ML20140C263

Insp Rept 50-440/97-06 on 970421-24.Violations Noted.Major Areas Inspected:Review of Plant Maint Dept Fuse Control Process,Procedure/Instruction Change Process & Selection of Qualified Maint Personnel to Do safety-related Work

ML20140C263
Person / Time
Site:	Perry
Issue date:	06/03/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140C185	List: ML20140C180 ML20140C258 ML20140C263
References
50-440-97-06, 50-440-97-6, NUDOCS 9706090185
Download: ML20140C263 (9)

See also: IR 05000440/1997006

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U. S. NUCLEAR REGULATORY COMMISSION

REGION lil

Docket No.: 50-440

License No.: NPF-58

Report No: 50-440/97006

Licensee: Centerior Service Company

Facility: Perry Nuclear Power Plant

Location: P. O. Box 97 A200

Perry, OH 44081

Dates: April 21 through 24,1997

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Inspectors: D. S. Butler, Reactor Engineer

Approved by: R. N. Gardner, Chief

Engineer Specialist Branch 2

Division of Reactor Safety

9706090185 970603

PDR ADOCK 05000440

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'! EXECUTIVE SUMMARY

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. Perry Nuclear Power Plant, Unit 1

NRC Inspection Report 50 440/97006(DRS) '

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j. This inspection involved a review of Perry's maintenance department fuse control process, t

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procedure / instruction change (PIC) process, and the selection of qualified maintenance

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personnel to do safety-related work.

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Maintenance ~I

o . The licensee was controlling fuses in an acceptable manner (Section M1).  !

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or The instrumentatios and control (l&C) supervisor and unit supervisor (US) did not i

follow the instruction change process before performing two surveillance.  ;

instructions. A " window of opportunity" was used as a basis to complete safety- i

related testing before completing the PIC process (Section M3). I

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-o .The licensee was controlling the selection of maintenance personnel to do safety

related work in an acceptable manner (Section M5). {

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ll. Maintenance

M1 Conduct of Maintenance

M1.1 Fuse Control

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{. a. Insoection Scone

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The inspector reviewed the licensee's fuse control process and verified proper

{ installation of several fuses in the main control room (MCR). Documents reviewed

included the following

j ' o Plant Administrative Procedure (PAP)-0201, " Conduct of Operations"

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o Materials Control Instruction (MCI)-0416,." Return of Material and Contractor

Assumption Activities"

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I o Special Project Plan 1002, " Safety Related Fuse Verification"

o Work Order No. 960002565

< 0 Drawing No. 208-038 806

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b. Observations and Findinos

Fuse replacement authority was delegated to operations, instrument and control

(l&C) and electrical maintenance. The different departments used procedure

PAP-0201 to control fuse replacements. Maintenance typically used the work order

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process along with PAP-0201 to control fuses. Fuse size and type information was

controlled on applicable electrical drawings. Steps were provided in PAP-0201 to

initiate a field change request and notify engineering when unidentified fuse size

and types were not depicted on drawings.

The inspector discussed fuse replacement practices, fuse accountability and the

return of unused fuses to stock with severalI&C technicians. The technicians

indicated that they did not maintain safety-related fuses in the shop. Fuses

maintained in the shop were for l&C use only. Replacement fuses were obtained

from either Operations or the warehouse. Operation's fuses were maintained oy

the control room assistants (CRAs) in a locked cabinet. The MCR maintained a fuse

log for cross referencing fuse types to a warehouse stock-code. The stock-code

numbers were clearly marked on the fuse bins and the fuses were audited by the

CRAs to ensure agreement with the number of fuses obtained from the warehouse

or used.

The inspector reviewed several fuse replacement checklists and verified that the

number of fuses used and maintained by Operations agreed with the CRA audit. In

addition, the inspector verified that I&C had replaced the correct fuses (F10) in

MCR panels 1H13P671 and 1H13P672. Both activities had been completed

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l In 1985, the licensee had completed a safety-related fuse verification program. All

! safety-related fuses, except for those located in the MCR, were walked down and

l any discrepancies were resolved. The verification process confirmed fuse size,

l- class, type and any speciallabels. Approximately 1000 MCR fuses were reviewed

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discrepancy population did not warrant a 100% walkdown since many of these

fuses were instrument fuses supplied with the equipment. In addition, the MCR

l equipment has been performing satisfactorily. MCR fuse discrepancies, when

! identified, would be resolved according to procedure PAP-0201,

c. Conclusions

( The inspector concluded that the licensee was controlling fuses in an acceptable

manner.

M3 Maintenance Procedures and Documentation

M3.1 Procedure Temocrary Chanae Process

a. Insoection Scone

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The inspector reviewed potential issue form (PlF) No. 96-2935 which had been

issued to investigate PIF No. 95-2490. The latter PlF had been closed without

addressing why two surveillance instructions (SVis) had been completed before

approval of their respective non-intent conditional procedure / instruction change

(PIC) request. Documents reviewed included the following: 1

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o PAP-0522, Revision 7, " Instruction Changes" l

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0 PAP-1105, Revision 8, " Surveillance Test Control" '

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O Perry Unit 1 Technical Specification (TS) 6.8.3, "Temporcry Changes" )

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o SVI-E32-T5400-A; E; J; and N, Revision 3, Main Steam isolation Valve

Leakage Control System - Steamline Bleedoff Flow Channel Calibration for

1E32-N053A; E; J; and N

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o Drawing No. B-208-071, Sheet A08, Revision M

b. . Qb_servations and Findinos

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On December 7,1995, an l&C technician stopped the performance of SVI E32- I

5400A at instruction step 5.1.24. The instruction step was verifying that relay l

1E32-K1 A contacts M2/R2 were closed. The expected voltage as referenced in the i

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instruction step was 0 Vac. However, the technician obtained a voltage of i

l approximately 120 Vac. The technician initiated an I&C Temporary Change

, Request for the four SVis on December 7,1995, to change the expected reference

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voltage to 120 Vac. The I&C supervisor independently reviewed the electrical

schematic and concluded that the expected voltage was 120 Vac.

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On December 8,1995, the I&C supervisor believed that a " window of opportunity"

existed to complete SVis E, and J before issuing the PIC. Since the expected

voltage was referenced in a parenthesis (parenthetical values found in SVis were

for reference points, and not intended to be actual data points) and the intent of the

step was to verify the contact was closed, the l&C supervisor felt the SVis could

be completed as written. The l&C supervisor concluded that procedure PAP-1105

provided sufficient latitude to complete the SVis before issuing the PIC. The

procedure stated,in part, that test instructions were followed in a step-by-step  !

sequence unless deviation was specifically allowed, such as working with l

inadequate instructions. The l&C supervisor described to the control room unit

supervisor (US) that the procedure step could be met although the expected voltage

was different from indicated. The US agreed that the two SVis could be performed

before PlC approval. Subsequently, the PICS were approved on January 9,1996.

The inspector reviewed TS 6.8.3 as implemented by procedure PAP-0522. The

procedure stated,in part, that non-intent conditional changes receive approval from

two members of plant management staff knowledgeable in the affected area, at ,

least one of whom is either the Shift Supervisor (SS) or Unit Supervisor (US); and l

that the change is assigned an effective date and is implemented in the respective i

instruction. Although I&C management and the US agreed that the 120 Vac

voltage value would confirm that the relay contact was closed, their decision to

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perform the two SVis before PIC approval bypassed specific temporary change

procedure requirements. The failure to follow procedure PAP-0522 by documenting

PIC approval and assigning a PIC effective date before implementing the two SVis

is considered a violation (50-440/97006-01) of 10 CFR 50, Appendix B,

i Criterion V, " Instructions, Procedures, and Drawings." The licensee recognized that

a potential conflict may exist between PAP-0522 and PAP-1105. PlF No. 97-0704,

, dated April 24,1997, was initiated by the licensee to investigate TS and Updated

! Safety Analysis Report (USAR) requirements associated with the instruction change

process.

c. Conclusion.1

The inspector concluded that the performance of the two SVis before completing

the PICS had minimal safety consequences since the expected reference voltage

had been independently confirmed to be 120 Vac and had been discussed with the

US. However, the inspector was concerned that the l&C supervisor used a

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" window of opportunity" as a basis to do safety related testing and time was spent

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trying to find a way to do the surveillance instructions before completing the PIC

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process. In addition, the US had the opportunity to implement the PICS before

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performing the surveillance instructions since the US's signature and date would

have approved the PICS for use with the instructions.

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M5 Maintenance Staff Training and Qualification I

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M5.1 Selection of Qualified Personnel to Perform Work i

a. Insoection Scooe

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The inspector reviewed the selection process used by electrical and mechanical i

maintenance departments to assign qualified mechanics to do safety related work.  !

The inspector reviewed 10 circuit breaker periodic / maintenance work orders ,

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performed during 1986 through 1996 to verify that qualified electrical mechanics

had been selected to do the maintenance activity. This included electrical mechanic

circuit breaker qualification records around June 1992 because OJT-4421 had been  ;

revised during this time period to include circuit breaker maintenance as a task.

Documents reviewed included the following:

o Site Trainee and Requirernents Tracking System Detailed Completions

o Work Order Nos. R86-04477; R86-06188; R87-00781; R87-00787; i

WO920001581; WO920001790; WO930002317; WO930002918; i

WO940002726; and WO96004245  :

o Training Manual Programs (TMP)-2400, Revision 3, " Maintenance Supervisor

Training and Certification Programs l

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o TMP-2'006, Revision 5, " Mechanical Maintenance Training, Qualification and l

Certification j

o TMP-2026, Revision 0, " Electrical Maintenance Training, Qualification and

Certification

o On the Job Training (OJT)-4421-05 " Circuit Breaker Maintenance"  !

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o OJT-4420-04, " Test Equipment" '

o OJT-5118, " Breaker Maintenance, 5HK/15HK"

o OJT-5120, " Breaker Maintenance,480V" l

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O OJT-5176, " Electrical Test Equipment"

o Classroom Course, ME-2129, " Circuit Breaker Maintenance and Testing"

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o OJT-4441, " Mechanic Grade 2 (Machinist) Qual Card Valve Maintenance"

o Perry Self-Assessment, January 8-12,1996, " Maintenance Training Program

Evaluation"  !

O PlF No. 95-0495, Documented Results of the Maintenance Training Program

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o PlF No. 95-0597, Work Activities that may Require Direct Supervision

b. Observations and Findinaq

The inspector determined that subsequent to the 1992 revision to OJT-4421,

incumbent electrical mechanics were evaluated and re-qualified to do circuit breaker

maintenance based on their completion of the training specified in ME-2129. The

inspector confirmed that the electrical mechanics selected to do the circuit breaker

maintenance had documented records attesting to their qualifications. The licensee

has initiated circuit breaker re-qualification for all of their electrical mechanics. As

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of April 22,1997,13 of 22 electrical mechanics received additional 480 volt circuit

breaker maintenance training and 8 received additional SKV and 15KV training.

Mechanic Qualification Matrixes were maintained in each maintenance department.

Maintenance supervisors used the weekly updated hard copy matrix or the plant

computer qualification list to select maintenance mechanics before assigning work.

The inspector reviewed the April 23,1997, work assignments and confirmed that

qualified mechanics had been selected to do the work.

The inspector reviewed OJT-5118, Revision 0, and OJT-5120, Revision 0,

qualification cards. Prerequisites for these cards included OJT-5107 (Test

Equipment) and ME-2129. Circuit breaker classroom training (ME-2129) had been

completed by the qualified electrical mechanics. However, the inspector could not

confirm that OJT-5107 had been completed. The licensee informed the inspector

that completion of OJT-4420-04 fulfilled OJT-5107. The inspector reviewed OJT-

4420-04 and concluded that the training provided was adequate to support the

circuit breaker maintenance qualification requirements. In addition, the inspector

confirmed that the circuit breaker qualified electrical mechanics had completed OJT- 1

4420-04. The licensee has recently changed the electrical mechanic test I

equipment requirements to OJT-5176. Additional test equipment was added and all  ;

electrical mechanics received additional training on the new OJT. The inspector did  !

not identify any concems.

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The inspector reviewed the process for selecting electrical mechanics to do safety- l

related work when the mechanics had completed their qualification card but the  !

certification paperwork had not been signed. The licensee indicated that  !

completion of the qualification card was sufficient notification that a mechanic was

qualified to do work. If the mechanic was newly qualified, five maintenance j

supervisors (electrical and mechanical) interviewed by the inspector indicated that '

they wouid spend additional time or assign a qualified mechanic to work with the

newly qualified mechanic if the work was complicated. The inspector reviewed

documentation for two newer qualified electrical mechanics to decide if they had

done any safety-related circuit breaker maintenance. The licensee initiated a name

and Perry badge number search for the two mechanics. The search did not identify

any safety-related circuit breaker maintenance activities that indicated they were j

the sole mechanics doing the work. The inspector did not identify any concerns. i

The inspector reviewed PlF Nos. 95-0495 and 95-0597. Both PIFs identified

certain work activities where mechanic qualifications could not be shown. Several

of these work activities included chiller maintenance, equalizing battery charge, and

flow control valve maintenance. The PlFs indicated that the identified activities

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should be done under direct supervision until past maintenance performance could

be verified. For those where past performance had been shown, those mechanics

were qualified for 1 year. Maintenance Policy No. 9638, " Craft Usage Prior to

Qualification," was issued to maintenance supervisors for implementation on

September 20,1996. The supervisors could use a pre-job briefing, post-job

briefing, or supervisor hold points during the performance of certain maintenance

tasks if mechanic qualifications could not be readily established. Interviews with

five maintenance supervisors indicated that many activities identified by the PlFs

were infrequently performed evolutions that gave the maintenance departments

time to re-qualify personnel. The supervisors indicated that they were

knowledgeable about the policy statement and would only select qualified personnel

or directly supervise the work activity. In addition, the inspector discussed

maintenance supervisor qualifications. The five supervisors indicated that they

would not directly supervise a work activity if they had not completed qualifications

in that area. The inspector did not identify any concerns.

During the document reviews, the inspector noted that a completed qualification

card (OJT-4441) lacked trainee initials at several valve evaluation points. Tha

mechanical trainer and evaluator had signed that the activity had been successfully ,

completed. The inspector interviewed the trainee and concluded that the training '

evolutions had been completed. The mechanical trainer indicated that many

qualification cards were being revised to require a trainee's signature following

completion of a task. The inspector reviewed several revised qualification cards

and concluded that the signature of completion was being controlled in an

acceptable manner. The inspector did not identify any concerns.

c. Conclusions

Overall, the inspector concluded that the licensee was controlling the selection of l

qualified maintenance mechanics in an acceptable manner. In addition, the

licensee's training program self-assessment seemed comprehensive. The licensee

acknowledged that deficiencies existed in the maintenance training program and

has taken steps to correct the identified weaknesses. In particular, the inspector j

reviewed the electrical mechanics qualification process and concluded that the

training improvement plan and time table to restore qualifications was progressing

in a satisfactory manner.

V. Manaaement Meetinos

X1 Exit Meeting Summary

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

conclusion of the inspection on A.pril 24,1997. The licensee acknowledged the findings i

presented. '

The inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

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i PARTIAL LIST OF PERSONS CONTACTED  !

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, . Licensee

. R. Brandt, Plant Manager

N. Bonner, Director, Nuclear Maintenance Department l

l . J. Heishman, Supervisor, Maintenance -

T. Henderson, Supervisor, Regulatory Affairs .  :

T. Rausch, Director, Nuclear Services Department l

D. Schwartz, Superintendent, Electrical

D. Wood, Maintenance Support Training Coordinator

L. Zerr, Regulatory Affairs

NRC

R. Twigg, Resident inspector, Rlli )

M. Urano, Observer, Rlli

INSPECTION PROCEDURE USED

IP 62703: Maintenance Observation i

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ITEMS OPENED, CLOSED, AND DISCUSSED j

Opened i

50-440/97006-01 . VIO failure to process a surveillance procedure / instruction change

before performing the procedure i

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