the inspectors identified numerous STAUFF clamps on all three | |||
divisional EDGs that did not appear to meet seismic qualification criteria. Many clamps | |||
were loose, possibly cf the wrong type (2 dimensionalir: stead of 3 dimensional, or vice | |||
versa), or had physicalimpairments that prevented them from operating correctly. These | |||
issues were reviewed in two subsequent walkdowns with licensee engineering personnel. | |||
9 | |||
_ _ - . | |||
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, | |||
. | |||
The engineering personnel stated that some of the physicalimpairments had probably | |||
existed since the tubing was installed. | |||
A potential issue form (PlF) was generated for this issue on January 20,1998,13 days | |||
after the initialidentification. The preliminary indication on the PlF was that an operability | |||
determination was not naeded for this condition. However, in parallel with the generation | |||
of the PlF, engineering personnel were performing a review to determine if the EDGs | |||
were operable. Once this review was completed, the licensee stated that, based on | |||
engineering judgement, the EDGs were operable. A full technical review of the seismic | |||
qualifications was in progress at the end of the inspection period to assess the | |||
qualification and operability of the EDGs. In addition, work was initiated to correct the | |||
deficiencies that had been identified. This issue is an Unresolved item | |||
(50-440/9702103(DRP)) based on the completion and inspector review of the licensee's | |||
engineering evaluations. | |||
c. Conclusions | |||
The inspectors questioned the operability of the EDGs based on numerous identified | |||
differences in clamps provided for seismic qualifications. This item remained open at the | |||
end of the inspection period. | |||
E2.2 Desion Chanoe Causes Scram | |||
a. Insoection Scope (37551 and 92903) | |||
The inspectors assessed the adequacy of a change in the design of nonsafety-related | |||
electro-hydraulic control oil tubing connections. Failure of one of the tubing connections | |||
caused a reactor scram on December 19,1997 (see Section 01.3). | |||
b. Observations and Findinas | |||
l | |||
; The licensee formed an incident response team to determine the causes of the scram. | |||
l The team included vendor representatives in addition to licensee personnel frora | |||
appropriate disciplines. The team's report included documentation of a systematic | |||
approach to identifying the root and contributing causes of the Scram. The team also | |||
systematically evaluated various options for correcting the causes. The team concluded | |||
that the failure of the tubing connection was caused by hydraulically induced vibrations of | |||
the tubing. The vibration coricem had been identified prior to the recently completed | |||
refueling outage and the design of the tubing was changed during the outage through the | |||
use of a specification change. The change consisted of replacing flared connections with | |||
compression fitting connections. The compression fittings weie superior in preventing | |||
leakage. The engineers who had initiated the change had evaluated the compression | |||
fittings for use with vibration. However, their evaluation had not considered the increased | |||
stress in the tubing at the compression fitting. The increased stress combined with the | |||
tubing vibration caused high cycle fatigue failure of the tubing. The licensee's senior | |||
management team accepted the incident response team's recommendation to install | |||
flared tubing connections and accelerate preparation of the tubing design modification to | |||
allow it to be installed if another forced outage occurs. | |||
10 | |||
. _ _ _ _ _ _. _ _ __ | |||
, | |||
. | |||
'. | |||
! | |||
c. Conclusions | |||
The incident response team's evaluation of the scram was thorough and the conclusions | |||
were well supported. However, the toam identified that an eariier change from flared tc | |||
compression tubing connections had not been adequately evaluated prior to completion. | |||
As a result, the tubing failed which caused a plant scram. The inspectors concluded that | |||
a violation of NRC requirements did not occur in this case because the inadequate | |||
evaluation occurred on a non safety related component and the maintenance rule | |||
requirements were tatisfied. | |||
lyafjant Support | |||
F2 Status of Fire Protection Facilities and Equipment | |||
F2.1 Fire Barriers | |||
a. {rupection S_ cope (71707) | |||
Using inspection Procedure 71707, the inspectors reviewed conditions affecting safety. | |||
related equipment, including fire barriers required by Appendix R of 10 CFR Part 50. | |||
b. Observations ansl Findinas | |||
During an inspection of the Division 2 and 3 Emergency Diesel Generator (EDG) rooms | |||
on December 8,1997, the inspectors noted that the fire door batween the rooms was | |||
stuck open. This type of door was designed to close automatically, with no hold-open | |||
mechanism. The inspectors reported the door's condition to plant opatakons staff, and | |||
the door was reclosed. The licensee reviewed security recoms to identify who had been | |||
in the rooms shortly before the inspectors. The licenseo concluded through interviews | |||
that the door had most likely been inadvertently left open when a cart was taken through | |||
the door several minutes before the inspector saw the door open. Yne licensee | |||
determined that a floor sealant, which had been applied in the rooms many rnonths | |||
earlier, had caused the door to stick on the door stop. This condition had not been | |||
noticed because the door would stick open only if it was taken fully open or 90 degrees | |||
open, as when the closing mechanism was tested. The inspectors did not observe | |||
similar flaws in 20 additional doors inspected. | |||
Appendix R, Section lit.N.4 of 10 CFR Part 50 f eeires, in part, that fire doors shall De | |||
kept closei and inspected daily to verify that they w in the closed position. This NRC | |||
identified failure to keep a required fire door closed is evnsidered a Violation | |||
(50 440/9702144(DRP)) of Appendix R. | |||
c. Conclusions | |||
The inspectors concluded that actions to verify fire doors were closed on a daily basis | |||
were generally effective. However, the licensee failed to recognize that a floor sealant | |||
applied in the EDG rooms introduced the possibility for fire doors to stick open which | |||
resulted in a violation of NRC requirer..ents when a fire door was identified by an | |||
inspector to be stuck open. | |||
11 | |||
-. - -. | |||
. - __ _ _ _ . _ _ . . _ _ _ _ _ _ . _ | |||
, | |||
. | |||
l | |||
' | |||
F2.2 Combustible Materials | |||
a. Inspection _ Scope (62707. 71750. and 92902) | |||
The inspecPars toured areas of the plant with safety related equipment to assess the | |||
effectiveness of 10 CFR Pari 50, Appendix R fire prevention measures associated with | |||
ongoing maintenance activities. | |||
b. Observations and Findinot | |||
On January 6,1998, the inspectors informed the shift supervisor that various items of | |||
combustible matenal were in an area that was posted as a combustible free zone of the | |||
emergency service water (ESW) pump house. The licensee promptly inspected the area | |||
and temoved the combustible material. The licensee also initiated a PlF to enter the | |||
issue h1 the corrective action system. The fire protection technician who inspected the | |||
area stated that when he had inspected the area a few days earlier, the combustible | |||
material had not been present. The combustible material appeared to be from a recently | |||
completed maintenance activity The inspectors did not observe combustible materials in | |||
other combustible free zones The inspectors reviewed USAR Section 9A.7, * Deviations | |||
to Appendix R," which included information related to this issue. | |||
Appendix R, Section ill G.2.b of 10 CFR Part 50 requires, in part, separation of cables | |||
and equipment and associated non safety circuits of redundant trains by a horizontal | |||
distance of move than 20 feet with no intervening combustibles or fire hazards, The | |||
combustible free zone in the ESW pump house had oeen established to comply with | |||
Appendix R, Administrative controls, postings, and boundary markings were in place to | |||
ensure compliance with Appendix R. However, the failure to follow the posted | |||
requirement was a Violation (50 440/9702105(DRP)) of NRC requirements. | |||
c. Conclusions | |||
The inspectors concluded that,in general, combustible materials were appropriately | |||
controlled, However, a violation involving the placement of excess combustible material | |||
originating from a maintenance work activity had been placed in an ESW pump house | |||
combustibo free zone was identified by the inspectors, | |||
X, Mananement Meetinas | |||
X1 Exit Meeting Summary | |||
The inspectors presented the inspection results to members of licensee management at | |||
the conclusion of the inspection on January 27,1998. The licensee acknowledged the | |||
findings presented. The inspectors asked the licensee whether any materials examined | |||
during the inspection should be considered proprietary, No proprietary information was | |||
identified. | |||
12 | |||
7 | |||
. | |||
PARTIAL LIST OF PERSONS CONTACTED | |||
L W. Myers, Vice President, Nuclear | |||
W. R. Kanda, General Manager Nuclear Power Plant Department | |||
T. S. Rausch, Director, Quality and Personnel Development Department , | |||
N. L Bonner, Director, Nuclear Maintenance Dyartment I | |||
R. W. Schrauder, Director, Nuclear Engineering Department | |||
H. W. Bergendahl, Director, Nuclear Services Department | |||
J. Messina, Operations Manager | |||
J. T. Sears, Radiation Protection Manager | |||
F. A. Kearney, Superintendent Plant Operations | |||
INSPECTION PROCEDURES USED | |||
l | |||
lP 37551: Onsite Engineering | |||
, | |||
IP 61726: Surveillance Observations , | |||
, | |||
IP 62707: Maintenance Observation | |||
! | |||
IP 71500 Batance of Plant | |||
IP 71707: Plant Operations | |||
IP 71714: Cold Weather Preparations | |||
IP 71750: Plant Support Activities | |||
IP 92700: Onsite Follow up of Written Reports of Non routine Events at Power Reactor | |||
Facilities | |||
IP 92901: Follow up Plant Operations | |||
IP 92902: Follow up Maintenance | |||
- | |||
IP 92903: Follow-up Engineering | |||
IP 92904 Follow up Plant Support | |||
ITEMS OPENED OR CLOSED (NONE DISCUSSED) | |||
Qpened | |||
50-440/9702101(DRP) URI Timeliness of Emergency Declaration and Notifications | |||
50 440/9702102(DRP) VIO Class 1E Raceway Markings | |||
50-440/9702103(DRP) URI Seismic Tubing Supports for EDGs | |||
50 440/9702104(DRP) VIO Failure to Keep Fire Door Closed | |||
50-440/9702105(DRP) VIO Corrbustibles in Combustible Free Zone | |||
Closed | |||
50 440/97 17 00 LER High Suppression Pool Level Signal Results in Engineered | |||
Safety Feature Actuation | |||
50-440/97009-01 VIO Failure to submit and LER for High Suppression Pool Level | |||
Signat | |||
13 | |||
_ _ ,, | |||
. | |||
LIST OF ACRONYMS ANDINITIALISMS | |||
CFR Code of Federal Regulations | |||
CM/GM Corrective Maintenance / General Maintenance | |||
EDG Emergency Diesel Generator | |||
EHC Electro Hydraulic Controls | |||
ESW Emergency Service Water | |||
IEEE Institute of Electrical and Electronics Engineers | |||
IR inspection Poport | |||
LCO Limiting Condition for Operation | |||
LER Licensee Event Report | |||
MDT Material Deficiency Tag | |||
M&TE Measuring and Test Equipment | |||
NRC Nuclear Regulatory Commission | |||
OG Off Gas | |||
PAP Plant Administrative Procedure | |||
POR Public Document Room | |||
PlF Potantialissue Form | |||
PLCO Potential Limiting Condition for Operation | |||
PSIG Pounds per Square Inch, Gage | |||
RFO6 Refueling Outage 6 | |||
RG Regulatory Guide | |||
RI Resident inspector | |||
RO Reactor Operator | |||
RPS Reactor Protection System | |||
, | |||
SRI Senior Resident inspector | |||
SRO Senior Reactor Operator | |||
SVI Surveillance instruction | |||
TCE Trichloroethylene | |||
TS Technical Specification | |||
UE Unusual Event | |||
URI Unresolved item | |||
USAR Updated Safety Analysis Report | |||
VIO Violation | |||
_. = | |||
14 | |||
}} |
Latest revision as of 09:58, 20 December 2021
ML20203D824 | |
Person / Time | |
---|---|
Site: | Perry ![]() |
Issue date: | 02/20/1998 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20203D810 | List: |
References | |
50-440-97-21, NUDOCS 9802260157 | |
Download: ML20203D824 (14) | |
See also: IR 05000440/1997021
Text
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U. S. NUCLEAR REGULATORY COMMISSION l
REGION lil
Docket No: 50-440
License No: NPF 58
Report No- 50-440/97021(DRP)
Licensee: Centerior Service Company
Facility: Perry Nuclear Power Plant
Location: P. O. Box 97 200
Perry, OH 44edi
Dates: December 2,1997, to January 27,1998
Inspectors: D. Kosloff, Senior Resident laspector (SRI)
J. Clark, Resident inspector (RI)
S, Campbell, SRI, Davis-Besse
K. Zellers, RI, Davis Besse
Approved by: Thomas J. Kozak, Chief
Reactor Projects Branch 4
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9002260157 900220
PDR ADOCK 05000440
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EXECUTIVE SUMMARY
Perry Nuclear Power Plant
NRC inspection Report No. 50-440/97021(DRP)
This inspection included a review of tespects 9l licensee operations, maintenance, engineering,
and plant support. The report covers aneight week period of resident inspection. Three
violations of NRC requirements were identified.
Operations
.
The conduct of operations was generally effective and professional. Communications I
among operators and within the operations department were not as effective as had been
observed during previous inspection periods (Section 01.1).
.
Good preparations for activities associated wah unusual plant conditions and the
relatively good material condition of the plant, notwithstanding the electro-hydraulic
control system and off gas cooling syt. tem problems, led to effective operator responses
to the automatic reactor scram and the chemical spill during this inspection period
(Section 01,3).
.
The inspectors concluded that the guidelines and expectations for the change in the
equipment tagging policy were not initially clearly communicated to the operators which
resulted in some degraded equipment not being tagged as expected by operations
management (Section O2.1).
Maintenance
.
Effective preparations led to the completion of a number of maintenance activities during
an unanticipated two day reactor shutdown which resulted in the resolution of several
outstanding material condition deficiencies. Effective planning and work execution led to
a relatively low corrective and preventative maintenance item backlog (Section M7,1).
.
The licensee inadvertently allowed the degradation of required raceway markings over
time to the extent that some were either i!!egible or missing, which was a violation of NRC -
requirements (Section M7.2).
Enaineerina
.
Aninadequate evaluation of a design change to the electro-hydraulic control system
contributed to an automatic scram (Section E2.2).
Plant Support
.
Actions to verify fire doors were closed on a daily basis were generally effective.
However, the licensee failed to recognize that a floor sealant applied in the EDG rooms
introduced the possibility for fire doors to stick open, which resulted in a violation of NRC
requirements when a fire door was identified by an inspector to be stuck open
(Section P1.1).
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.+ Combustible materials were generally well controlled,- However, the inspectors identified
a violation involving the placement of excess combustible material in ars ESW pump
house combustible free zone (Section P1.2).
3
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Report Details
Symmary of Plant 'Jiatus
The unit continued full power operation from the beginning of the report period until an automatic j
scram occurred due to an EHC leak and turbine trip on December 18,1997. Recovery from the
scram was completed on December 21,1997. Full power operation continued throughout the
remainder of the period, with the exception of normal power reductions for periodic valve testing
and control rod manipulations,
l. Operations
01 Conduct of Operations
01.1 General Comments
The inspectors observed numerous pre-job briefings, shift turnover briefings, and
operations activities that had been discussed at pre-job briefings. The inspectors
observed the response to an automatic scram, and the subsequent recovery and plant
startup activities. The inspectors also monitored the actions associated with the
emergency response to a trichloroethylene leak. While the conduct of operations was
generally effective and professional, communications among operators and within the
operations department were not as effective as had been observed during previous
inspection periods, Specific observations and conclusions are listed in the following
sections.
01.2 Communications
a. Inspection Scope (71707)
The inspectors conducted several periods of continuous control room observation to
f assess command and control activities, and operator communications.
l
b. Observations and Findinos
The inspectors obsented that three-way communications and repeat back
communications for alarm responses were not consistently or effectively utilized by some
operating crews, and some crew members, near the end of December. This was in
contrast to the excellent communications and alarm response detailed in several
preceding inspection reports. Specific observations were discussed with operations
management. Subsequent briefings and training was conducted by operations
management with their operating cmws. No further lapses in communications were
noted for the remainder of the inspection period.
c. Conclusions
The inspectors concluded that a lack of formality during the conduct of operations by
certain crews resulted in their failure to use effective communication techniques such as
three legged communications and repeat back of alarm acknowledgments in the middle
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of this inspection period. Operations management responded quickly and effectively to
correct this failure to meet management expectations.
01.3 Abnormal Plant Operations
a. Inspection Scope (71707. 92901. and 93702)
The inspectors responded to an automatic reactor scram and to a declaration of an
unusual event (UE). The inspectors assessed the effectiveness of operator responses,
communications, and use of plant procedures.
b. Observations and Findinas
Automatic Reactor Scram Due to Electro-Hydraulic Leak (EHC)
On December 18,1997, the plant automatically scrammed due to an EHC leak and
subsequent turbine trip. An inspector responded to the control room to monitor operator
actions. The inspector observed clear and concise orders and communications being
used. The operators effectively used plant procedures. The generally good material
condition of the plant, notwithstanding this equipment failure, resulted in no other safety
feature actuations or unanticipated challenges to the operators.
Unusual Event Due to Spill of Trichloroethylene (TCE)
On January 23,1998, approximately 275 gallons of TCE leaked fron, the off gas (OG)
brine system into the OG building. Since TCE is a mildly toxic gas, which required
restricted access to areas of the OG building and the use of forced air breathing devices
for entry, a UE was declared at approximately 3:10 a.m. The inspectors monitored the
emergency response actions and efforts to isolate and repair the OG system. Good
coordination was observed between responding groups. Personnel displayed a cautious
and thoughtful approach to handling the problems associated with the leak and the
system recovery. However, the inspectors questioned the timeliness of the initial UE
! declaration, and the notifications of offsite personnel required by Plant Administrative
l Procedure (PAP) 806, " Oil / Chemical Release Contingency Plan," Revision 2
) (November 1994). This issue will require furtt er discussion between NRC Region lll
emergency preparedness personnel and Perry staff. Therefore, this is an Unresolved
item (50440/97021-01(DRS)) to be evaluated in a future inspection.
c. Conclusions
Good preparations for activities associated with unusual plant conditions and the
relatively good material condition of the plant, notwithstanding the EHC and OG Cooling
system problems, led to effective operator responses to the automatic reactor scram and
the chemical spill during this inspection period.
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O2 Operational Status of Facilities and Equipment
O2.1 Control Room Eauipment Taaoina
a. Inspection Scope (71707 and 92901)
The inspectors assessed the implementation of a change to the licensee's policy for
tagging control room deficiencies,
b. Observations and Findinas
s
Several different methods were used to tag control room devices and indicators that
required supplementalinstructions for operation or that were degraded in some way.
Overlapping requirements for the various tagging methods resulted in some control room
devices or indicators being marked with multiple tags (e.g., danger tags, operations
administrative tags, material deficiency tags (MDT), and/or information tags). Operations
management noted that this condition could unnecessarily distract or confuse operators.
Therefore, after bench marking trips to other power plants, in November 1997, a new
policy was formv5ted to modify control room equipment tagging requirements which
resulted in the removal of many tags from the panels. The guidelines provided to the
operators for the implementation of this policy included that redundant tags be removed,
that control room MDTs be stored in a ROLODEX file in the control room if not placed on
the equipment, and that operators evaluate which tag would be appropriate for the
condition of the equipment to be tagged.
During control room observations, the inspectors identified several out-of service or
degraded equipment controllers or indicators that were not marked. During a subsequent
walkdown of the control panels with the operations manager, he indicated that two meters
( should have been tagged per the new policy and promptly ensured they were
acropriately taggeo - While the operators and other personnel were aware of the
equipment that was out of service, discussions with operations personnel revealed
various levels of understanding and differences in interpretations of the new policy.
These interpretation differences were apparent during the walkdown with the operations
manager, in response, on January 18,1998, operations management issued a -
.
memorandum to operations personnel which more clearly defined the guidelines and
expectations for the new policy. Based on follow up ooservations and discussions with
control room personnel, the inspectors concluded that the policy was more clearly-
understood.
. c. Conclusions
The inspectors concluded that the guidelines and expectations for the control room
equipment tagging policy change were not initially clearly communicated to the operators
which resulted in some degraded equipment not being tagged as expected by operations
management. Effor;s to reduce operator distractions are considered positive initiatives.
However, the net effect of reducing the amount of tags in the control room (i.e., less
information provided on the control panels for the operators' use versus less distractions)
can not be immediately assessed.
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08 Miscellaneous Operations issues
08.1 (Closed) LER 50-44019717 00: *High Suppression Pool Level Signal Results in
Engineerad Safety Feature Actuation." This event involved actuation of the logic to
transfer the suction of the high pressure core spray pump due to a minor level change in
the suppression pool. There was no actual equipment actuation. This event was
discussed in Inspection Report No. 50-440/97009(DRP) and was the subject of a violation
(50 440/97009-01) for failure to submit a licensee event report (LER). The logic actuation
had no safety consequences and no corrective actions were necessary.
'
08.2 (Closed) VIO 50-440/97009-01(DRP): Failure to submit an LER for high suppression pool
level signal. The LER closed in Section 08.1 of this report was submitted in response to
this violation. The corrective actions for this violation appest adequate and this item is
considered closed.
11. Maintenance
M1 Conduct of Maintenance
M1.1 General Comments
a. Inspection Scope (61726. 62707. 71500. and 92902)
The inspectors used Inspection Procedures 61726 and 62707 to evaluate several work
activities and surveillance tests. The inspectors observed emergent work as well as
planned maintenance conducted during the forced outage, plant startup, and normal
operations,
b. Observations and Findinas
The activities observed were generally accomplished effectively with appropriate use of
drawings and written instructions. Licensee personnel continued to maintain a low
threshold in using the corrective action process and material deficiency tags to identify
issues and potential equipment problems. Effective preparations for a forced outage
enabled the licensee to resolve several previously identified material condition
deficiencies during an unexpected plant shutdown. The overall maintenance backlog was
, at 414 items for combined corrective and general maintenance (CM/GM) as of
f January 26,1998. Licensee management established a new, lower backlog goal of
250 CM/GM items by December,31,1998. A Division 3 equipment outage was well
planned and executed, with safety equipment made available within the schedule despite
emergent work.
The inspectors performed a detailed review of Surveillance instruction (SVI) C71-TS232,
" Reactor Protection System - Electrical Power Monitoring Calibration / Functional for
1C71-S003B and 1C71-S003D." This included a review of the technical specificG-
basis, the Updated Safety Analysis Report (USAR), and associated drawings. The
instruction was clearly written and contained appropriate guidance and instructions. The
instrumentation and controls personnel who conducted the test were knowledgeable and
the responsible system engineer provided appropriate technical support.
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c. Conclusig_nm r
The inspectors concluded that effective preparations led to the completion of a number of
maintenance activities during an unanticipated two day reactor shutdown which resulted
in the resolution of several outstanding material condition deficiencies. Effective planning
and work execution led to a relatively low corrective and preventative maintenance item
backlog.
M7 Quality Assurance in Maintenance Activities
M7.'1 Measurina and Test Eauipmenj
a. Inspection Scope (61726. 62707. 71500. and 92902)
The inspectors assessed the effectiveness of various calibration activities for measuring
and test equipment (M&TE). A number of surveillance procedures were reviewed to
determine what M&TE was used, what the accuracy requirements were, and the
calibration methods that were used.
b. Observations and Findinas
The licensee's procedures for control and calibration of M&TE were detailed and
thorough. The licensee used a common corporate calibration facility with personnel from
the Davis Besse Nuclear Power Plant (Beta Labs). Except for contaminated devices,
M&TE are sent to Beta Labs (in Cleveland) for periodic checks.
The inspectors observed that more state-of-the art M&TE was t.eing used at Perry than in
the past. Although this provides technicians with better M&TE, the licensee was not
ensuring that the reference standaids were stik appropriate for the upgraded M&TE. The
licensee is committed to Institute of Electrical and Electronics Engineers (IEEE)
Standard 498, "lEEE Standard Requirements for the Calibration and Control of Measuring
l and Test Equipment Used in the Construction and Maintenance of Nuclear Power
l Generating Stations"(1977). This standard specifies that reference standards, used to
calibrate M&TE, must be at least four times as accurate as the M&TE. While several
years ago the reference standards were up to ten times more accurate than the M&TE,
the inspectors determined that some reference standards were exactly four times the
accuracy of the M&TE Deing used. The inspectors reviewed USAR Section 7.0,
" Instrumentation and Controls Systems," which included information related to this issue,
c. Conclusions
The inspectors concluded that administrative procedures and quality essurance programs
did not verify that calibration reference standards met accuracy requirements when the
M&TE was upgraded and therefore, that it was fortuitous that the standards used met the
IEEE requirements.
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M7.2 Divisional Raceway Markinos
. a. Inspection Scope (61726. 62707. 71500. and 92902)
The inspectors toured the emergency diesel generator (EDG) rooms to assess
maintenance activities and the general material condition of the equipment in the rooms,
b. Observations and Findinas
On January 7,1998, the inspectors observed nurr erous raceways in the EDG rooms that
did nnt have divisional markings on them. The markings are used to provide a visual !
methr.d to ensure proper separation of cables is maintained. The licensee concluded that
thn recewsys had been marked at one time, but that the markings had deteriorated over
tir, an1 had not been maintained.
Appendix B,Section V of 10 CFR Part 50 requires, in part, that activities affecting quality
,
shall be prescribed by documented instructions, procedures, or drawings, of a type
appropriate to the circumstances and shall be accomplished in accordance with these
instructions, procedures, or drawings. Perry Drawing Number D215001, Sheet 1,
Revision HH, dated May 3,1995, prescribed the marking requirements for Class 1E
raceways to ensure proper separation of cables is maintained. The marking of Class 1E
raceways is an ectivity affecting quahty. The failure to follow the prescribed drawing
requirements was a Violation (50-440/97021-02(DRP)) of NRC requirements.
c. . Conclusions
The inspectors concluded that the licensee inadvertently allowed the degradation of
required raceway markings over time to the extent that some were either illegible or
missing which was a violation of NRC requirements.
111. Enaineerina
.E2 Engineering Support of Facilities and Equipment
E2.1 Seismic Tubina Supcorts
a Inspection Scope (37551. and 92903)
The inspectors assessed the adequacy of maintaining seismic supports in the EDG
rooms and on EDG equipment.
b. - Observations and Findinas
On January 7,1998, the inspectors identified numerous STAUFF clamps on all three
divisional EDGs that did not appear to meet seismic qualification criteria. Many clamps
were loose, possibly cf the wrong type (2 dimensionalir: stead of 3 dimensional, or vice
versa), or had physicalimpairments that prevented them from operating correctly. These
issues were reviewed in two subsequent walkdowns with licensee engineering personnel.
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The engineering personnel stated that some of the physicalimpairments had probably
existed since the tubing was installed.
A potential issue form (PlF) was generated for this issue on January 20,1998,13 days
after the initialidentification. The preliminary indication on the PlF was that an operability
determination was not naeded for this condition. However, in parallel with the generation
of the PlF, engineering personnel were performing a review to determine if the EDGs
were operable. Once this review was completed, the licensee stated that, based on
engineering judgement, the EDGs were operable. A full technical review of the seismic
qualifications was in progress at the end of the inspection period to assess the
qualification and operability of the EDGs. In addition, work was initiated to correct the
deficiencies that had been identified. This issue is an Unresolved item
(50-440/9702103(DRP)) based on the completion and inspector review of the licensee's
engineering evaluations.
c. Conclusions
The inspectors questioned the operability of the EDGs based on numerous identified
differences in clamps provided for seismic qualifications. This item remained open at the
end of the inspection period.
E2.2 Desion Chanoe Causes Scram
a. Insoection Scope (37551 and 92903)
The inspectors assessed the adequacy of a change in the design of nonsafety-related
electro-hydraulic control oil tubing connections. Failure of one of the tubing connections
caused a reactor scram on December 19,1997 (see Section 01.3).
b. Observations and Findinas
l
- The licensee formed an incident response team to determine the causes of the scram.
l The team included vendor representatives in addition to licensee personnel frora
appropriate disciplines. The team's report included documentation of a systematic
approach to identifying the root and contributing causes of the Scram. The team also
systematically evaluated various options for correcting the causes. The team concluded
that the failure of the tubing connection was caused by hydraulically induced vibrations of
the tubing. The vibration coricem had been identified prior to the recently completed
refueling outage and the design of the tubing was changed during the outage through the
use of a specification change. The change consisted of replacing flared connections with
compression fitting connections. The compression fittings weie superior in preventing
leakage. The engineers who had initiated the change had evaluated the compression
fittings for use with vibration. However, their evaluation had not considered the increased
stress in the tubing at the compression fitting. The increased stress combined with the
tubing vibration caused high cycle fatigue failure of the tubing. The licensee's senior
management team accepted the incident response team's recommendation to install
flared tubing connections and accelerate preparation of the tubing design modification to
allow it to be installed if another forced outage occurs.
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c. Conclusions
The incident response team's evaluation of the scram was thorough and the conclusions
were well supported. However, the toam identified that an eariier change from flared tc
compression tubing connections had not been adequately evaluated prior to completion.
As a result, the tubing failed which caused a plant scram. The inspectors concluded that
a violation of NRC requirements did not occur in this case because the inadequate
evaluation occurred on a non safety related component and the maintenance rule
requirements were tatisfied.
lyafjant Support
F2 Status of Fire Protection Facilities and Equipment
F2.1 Fire Barriers
a. {rupection S_ cope (71707)
Using inspection Procedure 71707, the inspectors reviewed conditions affecting safety.
related equipment, including fire barriers required by Appendix R of 10 CFR Part 50.
b. Observations ansl Findinas
During an inspection of the Division 2 and 3 Emergency Diesel Generator (EDG) rooms
on December 8,1997, the inspectors noted that the fire door batween the rooms was
stuck open. This type of door was designed to close automatically, with no hold-open
mechanism. The inspectors reported the door's condition to plant opatakons staff, and
the door was reclosed. The licensee reviewed security recoms to identify who had been
in the rooms shortly before the inspectors. The licenseo concluded through interviews
that the door had most likely been inadvertently left open when a cart was taken through
the door several minutes before the inspector saw the door open. Yne licensee
determined that a floor sealant, which had been applied in the rooms many rnonths
earlier, had caused the door to stick on the door stop. This condition had not been
noticed because the door would stick open only if it was taken fully open or 90 degrees
open, as when the closing mechanism was tested. The inspectors did not observe
similar flaws in 20 additional doors inspected.
Appendix R, Section lit.N.4 of 10 CFR Part 50 f eeires, in part, that fire doors shall De
kept closei and inspected daily to verify that they w in the closed position. This NRC
identified failure to keep a required fire door closed is evnsidered a Violation
(50 440/9702144(DRP)) of Appendix R.
c. Conclusions
The inspectors concluded that actions to verify fire doors were closed on a daily basis
were generally effective. However, the licensee failed to recognize that a floor sealant
applied in the EDG rooms introduced the possibility for fire doors to stick open which
resulted in a violation of NRC requirer..ents when a fire door was identified by an
inspector to be stuck open.
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F2.2 Combustible Materials
a. Inspection _ Scope (62707. 71750. and 92902)
The inspecPars toured areas of the plant with safety related equipment to assess the
effectiveness of 10 CFR Pari 50, Appendix R fire prevention measures associated with
ongoing maintenance activities.
b. Observations and Findinot
On January 6,1998, the inspectors informed the shift supervisor that various items of
combustible matenal were in an area that was posted as a combustible free zone of the
emergency service water (ESW) pump house. The licensee promptly inspected the area
and temoved the combustible material. The licensee also initiated a PlF to enter the
issue h1 the corrective action system. The fire protection technician who inspected the
area stated that when he had inspected the area a few days earlier, the combustible
material had not been present. The combustible material appeared to be from a recently
completed maintenance activity The inspectors did not observe combustible materials in
other combustible free zones The inspectors reviewed USAR Section 9A.7, * Deviations
to Appendix R," which included information related to this issue.
Appendix R, Section ill G.2.b of 10 CFR Part 50 requires, in part, separation of cables
and equipment and associated non safety circuits of redundant trains by a horizontal
distance of move than 20 feet with no intervening combustibles or fire hazards, The
combustible free zone in the ESW pump house had oeen established to comply with
Appendix R, Administrative controls, postings, and boundary markings were in place to
ensure compliance with Appendix R. However, the failure to follow the posted
requirement was a Violation (50 440/9702105(DRP)) of NRC requirements.
c. Conclusions
The inspectors concluded that,in general, combustible materials were appropriately
controlled, However, a violation involving the placement of excess combustible material
originating from a maintenance work activity had been placed in an ESW pump house
combustibo free zone was identified by the inspectors,
X, Mananement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on January 27,1998. The licensee acknowledged the
findings presented. The inspectors asked the licensee whether any materials examined
during the inspection should be considered proprietary, No proprietary information was
identified.
12
7
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PARTIAL LIST OF PERSONS CONTACTED
L W. Myers, Vice President, Nuclear
W. R. Kanda, General Manager Nuclear Power Plant Department
T. S. Rausch, Director, Quality and Personnel Development Department ,
N. L Bonner, Director, Nuclear Maintenance Dyartment I
R. W. Schrauder, Director, Nuclear Engineering Department
H. W. Bergendahl, Director, Nuclear Services Department
J. Messina, Operations Manager
J. T. Sears, Radiation Protection Manager
F. A. Kearney, Superintendent Plant Operations
INSPECTION PROCEDURES USED
l
lP 37551: Onsite Engineering
,
IP 61726: Surveillance Observations ,
,
IP 62707: Maintenance Observation
!
IP 71500 Batance of Plant
IP 71707: Plant Operations
IP 71714: Cold Weather Preparations
IP 71750: Plant Support Activities
IP 92700: Onsite Follow up of Written Reports of Non routine Events at Power Reactor
Facilities
IP 92901: Follow up Plant Operations
IP 92902: Follow up Maintenance
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IP 92903: Follow-up Engineering
IP 92904 Follow up Plant Support
ITEMS OPENED OR CLOSED (NONE DISCUSSED)
Qpened
50-440/9702101(DRP) URI Timeliness of Emergency Declaration and Notifications
50 440/9702102(DRP) VIO Class 1E Raceway Markings
50-440/9702103(DRP) URI Seismic Tubing Supports for EDGs
50 440/9702104(DRP) VIO Failure to Keep Fire Door Closed
50-440/9702105(DRP) VIO Corrbustibles in Combustible Free Zone
Closed
50 440/97 17 00 LER High Suppression Pool Level Signal Results in Engineered
Safety Feature Actuation
50-440/97009-01 VIO Failure to submit and LER for High Suppression Pool Level
Signat
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LIST OF ACRONYMS ANDINITIALISMS
CFR Code of Federal Regulations
CM/GM Corrective Maintenance / General Maintenance
EDG Emergency Diesel Generator
EHC Electro Hydraulic Controls
ESW Emergency Service Water
IEEE Institute of Electrical and Electronics Engineers
IR inspection Poport
LCO Limiting Condition for Operation
LER Licensee Event Report
MDT Material Deficiency Tag
M&TE Measuring and Test Equipment
NRC Nuclear Regulatory Commission
OG Off Gas
PAP Plant Administrative Procedure
POR Public Document Room
PlF Potantialissue Form
PLCO Potential Limiting Condition for Operation
PSIG Pounds per Square Inch, Gage
RFO6 Refueling Outage 6
RG Regulatory Guide
RI Resident inspector
RO Reactor Operator
,
SRI Senior Resident inspector
SRO Senior Reactor Operator
SVI Surveillance instruction
TCE Trichloroethylene
TS Technical Specification
UE Unusual Event
URI Unresolved item
USAR Updated Safety Analysis Report
VIO Violation
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