IR 05000440/1986027

Oversight Team Insp Rept 50-440/86-27 on 861105-07.No Violation or Deviation Noted.Major Areas Inspected:Ler Analyzing & Reporting Program.Observations Made to Improve LER Program Identified

ML20214F930
Person / Time
Site:	Perry
Issue date:	11/17/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214F920	List: IR 05000440/1986027 ML20214F917
References
50-440-86-27, NUDOCS 8611250485
Download: ML20214F930 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/86027(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, OH Inspection Conducted: November 5 through 7, 1986 Inspectors: J. McCormick-Barger S. Stern J. Stefano '

R. Scholl R. Becker P. Leech E. Weiss G. O'Dwyer Approved By: R. C. Knop, f U Reactor Projects Section IB Date Inspection Summary Inspection on November 5 through 7, 1986 (Report No. 50-440/86027(DRP))

hreas Inspected: Special announced oversight team inspection consisting of resident, region, and headquarters based inspectors to perform an assessment of the licensees initial operational performance by focusing primarily on the Licensee's Event Report (LER) analyzing and reporting program. Areas reviewed included: attending a presentation by the licensee of it's LER program; the licensee's events reporting / notifications administrative program; the licensee's lessons learned program as it relates to events at other plants; and an assessment of specific LER Results: No violation of regulatory requirements or deviations from commitments were identified in the areas inspected. The licensee's initial operational perfonnance, based on our review of its LER's and LER program, appears to be acceptable. Several NRC observations were made during this inspection where improvements in the licensees LER program could be made to enhance its ability to reduce reportable events and/or correct identified deficiencies. These observations are identified in Paragraph 7 of this repor g12DO485861110 ~

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1. Persons Contacted

• • M. R. Edelman, Senior Vice President, Nuclear Group A. Kaplan, Vice President, Nuclear Operations Division

• M. D. Lyster, Manager, Perry Plant Operations Department (PP0D)

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• F. Stead, Manager, Perry Plant Technical Department (PPTD)

• C. Shuster, Manager, Nuclear Engineering Department (NED)

E. Riley, Manager, Nuclear Quality Assurance Department (NQAD)

• E. Buzzelli, Ger eral Supervising Engineer (GSE), Nulcear Licensing, and Fuel Management Section, PPTD

• S. Kensick, Technical Superintendent t

• B. D. Walrath, GSE, NQAD

• A. F. Silakoski, GSE, Reliability and Design Assurance Section

• K. R. Peach, GSE, Mechanical Design

*V. K. Higaki, GSE, NQAD

• S. J. Wojton, GSE, Radiation Protection

• R. Stratman, General Supervising Operator

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• R. J. Tadych, Operating Supervisor, Training l *G. Anderson, Lead Engineer, I&C

• D. R. Hoffman, Licensing / Compliance Engineer

• B. P. Stetson, Licensing Engineer, PPTD

• G. S. Cashel, Licensing Engineer, PPTD

• P. A. Russ, Compliance Engineer, PPTD

• T. E. Hicks, Operations Engineer, PPTD

• D. O. Myers, Quality Engineer, NQAD

• P. Telthorst, Licensing Engineer, Illinois Power Company

• Denotes those attending the exit meeting held on November 7, 198 **Mr. Edelman attended a mini-exit meeting held on November 6,1986.

l The inspectors also contacted other individuals during the inspectio . Licensee's Presentation of its LER Reporting and Analyzing Program (30703)

In a letter from Region III to the licensee, dated October 23, 1986, the licensee was requested to prepare a presentation of its LER reporting and analyzing program to be presented during the oversight team inspection entrance meeting. On November 5, 1986, the inspectors

attended this presentation. The licensee discussed its organization j and how it related to the LER program, and its process for identifying

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and correcting LER This presentation provided useful information to the tern members in

preparation for the indepth review of the licensee's program '

! Management programs for resolving generic issues, such as multi-discipline task forces, identified during the presentation, were

} further reviewed by the oversight team and are addressed in later

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sections of this report.

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3. Review of the Licensee's Events Reporting / Notifications Administrative Program (92720)

The inspectors performed a detailed review of the licensee's Event Reporting / Notifications program to assure that the program met regulatory requirements and that events are being properly classified and/or reporte The inspectors reviewed Perry Administrative Procedure (PAP) - 0603

" Licensing Events Reports", revision 3, and PAP-0606, " Condition Reports and Immediate Notification", revision 4. The inspectors found that the procedures closely followed 10 CFR 50.72/10 CFR 50.73 reporting requirements. The procedures specifically listed criteria for generating Condition Reports (CRs), 10 CFR 50.72 notifications, and LERs. The inspectors noted that PAP-0606 had undergone revisions to attempt to reduce the number of CRs that were being prepared but subsequently not requiring 10 CFR 50.72 notifications and/or LERs. These revisions did not appear to impact the licensee's program for identifying or reporting events. However, the inspectors were concerned that removal of non-reportable events from the CR program such as failed SVI's and other normal failures which are tracked by work orders, may not be adequately trended for generic concerns. This concern was brought to the attention of licensee's an management during)the open item (440/86027-01(DRP) . inspection exit and is considered Prior to the performance of this inspection, the team performed a review of all LER's issued by the licensee from license issuance on March 18, 1986, through October 24, 1986, (LER's86-001 through 86-064). In addition, the inspectors performed indepth reviews of the following LERs and/or CRs to determine the adequacy of the licensee's threshold for reporting plant events:

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Conservative Design Setpoints Resulted in Actuations of Drywell Vacuum Relief System (3 separate events)

l CR 86-595/596* - Initial (June 20,1986) Charcoal Fire Event CR 86-0656* -

Charcoal Fire Reignition Event CR 86-285** -

SLCS Pump Coupling

• Emergency plan notification made; no LER issued

• • 10 CFR 50.72 notification made; no LER issued From the review of the above documents, the CR log, and the

, administrative program for reportable events, the inspectors determined that 10 CFR 50.72 notifications were timely; CRs sufficiently related the scope of the events; the licensee conservatively reported events when not sure of impact; 10 CFR 50.72 notifications were adequately evaluated to determine if LERs were also required; licensee assessement of the events followed provisions of 10 CFR 50.59; and the results of

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analyses were reviewed / actions approved by PURC before issuance of the LER In addition, the inspectors found the reports to be generally thorough and complet The inspectors found the administrative procedures somewhat cumbersome, with various types of documentation used for tracking events from inception to final resolution, and suggested that some degree of streamlining / simplifying of the process be considered.

d In response to the inspectors suggestion, the licensee described and the inspectors reviewed the licensee Work Review Task Force. The objective of this task force is to provide an ongning evaluation of the work process at the Perry Plant, to critically assess program, program

, implementation, interfaces, utilization of project resources, and

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performance indicators for the purpose of developing recommendations to increase effectiveness and efficiencies in performance of work. A

, primary goal of the task force is to examine the means to accomplish i'

actions at Perry, avoiding unnecessary duplication, streamlining processes, etc.

The inspectors found the task force objective and goals to be appropriate. However, the task force charter and the job to be done a appears to be very large. Initially task force identified action

items missed their deadlines due to insufficient task force resources and/or unrealistic deadlines. The inspectors believe that the task force actions can be expedited through a variety of mechanisms such as

i spinning off subtasks increasing resources to the task force j using a facilitator with a proven track record in this area j elevate level of responsibility in task force leadership i

The inspectors believe the licensee should continue to evaluate practices at other plants identifying those which could improve organization performance, yet be compatible with Perry practice . Licensee's LER Trend Report Review (92720)

, The inspectors performed a review of the licensee's second and third quarterly trend reports covering the time periods of January 1,1986, through June 30, 1986, and July 1, 1986, through August 30, 1986,

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respectively. In addition, the inspectors reviewed the licensee's 1 monthly trend report for the month of October. The trend reports provided analyses of reportable events that had occurred during the i period covered by the reports. The LER's were evaluated in the areas of

, Equipment Malfunctions, Program / Procedural Deficiencies, and Personnel i Errors. After categorizing the LER's in the above areas, the reports j discussed the events and provided specific recommendations to the j applicable site organizations. The reports requested that the applicable l organizations respond in writing to the recommendations within specified time frames.

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1 The inspectors requested copies of the various organizations responses

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to the recommendations to determine the site acceptance of the LER Trend

Report recommendations and the degree to which the analyses were aiding in managements approach to addressing these events. The inspectors were given a status of the recommendations provided in the trend reports, but were informed that written responses were not always provided by the organizations that were requested to take action. A review of the status of the recommendations and discussions with the licensee's staff indicated that the applicable licensee organizations are taking actions on the recommendations. When the inspectors brought the concern about lack of formal responses to trend report recommendations to the attention

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of the licensee's management, the inspectors were informed that responses will be changed from a request to a requirement.

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Generally, the LER Trend Reports were found by the inspectors to be well written and a useful tool in identifying adverse trends in licensee

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performance. Site organizations, though not always responding formally to trend report recommendations, appeared to be taking corrective actions to address the identified adverse trend I

Review of Licensee's Lessons Learned Program as it Relates to Other Plants Events (92720) (61725)

During the oversight team preinspection review of Perry LERs, it became apparent that many of the reportable events were similar to events that have occurred at other nuclear power plants. During the entrance presentation, the licensee described its program for obtaining and i reviewing lessons learned from events that have occurred elsewher This program included, among other things, a formal exchange of LERs with other BWR facilities, review of INP0 reports, IE Bulletins and other

sources of information, and formation of task forces to pursue generic problems and corrective actions using input from other facilitie Indepth inspection of this area revealed that the licensee's review of outside information from a technical standpoint appeared to be adequat That is, events where being reviewed by management and the technical staff for applicability and follow-through. However, when questioning plant operators and technicians about specific events at other facilities, they were generally unaware of the events specifically or generically until the same type of event occurred at the Perry sit When asking the same type questions of management and Perry technical

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staff, the individuals were found to have been aware of the problems at other facilities and attempting to find solutions to the problems applicable to Perry (but not always successfully). To enhance the effectiveness of lessons learned from other plants events, the inspectors believe that licensee management should better inform its operators and technicians of events that have occurred elsewhere, particularly events that are related to personnel error and/or equipment that is similar to

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equipment found at Perry.

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i In addition to reviewing the licensee's lessons learned program, an ( indepth review of the licensee's Instrumentation and Control (I&C)

Program Task Force was conducted by the inspectors to further evaluate the licensee's approach to reducing LER's, particularly those that are occurring throughout the industry, and determining good corrective actions to existing problem areas. The task force consists of a multi-discipline group of people whose plan of action includes performing a three phase study to identify and analyze the root cause of I&C events and improve performance of Perry in the I&C area. The three phases of the study are: Top level survey of Industry, INP0, and NRC experience to identify root causes of I&C event I Indepth survey of recant INP0 and NRC documented events at vintage BWRs, to identify good practices, pitfalls, et (lessonslearned).

III. Application of lessons learned to Perry plan Phase I was completed by a CEI contractor, IMPELL. Phase II which is also being carried out by IMPELL, is currently underwa The inspectors concluded from review of this task force that the licensee is embarking on a good long term study of I&C problems. However, CEI is currently experiencing I&C problems and is in need of a short term make-well effort as well as the long term program. The inspectors did recognize that the licensee's efforts in the I&C area, that began in May 1985, have factored in some industry experience and resulted in some immediate corrective actions, yet still nay not have addressed certain other areas identified from other facilities experience . Assessment of Specific LERs (61725) (62700) (92700) (41701)

Prior to the start of the on site inspection, the licensee's LER's (LERs86-001 through 86-064) were sorted into the four broad categories of:

I&C, Mechanical, Electrical, and LERs primarily attributed to procedural, administrative, or operator errors. The inspection team was in turn divided into four groups af two inspectors each and performed a detailed review of the LERs in their respcctive category. This review included the identification of advei e trends in licensee perfonnance, major and minor event classification, and completeness of the LERs. In addition, the inspectors reviewed the licensee's quarterly trend reports to determine if the licensee's analyses were adequately identifying adverse trend During the onsite inspection, the inspectors performed indepth reviews of several LERs and 10 CFR 50.72 notifications in their respective categories to determine if the events were properly documented and the root cause and corrective actions were appropriate and comprehensiv The inspection included interviewing key individuals, reviewing procedures and hardware if applicable, and reviewing supportive documentation including the licensee's corrective actions taken to

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reduce the possibility of recurrence. The following are observations made by the inspectors during their onsite review of plant events: Licensee 10 CFR 50.72 notifications 4098, 4482, 5117, 5218, 5245, 5358, 5432, and 5440 involved lifting of leads or installation of jumpers for periodic surveillance Such actions are prohibited by Regulatory Guide (RG) 1.118 " Periodic Testing of Electrical Power and Protection Systems". The licensee, in FSAR Sections 7.1 and 8.1, committed to RG 1.118 without exception. Therefore, the inspectors undertook an examination of the plant licensing bases, FSAR requirements, the staffs SER, and plant procedures in this regar The inspectors found that Perry FSAR Chapter 1 (Amendment 21) took exception to the position on use of jumpers, lifted leads et required by RG 1.118. In addition, in a letter to NRR, dated August 20, 1985, the licensee identified and discussed the exceptions to RG 1.118. This matter was reviewed by the staff and the staff acceptance was documented in Section 7 of SSER The inspectors audit of the plant test and maintenance procedures indicated that the administrative controls identified in the August 20, 1985, letter were being implemente In addition, the licensee is in the process of installing some test switches where operating experience has shown that the use of jumpers and lifted leads was not practical. Also, terminal boards are being modified to permit jumpers to be more easily and securely installe However, due to the inconsistency between Perry FSAR chapters 1, 7, and 8, the licensee committed to revise Sections 7.1 and 8.1, to reflect the exception to RG 1.118 identified in Chapter 1 of the FSAR, during its next annual FSAR updat The inspectors also reviewed the impact of jumpers, lifted leads, and removed fuses on the indication of bypassed and inoperable system / equipment statu Perry test procedures require that the Unit Supervisor sign off on test steps that disable systems and the inspectors noted that most systems had a manual switch mounted

) on the control bench board for the purpose of initiating a

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bypassed and inoperable status indication. These switches were observed to be in use, i Operating experience at many plants have identified situations in

! which the provisions of Technical Specification 3.0.3 were violated because different tests, by different individuals, were run on redundant trains at the same time. Therefore, the inspectors i reviewed the administrative controls used at Perry to reduce the

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likelihood of similar occurrence The licensee's first control is that only odd numbered divisions

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may be tested on odd numbered days and only even numbered systems may be tested on even numbered days. Thus Division 2 may not be I tested when Division 1 or 3 is in test.

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To prevent entry into Technical Specification (TS) 3.0.3 when testing Division 1 and 3, the plant uses an LC0 tracking procedure that requires the Unit Supervisor to make a confirmation (either a positive or a negative declaration) as to TS 3.0.3 and 3. impact before entering an LCO. In addition, potential LCOs (a condition that would cause the plant to enter an LC0 in a different operating mode) are also tracked. This procedure, in conjunction with the annunciation capability mandated by Regulatory Guide 1.47 (committed to in Perry FSAR Table 7.1), provides reasonable control of situations that may result in entry to TS 3. c. Resolution of the Nuclear Instrumentation Noise problems as identified in LER 86-001 and 86-006 raised questions in the inspectors view as to the completeness of the licensee's corrective action. Therefore, the inspectors interviewed licensee personnel and discovered that the licensee has a long tenn project to reduce electronic noise that, in addition to the ground system revisions identified in LER 86-001 and 86-006, includes additional shielding l and identification and elimination of noise sources by circuit i modifications. The inspectors concluded that the licensee has a responsive program for the reduction in nois ,

d. During the review, and subsequent interviews with plant operators, of LER 86-055 " Isolated Instrument Results in Pressure Transient and Reactor Scram", the inspector determined that the operators at the controls during the event did not have simulator training that accurately duplicated the nonlinear response of the steam bypass and pressure regulating syste Beceuse of the concerns raised about the adequacy of operator training, the insp.:ctors audited the training program as it affects simulator differences from actual plant design and performance, changes in training and simulator design to match plant modifications, and verification of the adequacy of the simulator in representing actual plant respons From this review, the inspectors determined that several distinct but related programs are in place to address concerns such as those expressed above. These programs include plant operator feedback of differences between simulator and actual plant response (the simulator instructors also stand an eight hour plant watch every month), training department review of all BWR LERs, IE Bulletins and Notices, and participation in Industry sponsored forums. In addition, the licensee is seeking INP0 certification of their simulator progra The inspectors concluded that the licensee has an acceptable program for keeping the simulator up to date so that it adequately represents the response of the Perry Plant and is a useful tool for operator trainin _ _ _ _ _ _ _ _ _

. During review of LER 86-051 " Failure to Document Design Change Results in RHR Valve Inoperabilities", the inspectors questioned plant staff as to how a determination was made that the event was considered to be an isolated occurrence. The licensee had stated this in the LER without providing justification. The licensee produced Action Request (AR) 0104, dated August 19, 1986, which documented the performance of a design verification review that adequately supported the licensee's conclusion that the event was isolate In general, the licensee's LERs were found to be well written, and identified appropriate root cause and corrective actions. However, during the inspectors review of licensee's followup to corrective actions, the inspectors noted long lead times between the identification and implementation of corrective actions. These lead times have resulted, in some cases, in events recurring prior to the implementation of the identified corrective actions. Trend reports appeared to have identified significant adverse trends (see Section 4 of this report) and proposed helpful recommendations to prevent recurrence . Summary of Observations and Conclusions (71707)

The licensee's reportability program for plant events was found to meet regulatory requirements and have the necessary ingredients to reduce the frequency of events and assure safe operation of the plant. The licensee has exhibited a low threshold for reporting 10 CFR 50.72 and 50.73 events and was found to adequately analyze the events for determination of root cause and appropriate corrective actions. The licensee's LER Trend Reports were found to be a useful tool, designed to identify positive and negative trends and provide helpful recommendations for management to use to correct plant deficiencie Interviews with plant staff, including management, technical, and operations personnel, and observations of a shif t turnover and performance of plant testing, revealed that upper management is actively involved in resolving plant events, and plant staff is knowledgeable of plant procedures and equipment and conducted themselves in a professional manner. During the conduct of the inspection, the following observations for improvements in the licensee's LER program were identified: The licensee should continue to work toward streamlining / simplifying the process for identifying, documenting, and tracking events from inception to final resolution, The licensee should consider taking steps to expedite the action items identified by the Work Review Task Forc The licensee should assure that timely written responses to LER Trend Report recommendations are forthcoming from the applicable organization The licensee should develop a program that assures that operators and technicians are better informed of events that have occurred

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elsewhere, particularly events that are related to personnel error and/or equipment problems that are similar to equipment or conditions found at Perry. Emphases should also be placed on assuring that operators are trained on what they should expect to see during the initial plant startup when considering events that have occurred at other recently licensed BWR plants during initial startu The licensee should expand the scope of the I&C Task Force to include identifying more short term solutions to plant I&C problem Management should review Perry corrective actions for reportable events to see if the current lead time for implementing these corrective actions could be reduced or interim actions taken to reduce the likelihood of recurrenc The inspectors believe these improvements could enhance the licensee's ability to reduce reportable events and/or correct identified deficiencies to help assure safe operation of the plant. Further review in this area will be tracked as an open item (440/86027-02(DRP)).

8. Open Inspection Items Open 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 3 and . Exit Interviews (30703)

The inspectors met with the licensee representatives denoted in Paragraph 1 throughout the inspection period and during the exit held on November 7, 1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature,

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