IR 05000440/1985030

Insp Repts 50-440/85-30 & 50-441/85-14 on 850506-10 & 13-17. No Noncompliance Noted.Major Areas Inspected:Actions on 10CFR50.55(e) Items & Evaluation of Actions Re IE Circulars

ML20126C372
Person / Time
Site:	Perry
Issue date:	06/11/1985
From:	Knop R, Scheibelhut C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20126C347	List: IR 05000440/1985030 ML20126C344
References
50-440-85-30, 50-441-85-14, IEC-80-03, IEC-80-3, IEC-81-12, NUDOCS 8506140398
Download: ML20126C372 (10)

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U. S. NUCLEAR REGULATORY CGIMISSION

REGION III

Report N /85030 (DRP); 50-441/85014 (DRP)

Docket N ; 50-441 License N CPPR-148; CPPR-149 Licensee: Cleveland Electric Illuminating Company Post Of fice Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Units 1 and 2 Inspection at: Perry Site, Perry, OR Inspection Conducted: May 6-10 and May 13-17, 1985 YPL/ l Inspector: C. H. Scheibelhut h/lf/ 8 8 Date

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Approved by: R. C. Knop, Chief 6,/#/7J~

Reactor Projects, Section IA Date Inspection Summary Inspection on Mat -10 6 and Mar 13-17. 1985 (Reports No. 50-440/85030(DRP)1 50-441/55014 TDRP)T Areas Inspected: Routine safety inspection by a Regional Inspector of licensee actions on 10 CFR 50.55(e) items and evaluation of licensee action with regard to IE Circulars. 'Ihe inspection involved a total of 68 inspector-hours onsite by one NRC inspector and includes 0 inspector-hours during off-shift Results: No items of noncompliance were identified in the areas inspecte PDR ADOCK 05000440 0 PDR

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4 Persons Contacted

Cleveland ; Electric Illuminating Company

'C. M. Shuster, Manager, Quality Assurance (QA)-

F. R. Stead. Manager Nuclear Engineering Department (NED)

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7 1- E. C. Willman, ' Senior Engineer. NED

! R. G. Solt. Supervisor. Procurement and Administration Quality Section r

(PAQS)

S. Tulk, Supervisor, Construction Quality Section R. O. Neuendorf, Audit Coordinator. Nuclear Quality Assurance Department-(NQAD)

< ~ C. L.' Thompson, Technical Aide, QA The inspector also contacted other licensee and contractor personnel i

' during the course of the inspectio !

The personnel listed above attended the exit interview on May 17, 198 ' Licensee Actions on 10 CFR 50.55(e) Items (Closed) 10 CFR 50.55(e) Report (440/81008-EE, 441/81008-EE (DAR 7 60)): " Bailey' 720 Utility Station." The Be lley Control Company identified a potentially reportable condition with the.720 Utility

. Station that they supplied to the licensee through General Electric (GE). These devices have pushbuttons that may stick in an open or

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closed position as a result of irregularities on the plastic part

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used in the switch assembly.

The licensen wrote Nonconformance Report (NR) 0QC-043 to document *

-the problem and track the disposition. GE wrote Field Deviation

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Disposition Reports (FDDRs) KL1-671 (for unit 1) and KL2-600 (for unit 2) to disposition the problem. As a result of - these FDDR a i total'of 71 of the devices (all of the devices in safety-related j systems) were removed from the plant returned to the vendor for ,

j rework, and reinstalled in the plant.

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The inspector - reviewed the completed NR. the FDDRs. and the follow-ing Inspection Reports that documented the operability of the re-worked devices and their reinstallation: R-82-0863. R-83-0971. R-

.83-1222. R-83-1451, ' R-83-2604. R-83-3713. R-84-4672. R-84-5034 and R-84-762 The review showed that all of the Bailey 720 Utility ;

,L . Stations installed in safety-related systems had been removed, re-i turned to the vendor for rework, inspected for proper operation, and satisfactorily reinstalled. This item is close ; (Closed) 10 CFR 50.55(e) Report (440/83008-EE (DAR 123)): " Control

Complex Chilled Water System Automatic Restart. See GAI Part 21 letter dated June 30, 1983." The licensee's architect-engineer, Gilbert Associates, 'Inc. (GAI) was performing a system interaction

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l review and determined that either a Loss of Offsite Power (LOOP) or

. Loss of Coolant Accident (LOCA) would cause a trip of the control i 2

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complex chiller which was operating. The design would have left the chiller inoperable for a minimum of twenty _ minutes due to protective

'interlocks. Operator action would have been required to restart the chiller. The design conflicted with FSAR requirements which specify automatic restart. GAI wrote a 10 CFR 21 report.and the licensee wrote a 10 CFR 50.55(e) report to document the conditio The licensee issued Engineering ' Change Notices (ECNs) 21138-86-403 and 20400-33-3281 and Work Authorizations (WAs) NTS-84-8665. NTS-85-0650, and NTS-85-1158 to correct the deviation. The licensee wrote a Corrective Action Request (CAR) 83-06 to determine the root cause of the condition and if it was a generic problem. Under this CAR, GAI initiated a Safe Shutdown System Review (SSSR) and the licensee-had an independent Systems Functional Capability Review (SFCR)

performed by an outside contracto Paragraph 2.b of Inspection Report 50-440/85019 (DRP), 50-441/85010 (DRP) indicates that the corrective actions taken under the CAR were effective in resolving the generic concerns raised by this devia-tio The inspector determined that the work necessary to provide an automatic restart of the control room chillers following a LOOP or LOCA was completed for unit The inspector reviewed the ECNs and WAs and concluded that the changes were proper and accomplished in accordance with the licensee's quality assurance program. This item is close c. (Closed) 10 CFR 50.55(e) Report (440/83023-EE (DAR 147)): "Woolley Part 21 - Environmental qualification of personnel airlock See Woolley letter dated September 19, 1983." The W. J. Woolley Co. .

vendor of the personnel airlock inflatable seals, wrote a 10 CFR 21 report indicating that the seals may not be environmentally quali-

.. fled for the temperature in the drywell. The licensee wrote a 10 CFR 50.55(e) report to the NRC concerning the proble The licensee wrote Nonconformance Report (NCR) TAS-070 to document the condition and track the disposition. The vendor redesigned the inflatable seal and environmentally qualified it, by testing, for the Perry conditions. However, the new design required that the maximum air pressure be less than the air pressure provided by the plant air system. Accordingly the licensee prepared ECN 22531-45-1899 incorporating a flow restrictor and relief valve in the inflat-able seal' air supply syste Inspection Report No. 5978 presented the quality assurance documents covering the installation of the restrictor and relief valve. Since the old seal had exceeded its five year " shelf life", the NCR was used to remove and scrap the old seal and' install the new on The inspector determined the new seal, restrictor, and relief valve had been installed. A review of the W. J. Woolley letter of September 18,1983, the 50.55(e) report, the NCR, the ECN, the inspection report, and the W. J. Woolley inflatable Seal Qualifica-tion Report showed that the problem had been satisfactorily resolved for unit 1. This ites is close ,

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k, Ed . - (Closed) 10 CFR 50.55(e) Report (440/84006-EE (DAR 159)): " Pacific

-_ Air Products Part 21 - The. linear converters furnished for Perry may

. wear excessively (HVAC)." On February 1.1984, the Pacific Air Products Co. (PAPCO) notified the licensee that they had filed a 10 CFR 21 notification with the NRC relative to a potential for pre-nature failure of PAPCO supplied linear converters on multi-blad dampers and louvers utilized in safety-related heating, ventilation, and air conditioning (HVAC) system Inspection Report 50-440/84015 (DRP), 50-441/84014 (DRP) gave de--

tails on an interim inspection on this item. The item was lef t open

• pending NRC verification of the following actions:

1. . Verify that M32 and M43 linear converters were properly _lubri-cated and adjusted to reduce oscillations to 20 or less per hou .. Verify that that M15 linear converters were rebuil . . Verify that an acceptable maintenance program was established for the linear converters in the maintenance manua Under NCR TAS-109, the licensee wrote Work Authorizations NTS-85-3686 for the M32 system linear converters, and NTS-84-7538 for the M43 system linear converters. These WAa covered the field lubrica-tion of the converters and the control system adjustments to reduce ,

oscillations to under 20 per hour. The Robert . Isray Company, the HVAC subcontractor, issued P.O. 49-2711 to have the MIS system linear converters rebuilt by the factor The Isray Installation Surveillance Checklist QCP-11-6/707 documented the installation of the rebuilt converter The licensee wrote Preventive Maintenance Instruction R4I-002 Re O, dated January 8,1985, " Preventive Maintenance Program for the SL 100 ~ LC Converters" to establish an ' approved maintenance procedur The inspector verified that the three open items were accomplished '

satisfactorily for unit I by inspection and review of the above documents. This item is close e.- . (Closed) 10 CFR 50.55(e) Report (440/84009-EE (DAR 162)): "HPCS System - No' power monitor downstream of the fuses that supply some control relays. The SFCR, mentioned in paragraph 2.b above, found that there was no bypass and inoperable status indication provided in the control room (in accordance with Regulatory Guide 1.47) if the fuses for three relays were blown or remove If the fuses were gone LOCA initiation signals to some safety-related equipment including the HPCS diesel,'would not be sen The licensee wrote Engineering Design Deficiency Report (EDDR)-007 to evaluate the conditio The evaluation concluded that the fuses were not necessary because good engineering practice does not call for fuses to be used with that type of relay. Accordingly, the licensee wrote ECN 20331-86-356 to remove the fuses and correct the

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associated drawings. WA No. NTS-84-1882 provided the work authori-sation and the necessary QA reviews. - Drawings - B-208-065 sheet A100, Rev. F. E-210-100 sheet 395. Rev. G, and E-210-100 sheet 396 Rev. H were revised to show the deletion of the fuse .The inspector determined that the fuses in question were removed in the unit 1 control syste The inspector's review of the EDDR showed that a proper decision _was made. The review of the other documents showed that the work was done in accordance with the QA  :

plan. This item is close (Closed)'10 CFR 50.55(e) Report (440/84010-EE (DAR 163)): "HPCS l

System - MOV E-22F001 shuts before E-22F015 is fully open which  ;

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could result in less than specified flow." The SFCR, mentioned in paragraph 2.b above, found that the HPCS pump suction isolation '

valve E-22F001 could shut before pump suction isolation valve E-22F015 would be fully open. This would occur if the HPCS pump were i-switching water sources from the condensate storage tank to the [

suppression pool and could result in tripping the pump on low t suction head or a reduced flow rat The licensee wrote EDDR-008 to investigate the problem and suggest a solution. The investigation found that the limit switch settings on the valves were not specific on the elementary diagrams. Conse-quently, ECN 21119-86-397 was written to specify limit switch settings on elementary diagram-B-208-065 sheet A10. Rev. F and accomplish the work in the fiel The inspector reviewed the EDDR,' ECN, drawing, and Inspection Report R84-2237 which verified the change and ratesting to prove' satis-factory operation. The review showed that for unit 1 the suction isolation valve to the suppression pool, E-22F015. is fully open before the suction valve to the condensate storage tank, E-22F001, begins to clos This item is close { (0 pen) _10 CFR 50.55(e) Report (440/84014-EE, 441/84014-EE-(DAR 172)): '"HPCS power supply - FSAR states that regulator switch S-26 in a manual position will prevent the diesel generator from start- '

in There is no indication of this logic on the drawings." The SFCR, mentioned in paragraph 2.b above, found that if the voltage i regulator switch on the.HPCS diesel generator (located in the diesel ,

generator room) were in the manual position, the diesel generator i would start. This condition was contrary to the FSAR requirements  !

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that called for lockout of the diesel generator and annunciation of the condition in the control roo '

The licensee responded by saying that the normal position of the voltage regulator switch is in the automatic position and that it would not be in the off or manual position when the HPCS system t would be required to function. He further stated that it was deter-

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I t mined that it was not necessary to provide a diesel generator over-

. ride lockout for the voltage regulator switch in the manual or off l l position and that the FSAR would be updated to reflect thi :

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O The inspector does not concur with these decisions. Further inspection revealed that if the diesel generator manual / automatic control switch (located in the diesel generator room) is its the manual mode, the diesel generator is locked out and the condition is annunciated in the control roo If the maintenance-test-auto switch is in the maintenance mode, the same conditions exist. A number of other conditions, not associated with switch positions, also cause lockout and annunciation in the control room. If the voltage regulator switch is in the manual mode and an emergency start signal were received, the diesel would start but the generator would supply non-regulated voltage to Class IE equipment. If the same switch were in the off position and an emergency start signal were received, the diesel would start but no power would be supplied to the HPCS system. Therefore a discrepancy exists. Three switches exist on the same panel. The mispositioning of any one of the three would cause loss of the HPCS diesel generator when required to function. Two of the switches cause diesel generator lockout and annunication in the control room when mispositione The third switch could be mispositioned with the operator unaware that the HPCS system was out of servic Therefore, this item remains open until the inspector can review the licensee's response to these concern h. (Closed) 10 CFR 50.55(e) Report (440/84017-EE, 441/84017-EE (DAR 177)): " Nonessential instrument power is utilized to power safety-related temp controller G33N008." The SFCR, mentioned in paragraph 2.b above, found that nonessential instrument power is utilized to power temperature controller G-33-N00 A contact from this con-troller is utilized in a Reactor Protection System (RPS) Bus A circuit which provides inputs to ESF circuit Inadequate separa-tion (electrical) is provided and G-33-N008 is not a qualified devic The licensee discovered that the problem was the result of Perry Equipment Qualification being updated from 1971 standards to present standards. The problem was previously identified under the GE Qualification Program and is being tracked under that progra The inspector agrees that this item is not reportable under the require-ments of 10 CFR 50.55(e).

The inspector reviewed the actions taken under the GE qualification program. The device in question senses the temperature of the water going to the mixed bed ion exchange resins in the reactor water cleanup system (a non-est system). If the water temperature gets too high, the controller shuts one of the isolation valves in the system to protect the resins from thermai degradation. A failure mode ef fects analysia (PY-GAI/ GEN-2720. dated June 17, 1983) showed that failure of the controller would not compromise safety functions, i.e., operation of the containment isolation valves. To solve the electrical separation problem, FDDR KL1-3021 changed the power supply to the controller from nonessential instrument power to RPS power. The inspector concurs that the disposition was prope This item is close ____

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'i.- (Closed) 10 CFR 50.55(e) Report (440/84018-EE, 441/84018-EE (DAR  :

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-178)): " Failure of K-7D relay contact could result in both the inboard and' outboard isolation valves not closing." The SFCR, mentioned in paragraph 2.b above, found that a failure of relay K-7D in panel H13-F694 (contacts T1, M1, T3, M3) resulting in a short

[ .w ill keep all solenoids'of both inboard and outboard Main Steam '

Isolation Vsives (MSIVs) energized disabling the isolation logi This condition appears to violate the single failure criterio I The licensee wrote EDDR No. 083 to investigate the condition. GE '

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- reviewed the drawings and reported (letter FY-GEN /CEI-218, dated July 12. 1984) that the single failure criterion was not violate As shown on elementary diagram 828-E-445CA, relay K-75 is in series with relay K-7D (contacts T1. M1, T3. M3) and has a redundant ,

. function. Thus failure of both relays by shorting must be postu- i

~ 1sted to prevent closure of the MSIV The inspector reviewed the EDDR, the GE letter and the drawing and concurs that the SFCR finding was in error. The single failure  ;

criterion is not violated in this instance. This item is close (Closed) 10 CFR 50.55(e) Report (440/84019-EE, 441/84019-EE (DAR l 179)): "A relay contact was not properly installed that would prevent a RCIC low suction trip for 15 see af ter a main steam valve o pens ." The SFCR, mentioned in paragraph 2.b above, found that the '

FSAR (Section 5.4.6.2) requires a 15 second bypass of the RCIC pusp '

low suction pressure trip after the steam supply valve to the RCIC .

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pump turbine opens. They found, also, that the present design does not allow for thi ,

The licensee requested CE to evaluate the condition. GE replied ,

(letter FY-GEN /CEI-2147) that the bypass is unnecessary because  !

sufficient suction pressure is provided by elevation differences ,

between the pump and water source. Further, their RCIC system  !

design documents do not require such a bypass. They recommended that the FSAR be changed to delete the bypass' requirement. Accord-ingly, in Amendment 15 to the FSAR submitted December 31.1984. the licensee deleted the requirement for the bypas The inspector reviewed the GE letter and amended FSAR and concurs with the conclusion that the time delay bypass of the low suction trip is unnecessary. This item is close (Closed) 10 CFR 50.55(e) Report (440/84020-EE, 441/84020-EE (DAR ,

181)): " Failure of a DC motor winding for the RCIC system is not

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l indicated when the switch is in the operating and bypass posi-  ;

tion." The SFCR, mentioned in paragraph 2.b above, found that a L loss of power, due to blown fuses, to DC motor operated valve motors in the ROIC system was not included in the inoperative and bypass annunciator syste The licensee wrote EDDR 103 to investigate the conditio He found that d'en power is deliberately disconnected at the motor control center, as shown on Elementary Diagram B-208-075 sheet A09, the fact I

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is annunciated in the control roo Further, Regulatory Guide 1.47,

" Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems", does not require indication for events postulated to occur less frequently than once a year. Since blown fuses are not. expected to occur more frequently than once a year, the existing system meets the intent of the Regulatory Guid The inspector reviewed the drawing and the Regulatory Guide and concludes that the existing system meets the intent of the Regula-tory Guide. This item is close . (Closed) 10 CFR 50.55(e) Report (440/84023-EE, 441/84023-EE (DAR 184)): " Reactor Core Isolation System Valve E51F063 - Design re-quired an opening and closing time of 10 see at 1177 psi. GAI spec

. required 20 sec cpening at 741 psi." An NRC Construction Assessment Team (CAT) found the above discrepanc The licensee performed an engineering evaluation of the discrepancy and presented the results in Memorandum 501-10345 dated May 23, 1984. The evaluation found that a previous study had shown that 10 CFR 100 guidelines could be exceeded under a combination of certain conditions if the RCIC/RHR steamline ruptured outside of containment during normal plant condition Accordingly, the inboard isolation valve, E51F063. was changed f rom a normally open to a normally closed valve. This change removed any closing time requirement During normal plant conditions, valve E51F063 is bypassed by a small

.(1 in.) " keep warm" valve that keeps the steamline hot to the RCIC turbine shutoff valve E51F045. This condition ensures that no pressure differential exists across E51F0663 when the RCIC system is shut down. Tb limit the pressure drop across E51F063 when the RCIC system is called on to operate, a two-second time delay has been added to the opening of E51F045 This will limit the opening pres-sure drop across E51F063 to 741 psi. Valve E51F063 was factory tested for opening and closing times with a 750 poi differentia It opened in 13.9 seconds and closed in 19 seconds. This opening time is well within the 20 second requiremen The licensee amended

the FSAR to be consistent with the GAI specification and asked GE to

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change their specification. GE issued FDDR KL1-452 to amend their specification for the valv The inspector reviewed the memorandum, the factory test results, the

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amended FSAR, and the GE specification, and determined that the preoperational test for the RCIC system has been reviewed. The inspector agrees that the discrepancy is not reportable under 10 CFR 50.55(e). This item is closed.

[ (Closed) 10 CFR 50.55(e) Report (440/84028-EE (DAR 189)):

" Incorrect electrical design if gone uncorrected would not have

. allowed the DG to synchronise to grid in certain switch posi-

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t ions ." The SFCR, mentioned in paragraph 2.b above, found that for

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Division 1, units 1 and 2, wrong contacts were used in the remote-local switch'that controls the preferred supply breaker. On loss of offsite power, the diesel would start, but the generator would not connect to the bus.

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The licensee wrote ECN 22054-86-454 to correct the situation. WA NTS-84-6592 provided authorisation to make the changes and provide

. QA documentatio The inspector reviewed the ECN associated drawings and WA and deter-mined that the changes had been made and ' tested on unit 1. This item is close (Closed) 10 CFR-50.55(e) Report (440/84034-EE, 441/84034-EE (DAR 199)): '" Deficient' Rockbestos Twinax Cable - Third layer of insula-tion was bonded to second layer during manuf acturing process."

While terminating a particular lot of twinax cable, the licensee found that the normal. procedure would not work. Nonconformance report LKC-4760 was written to document the problem and provide a dispositio A sample of the cable was sent to Rockbestos, the vendor, for evaluation. The Rockbestos evaluation was transmitted to the licensee in a letter dated September 5,1984. The evaluation stated

hat manufacturing problems during the production of the lot of cable had caused unwanted bonding between the second and third la,ters of insulation. Electrically, the cable met all of the requirements but termination problems could be expected. The licensee then developed a special termination procedure to be used with the particular lot of cable. The vendor subsequently approved the special procedur The inspector reviewed the vendor's evaluation and the special termination procedure. The review showed that the problem was not a significant deficiency reportable under the requirements of 10 CFR 50.55(e). This item is close o.' (Closed) 10 CFR 50.55(e) Report (440/84037-EE, 441/84037-EE (DAR 201)): "Conam part 21 concerning 821 defective power lead gland sealing assemblies at Perry l 'and 2." The Conax Corporation in-formed the licensee of a potential defect in power lead gland seal-ing assemblies as part of a 10 CFR 21 report. Similar assemblies at another nuclear facility had experienced total conductor separatio The licensee wrote nonconformance reports TAS-90 (unit 1) and TAS-91 (unit 2) to document the situation and track the resolution. At the vendor's request, 41 assemblies were returned for testin The Conax Final Engineering Report (IPS-1253) on the subject indicated that a production technique peculiar to the unsatisfactory assen-blies was.used. Testing of the 41 Perry units simultaneously with six of the unsatisfactory units revealed that all of the Perry units passed the test while five of the six unsatisfactory units faile They concluded that the Perry units were satisfactory for their intended use and that they had found the reason for the failure of the other unit The inspector reviewed the Conax report and concurs with their finding This item is close .

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No items of noncompliance 'or deviations were identifie . , Evaluation of Licer.see Action with_ Regard to IE Circulars For the IE Circulars listed below, the inspector verified that the circu-lars were received by the licensee management, that a review for applic-ability was performed, and if the Circular was applicable to the facility, appropriate corrective actions were taken or scheduled to be t ake (Closed) IE Circular 80-03 (440/80003-CC, 441/80003-CC): " Pro-tection from Toxic Gas Hazards." The circular recommended that licensees review their FSARs in light of the guidance contained in revised Standard Review Plans (SRPs) 2.2.1-2.2.2 " Potential Hazards in Site Vicinity", 2.2.3 " Evaluation of Potential Hazards", and " Habitability Systems". The licensee made the review and found that two potential hazards were applicable to the Perry Plant. Accord-ingly, the FSAR was changed to recognize chlorine gas and ethylene oxide gas as potential hazards. In addition, redundant chlorine and ethylene oxide detectors were installed at the two air intakes for the control room habitability syste The inspector determined that the detectors have been installed and are scheduled for test. This item is close (0 pen) IE Circular 81-12 (440/81012-CC, 441/81012-CC): " Inadequate

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Periodic Test Procedure of MdR Protection System." The licensee reviewed this Circular and concluded that it was applicable to the Perry Plant. The Circular cited a case wherein the trip circuit breakers in a nuclear plant did not trip immediately during a test on an undervoltage conditio It was found that the undervoltage trip devices were out of adjustment. The shunt trip of the breakers functioned as designed. The Circular recommended that the pro-cedures for surveillance testing of RPS circuit breakers include independent testing of each trip function (i.e., undervoltage and shunt) including position verification to ensure that the breaker actually trip The inspector determined that the specific procedures for this testing have not all been written. Therefore, the item remains open untti the inspector reviews the pertinent procedure No items of noncompliance or deviations were identifie . Exit Interview The inspector met with the resident inspector and licensee representa-tives (denoted in paragraph 1) at the conclusion of the inspection on May 17,198 The resident inspector summarized the scope and findings of the inspectio The licensee acknowledged the inspector's finding _ . - _ _ _ _ . _ - - - _ _ _ .