IR 05000440/1986021

Insp Rept 50-440/86-21 on 860707-25.No Violations or Deviations Noted.Major Areas Inspected:Operational Readiness,Including Implementation of Design Changes & Mods, Surveillance Testing & Preventive Maint

ML20205F890
Person / Time
Site:	Perry
Issue date:	08/13/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205F869	List: IR 05000440/1986021 ML20205F864
References
50-440-86-21, NUDOCS 8608190348
Download: ML20205F890 (18)

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U. S. NUCLEAR REGULATORY COPtilSSION

REGION III

Report No. 50-440/86021(DRP)

Docket No. 50-440 License No.NPF-45 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio i Inspection Conducted: July 7 through July 25, 1986 Inspectors: R. C. Knop J. H. Neisler J. W. McCormick-Barger A. D. Morrongiello K. A. Connaughton L. H. Jones D. L. Summers Approved By: R. C. Knop, Chief Reactor Projects Section IB Date Inspection Sunnary Inspection on July 7 through July 25, 1986 (Report No. 50-440/86021(DRP))

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Areas Inspected: Special announced inspection by resident and region based inspectors to perform a pre-full power license operational readiness inspection of the Perry plant. Areas reviewed included: implementation of design changes and modifications; surveillance testing as required by Technical Spccifications; preventive maintenance; control of lifted leads, jumpers, and temporary mechanical alterations; annunciator status and control; operation of plant; and control of out of service equipment and equipment tagging. In addition to the above review an inspection of the licensee's Operational Quality Assurance Program was conducted during June and July and documented in Inspection Report (50-440/85014(DRS)). The Operational Quality Assurance Program inspection is considered a part of this pre-full power license operational readiness inspectio i 0608190348 860813 0 ADOCK 0500

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Results: No violations of regulatory requirements or deviations from commitments were identified in the areas inspected. The Operational Readiness !

review indicated that plant management and operations and support personnel .

were following administrative controls and that implementation of activities I

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associated with plant operations was being conducted in accordance with plant procedures and instruction i

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DETAILS Persons Contacted M. Lyster, Manager, Perry Plant Operations Department F. Stead, Manager, Perry Plant Technical Department E. Riley, Manager, Nuclear Quality Assurance Department C. Shuster, Manager, Nuclear Engineering Department D. Takacs, General Supervisor, Maintenance A. Silakoski, General Supervising Engineer (GSE), Reliability and Design Assurance Section K. Pech, GSE, Mechanical Design Section B. Walrath, GSE, Operational Quality Section W. Kanda Jr., GSE, Technical Section E. Buzzelli, GSE, Licensing and Compliance Section R. Jadgchew, GSE, Instrumentation and Controls Section M. Cohen, General Supervisor, Nuclear Construction Service Section R. Stratman, GSE, Operations Section S. Wojton, SSE, Radiation Protection Section N. Newkirk, GSE, Electrical Design Section V. Higaki, GSE, Maintenance and Modification Quality Section R. Tadych, GSE, Training Section The above persons attended one or more of the exit meetings held on July 11,18, and 25,1986. The inspectors also contacted other individuals during the inspectio . Review of Design Changes and Modifications (37700)

The NRC inspector performed an in depth inspection of the system for control and documentation of design changes and modifications. The Inspection and Enforcement Manual 37700 was used as a guide in this inspection as well as the Perry Nuclear Plant Administrative Procedures (PAP) and Nuclear Engineering Department Procedures (NEDP).

During the course of the inspection, members of the Nuclear Engineering, Systems Engineering, Design Change Processing, and Maintenance groups were interviewed to determine their areas of responsibility, function, and qualification Before and during the inspection, the following administrative procedures were reviewed:

PAP-0301, Revision 4, dated April 22, 1986, " Design Modification Process."

PAP-0303, Revision 6, dated April 28, 1986, "As Built Drawings."

PAP-0402, Revision 2, dated May 30, 1986, " Procurement of Spare Parts, Material and Replacement."

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PAP-0607 Rev . ion 1, dated May 2, 1986, " Perry Plant Drawing Control."

NEDP-0301, Revision 0, dated May 6, 1985, " Design Control Program."

ND 35-0304, Revision 3, dated April 28, 1986, " Processing As Built Drawings."

The inspector requested a list of all Engineering Design change Records (EDCRs) and Design Change Reports (DCR) which had been active since

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November 15, 1985. A list of 32 EDCRs and DCRs was generated. The list, from a computer based status reporting system, had a complete description of the activity on each ite From the list, five Design Change Packages (DCP's) were chosen for further study. These included four DCRs and one EDCR. These are:

DCP 85-0483, dated November 1, 1985, " Modify Hanger 1E12-H148 Due to Vibration Problem."

3CP 85-0575, dated November 15, 1985, " Installation of Individual

! Fuses for Optical Isolators in 1H13-P616 and P629."

DCP 86-0029B, dated January 28, 1986, " Installation of Individual Fuses in EH1110. EH1106, and EF1B06 to replace the 32v Fuses with 120v Fuses."

DCP 86-0029C, dated January 28, 1986, " Replacement of 20-30a 32v Fuses with 120v Fuses."

DCP 86-0220, dated March 7,1986, " Place Flow Orifices Immediately Upstream of Valves E12-F018A, B, and C."

The first DCP inspected, DCP 85-0483, documented a change to a pipe hanger (snubber) on the RHR system which completed an open item from the system vibration testing program. The Engineer Change Notice (ECN)

was retrieved from the Document Control microfilm system and inspecte The package included all document changes made as well as the mairtenance work package. The work was detailed in ECN 27438-44-8222 R/C and performed in accordance with Work Order (WO) 85-9529. The Engineering Document Control system was inspected to determine if all required information was included in the file. A field inspection of the installation was then made. The equipment was located in RHR C Pump Room, elevation 568, Room 5, south side of room. All as-built information was field checked. No deviations were identifie The second DCP inspected (DCP 85-0575) documented a change of fuse sizes for optical isolators. This change was approved and a Work Order (WO-9586) writte The Work Order was in Scheduling and no work had been performe The DCP file was inspected for completeness and the Nuclear Engineering Department (NED) 10 CFR 50.59 Applicability Check Sheets, dated November 15, 1985, and December 18, 1986, the NED Safety Evaluation, dated

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November 16, 1985, and the Environmental Applicability Review, dated February 18, 1986, were reviewed. The package included all document changes required to update the document system and a complete work package. No concerns were identifie The third DCP inspected (DCP 86-0029B) documented replacement of fuse This change had been completed and all documents updated. The work was performed under WO 2488, and Change Update Notices (CUNs) 1829, 1830, 1831,1832,1833, and 1964 were processed through Engineering Document Control. The drawing file in Engineering Document Control was reviewed and the revisions were properly documented. The drawing file in the Control Room was then checked and the proper drawing revision was included in that fil A copy nf WO 86-2488 was obtained and reviewed. The Stores Requisition used to obtain the fuses was attached to the work order. The information on the requisition was checked in the warehouse and in the P.aintenance Tool Room. The purchase order used to purchase the fuses (P0 7724) was retrieved from the files and reviewed. The provisions of the purchase order were compared with the requirements of Reg Guide 1.754 and Nuclear Quality Assurance Procedure (NQAP) 0403, Revision 2, Item 4.4. Field inspection of the changes documented by the CUNs could not be accomplished without putting the reactor in an LC0 condition, so the field inspection was not performed. However, each CUN had a verification signature and date on the face of the CUN. In the inspection of this DCP, no discrepancies were identifie The fourth DCP inspected, DCP 86-0029C, was similar to DCP 86-0029 It was inspected in parallel with DCP 86-0029B and no deviations were identifie The fifth DCP inspected, EDCR 86-0020, consisted of a design package to move three flow restricting orifices in order to dampen flow induced vibration in the pipin The EDCR had been approved by Management but had not been assigned to a Project Engineer for further processing and implementation. The inspector verified that the complete design package was on file in the Plant Modification File, that ECN 28403-86-2200 R/E described the work and that the priority was to complete this change by commercial operation. No discrepancies were identifie The NRC inspector found that there were no active RHR work orders being worked by Maintenance during the period of inspection, so an active safety related work order, WO 86-9972, " Check for Seat Leakage on the EP-107 Valves" was chosen in order to inspect work actually proceeding in the field. The task was to inspect 177 hydraulic accumulator drain valves in the control rod drive system to determine if any of the valves leaked through the sea The work was performed by three maintenance persons. The task, although a relatively simple inspection task, was thoroughly explained and detailed. The check sheet for recording the results of the inspection was complete and well designed. The mechanics were questioned about

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their qualifications for the work and their qualifications were satisfactory. They also were well briefed before the start of work and cautioned to maintain contact with Operation During the period of performance, radiological, operational, and safety controls were observed carefully by the mechanics and the work was accomplished without incident. One QC witness point was identified on the package: for the inspector to witness 15 to 20 valve inspections out of the total of 177 valves. The inspector actually witnessed over tulf the inspections. The QC inspector was interviewed and appeared to have adequate knowledge of the task to perform the inspectio The inspection identified two valves that leaked. This was noted on the work request. The inspector field witnessed a portion of the work, performed a thorough review of the documents relating to the werk, and did not identify any discrepanc The six work packages inspected to this point were all on safety related systems and were well documented but were relatively simple engineering tasks. One active engineering task which included a significant amount of engineering was the conversion of the safety related instrument air system from a high pressure system to a low pressure system, DCP 86-0602, A, B, C and D. The inspector interviewed several Nuclear Engineering Section engineers, including the Senior Project Enginee The engineering file in the Nuclear Engineering Section was inspecte It contained a list of all equipment list changes and documented changes necessary to completely define the modification. The calculations necessary to confirm that pipe hangers and other structural designs were included in the package and found to be adequate. The work was divided into four packages according to engineering discipline. The file was well organized, complete, and easy to follo ,

The inspector also performed an implementation review of WO 86-10357 that was prepared to modify the Safety-Related Instrument Air System per DCP 86-602. The WO included the installation of conduit and associated wiring to be used with a pressure transmitter that was to be installed in the Instrument Air System by a separate WO. Since work was in progress, the inspector toured *.he worksite, reviewed the WO, and interviewed the work foreman, and the quality control inspector assigned to the activit During review of the WO and associated DCP, the inspector noted that the instructions for performing the work were written assuming that licer.see employees were to perform the work using licensee procedures and specifications. The work was actually performed by a contractor, L. Comstock, who had their own licensee approved procedures. Since the DCP references CEI procedures and not L. K. Comstock procedures, the inspector questioned the validity of allowing a contractor to perform work to a DCP that did not reference the contractor's specific procedures and instructions. The licensee informed the inspector that the contractor's procedures were equivalent, approved by the licensee, and i acceptable for performance of the assigned task. The inspector's review

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of the contractor's procedures, including installation details, revealed that the procedures appeared to be adequate, and included appropriate i

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Quality Control inspection requirements. Although the inspector had no specific safety concerns with the WO being reviewed, the inspector did discuss with the licensee the generic concern of having contractors use their own procedures to perform work on the completed plan Specifically, the licensee lacked a program that assured that changes to their installation procedures are also reflected in contractor procedures. Also, changes to contractor procedures did not appear to require licensee engineering review. The licensee committed to review

! this concern, and made appropriate administrative changes as they find necessary. This concern is considered as open item (440-86021-01(DRP)).

During the review of the licensee's and contractor's procedures for performing the work required by the above WO (WO 86-10357), the inspector noted that the contractor's procedures included detailed Quality Control (QC) inspector instructions and check list to be used during QC inspections of the work being performed. However, the licensee's procedures lacked detailed QC instructions. The inspector met with the licensee's Quality Control Managers and informed them of this concer The licensee committed to review QC requirements and procedures to see if more specific details are necessary to assure QC inspections are adequately defined and performed. This concern is also considered an open item (440-86021-02 (DRP)).

A review of the licensee's Post Modification training progr6m was conducted to assure that the program provides a personnel training evaluation for each design change that is implemented. The inspector met with the licensee's training department and was shown that as part of the

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design package review process, Training is required to review the package and determine training requirements as applicable. After performing their evaluation, Training signs the design package. Depending on the nature of the design change, Training will either conduct immediate training of the change or incorporate the change into their ongoing training progra In addition to the program and implementation review of Design changes and Modifications, the inspector reviewed the licensee's program for

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training and installation of RayChem heat shrinkable tubing. RayChem

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applications were reviewed because of problems encountered at other Nuclear Power Plants due to those licensees not following RayChem procedures for installation of their heat shrinkable tubin The inspector performed a revf es of the licensee's Generic Electrical Instruction (GEI) - 0007, Revision 0, dated November 9,1986, " Instruction for Cable / Wire Terminations," and conducted discussions with the training department, the electrical eng*neering project management staff, and the Quality Control Organization to determine if adequate procedures and training of workers existed. The inspector found that training was being performed by RayChem personnel and that GEI - 0007 contained, as an appendix, the actual RayChem installation instruction No violations of regulatory requirements or deviaticns from commitments ,

were identified in this are !

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. . Review of Surveillance Testing as Required by Technical Specifications

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(61726) (61725)

The NRC inspector performed an in depth inspection of Technical Specifications (T/S) and Surveillance Testing requirements as specified in Perry Nuclear Plant (PNP) Administrative Procedures and the Plant Operating Manual. PNP Technical Specifications, Surveillance Instructions (SVI), Limiting Conditions for Operation (LCO) Tracking Logs, both potential and active, and daily LCO Surveillance Requirement Logs were obtained and reviewe Before and during the inspection, the following procedures were reviewed:

0AP-1701, Revision 2, dated June 20, 1986, " Tracking of LCOs."

0AP 1702, Revision 3, dated February 19, 1986, " Operations Sections Rounds Sheets, Logs and Records."

OM-14:TM-7.3, Revision 1, dated April 15, 1936, " Departmental Training, Technical Section and I&C Section."

PAP-0903, Revision 2, dated July 5,1985, " Repetitive Task Program."

PAP-1105, Revision 2, dated October 22, 1985, " Surveillance Test Control."

PAP-1113, Revision 0, dated May 16, 1985, " Surveillance Requirements Tracking."

PAP-1114, Revision 1, dated December 18, 1986, " Operational Condition Change Checklist."

PAP-1201, Revision 2, " Control and Calibration of Measuring and Test Equipment."

1he following Surveillance Instructions were reviewed during this inspection:

SVI-B21-T0136, Revis'en 2, " Emergency Core Coolant System / Reactor Core Isolation Cooling Reactor Vessel Water lo Level 1 and 2, Channel A Calibration for IB21-N091A."

SVI-C51-T0027A, Revision 2, dated July 16, 1986, "APRM A Trip Channel Functional."

SVI-C61-T1104, Revision 2, dated July 3, 1986, " Accident Monitoring l and Remote Shutdown Channel Checks."

SVI-E12-T0146, Revision 1, dated July 13, 1986, " Emergency Core Coolant System / Low Pressure Coolant Injection Pump A Start Time Delay Relay, Channel Function / Channel Calibration for 1E12A-K70A."

SVI-E12-T5368, Revision 1, dated July 16, 1986, " Emergency Core Cooling System / Low Pressure Coolant Injection Pump B Start Time Delay Channel Functional / Calibration for IE12A-K70B."

SVI-E31-T0115A, Revision 1, dated March 11, 1986, " Residual Heat Removal Equipment Area 1 Temperature High Channel Calibration for IE31-N600A and 1E31-608A."

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SVI-E31-T0114A, Revision 1, dated July 15, 1986, " Residual Heat Removal Equipment Area 1 Temperature High Channel A Functional for 1E31-N600A,and'1E31-N608A."

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SVI-E31-T0123A, Revision 1, dated June 23,1986, " Reactor Core Isolation Cooling Steam Line Flow High and Timer Channel Functional for 1E31-N683A."

SVI-E31-T0124A, Revision 1, dated March 28, 1986, " Reactor Core Isolation Cooling Steam Line Flow High and Timer Channel

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Calibration for IE31-N083A." .

The following Operation Shutdown Technica) Sp'acification Rounds were reviewed on July 14,'1986:

Item 8, Tech Spec 4.4.9.2, " Shutdown Cool',ng."

Item 9 Tech Spec 4.3.3.1-1, "HPCS Pump'Oie,c Wege Pressure."

Item 27, Tech Spec 4.3.3.1-1A.la " Reactor Vessel Level."

Item 29, Tech Spec 4.3.3.1-1A.1c, "LPCS Pump Discharge Flow - Low."

Item 30, Tech Spec 4.3.3.1-1.Alg, "LPCI Pump Flow-idw."

Item 42, Tech Spec 4.3.1.b, " Suppression Pool Water Level."

Item 49,TechSpec4.3.2.a',:"SuppressionPoo1MaterLevel."

e Other documents reviewed included:

Systems Description Manual E12, "Ror.feua13 Heat Removal System."

Perry Plant Weekly Surveillance Schedule' fd the week starting

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July 14, 198 ts Daily LCO Surveillance Require #ents Log dated July /11,1986.

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Perry Plant Maintenance Information System T/S Matrix by Tech Specs, dated July 14, 198 e'

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l Procedures PAP-1105, PAP-1113, andl PAP-1114 were reviewed and the Surveillance Coordinator was interviewed to detereine if Technical Specification frequency requirements had been incorperated into the surveillance program.

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A " PNP Information System T/S r 'f atrix By Tech Spec" was provided which

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contained the Tech Spec and tbt accompanying SVI numbe-s. This matrix also contained the test frequency recuired by the Tech Spec. The

" Surveillance Instructions" computer printout, which contained the completion date, due date and late date of each SVI, was provided. A cross reference of Tech Spec and SVI requirements were included in

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The NRC inspector found that three surveillance schedules are maintained: less than weekly, weekly or greater, and long term. The less than weekly schedule is maintained in accordance with Attachment 10 of 0AP-1702, " Operational T/S Rounds" and weekly or greater and long term schedules are in the computer and maintained in accordance with PAP-1113. Copies of these schedules were reviewed and no discrepancies note The ontingent surveillances were not investigated because they are required as a result of changes in plant conditions and none were scheduled during the inspectio The NRC inspector requested a copy of ' slipped (late date) surveillance A review of the Residual Heat Removai System (RHR) weekly and operation schedules confirmed the coordinator's statement that no backlog of slipped Tech Spec required surveillances existed. However, PAP-1105, PAP-1113, and 0AP-1701 require the Unit Supervisor to initiate a LC0 if Tech Spec requirements should sli The LC0 logs for potential, active, and long term LCOs were reviewed using PAP-1105, PAP-1113, 0AP-1701, and 0AP-1702 as a guide. No problems were noted. However, one active LC0 had been initiated concerning Tech Spec Section 3.3.7.0 and identified on the daily surveillance log dated July 17, 1986. The LC0 and Tech Spec action were verified on the daily lo The procedures above require that the Unit Supervisor initiate a potential LC0 prior to approving performance of SVIs. At that time, the clock is started and, if the SVI cannot be completed in the time required by the Tech Spec, an active LC0 is issued. Also, personnel performing the SVI are required to immediately inform the Unit Supervisor of the time laps, at which time an active LC0 is initiated and the equipment is declared inoperabl Twelve Tech Spec requirements were compared to the appropriate SVIs to assure that the Tech Spec requirements had been included. No discrep-ancies were noted. SVI parameters were found to use the same units of measurement as the instrument being recorded and were converted to the same units as used in the Tech Spec Eight completed SVIs (SVI-E12-T5368, SVI-C51-T0027A, SVI-E12-T0146, SVI-E31-T0115A, SVI-T0114A, SVI-E31-T0123A, SVI-B21-T0136 and SVI-C61-1104) were reviewed. No concerns were identifie The inspector noted that completed SVI-C61-1104 had failed the acceptance criteria and an LC0 was required. The LC0 log for System C-61 was reviewed and a potential LC0 had been issued. Further investigation of LC0 requirements indicated that a potential LC0 was the correct actio Instruction for completing a partial SVI on the failed section of the SVI was issued and it was confirmed that the operators had used the wrong scale to obtain readings. The surveillance test was then accepte _ - _ _ _ _

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Seven Operational Condition 4 Tech Spec P.ounds (items 8, 9, 27, 29, 30, 42 and 49) for July 14, 1986, were reviewed and checked with the Shift Technical Advisor. No discrepancies were note Two surveillance tests in process, SVI-E12-T5368 and SVI-C51-T0027A, were witnessed to determine if technicians were following the approved ;

instructions and procedures. No deficiencies were observed. Personnel performing the activities appeared knowledgable and competen l Certification and qualification of the six I&C technicians (one a I consultant) who performed the surveillances were compared with the requirements of OM-14:TM-7.3 and appeared adequat Procedure PAP-1201'vas reviewed to assure that requirements had been established for M&TE found to be out of calibration. When M&TE have been used and later found out of calibration, lost, or damaged, a review of past calibrations are made to determine the past reliability of the instrument. If the out of calibration M&TE was used on plant instruments, a "M&TE Out of Calibration Report" is sent to the responsible group. The lead supervisar/ engineer perfonns an evaluation l to determine if any equipment in sa dce has been affected. The j inspector was not able to inspect fu compliance with this procedure because time was not availabl l

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No violations of regulatory requirements or deviaticus from comitments were identified in this are l 4. Preventive Maiatenance (62700)

The inspector reviewed the procedure governing the preventive maintenance l program at Perry, PAP-0903, " Repetitive Task Program," Revision 2 dated 4 July 5, 1985. Inspection of the licensee's implementation of this l procedure revealed that repetitive maintenance is controlled through a computerized data base in the licensee's scheduling departmen Each repetitive maintenance task is printed on a card showing the task and the date the task is to be performed. The task cards are received each day by the repetitive maintenance scheduling section at the site, reviewed for accuracy and completeness, and assigned to the appropriate department or section for action. When the required maintenance actions are complete, the task card is returned to the plant repetitive maintena,nce scheduling section for review and processin )

The inspec.tcr ascertained that the quality assurance maintenance and modifications section performs random surveillances of the repetitive task progranJ to determine whether the program is being conducted according to the approved procedures. At the time of the inspection, quality assurance was performing a study to determine what further actions were needed to assure the quality of the repetitive (preventive) tasks meet the requirements of the Perry Quality Assurance Program. The study l was initiated as a result of audit PIO 86-31, dated June 13, 1986, that identified a need for additional quality involvement in repetitive ma'intenance activities, particularly direct observation of task action . i

. . Work Request / Work Order program The inspector reviewed procedures PAP-0902 " Work Request System" f Revision 2, dated November 20, 1985 and pap-0905, " Work Order i Process" Revision 4, dated March 25, 1986. Subsequent to the review of these procedures, the inspector selected several work' order numbers and followed the work orders through the maintenance system. Work requests are initiated by the person or group that identifies a problem. The work request goes to the control room where it is reviewed and if needed a numbered work order is issue The work request and work order is then sent to the maintenance planning section. The maintenance planners research manufacturers'

and designers' literature and plant procedures, prepare travellers and a detailed work procedure with appropriate drawings, order parts, and prepare tag out recommendations. The maintenance planner and the responsible system engineer determine the requirements for post maintenance testing to assure the equipment is functional within Tech Spec requirements. The work order package is reviewed by the Maintenance and Modification Quality Assurance Section before work begin The unit supervisor releases all equipment before work can begin for both safety related and non-safety related equipment. When work is completed the job supervisor examines the work and documentation and signs the work order indicating that the work has been accomplished in accordance with the work order. Quality Assurance reviews the completed work package before the control room closes out the work .

order and restores the equipment to operating status. The system responsible engineer reviews the completed work order to assure appropriate post maintenance testing had been performe The inspector observed that all work orders were routed to the unit supervisor (SRO) in the control room. No work can commence without the unit supervisor's approval and he has responsibility to assure that adequate retests of equipment and systems are performed at the completion of wor In general, the inspector concluded that the work request and work order program was being implemented according to the approved procedures, post maintenance testing was being performed, and that cleanliness controls were in effec Training The inspector examined training records for 16 maintenance and instrument and control technicians. Formal training is presented to technicians in accordance with the Perry Training Manual Sections 7.2 and 7.3. The training for the technicians appeared to be adequate for the current status of the plant. A requalification training program for technicians is being developed and scheduled to be in place by the end of 198 .;

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There is currently no training program for maintenance and I&C planners. The licensee representatives at the exit interview informed the inspector that training requirements for planners were the subject of a study in progress and that a training program to satisfy these requirements was being developed as the requirements were identifie No violations of regulatory requirements or deviations from commitments were identified in this are . Control of Lifted Leads, Jumpers and Temporary Mechanical Alterations (37700)

The inspector reviewed Plant Administrative Procedure (PAP)-1402,

" Control of Lifted Leads, Jumpers, Temporary Electrical Devices, and Mechanical Foreign Items," Revision 3, dated November 8,1986, and active temporary changes thereto. The inspector determined from this review that the subject procedure had been written, reviewed, and approved in accordance with licensee administrative controls. The procedure assigned responsibility and authority for the control of temporary equipment alterations to specific licensee personne Instructions were provided for technical review, documentation, implementation, and removal of temporary alterations, including provisions for the performance of safety evaluations required by 10 CFR 50.5 The inspector reviewed the Mechanical Foreign Item / Lifted Lead, Jumper, Electrical Device (MFI/LLJED) Index generated in accordance with PAP-1402. Specifically, the inspector reviewed MFI/LLJED items for the years 1984, 1985, and 1986. This review disclosed that approximately 50 temporary alterations were in effect at the time of the inspectio Two alterations identified by Tag Order Log Numbers15-825 were initiated in 1985 but did not have documented implementation or removal dates. The inspector referred this matter to licensee personnel who subsequently determined by review of associated work documents and field vcrifications that the alterations had not been implemented because they were determined unnecessary following tag order number issuance. Licensee personnel cancelled these entries in the tag order inde PAP-1402 required that Perry Plant Technical Department personnel conduct monthly reviews of active tag orders greater than three months ol These reviews were to be conducted to determine whether or not the ,

temporary alterations associated with such tag orders were still I necessary. These reviews were to be documented in the tag order inde PAP-1402 required the Unit Supervisor to conduct quarterly audits of active tag orders including verification that tags were properly hung and in good condition. These audits were to be documented on the tag order log sheet The inspector's review of the tag order index determined that the technical department tag order reviews were not always performed within the monthly intervals prescribed by PAP-1402. Inspector review of active j

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tag order log sheets and interviews with licensee operating personnel disclosed that the quarterly audits of active tag orders were conducted at the prescribed interval but were not necessarily performed by the Unit Supervisor. This function was usually delegated to other personnel within the operating department. The inspector requested licensee management personnel to review these matters to assure that tag order reviews and audits are conducted in a timely manner by qualified individuals and in accordance with procedural requirements. These matters will remain an open item pending inspector's review of licensee actions (440/86021-03(DRP)).

The inspector verified by direct visual observation that temporary alterations associated with the following tag orders were in place as described in the tag order logs and were identified by appropriate tagging:

Tag Order Log Numbers

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14-040 16-075 16-233 16-404 16-429 16-430 16-496 No violations or deviations were identifie . Annunciator Status and Control (37700)

By direct observation, the inspector reviewed the status of annunciators located on panels in the main control room, the Division 1 diesel generator room, and the Division 3 diesel generator room. The inspector also interviewed licensee operating personnel regarding a number of actuated annunciators. From these observations and interviews the inspector determined that of the approximately 1140 control room annunciators, five annunciators were intentionally disable The inspector performed a cursory review of approximately 130 annunciators which were actuated at the time of the inspection and determined that with few exceptions, the actuated annunciators merely reflected current plant conditions and were not attributable to off-normal conditions, sensor failures, or other equipment malfunctions. Operating personnel appeared to I be knowledgeable concerning annunciator status and were l observed to be attentive and responsive to annunciators which l actuated during the time the inspector was in the control roo Annunciators which could not be reset or which were presenting spurious false alarms due to equipment or sensor failures could have been disabled in accordance with Perry Administrative Procedure PAP-1402, " Control of l

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Lifted Leads, Jumpers, Temporary Electrical Devices, and Mechanical Foreign Items." The subject procedure established controls for the identification, documentation, repair, and restoration of disabled annunciators. Inspector review of selected tag orders generated in accordance with PAP-1401 for total or partial disablement of annunciators and inspector observations of annunciator panels disclosed that the licensee had properly identified the affected annunciators by affixing adhesive labels to the annunciator windows. The adhesive labels indicated the degree to which the annunciators were disabled and contained the tag order number associated with the disablement. To indicate the status of annunciators located on the reactor operators console (Panel P680), similar but smaller adhesive labels were employed which indicated the degree to which the annunciators were disabled. A P680 Annunciator Status Log was established and maintained to cross reference affected annunciator window locations with tag orders which affect annunciator operabilit The inspector reviewed this log and verified that labelled annunciators were identified in the log, and conversely, that disabled annunciators identified in the log were suitably labelle In summary, the overall status of plant annunciators appeared consistent with plant condition Licensee administrative controls for the identification and correction of annunciator malfunctions were effectively implemente No violations or deviations were identifie . Operation of plant (71715)

Portions of routine inspections were performed by the inspector covering plant operations. Control room behavior and professional conduct of personnel is of concern to the NRC. The inspector's observations in both of these areas showed that the operators were professional in their conduct and neat in appearance. Operators were attentive to the unit and annunciators were acknowledged and analyzed, no matter how routine or repetitive the events wer Shift turnovers were formal and the shift being relieved made use of shift turnover sheets. During the turnover it was noticed that plant business continued. A simple improvement to the shift turnover would be to provide a quiet period during turnover when routine business would be halted. This would allow for an uninterrupted discussion to occur between the changing * shifts. Operating logs by the Supervising Operator were timely written and did reflect plant conditions. The information in the Shift Supervisor's log, however, should be expanded to reflect his involvement in plant operations since he is accountable. The Shift Supervisor's responsibilities were primarily directed towards maintaining an overview of reactor operations. The Unit Supervisor and the Supervising Operator's responsibilities were spelled out and adhered to. The Unit Supervisor did maintain control of the unit's operation while the Supervising Operators were attentive to the unit and controlled access to the

" horseshoe" are :E

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Communications represents another important area of concern. Generally, ,

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comunication between the work crews and the Supervising Op'erator were good. However, it was observed that there was a tremendous amount of information being conveyed to the Supervising Operator and this raised a concern about the operator being able to give his full attention to the unit. A suggestion was made to plant management to review the types of information given to the Supervising Operator and to remove infonnation sources deemed redundant or superfluous. Communications between the Unit Supervisor and the various working groups was also goo During the inspection several other areas of concern were also note It was observed that one could not readily tell by looking at tags on the control room panels whether a meter or piece of equipment was out-of-service or could be used under limited conditions. A suggestion was made to plant management to use a tagging system that differentiated between items out-of-service for repairs and those that could be used under limited conditions. Another area in which improvements could be made was in Conditions Reports. The reports as now written capture useful data as well as data of minimal use. This leads to an explosion of information and great difficulty in processing this infonnation. The suggestion was made to redefine criteria for initiating a Conditional Repor It was also suggested to plant management that a program of training the maintenance staff in plant systems be considered in that this would be beneficial to smooth operation of the plan In summary, staffing, training, performance, and management involvement appear adequate to ensure safe operation of the uni . Control Of Out of Service Equipment and Equipment Tagging (71707) ,

i The inspector reviewed the following Plant Administrative Procedures (PAPS) utilized to identify document control and restore equipment and systems taken out of service:

PAP-0201 " Conduct of Operations" PAP-0205 " Operability of Safety Systems" PAP-1914 " Impairment" PAP-0504 " Electrical Operating Rules and Practices"

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PAP-1401 " Equipment Tagging" PAP-1402 " Control of Lifted Leads, Jumpers, Temporary Electrical Devices, and Mechanical Foreign Items" PAP-0305 " Safety Evaluations"

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The inspector reviewed the Tag Out Index generated in accordance with PAP-1401 and determined that at the time of the inspection, approximately 195 tag outs remained in effect, either in support of ongoing activities or pending restoratio From the population of tag outs in effect, listed in the tag out index, the inspector selected the following tag outs for further review:

Tag Out Number Component or System Effected 16-2600 Diesel generator standby air compressor 1E22-C004A 16-2506 Diesel generator standby air compressor IE22-C004A 15-1367 RHR system 1E12A and IE128 -

16-2880 CRD pump IC11C001A 16-2810 Containment vessel chilled water pump 16-1067 Control complex chiller OP47B0001B 16-2190 Division 1 diesel generator room ventilation 16-2191 Division 1 diesel generator room ventilation 16-2901 Containment vessel and drywell purge 16-2836 Feedwater header shutoff valves IB21-F065A and IB21-F065B 16-2876 Division 2 reserve battery charger OR425009 The inspector's review of the tag out sheets verified that for each tag out the following information required by PAP-1401 was included and adequately detailed: the reason for the tag out, identification of radiational work permits and work orders associated with the tag out, 1 identification of the person in charge of the activity requiring the tag out, and identification of the individual performing the technical review 1 of the proposed tag out. In addition, the inspector verified that i associated requirements in the areas of fire protection, technical '

specification limiting conditions for operation, and independent verification were identifie Finally, the inspector verified that the tag outs had received proper authorization prior to implementatio Following the document review described above, the inspector verified by direct visual observation that components utilized to affect the out of service work were tagged and in the conditions or positions specified on the tag out sheet l

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The inspector reviewed applicable piping and instrument diagrams and electrical drawings to determine whether or not the out of service boundaries established by the tag outs were adequate for the protection of equipment and personnel, and to allow performance of work activities requiring the tag outs. Based upon the inspector's reviews and observations, the inspector determined that the licensee had established highly detailed and effective procedures for the control and restoration of equipment taken out of service. The out of service conditions selected for detailed inspector review were found to be properly implemented in accordance with the subject procedure No violations or deviations were identifie . Open Inspection Items Optn inspection items are matters which have been discussed with the licensee, which will be reviewed further by the inspector and which involve some action on the part of the NRC or licensee or both. Open inspection items disclosed during the inspection are discussed in Paragraphs 2 and . Exit Interviews (30703)

The inspectors met with the licensee representatives denoted in Paragraph 1 throughout the inspection period and during exits held on July 11,18, and 25,1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report. The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur _