IR 05000440/1999003
| ML20195G698 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/10/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20195G678 | List: |
| References | |
| 50-440-99-03, 50-440-99-3, NUDOCS 9906160147 | |
| Download: ML20195G698 (19) | |
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[ U. S. NUCLEAR REGULATORY COMMISSION REGION Ill
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. Docket No: 50-440 License No: NPF-58 Report No: 50-440/99003(DRP)
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i l- Licensee: FirstEnergy Nuclear Operating Company.
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P.O. Box 97 A200 Perry, OH 44081 l Facility: Perry Nuclear Power Plant Location: Perry, OH l
Dates: April 7 through May 17,1999 j inspectors: C. A. Lipa, Senior Resident inspector l l J. A. Clark, Resident inspector 1 Approved by: Thomas J. Kozak, Chief Reactor Projects Branch 4 Division of Reactor Projects l
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9906160147 990610 PDR ADOCK 05000440 0 PDR .
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EXECUTIVE SUMMARY Perry Nuclear Power Plant NRC Inspection Report 50-440/99003(DRP))
This inspection report included resident inspectors' evaluations of aspects of licensee operations, engineering, maintenance, and plant support activitie Operations
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The inspectors concluded that the overall conduct of operations continued to be professional with an appropriate focus on safety Lessons learned were applied from the previous refueling outage in the areas of procedure adherence, safety tagging, and work control in general, the licensee effectively managed a complex refueling outage with only minor problems noted (Section 01.1).
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A Non-Cited Violation was identified through two examples of operations department !
personnel failing to follow procedures as written. The inspectors were specifically concerned that, in these cases, operations personnel exercised some latitude with the
. procedures that was not applicable (Section 01.2). )
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The inspectors concluded that the licensee was effective in inspecting, identifying, and I correcting fuel failures which occurred during the operating cycle. Although the licensee i could not guarantee the removal of all foreign material from the reactor vessel, steps were taken to minimize the potential for future fuel damage (Section 01.3).
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The plant Technical Specifications limit individual work hours to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day l period unless very unusual circumstances arise requiring deviation from the limit. Most plant employees worked approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> each week during the refueling outag j Numerous deviations were processed during the outage to approve work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a week. Some of the deviations did not document specific reasons for the deviations nor did they provide any limit to the number of houns worked in a week. Plant management indicated that these deviations were for work on critical path activities which were considered to be very unusual circumstances (Section O3.1).
I Maintenance
- The inspectors concluded that outage-related maintenance and surveillance activities were well coordinated and performed properly, with few exceptions. Management oversight of activities was good (Section M1.1).
- A series of two surveillance failures concurrent with a scheduled maintenance activity led to a condition where the emergency diesel generators (EDGs) for Divisions 1,2, and 3 were inoperable at the same time during the refueling outage. The inspectors determined that the licensee met all Technical Specification requirements associated with the scheduling of these activities and that, due to the Division 1 EDG being available, there was no increase in plant risk as a result of these activities (Section M1.2).
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A maintenance technician left test equipment in a relay following a calibration activity as a result of inattention to detail. This was identified when the Division 2 EDG Loss of Offsite Power Test failed and resulted in an Non-Cited Violation (Section M1.3).
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The inspectors concluded that engineering department personnel provided timely and effective technical support to other departments for a variety of activities during the refueling outage (Section E1.1).
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The licensee utilized effective methods to maintain fuel accountability and verify the -
proper placement of fuel bundles in the core prior to reactor vessel reassembly (Section E7.1).
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Report Details Summary of Plant Status Refueling outage seven (RFO7), which began on March 27,1999, was ongoing at the beginning of this inspection period. On May 2, licensed operators commenced a reactor startup and the reactor was critical at 10:48 p.m. On May 3, operators synchronized the plant main generator to the electrical grid at 9:49 p.m., ending RFO7. Full power was attained on May 8, 1999, and the plant was maintained at or about 100 percent power through the end of the inspection perio . Operations 01 Conduct of Operations 01.1 Review of Routine Plant Operations inspection Scooe (71707)
Using the guidance of Inspection Procedure (IP) 71707, the inspectors conducted frequent reviews of ongoing plant operations during RFO7 and subsequent retum to full power operation Observations and Findinas in general, the licensee effectively conducted a complex refueling outage with only .
' minor problems noted. The outage was conducted from March 27 through the !
synchronization of the main generator to the grid on May 3,1999. The inspectors observed that all outage activities were conducted safely, with workers exercising conservative decision making. Major activities completed during the outage included:
refueling of the reactor, jet pump cleaning,10-year maintenance on the Division 2 emergency diesel generator, fuel assembly inspections, reactor pressure vessel nozzle inspections, elimination of the main steam isolation valve leakage control system, and plant material condition improvement During the Fell 1997 refueling outage (RFO6), several examples of personnel errors and personnel failing to follow written procedures were identified. Since RFO6, the licensee implemented a new procedure adherence guideline and conducted numerous training sessions for plant personnel on procedure adherence importance. The licensee also developed a performance indicator tracking system that includes periodic discussion of procedure adherence at management meetings. While the inspectors noted that
. procedure adherence improved from the last outage, some instances where workers failed to follow procedures occurred during RFO7 (see Section 01.2). The licensee also conducted training on safety tagging for plant and contractor personnel, to ensure adequate attention to detail through self-checking and peer reviews occurred during tagging activities. The inspectors reviewed several safety clearances, and the hanging and removal of various tags, with no problems noted. Near the end of RFO6, the licensee also adopted a new methodology for work control during outages. This method assigns specific control functions to a work control center, control room personnel, and
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4 refueling personnel. Training was also conducted by the licensee on how these groups are to interact with each other, including conduct of briefings, communications, and SRO oversight. ' The inspectors observed good coordination between these groups
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throughout the outag The inspectors observed several training sessions which were developed to help prepare operators for startup activities. This was a good use of the control room simulator and provided opportunities to practice many of the startup tasks. During the actual reactor startup, the inspectors observed good three-way communications, which was an improvement over communications observed during the shutdow Conclusions -
The inspectors concluded that the overall conduct of operations continued to be professional with an appropriate focus on safety. Lessons leamed were appiied from the last refueling outage in the areas of procedure adherence, safety tagging, and work control. In general, the licensee effectively managed a complex refueling outage with only minor problems note .2 bdherence to Written Procedures Inspection Scope (60710. 71707. and 71711)
The inspectors followed the guidance of IPs 60710,71707 and 71711 while monitoring or reviewing the performance of numerous outage related activitie Observations and Findinos During the observation or review of the performance of numerous operations department procedures, the inspectors noted some procedure adherence problems, in two cases, operators incorrectly interpreted procedural requirements which resulted in two examples of a violation. in another instance, procedures were not revised to update precautions and limitations. The concems are described below- i (1) Fuel Movement Checklist Error
- On April 5,1999, a step of the fuel movement checklist was being performed to
. remove a fuel bundle from core location 13-52. However, refueling operators I grappled and partially removed a fuel bundle from core location 15-50. One of the refueling bridge workers noted the error after the bundle had been lifted approximately 70 inches. The refueling ' supervisor notified the operations shift supervisor (SS) of the error, and requested direction on how to proceed. Fuel Transfer instruction FTI-D0009, Revision 5, defined lifting an incorrect bundle as a mispositioning error and prohibited reinsertion of the bundle in the original I location. The FTl specified that a mispositioned fuel assembly be placed in the containment fuel storage rack. However, the SS did not consider this a mispositioning error, and directed the refueling supervisor to reseat fuel bundle 15-50. Further review of this event revealed that this was a mispositioning error. Technical Specification 5.4.1.a requires written procedures !
. to be implemented covering the applicable procedures in Regulatory Guide I (RG) 1.33. A procedure for fuel movements is specified in RG 1.33, Appendix A; j
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The operators' failures to follow FTI-D0009, as written, is considered an example of a violation of TS 5.4.1.a. This Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement i Policy (NCV 50-440/99003-01(DRP)). This Violation is addressed in licensee's
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corrective action program (CAP) as CR 99-089 The licensee initiated a category 1 condition report (CR 99-0897) after l operations management became aware of the error. The SS was temporarily
relieved of duties and counseled about the issue. The CR investigation was j completed by the licensee, and several corrective actions were initiated and l implemented before the end of the inspection period. These included additional l operator training on fuel movements, better lighting and camera performance for
! the refueling mast, and a procedural change to FTI-D0009 to clarify the expected actions of refueling personne (2) CRD Drive Water Pressure The inspectors reviewed the narrative logs on April 17,1999, and noted an entry during the previous 24-hour period where the step for retuming the control rod
- drive (CRD) pressure to normal, per Section 7.9.1 of sol-C11 " Rod Control and L Information System," Revision 7, was marked as N/A by the SS. Section 7.9.1 of i
sol-C11 required, in part, that CRD pressure be restored to the normal band after it had been elevated for an individual rod. The inspectors asked the SS I how this step could be considered N/A. The SS stated that it was not practical to l reduce CRD pressure to the normal band after each individual rod and that N/A
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of this step was permitted under PAP-528, " Procedure Use and Adherence,"
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, PAP-528 permits the use of N/A for System Operating Instruction (SOI) steps l under two circumstances: 1) for a step in the prerequisites of an sol when plant conditions do not require or allow the performance of those steps; and 2) per
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Section 8 of PAP-528, the SS can use N/A when a procedure step does not i
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apply. However, Section 8 of PAP-528 states, in part, "N/A may be utilized when station conditions prohibit or negate the need to perform a step and the intent of l the procedure is not altered. The use of N/A simply due to a preference not to l perform the actions as specified in the procedure is not permitted."
l The inspectors questioned the SS on whether SOI-C11, Step 7.9.1.e could have l been performed under the present plant conditions and the applicability of either method described in PAP-528 to use N/A for this step. The SS replied to the l inspectors that the step could have been performed and that, after review of PAP 528, he did not concur with the decision to N/A the step. The SS stated that he would submit a procedure change request to sol-C11 to allow CRD drive l pressure to remain elevated while conducting multiple rod movements. After
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further discussions with operations department management, a condition report (CR-1470) was initiated for this issue. Technical Specification 5.4.1.a requires written procedures to be implemented covering the applicable procedures in RG 1.33. Procedures for operation of the control rod drive system and procedure adherence are specified in RG 1.33, Appendix A. The operators'
failures to follow SOI-C11 procedural steps, as written, is considered an additional example of a Violation of TS 5.4.1.a. This Severity Level IV violation is
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L being treated as an NCV, consistent with Appendix C of the NRC Enforcement l i Policy. This Violation is addressed in licensee's CAP as CR 99-147 l (3) Infreouentiv Performed Test or Evolution (IPTE) Controls in Surveillances
- The inspectors reviewed surveillance tests prior to scheduled completion and noted that several procedures had a Precaution and Limitation (P&L), which indicted that the test was to be controlled as an IPTE. Prior to the outage, Perry l management personnel reviewed the planned outage work activities and l determined which activities would be treated as an IPTE. PAP-1121, " Conduct of IPTE," allowed management personnel to decide not to treat activities that met the criterion for an IPTE as an IPTE. However, the surveillance instructions for the activities, such as the LOOP /LOCA tests, specified in the P&L' that the test
, met the criteria of an IPTE put forth in PAP-1121 and stated that Management i Designee and Oversight Team involvement was required including but not l limited to: 1) completion of a pre-evolution checklist; 2) termination of the test if l
the level of safety is reduced to an unacceptable level; and 3) review of the performed test following completion for improvements or necessary procedure changes. For these tests, the inspectors asked the test performer why it was acceptable to disregard the P&L in the surveillance instruction. The test l performer explained the management decision regarding IPTEs and indicated
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that the P&L could be treated as an obvious error as allowed by PAP-528.
l The Plant Manager provided the inspectors with a list of those tests which were designated as IPTEs for RFO7. PAP-1121 did not require the LOOP /LOCA tests to be IPTEs; it only required con %eration of the need to control the tests as IPTEs. The inspectors had no concems with the LOOP /LOCA test performances or with the decision to not treat the tests as IPTEs. The inspectors remained concemed that the P&L in the surveillance instructions was not adhered to or changed. The licensee indicated that while the P&L implied that the tests were to be treated as an IPTE, PAP-1121 governed the activit The licensee initiated CR 99-1470 to document and review the inspectors'
concems that the test performers did not request a change to the P&L to clarify that the tests were not being treated as IPTEs. This was not considered to be a violation of NRC requirements because PAP-1121 allowed a management decision on the need to control the tests as IPTE Summary The inspectors discussed the three concerns listed above with licensee management at the exit meeting. There was considerable discussion of the intent of the allowances provided within PAP-528. The inspectors noted that in several cases, operators applied
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c. Conclusions A Non-Cited Violation (NCV) was identified through two examples of operations department personnel failing to follow procedures as written. The inspectors were specifically concemed that, in these cases, operations personnel exercised some latitude with the procedures that was not applicabl L
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j 01.3 Refuelina and Core Alterations Inspection Scope (60710)
The inspectors followed the' guidance of IP 60710 in monitoring the performance of refueling and core alterations activities. The inspectors observed activities associated with fuel movement on the refueling floor, in the fuel handling building, and from the control room.' Observations and Findinas The inspectors observed aumerous activities associated with the offloading and refueling of the reactor core, and with handling fuel bundles for sipping, inspection, and reconstitution tasks.' With the exception of a single mispositioning (see Section 01.2), all ;
fuel movements were conducted without error. All refueling activities were appropriately ;
manned and supervised with qualified personnel. Communications between the locations for refueling activities was typically clear, and personnel utilized three-legged communications as expected. Workers were observed using attention-to-detail while conducting sipping tests on the suspected leaking fuel bundles, and on all other fuel bundles that would remain in the core for the next fuel cycle.'
The licensee quickly located the specific failures for all three previously indicated fuel i leaks. The licensee determined from the inspections that the three leaking fuel bundles l were damaged by foreign material debris in the reactor vessel. One fuel assembly was i observed to have a small metal shaving still wedged in the spacer piece at the site of the defect. The licensee conducted detailed visualinspections of another 40 random bundles to look for any apparent damage or debris. The licensee did not find any addition failures during these inspections, but did find additional debris. The licensee also identified a potential fourth leaking fuel bundle through the sipping operation l
~Although this bundle was carefully visually inspected, no indications of the leak could be
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determined. <The licensee decided to segregate this fuel bundle, and refuel the reactor core without reinstalling it. One of the leaking bundles was reconstituted by replacing the flawed pin, with an individual fuel pin from the segregated bundle, and was reinserted in the cor The licensee discussed the fuel defects with its vendor. The fuel vendor concurred with the cause of the flaws being damage from foreign material. The licensee and the fuel vendor also concluded that there is a possibility that some foreign material could still be present in the reactor vessel. The licensee informed the inspectors that a complete core offload and vessel cleaning was considered. However, they concluded that removal of all small debris could not be guaranteed, and that the overall benefit of vessel cleaning would therefore be marginal. As a preventive measure, the licensee coordinated with the fuel vendor and installed 280 new fuel assemblies that have debris filters in the nose piece. These 280 bundles represeret approximately 37 percent of the total fuel bundle The licensee plans to install additional nose piece filters during subsequent refueling outage .
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, Conclusions The inspectors concluded that the licensee was effective in inspecting, identifying, and correcting fuel failures which occurred during the operating cycle. Although the licensee could not guarantee lhe removal of all foreign material from the reactor vessel, steps
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02 Operational Status of Facilities and Equipnient
- O2.1 General Plant Tours and System Walkdowns (71707. 71711)
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The inspectors followed the guidance of IP 71707 and 71711 in walking down accessible portions of several systems and areas, including:.
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Drywell and containment
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Reactor core isolation cooling system
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Fuel handling building l Equipment operability and material condition were acceptable in all cases.
I Housekeeping was considered to be reasonable for a refueling outage and cleanup activities were planned. Minor discrepancies were brought to the licensee's attention and were corrected. The inspectors walked down the drywell prior to plant startup, after clean-up was complete and noted that its condition and cleanliness were goo Operations Procedures and Documentation
! . O3.1 - Review of Overtime Usaae Durino Refuelina OL4eoe Inspection Scope (71707)
l The inspectors followed the guidance of IP 71707 and reviewed the use of overtime I
during the refueling outage. This included a review of the licensee's administrative procedure, applicable TS, overtime hours and deviation requests for individuals in the Maintenance, Operations, and Radiation Protection department Observations and Findinas
- The inspectors observed that most Perry Plant employees and contractors were on the refueling outage schedule of 12-hour shifts,6-days a week as allowed by the licensee's fitness-for-duty program, PAP-0224, and TS 5.2.2.e. This effectively put most plant workers right at the gukieline limits established by TS 5.2.2.e. The TS states that the i arnount of overtime worked by unit staff members performing safety-related functions shall be limited and controlled in accordance with NRC Policy Statement on working-9 i
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, hours (Generic Letter 82-12). The GL states, in part, "Enough plant operating personnel shell be employed to maintain adequate shift coverage without routine heavy use of
. overtime. However, during extended periods of shutdown for refueling, the following guidelines shall be followed." One of the guidelines is that an individual should not be permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period (excluding shift tumover time). The GL goes on to specify that very unusual circumstances may arise requiring deviation from the guideline : The inspectors reviewed the implementation of this NRC Policy Statement. The inspectors identified that over 250 separate deviations were issued during RFO7. In many of these deviations, the list of affected individuals contained 10 or more name Most of the deviations authorized were for specific activities; however, there were some that indicated blanket approval to work hours beyond the GL guidance without any other limits or specific reason given. The departments involved were mostly contract
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maintenance, instrumentation and controls, and operations personnel. During discussions with plant management, they indicated that the deviations were justified because certain critical path activities were considered to be very unusual circumstances. The licensee initiated CR 99-1067 to review overtime use during RFO7 and to review the effectiveness of corrective actions following similar issues that were identified by Quality Assurance in RFO6. Following the initiation of CR 99-1067, licensee management promptly implemented interim corrective actions to improve documentation of the basis for individual overtime deviation Conclusions The plant Technical Specifications limit individual work hours to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period unless very unusual circumstances arise requiring deviation from the limit. Most plant employees worked approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> each week during the refueling outag Numerous deviations were processed during the outage to approve work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a week. Some of the deviations did not document specific reasons for the deviations nor did they provide any limit to the number of hours worked in a week. Plant management indicated that these deviations were for work on critical path activities which were considered to be very unusual circumstance Miscellaneous Operations issues 08.1 The Severity Level IV Violations listed below were issued in Notices of Violation prior to the March 11,1999, implementation of the NRC's new policy for treatment of Severity Level IV Violations (Appendix C of the Enforcement Policy). Because these Violations would have been treated as NCVs in accordance with Appendix C, they are being closed out in this repor (Closed) Violation NIO) 50-440/97012-03: Use of improper Data on SVI. This violation is in the licensee's CAP as Potential issue Form (PIF)97-144 (Closed) Violation NIO) 50-440/97016-03: Improper Safety Tagging. This violation is in the licensee's CAP as PlF 97-196 [Qiosed) Violation NIO) 50-440/97021-02: Incomplete Class 1E Raceway Marking This violation is in the licensee's CAP as CR 98-1132, PlF 98-118, and PlF 98-14 ,
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. (Closed) Violation NIO) 50-440/97021-06: Combustibles in Combustible Free Zon This violation is in the licensee's CAP as PIFs 97-1997 and 98-15 (Closed) Violation NIO) 50-440/97022-01: Failure to Adhere to Safety Tagging Procedure.' This violation is in the licensee's CAP as PlF 97-2085
'(Closed) Violation NIO) 50-440/98007-01: Incorrect Removal of Safety Tag and Installation of Fuse. This violation is in the licensee's CAP as PlF 98-37 (Closed) Violation NIO) 50-440/98010-01: Incorrect Fuse Removed. This violation is in the licensee's CAP as CR 98-105 (Closed) Violation NIO) 50-440/98010-03: Missed Step in Surveillance Restoration
. Checklist. This violation is in the licensee's CAP as CR 98-104 (Closed) Violation NIO) 50-440/98010-04: Expired Transient Combustible Permit. This
. violation is in the licensee's CAP as CR 98-107 (Closed) Violation NIO) 50-440/98018-01: Failure to implement Requirements of Burn Permit. This violation is in the licensee's CAP as CR 98-190 . Maintenance M1 Conduct of Maintenance M1.1 Review of Re'uelina Outaoe Maintenance and Surveihnce Activities
. Insoection Scone (62707. 80710. 71711. 61726)
The inspectors observed and reviewed portions of the following outage-related work activities:
.- Work Order (WO) 97-3105,ilydrolaze Jet Pump Inlet Mixer
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WO's (multiple), Division 2 EDG Overhaul
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WO 98-1147, Dynamic and 'e.atic Testing Nuclear Closed Cooling Motor Operated Valves
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WO 98-2466, Supply Temp Power to Breaker Cubicle ED1 Ar2
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.WO 99-1170, D19K100 High Voltage Failure
~. WO 99-7196, Raplace Division 3 Diesel Generator Governor
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.- SVI-C71-T5425, Mode Switch Shutdown Position Functional Test
.' ISl-B21-T1300, Reactor Coolant System Leakage Pressure Test
. SVI-E22-T1319, Diesel Generator Start and Load Division 3
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SVI-E22-T1329, Division 3 High Pressure Core Spray (HPCS) Diesel Generator 18 Month Functional Test
SVI E22-T1339, Division 3 HPCS Diesel Generator 18 Month Loss of Offsite Power (LOOP) Test
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SVI-E22-T5397, HPCS Initiation and Loss of EH13 Response Time Test i
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SVi&51-T1272, RCIC System Low Pressure Operability Test i
SVI-R43-T1317, Diesel Generator Start and Load Division 1
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SVI-R43-T1318, Dies,el Generator Start and Load Division 2
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SVI-R43-T1337, Division 1 Standby Diesel Generator 18 Month LOOP Test
SVI-R43-T1338, Division 2 Standby Diesel Generator 18 Month LOOP Test
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SVI-821-T2005, Safety Relief Valve Exercise Test
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SVI-B13-T0001, Shutdown Margin Calculation
- SVI-C11-T1006, Control Rod Maximum Insertion Time
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SVI-B21-T1176, Reactor Coolant System Heatup and Cooldown Surveillance Most maintenance and surveillance activities were performed in a appropriate manner, with satisfactory results. Exceptions are discussed in Sections 01.2 and M1.3. The inspectors observed good management oversight in the plant and control room during the refueling outage. The inspectors observed control room, work support center, and outage project manager tumover meetinga and noted good coordination and communication between departments. The inspectors concluded that outage-related maintenance and surveillance activities were well coordinated and performed properly, with few exceptions. Management oversight of activities was goo M1.2 Schedule of Emeraency Diesel Maintenance and Testina Inscection Scope (62707. 62726)
On April 22,1999, the licensee identified that all 3 EDGs were inoperable. The Division 1 EDG was inoperable due to a scheduled maintenance activity and Division 3 was inoperable because it had failed the LOOP /LOCA test. The Division 2 F.DG, which was scheduled to be operable, became inoperable when it failed its loss of offsite power (LOOP) test. The inspectors reviewed the licensee's scheduling of maintenance and testing for the 3 Divisional EDGs during the outage. This included a review of TS requirements, administrative procedures, and the licensee's controls for minimizing i shutdown ris ;
,. Observations and Findinos f Once the 3 EDGs were identified to be inoperable, the licensee entered TS 3,8.2, 'AC l Sources - Shutdown," which required one EDG to be capable of supplying power to one Division (Div.1 or 2) of onsite Class 1E AC electrical power distribution subsystem With no operable EDG, Condition B of the TS was entered, which required:
1) suspending core alterations, 2) suspending movement of irradiated fuel assemblies, 3) suspending any operations with the potential to drain the vessel, and 4) initiating I action to restore an EDG to an operable status, immediately. The first three requirements were already met because these activities were not in progress. To meet the 4* requirement, the licensee initiated an immediate investigation to restore the i Division 2 EDG to an operable status. Following successful repair, the Division 2 EDG l was restored to operable status on April 23,1999.
i l An overhaul of the Division 2 EDG was completed and the EDG was declared operable on April 16. The Division 3 EDG received minor maintenance and was out of service j- from April 6-16. The Division 3 EDG then failed a LOOP /LOCA test on April 19 due to a failed diode and governor problems. Repair and retest were completed on April 24 and
the Division 3 EDG was declared operable. The Division 1 EDG was taken out of service April 17-23 for minor maintenance activities. A LOOP /LOCA test was scheduled for the Division 2 EDG to occur on A'>ril 26; however, due to a schedule realignment, the
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licensee decided to perform the LOOP /LOCA test on April 22 even though both the
! Division 1 and 3 EDGs were inoperable at that time.
I l The inspectors questioned why the Division 2 LOOP testing was not performed prior to t
removing the Division 1 EDG from service. The licensee's initial plan was to always
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have one EDG operable and available. The Division 2 LOOP /LOCA testing needed to M performed later in the outage because of the unavailability of other systems required to support the test. The support systems were made available earlier than expected and the decision to perform the Division 2 LOOP test while the Division 1 EDG was
. inoperable was reviewed by the shutdown safety group. The decision to perform the
- test while the other EDGs were inoperable was based on the fact that the Division 1 i EDG was available and running at the time and that the LOOP /LOCA test does not itself render the EDG inoperable. Due to the Division 1 EDG being available, plant risk was not increased as a result of these activitie Conclusions A series of two surveillance failures concurrent with a scheduled maintenance activity led to a condition where the emergency diesel generators for Divisions 1,2, and 3 were inoperable at the same time during the refueling outage. The inspectors determined
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M1.3 Division 2 LOOP Test Failure
] Inspection Scope (61726)
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The inspectors followed the guidance of IP 61726 to review the circumstances !
surrounding a surveillance test failure on the Division 2 EDG. The inspectors reviewed the applicable TS sections, the surveillance instruction, and associated work document Observations and Findinas On April 22,1999, during performance of surveillance SVI-R43-T1338, " Division 2 -
~ Standby Diesel Generator 18-month LOOP Test," the LOOP signal did not occur as expected. The SVI directed workers to pu!l a fuse to simulate an undervoltage condition; however, tl.is did not result in the undervoltage condition as expected. The licensee terminated the test and restored the system configuration to norma Operations and Engineering department personnel began an immediate investigation and CR 99-1234 was initiated. The cause was determined to be that test devices were inadvertently laft in an EDG relay following a calibration on April 1,1999. The devices were subsequently removed and the surveillance was reperformed satisfactorily on April 23,199 The test devices were small pieces ofiygon tubing used to block certain contacts of the relay during calibration. The electrical maintenance technicians had performed SVI-R22-T5073, " Division 2,4-KV Bus Undervoltage/ Degraded Voltage Channel Calibration" and gel-0105, " Maintenance and Calibration of Type NGV-11 Relays."
Step 5.4.1.1 of gel-0105 directed workers to mechanicaliy block closed 2 out of 3 units within the relay. Step 5.4.2.5 directed workers to release the mechanically closed unit During an interview, the technician stated that he had used the tygon pieces to mechanically block the relay units, but forgot to remove them when the calibration was complete'.
The inspectors reviewed the timeline associated with the activities on the Division 2 !
EDG. Following maintenance and testing, the Division 2 EDG was declared operable from April 16 until the test failure on April 22. The inspectors reviewed the system diagrams with engineering personnel and determined that the tygon pieces did not render the EDG inoperable. The system would have responded properly to a true low voltage conditio Technical Specification 5.4.1.a requires written procedures to be implemented covering ,
the applicable procedures in Regulatory Guide (RG) 1.33, Appendix A. Procedures for surveillance testing are specified in RG 1.33, Appendix A. The technician's failure to '
remove the relay blocks as specified in gel-0105 was a Violation of TS 5.4.1.a. This Severity Level IV violation is being treated as an NCV, consistent with Appendix C of the NRC Enforcement Policy. This Violation is addressed in licensee's CAP as CR 99-1234. (NOV 50-440/99003-02(DRP)) Conclusions A maintenance technician left test equipment in a relay following a calibration activity as a result of inattention to detail. This was identified when the Division 2 EDG LOOP Test failed and resulted in an NC v .
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- M8 k Miscellaneous Maintenance issues
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M8.11 (Closed) Licensee Event Ren~t (LER) 50 "0/1000-02: Limiting Condition for l
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. Operation 3.0.3 Entered Due to TS Bases Statement interpretation. This event was i l- discussed in inspection Report 50-440/g9002, Section 01.3. When operators i
attempted to start the "A" RHR pump to initiate' shutdown cooling, the pump did not
~ start. The cause was later determined to be a failed optical isolator in the pump starting l
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logic. During initial troubleshooting of the problem, the licensee entered TS 3. because the operators were not certain that they had met the conditions of TS 3.4.9, Action A.2. This required verifying an alternate method of decay heat removal within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Although the licensed operators knew that the main condenser was available and removing heat, they were initially confused by the wording in the TS Bases.- The
- licensee subsequently determined that the conditions of Action A.2 were me Appropriate repairs were made to enable the "A" RHR pump to be started and there L were no further problems with shutdown cooling during the refueling outage. This item p is closed.
l 111. Ennineerina E1 Conduct of Engineering L E Enaineerin'a Suonort of RefL=!!na Outece Activities Insoection Scooe (37551)
i Tne inspectors used the guidance of IP 37551 and evaluated engineering involvement in resolution of ernergent material condition problems and other outage related activitie The inspectors reviewed areas such as operability evaluations, and root cause analyse The effectiveness of the licensee's controls for the identification, resolution, and prevention of problems was also examine )' . Observations and Findinas I Engineering departraent personnel provided outage support by acting as project managers for many of the outage projects, providing modification packages to improve ;
plant material condition, and working with maintenance personnel to resolve several of - :
the longstanding operator work arounds. Engineering personnel also reviewed i emergent equipment issues and addressed operability questions. In these instances, '
engineering pr.rsonnel provided timely and technically adequate support to other departments. Some of the equipment and areas covered included, improvements to the ;
feedwater check valve penetration, feedwater penetration nozzle repair, core shroud l
- weld inspections, tomado protection modifications, plant computer upgrades, electro hydraulic control system pressure accumulators, fuel leak cause determination, jet pump l cleaning, RCIC test questions, local leak rate testing, EDG failure troubleshooting, main
' steam isolation valve packing leakage, motor operated valve testing and repair, and air operated valve testing.-
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- Conclusions The inspectors concluded that engineering department personnel provided timely and effective technical support to other departments for a variety of activities during the
- refueling outag E7 Quality Assurance in Engineering Activities E7.1. Ccre Fuel Accountability and Verification a. - ~ triggetion Scooe (60710) -
The inspectors followed the guidance in IP 60710 to monitor and review the licensee's
- fuel accountability practices during refuelin ' Observations and Findinas The inspectors ~ observed numerous fuel bundle movements from the control room. The iraspectors noted that each movement was performed in accordance with a reactor engineering predetermined sequence listed on a Fuel Movement Checklist. Refueling and reactor engineering personnel used exact communications and properly documented each movemen The inspectors viewed the camera monitor video tapes of the core verification. The
- licensee used high quality video equipment to carefully verify that fuel bundles were in the correct core location, correct orientation, and proper physical positioning. The licensee taped the layout of the core load from numerous angles and during numerous passes of the camera throughout the core. The inspectors noted that individual bundle information was verified through' serial numbers checked against the checklist. On a j horizontal camera pass through the core, reactor engineering department personnel - l identified one fuel bundle that was raised approximately one inch above its expected position. The bundle was hoisted and properly reseated according to procedure. All ]
aspects of the core verification were completed satisfactoril Conclusions )
The licensee utilized effective methods to maintain fuel accountability and verify the proper placement of fuel bundles in the core prior to reactor vessel reassembl L_Mananoment Meetings X1 Exit Meeting Summary The inspectors presented the impection results to members of licensee management at the conclusion of the inspection on May 17,1999. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary infoimation was identifie _
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PARTIAL LIST OF PERSONS CONTACTED Licensee H. Bergendahl, Director, Nuclear Services Department
' N. Bonner, Director, Nuclear Maintenance Department B. Boles, Manager, Plant Engineering R. Collings, Manager, Quality Assurance H. Hegrat, Manager, Regulatory Affairs T. Henderson, Supervisor, Compli,ance W. Kanda, General Manager, Nuclear Power Plant Department F. Kearney, Superintendent, Plant Operations B. Luthanen, Compliance Engineer L. Myers, Vice President, Nuclear J. Powers, Manger, Design Engineering T. Rausch, Operations Manager S. Sanford, Senior Compliance Engineer R. Schrauder, Director, Nuclear Engineering Department J. Sears, Manager, Radiation Protection J. Sipp, Manager, Radwaste, Environmental, and Chemistry J. Wood, Vice President, Nuclear i
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ll lNSPECTION PROCEDURES USED ]
- IP 37551
- Onsite Engineering 11
. IP 60710 - Refueling Activities i'. IP 61726: Surveillance Observation IP 62707: Maintenance Observation
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IP 71707: Plant Operations IP 71711: . Plant Startup From Refueiing
. lP 71750: . Plant Support ,
IP 92901: Followup - Operations IP 92902: Followup - Mmtenance IP 92903: , Followup - Engleeering _
. ITEMS OPENED, CLOSED AND DISCUSSED
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l 50-440/99003-01 NCV Failure to Follow Procedure - Two Examples 50-440/99003-02 NCV Test Equipment Left in a Safety-Related Relay
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Closed 50-440/97012-03- VIO Use of improper Data on SVI 50-440/97016-03- VIO -Improper Safety Tagging 50-440/97021-02 VIO Incomplete Class 1E Raceway Markings 50-440/97021-06 VIO Combustibles in Combustible Free Zone 50-440/97022-01 VIO Failure to Adhere to Safety Tagging Procedure / Inadequate Tag-l Out .
50-440/98007-01 - VIO Incorrect Removal of Safety Tag and installation of Fuse 98-377.
! 50-440/98010-01 VIO .' ncorrect Fuse Removed 50-440/S8010-03 VIO Missed Step in Surveillance Restoration Checklist i 50-440/98010-04 VIO Expired Transient Combustible Permit l 50-440/98018-01 VIO - Failure to implement Requirements of Burn Permit
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50-440/99002-00- LER LCO 3.0.3 Entered Upon Shutdown Cooling Pump Failure L, 50-440/99003-01- NCV Failure to Follow Procedure - Two Examples i L 50-440/99003-02 NCV Test Equipment Left in a Safety-Related Relay Discussed
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t LIST OF ACRONYMS USED -
CAP Corrective Action Program CFR' Code of Federal Regulations CR l Condition Report -
CRD- ' Control Rod Drive DRP Division of Reactor Projects EDG Emergency Diesel Generators HPCS High Pressure Core Spray
.IP Inspection Procedure
- IR inspection Report LCO Limiting Condition for Operation LER . Licensee Event Report LOOP Loss of Offsite Power .
- NCV Non-Cited Violation NR Nuclear Regulatory Commission P&L Precaution and Limitation PAP - Plant Administrative Procedure PlF Potential issue Form RCIC Reactor Core isolation Cooling RG Regulatory Guide RHR- Residual Heat Removal sol' System Optratng instruction i SRO Senior Reactor Operator SVI Surveillance Instruction
- TS Technical Specification l US Unit Supervisor
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