ML20195C736
ML20195C736 | |
Person / Time | |
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Site: | Perry |
Issue date: | 11/10/1998 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20195C715 | List: |
References | |
50-440-98-18, NUDOCS 9811170204 | |
Download: ML20195C736 (19) | |
See also: IR 05000440/1998018
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, U. S. NUCLEAR REGULATORY COMMISSION
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REGIONlli
Docket No: 50-440 i
License No: NPF-58 l
Report No: 50-440/98018(DRP)
Licensee: Centerior Service Company
P.O. Box 97 A200
Perry, OH 44081
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Facility: Perry Nuclear Power Plant
Location: Perry, OH
Dates: September 9 - October 20,1998
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Inspectors: C. Lipa, Senior Resident inspector
D. Calhoun, Resident inspector
J. Clark, Resident inspector
S. Dupont, Project Engineer
Approved by: Thomas J. Kozak, Chief
Reactor Projects Branch 4
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9811170204 981110
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PDR ADOCK 05000440
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EXECUTIVE SUMMARY
Perry Nuclear Power Plant
NRC Inspection Report 50-440/98018(DRP)
This inspection report included resident inspectors' evaluation of aspects of licensee operations,
engineering, maintenance, and plant support.
Operations
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The inspectors concluded that operators appropriately followed procedures and that
shift tumovers were consistent from shift to shift. The overall conduct of operations
continued to be effective with an appropriate safety focus. (Section O1.1)
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The inspectors concluded that a special evolution was effectively conducted to isolate
and suppress a small fuel leak. Operations department personnel maintained a high
level of reactivity control awareness during the several hundred control rod
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manipulations which occurrea during the special evolution. (Section 01.2)
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The licensee took prompt and conservative actions upon the report of possible seismic
activity in the vicinity of the plant. Operations department personnel conducted
verifications of key indicators and plant walkdowns, even though no seismic alarm was
received. (Section 01.3)
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Operations department personnel responded appropriately to abnormal indications for x
the rod control and information system. The coordination between the workgroups
involved in the troubleshooting and repair was good, distractions to the operators were
kept to a minimum, and the problem was repaired in a timely manner.
(Section 01.4)
Maintenance
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Plant management demonstrated good involvement in the prioritization of the control
complex chill water motor replacement, the assignment of a project manager for the
work activity, and during the oversight of the activity, which resulted in the motor being
replaced in an efficient and timely manner. (Section M1.2)
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The inspectors concluded that a fire watch demonstrated inadequate knowledge of his
fire watch responsibilities during welding activities on the Division 1 diesel generator
silencer. One violation was identified when a fire watch inappropriately allowed welders
to perform hot work with a significant quantity of wood in the immediate work area. In
addition, after c.cciding to use the wood, maintenance department personnel did not
initiate a transient combustible permit (TCP) for the temporary staging of the wood. The
fai!ure to generate a TCP was similar to, but not a direct repeat of, other recent
examples of problems with station personnel's awareness of when a TCP is required.
(Section M1.3)
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Enaineerina
'. The inspectors concluded that a chemistry technician properly analyzed a routine off
gas sample which indicated a small fuel pin leak had occurred and promptly notified the
appropriate station personnel. Also, engineering department personnel provided good
support for determining the location and suppressing the leak. (Section E1.1)
Plant Suooort
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Although the licensee's contamination control program allowed plant personnel to
extend contamination area boundaries in certain situations, this policy was not
consistently understood or implemented by radiation protection technicians.
(Section R1.1)
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Report Details
Summary of Plant Status
At the beginning of this inspection period, the plant was operated at 100 percent power. Plant
power was reduced to 60 percent on September 12,1998, to determine the location of a small
fuel leak which had been detected through the identification of a slight increase in reactor
coolant activity. The leak was localized and suppressed on September 14,1998, and the plant
was returned to full power. In order to maintain the leak suppression, plant management
directed that the weekly control rod surveillance testing activities would be conducted at
90 percent power instead of 100 percent, and that power changes would be limited to 1 percent
per hour. These restrictions continued throughout the remainder of the inspection period, and l
were expected to remain in effect until the April 1999 refueling outage. !
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1. Operations
- 01 Conduct of Operations
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O1.1 General Comments
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a. Inspection Scoce (71707)
The inspectors followed the guidance of inspection Procedure 71707 and conducted
frequent reviews of plant operations. This included observing routine control room
activities, reviewing system tagouts, attending shift tumovers and crew briefings, and
performing panel walkdowns. The inspectors also observed operators performing !
routine equipment cycling.
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b. Observations and Findinas l
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Operations management initiated several improvements to crew briefings including i
moving the briefing out of the Unit 1 control roorr to prevent distractions. Shift turnovers ;
were thorough and consistent from shift to shift. The inspectors observed that operators i
consistently followed equipment operating procedures and alarm response instructions.
Overall, the conduct of operations was appropriately focused on safety.
c. Conclusions 4
The inspectors concluded that operators appropriately followed procedures and that
shift tumovers were consistent from shift to shift. The overall conduct of operations
continued to be effective with an appropriate safety focus.
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01.2 Fuel Leakaoe Testina and Suporession
a. Insoection Scope (71707)
The inspectors followcd the guidance of Inspection Procedure 71707 in assessing
operations department personnel performance in isolating and suppressing a small fuel
leak which was detected through the identification of a slight increase in reactor coolant
activity.
b. Observations and Findinas
Operations and engineering personnel developed a special evolution to localize and
suppress a fuel leak that was detected on September 1,1998. On September 12,1998,
the evolution was commenced. The inspectors observed the briefings associated with
this evolution and determined that the briefings were formal and had an appropriate
focus on human performance and plant safety.
- The evolution involved a large number of repetitive control rod manipulations, with
subsequent chemistry samples, to determine the specific location of the lesk. The test
was conducted throughout the weekend. In all, operations department personnel
performed several hundred control rod manipulations without error. The operators
maintained their sensitivity for reactivity controls throughout the evolution. In addition,
operators used appropriate three-way communications amongst themselves and with
other personnel.
c. Conclusions
The inspectors concluded that a special evolution was effectively conducted to isolate
and suppress a small fuel leak. Operations department personnel maintained a high
level of reactivity control awareness during the several hundred control rod
manipulations which occurred during the special evolution.
01.3 Ooerations Response to Report of Seismic Activity
a. Inspect'on Scope (71707)
The inspectors followed the guidance of Inspection Procedure 71707 in assessing the
operations department personnel response to a report of seismic activity in the vicinity of
the plant. The inspectors also reviewed logs and conducted interviews with operations
department personnel.
b. Observations and Findinas
On September 25,1998, control room personnel received several reports from outside
personnel that there had been a seismic event in the area. The licensee subsequently
confirmed, through media reports and information from the National Earthquake Center,
that a seismic event had been reported in Sharon, Pennsylvania (approximately 45 miles
southeast of the Perry Plant). Control room personnel had no direct indication of the
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activity, and had no abnormal alarms or indications. Operations department personnel
also verified that the seismic monitors were in operation, but not alarming.
Operations department personnel conservatively entered the Off Normal Instruction
(ONI) for seismic activity. Post seismic event walkdowns of plant systems were
conducted, which determined there were no abnormalindications. Operations
department personnel exited the ONI after all walkdowns and verifications were
complete. The licensee also notified the NRC and issued a press release describing the
plant status.
The licensee subsequently reviewed the seismic instrumentation for indications over the
reportable 0.05g ground acceleration limit. Both the active and passive sensors showed
no indication of the event. The inspectors were informed by operations and engineering
personnel that based upon the available information, the earthquake produced less than
0.03g of ground acceleration in the vicinity of the plan *.
c. Conclusions
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The inspectors concluded that the licensee took prompt and conservative actions upon
receiving a report of possible seismic activity in the plant vicinity. Operations
department personnei conducted verifications of key indicators and plant walkdowns,
even though no seismic alarm was received.
O1.4 Operations Response to Rod Gana Drive System Power Suoolv Failure
a. Inspection Scope (71707)
The inspectors followed the guidance of Inspection Procedure 71707 in assessing the
operations department personnel response to a failure of a power supply in the rod gang
drive system.
b. Observations and Findinas
On October 2,1998, operations department personnel informed the inspectors of an
entry into ONI-C11, " inability to Move Control Rods." This was due to an apparent
lockup of the rod control and information system (RCIS). The inspectors monitored
initial control room operator actions for the event. Operations department personnel
thoroughly assessed the situation and used appropriate procedures. The licensee
formed a team of operators, maintenance technicians, and engineers to investigate and
correct the problem. The inspectors noted that the licensee kept activities of the group
l outside the control room as much as possible, to allow operators to focus on continued
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plant operations.
The investigation team determined that a 5-volt power supply in the rod gang drive
system had failed. Briefings were held to discuss repair plans and plant operations.
The inspectors observed that the briefings were open and informative. Operations
department personnel entered 12-hour limiting condition for operation (LCO) 3.1.3 due
to the loss of rod position indication to replace the power supply. Maintenance
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personnel subsequently replaced the power supply and retested the RCIS. Operations
department personnel verified proper rod position indication and RCIS operation and
subsequently exited the LCO, '
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- c. Conclusions
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Operations department personnel responded appropriately to abnormal indications for
the rod control and information system. The coordination between the workgroups .i
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involved in the troubleshooting and repair was good, distractions to the operators were
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. kept to a minimum, and the problem was repaired in a timely manner.
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07- - Quality Assurance in Opentions '
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L 07.1 Licensee Self-Assessment Activities (71707)
During the inspection period, the inspectors observed multiple licensee self-assessment I
y activities, including:
L Plant Onsite Review Committee, September 17,1998 ,
l Corrective Action Review Board, September 30,1998
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Daily Management Review of New Condition Reports 1
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The meetings were attended by appropriate personnel and there was good discussion
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of issues. The inspectors observed that s 3veral items were identified for priority
upgrades or additional work during these meetings. The inspectors concluded that the
observed self-assessment activities were thorough, self-critical, and effective in
identifying problems and developing appropriate corrective actions. )
i 08 Miscellaneous Operations issues (92700,92901)
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08.1 (Closed) Licensee Event Report (LER) 50-440/98002-00(DRP): On July 1,1998, a trip
unit failure initiated reactor core isolation cooling (RCIC) with a subsequent reactor
scram. This event was documented in inspection Report 50-440/97013. The inspectors
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l concluded in the inspection report that the licensee's preliminary root cause
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investigation had determined that the root cause of the scram was due to RCIC
j. - initiation, and that RCIC had initiated due to the failure of a capacitor on a
instrumentation card. The inspectors subsequently reviewed the licensee's completed
l Category 2 investigation and concluded that the licensee had conducted a very thorough
l investigation. The licensee's preliminary root causes were documented in the root !
l. cause report. The licensee replaced the damaged card and conducted testing to
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restore the system to service. This item is closed.
08.2 (Closed) Violation 50-440/97009-02(DRP): Engineering personnel did not give
l procedure guidance on how to handle post test changes to previous acceptance criteria.
The inspectors reviewed the licensee's response to this violation dated i
December 23,1997. The licensee changed plant administrative procedure, PAP-1105, !
, " Surveillance Test Control," Revision 8, August 1998, for changing maintenance and
. test procedure acceptance criteria. Additional training was also given to responsible
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engineers as to the effeas of procedure changes. The inspectors have noted no repeat
occurrences of this issue. The inspectors concluded that the corrective actions for this
violation are adequate and this item is closed.
11. Maintenance
M1 Conduct of Maintenance
M1.1 General Comments
The inspectors observed or reviewed all or portions of the following work activities.
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Surveillance instruction SVI-E22-T1202, *High Pressure Core Spray System
Flow Rate - Low (Bypass) Channel Functional for 1E22-N656," Revision 3
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Work Order (WO) No. 98-5174, emergency service water altemate tunnel sitt
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inspection
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WO No.97-298, replacement of operator for E1200028A, containment spray "A"
first shutoff valve
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gel-0006, " General Maintenance of Motor Control Centers," Revision 5, on main
steam isolation valve leakage control inboard valve,1E32-F002N-EF1B07-TT
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WO No. 91-4164, welding of the Division 1 diesel generator silencer
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WO No. 98-4174, replace hydraulic power Unit "A" subloop filter elements
Noteworthy observations are discussed below in Sections M1.2 and M1.3.
M1.2 Proactive Actions to Replace the "A" Control Comolex Chill Water Chiller Motor
a. Insoection Scope (62707)
The inspectors reviewed the licensee's response to the unexpected trip of the "A"
contro! complex chill water chiller motor. The inspectors interviewed operators and
mechanics and observed motor replacement activities.-
b. Observations and Findinas
On September 15,1998, operators started the "A" control complex chill water chiller
P47A to support a 2-hour run of motor control center switchgear and miscellaneous area
heating, ventilation, and air conditioning system. However, the chiller tripped
approximately 15 minutes into the run. The operating crew on shift determined that the
failure of the chiller placed the plant in a 30-day Technical Specification LCO. The
licensee investigated the problem and determined that P47A tripped on a motor low
temperature alarm due to the failure of the motor's temperature sensors. The motor
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had two sets of temperature sensors and one set had failed earlier in the year. The
backup set of temperature sensors allowed continued operation until its failure on
September 15,1998. The licensee, in discussion with the vendor, determined that the
motor had to be replaced. The licensee planned to install a spare motor which was in
the warehouse. The licensee classified this motor replacement activity as a priority
Level I! and assigned a project manager to ensure the evolution was conducted in a
timely and controlled manner. On September 19,1998, the inspectors noted that the
! maintenance supervisor performed oversight'responsib!!ities during the motor
! replacement activities and that the on-shift operating crew shift supervisor observed
parts of the activities. The motor was replaced in a timely manner well within the 30-day
LCO.
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Plant management demonstrated good involvement in the prioritization of the control l
, complex chill water motor replacement, the assignment of a project manager for the i
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work activity, and during the oversight of the activity which resulted in the motor being
- replaced in an efficient and timely manner.
M1.3 Division 1 Diesel Generator Silencer Maintenance
a. Inspection Scooe (71750. 62707)
The inspectors observed the maintenance activities on the Division I diesel generator
(DG) silencer. The inspectors reviewed applicable documentation and interviewed
maintenance and fire protection department personnel. ;
b. Observations and Findinos
On September 2,1998, the inspectors observed two welders on the Division 1 DG room l
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roof performing hot work on the DG silencer. A fire watch was providing control over the
hot work activities and had a portable fire extinguisher. The inspectors noted a
significant amount of wood had been staged to support the welding activities in the
immediate area and questioned the appropriateness of having the wood in the area
while hot work was in progress. The fire watch informed the inspectors that he believed
the wood had been fire treated and therefore it was approved for the area. The
inspectors reviewed Burn Permit No. B98-DG-83, which was in use for the activity, and
determined that it specified that 3.11 combustibles within 35 feet of the hot work be
removed or covered. The fire watch incorrectly still considered the area suitable for hot
work because the portion of the wood on which the welders were sitting was covered.
The inspectors discussed this situation with a fire protection technician (FPT) who
subsequently moved all of the wood to a distance greater than 35 feet from the hot work
area.
Perry Nuclear Power Plant Unit 1 Technical Specification (TS) 5.4.1.a., requires that
written procedures shall be implemented covering the applicable procedures
recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978.
Appendix A, of RG 1.33, lists the Plant Fire Protection Program as an activity that
should be covered by written procedures. Perry Administrative Procedure (PAP)1916,
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" Duties of the Fire Watch," Revision 4, Step 6.3.5, specified that prior to and during hot
work activities, the fire watch person shall be responsible for verifying that the special
instructions of the applicable Bum Permit have been met, and that no fire hazards exist
i that would prohibit commencement of work. The failure of the fire watch to ensure the ,
specialinstructions of the Burn Permit were met is a violation of TS 5.4.1.a
During the FPT's assessment of the situation ~ he determined that a Transient
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Combustible Permit (TCP) should have been generated for the wood in the hot work
area but was not. Specifically, PAP-1913, " Control of Transient Combustibles,"
Revision 4, Section 6.4.1, states that a TCP was required to authorize, track, and
document the use of transient combustible materials when the quantity of the
flamrnable/ combustible material exceeds the minimum requirement listed on
Attachment 1. Attachment 1, " Listing of Combustible Material Quantities not Requiring a
Transient Combustible Permit," Item No. 4, Lumber Treated Fire Resistant, specified i
that a transient combustible permit was required for a quantity of lumber that exceeded ,'
50 board feet (1 board foot = 12" X 12" X 1"). The amount of lumber on the DG room
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roof exceeded 50 board feet. '
In addition to moving the wood to a cistance greater than 35 feet from the area, the FPT
initiated the following corrective actions: 1) informed the fire protection and mechanical
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maintenance supervisors of the prob!em; 2) interviewed the workers involved in the
incident; and 3) generated a condition report. Subsequently, the maintenance
supervisor generated a TCP for the wood. The failure to initially generate a TCP for the
wood is a violation of TS 5.4.1.a. This non-repetitive, licensee-identified and corrected
violation is being treated as a non-cited violation, consistent with Section Vll.B.1, of the .
NRC Enforcement Policy (NCV 50-440/98018-02(DRP)).
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The inspectors considered that the safety significance of this event was low because the
fire watch was present during the hot work activity and could have used a portable fire
extinguisher to quench a fire. However, the inspectors were concerned with the
licensee's failure to generate a TCP when the wood was staged during the welding
activity and with the inadequate knowledge level of the fire watch during the
performance of his duties. The licensee's failure to generate the TCP was similar to, but
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not a direct repeat of, other recent examples of problems with station personnel's
l awareness of when a TCP is required (see inspection Reports 50-440/97021
l and 50-440/98010). The licensee indicated that a collective significar% condition report
would be initiated to assess this aspect of the fire protection program and to develop )
corrective actions to improve performance in this area.
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c. Conclusions
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The inspe:: tors concluded that a fire watch demonstrated inadequate knowledge of his
fire watch responsibilities during welding activities on the Division 1 DG silencer. One
violation was identified when the fire watch inappropriately allowed welders to perform
hot work with a significant quantity of wood in the immediate work area. In addition,
after deciding to use the wood, maintenance department personnel did not initiate a
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TCP for the temporary staging of the wood. The failure to generate a TCP was similar
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to, but not a direct repeat of, other recent examples of problems with station personnel's
awareness of when a TCP is required.
M1.4 Time-out Meetina for Plant Personnel to Address Human Performance
On September 14,1998, the licensee conducted a " Human Performance Time-out"
meeting to inform station personnel of the results of assessments, done by an outside
organization, of the station's performance, to discuss recent human performance errors,
and to review tools to enhance human performance. The licensee planned to have j
periodic meetings of this nature to keep site personnel aware of their progress in '
meeting station management's expectation toward improving human performance. The
! inspectors obsented one maintenance department personnel meeting and determined
that the meeting became more effective as it progressed because the meeting became
more interactive. The third speaker effectively communicated that the station needed to
l continue to make progress in the area of human performance and that through the J
l implementation of procedure adherence, peer checking, and the stop, think, act, and !
review efforts, the station's performance would be enhanced. The inspectors concluded
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that during the meeting, the licensee effectively communicated the status of personnel
performance in the area of human performance and reinforced management
expectations and commitments to effect change in this area.
l M2 Maintenance and Materiel Condition of Facilities and Equipment
M2.1 Plant Materiel Condition
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l The inspectors conducted numerous observations and tours in areas of the plant where
l work on safety-related equipment was being conducted. The inspectors noted that
several areas of the plant where maintenance activities were recently conducted were
not thoroughly cleaned up after the work. Items such as tie wraps, tape, and small
foreign material covers were found around the equipment. The inspectors concluded l
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that there were no regulatory requirements involved in these occurrences. However, the
inspectors brought the observations to the attention of plant management. Plant
management indicated that they had independently observed similar housekeeping
issues and were implementing actions to improve performances in this area.
M8 Miscellaneous Maintenance issues (92700,92902)
M8.1 (Closed) Unresolved Item (URI) 50440/96017-02: Failure to obtain motor operated
valve stroke time data. The inspectors observed that an operator failed to obtain stroke
I time data due to an error during the performance of a surveillance test. The inspectors
were concerned that the data was taken during a subsequent stroke ar,J that this data
may not be valid due to a possible preconditioning of the motor operated valve. Upon
further review, the inspectors concluded that the data was valid. There were no further
l concerns. This item is closed.
M8.2 (Closed) LER 50-440/97006-00(DRP): A technician error issulted in a high pressure
i core spray (HPCS) system actuation without injection. Ca June 10,1997, while
performing reactor vessel level instrument check valve operability checks, a technician
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failed to follow procedures and did not correctly restore a reference leg purge valve. A
pressure spike was induced into the reference leg and resulted in the level transmitters
sensing an erroneous low reactor water level indication which completed the logic to
actuate HPCS. However, because the reactor was shutdown and vessel level was
above the HPCS injection valve closure set point, the injection valve did not open and
HPCS did not inject into the vessel. The licensee took appropriate corrective actions
with the individuals involved with the event, as well as providing lessons learned training
to other technicians and supervisors. This failure to follow procedures constitutes a
violation of the TSs with minor significance and is not subject to formal enforcement
action.
M8.3 (Closed) Inspection Followuo item (IFI) 50-440/98009-03(DRP): On April 10,1998, the
Division 2 emergency DG was tested under surveillance instruction (SVI)
SVI-R43-T1318, " Division 2 Diesel Generator Start and Load." While unloading the DG,
operations department personnel observed erratic swings of approximately 1500 kW in
electrical loading and secured the DG. The load swings were considered to originate
from a problem with the DG regulator. The licensee conducted thorough testing and
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increased monitoring of the DG. However, the problem was not seen again. A root
cause analysis failed to determine a definite cause for the problem. The licensee
determined that some initial work performed before instrument testing, including
lubrication of the governor linkage and tightening of an amphenol connector, could have
repaired the problem. Due to repeated successful runs of the DG since the April
occurrence, the licensee has closed their investigation. The inspectors concluded that
the corrective actions for this item were adequate and this item is closed.
Ill. Enaineerina
E1 Conduct of Engineering
E1,1 Fuel Defect Indicated by Samole from Off Gas System
.a inspection Scope (37551)
The inspectors reviewed the licensee's response to indications of a minor leak in a fuel
! assembly. The inspectors reviewed applicable data and interviewed engineering and
chemistry department personnel.
b. Observations and Findinat.
On September 2,1998, a chemistry technician obtained and analyzed the weekly
sampic from the off gas system. The results indicated that a minor fuel assembly defect
existed, based on a slight increase in Xenon-133 and the ratio of lodine-133 to
lodine-138. Chemistry department personnel promptly communicated the results to
engineering department personnel and station management. As a result, engineering
department personnel implemented the station fuel reliability improvement plan and had
an independent sample taken and analyzed. On September 3,1998, engineering
analysis confirmed that a fuel rod had developed a small pinhole leak. The licensee
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t contacted the fuel vendor, General Electric (GE), to solicit their support while
concurrently implementing the station fuel reliability plan. The vendor concurred with the
licensee's assessment of the sample analysis.
The licensee decided that fuel defect localization testing would be conducted from
September 11-14,1998, to determine the location and then suppress the leak. The
operators reduced reactor power to 65 percent to perform the testing. The licensee
identified the leak, by using a control rod pull pattem supplied by GE. After identifying
the leaking fuel assembly, the operators inserted control rods to suppress fission activity
in the fuel assembly and prevent further opening of the pinhole leak. Even with the
control rods inserted, the fuel bundle still produced approximately 1 KW/ foot due to the
internal fission of the bundle. The licensee had not determined the root cause of the
fuel defect but suspected it was due to debris.
Licensee management initiated a standing instruction for the operators: 1) weekly
control rod testing was to be conducted at 90 instead of 100 percent power and reactor l
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engineer presence was established for power restoration; 2) increased monitoring of the
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off gas system was implemented; and 3) engineering representatives were to be
contacted prior to any change in reactor power.
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c. Conclusions
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The inspectors concluded that a chemistry technician properly analyzed a routine off
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gas sample which indicated a small fuel pin leak had occurred and promptly notified the )
appropriate station personnel. Also, engineering department personnel provided good j
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support for determining the locatien and suppressing the leak.
E8 Miscellaneous Engineedng issues (92903)
E8.1 (Closed) URI SO4Q/06005-06: Description of fue-1 pool sipper in Updated Safety
Analysis Report (USAR). The inspectors originally considered that there was a potential
discrepancy regarding the description of fuel pool sipper in Section 9.1.4.2.3.5 of the
USAR. Upon further review, no discrepancy existed. This item is closed.
E8.2 (Closed) URI 50-440/96006-04: The inspectors initially identified apparent
inconsistencies between the plant configuration and the USAR descriptions for the
! Division 1,2, and 3 emergency DG air start systems. Upon further review, no
inconsistencies existed. This item is closed.
! E8.3 (Closed) LER 50-440/97008-00 and 01: This was a retraction of Event Notification
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Number 32737 dated August 7,1997, that identified two occurrences when it appeared
that plant cooldown rate exceeded Technical Specification limits. On September 10,
1992, and January 7,1997, the reactor vessel bottom head drain temperature exceeded
a 100 degree F per hour cooldown rate following separate reactor scrams. Both events
were appropriately notified to the NRC (Events Number 24205 and 31549) per
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10 CFR 50.72 and subsequently per 10 CFR 50.73. On April 4,1998, GE provided an
! analysis of both events and determined that the use of the bottom head drain
temperature was neither the primary nor attemate point of measurement to ensule
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compliance to Technical Specifications. The Technical Specification limit is based on
maintaining the reactor vessel bulk temperature at less than 100 degrees F per hour
cooldown rate. Evaluations of both events demonstrated that the vessel was heating up
while the bottom head drain line was cooling down and temperature indications at that
location were not representative of vessel bulk temperatures. These differences in
vessel and drain line temperatures were due to a stagnant flow condition in the drain
line. The drain line temperature measurement is not reliable unless flow exists in the
drain line. The GE engineering personnel concluded, based on evaluation of the
preferred measurement of the steam dome saturation temperature data, that neither
event exceeded TS limits. Based on this conclusion, the licensee retracted the event
notification and revised LER 97008-00. The GE analysis also provided attemate
guidance of using multiple locations of measurements to provide conservatism and
ensure that TS liinits were not exceeded. The licensee implemented Revision 5 to
SVI B21-T1176, " Reactor Coolant System Heatup and Cooldown Surveillance," to
include multiple monitoring points. During on-site inspection, the inspectors reviewed !
GE's analysis and verified that the SVI revision implemented GE's recommendations.
Based on these reviews, this LER is clesed. I
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E8.4 (Closed) URI 50-440/97021-03(DRPk On January 7,1998, the inspectors identified l
numerous tubing support clamps on all three divisional DGs that did not appear to meet
seismic qualification criteria. The licensee conducted a thorough review of the DG .
- tubing supports. The licensee presented documentation to the inspectors to show the I
original design criteria for the supports. The licensee concluded that the DGs were
operable because no maximum spacing between supports was exceeded. However, ,
the licensee identified that several mounting configurations could hamper the proper ;
torquing of the clamps. The licensee also found several clamps that required retorquing
or replacement. The licensee completed these clamp repairs. The inspectors
concluded that the tubing support clamps met the seismic criteria, that no violations
occurred and that this item is closed.
E8.5 (Closed) URI 50-440/98009-05(DR_P_l: On March 23,1998, the inspectors identified
several cat e trays in the cable spreading rooms that were apparently filled to beyond
50 percent of their volume. Section 8.3 of the Perry USAR stated that cable trays have
4" or 6" side rails and that, by design, will be filled to no more than 50 percent by
volume. When extra fill capacity was needed for trays with 4" side rails, plant design
drawings and construction techniques incorporated the use of 2" extender rails.
'
However, these extender rails were not present on the noted trays.
Initially, engineering personnel could not provide calculations or documentation to the
inspectors to show the reason or justification for not using extender rails. Engineering
l personnel subsequently completed a thorough review of original construction
l documentation, it was determined that ampacity and seismic concerns were properly
f analyzed in the original documentation. However, the instructions in the original design
l drawings were vague. Since the 4" trays were analyzed for increased load, they were
shown as 6" trays. The licensee concluded that it was possible that field personnel, >
during original construction, could have concluded that the 2" extenders were not
needed. Engineering personnel submitted a work request for the addition of the
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, . 2" extenders on the applicable trays. These extenders have been installed on the trays
that are filled over 50 percent capacity, The inspectors concluded that no violations
occurred and that the 4" trays are rated for increased load. This item is closed.
IV. Plant Suonort
R1 Radiological Protection and Chemistry Controls
R1.1 Radiation Protection Practice of Uncontrolled Extension of Contaminated Area
a. Insoection Scope (71750)
The inspectors observed plant personnel perform an inspection of a valve in a
contaminated area. The inspectors interviewed radiation protection and engineering
department personnel and reviewed applicable procedures.
- b. Observations and Findinas
.
On September 16,1998, the inspectors observed two engineering department
personnel perform a visual inspection of control rod drive hydraulic system "B" flow
. control valve 1C11F00028. The valve was located in the containment building inside a
contaminated area boundary. The engineers were inspecting the valve for wall
thickness. When the engineers arrived at the valve, a foreign material exclusion cover
had been placed on top of the valve body since the valve's bonnet had been previously
removed. The cover was held in place by several bolts and nuts. One engineer entered
the contaminated area boundary while the second engineer stood outside the boundary. i
The second engineer held an open bag across the contaminated boundary for j
temporary storage of the removed bolts and nuts. The engineer then performed his
visualinspection inside the valve. 1
Upon the completion of his inspection, he requested the other engineer to lay out a tarp
so he could exit from the contaminated area. The engineer exited the contaminated
area, stepped onto the tarp, and kept his protective clothing donned. With the engineer
standing outside the contaminated boundary area rope, the inspectors questioned
whether the contaminated boundary had been inappropriately extended without radiation
protection department approval. At that time, a radiation protection technician (RPT)
came by and the inspectors questioned the RPT on the radiological work practice of the
engineers. The RPT contacted the health physics control point and was informed that
the engineers' actions were in accordance with the briefing which had been conducted
for their work activity.
Later, the inspectors had discussions with the RPT who had conducted the engineers'
briefing. The RPT informed the inspectors that he directed the engineers to use the tarp
as the boundary to stand on while removing their protective clothing. The RPT gave this
direction because step off pads were not used in containment due to the potential for
. them to become entrapped in the emergency core cooling system strainer. The RPT
further informed the inspectors that PAP-0511, " Radiologically Restricted Area"
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Revision 6, allowed this practice and that this had been a long-standing practice at the l
l plant. After review of the applicable parts of PAP-0511, the inspectors determined that
i the procedure did not prohibit this practice. The licensee performed a subsequent
survey of the area and did not identify any contamination.
l The inspectors also discussed this practice with the Radiation Protection Manager, who.
l subsequently walked down the area, interviewed the RPT, and generated a condition
l report. The Radiation Protection Manager indicated that a review of this practice would
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be initiated. The licensee conducted interviews among the RPTs and determined that l
this practice was not uniformly understood by radiation protection department personnel.
c. Concbsion
Although the licensee's contamination control program allowed plant personnel to
l extend contamination area boundaries in certain situations, this policy was not
consistently understood or implemented by radiation protection technicians.
- F8 Miscellaneous Fire Protection issues (71750) l
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F8.1 (Closed) Vio'atin 150-440/97021-04(DRP): On December 8,1997, inspectors found the
- fire door betwen the Division 2 and 3 emergency DG rooms stuck open. The licensee
l subsequently discovered that the door stuck on the floor sealant that had been recently
applied. The licensee conducted a review of other fire doors to ensure no other door
would stick open in a similar fashion. No other problems were noted. The inspectors
,
have noted no repeat occurrences of this issue. The inspectors concluded that the
l corrective actions for this item are adequate and this item is closed.
V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at
the conclusion of the inspection on October 20,1998. The licensee acknowledged the
findings presented. The inspectors asked the licensee whether any materials examined
during the inspection should be considered proprietary. No proprietary information was
identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee !
! L. Myers, Vice President, Nuclear
H. Bergendahl, Director, Nuclear Services Department
N. Bonner, Director, Nuclear Maintenance Department
'
W. Kanda, General Manager, Nuclear Power Plant Department i
F. Kearney, Superintendent, Plant Operations 1
T. Rausch, Operations Manager l
R. Schrauder, Director, Nuclear Engineering Department !
J. Sears, Radiation Protection Manager
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l INSPECTION PROCEDURES USED :
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l lP 37551: Onsite Engineering )
IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing !
Problems '
IP 61726: Surveillance Observation
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IP 62707: Maintenance Observation
IP 71707: Plant Operations
IP 71750: Plant Support
I IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor
,
Facilities
! IP 92901: . Followup - Operations ;
IP 92902: Followup - Maintenance l
lP 92903: Followup - Engineering '
l ITEMS OPENED, CLOSED, AND DISCUSSED
Ocened'
50-440/98018-01 VIO Failure to implement Requirements of Bum Permit
50-440/98018-02 NCV Failure to initiate Permit for Transient Combustibles
Clowd
50-440/96006-04 URI USAR Section 9.5.9.2.4, DG Air-Start Description
50-440/96017-02 URI DG and HPCS Test Possible Preconditioning
50-440/97006-00 LER HPCS Actuation Without injection
50-440/97008-00&O1 LER Technical Specification Limits Exceeded and Plant Operation
Continued Without Performing Required Actions
50-440/97009-02 VIO Standby Liquid Control Pump indicated Flow Low
_
-50-440/97021-03 URI - Seismic Tubing Supports for DG :
50-440/97021-04' VIO Failure to Keep Fire Door Closed
.50-440/98002 00 LER Trip Unit Failure Initiates RCIC With Subsequent Reactor Scram
50-440/98009-03 IFl Division 2 DG Load Swings
[ 50-440/98009-05 URI Cable Tray Loading Not in Conformance with USAR
50-440/98018-01 NCV Failure to initiate Permit for Transient Combustibles
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LIST OF ACRONYMS USED
CFR. Code of Federal Regulations l
CV Check Valve
DG Diesel Generators
DRP Division of Reactor Projects i
FPT Fire Protection Technician )
GE' General Electric !
HPCS. High Pressure Core Spray j
'IFl Inspection Followup item ' l
IP inspection Procedure
LCO Limiting Condition for Operation
LER Licensee Event Report
NCV Non-cited Violation
NRC- Nuclear Regulatory Commission
ONI Off NormalInstruction
PAP Plant Administrative Procedure
- PDR Public Document Room- !
RCIC Reactor Core Isolation Coohng
I
RCIS Rod _ Control and Information System
RG Regulatory Guide
RPT Radiation Protection Technician j
STAR Stop, Think, Act, and Review j
SVI Surveillance instruction l
TCP- Transient Combustible Permit l
TS Technical Specification
.USAR Updated Safety Analysis Report l
URI Unresolved item l
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