ML20247G934

Insp Rept 50-440/89-22 on 890807-23.Violations Noted.Major Areas Inspected:Licensee Response to Diagnostic Evaluation Team Rept of Facility,Dtd May 1989

ML20247G934
Person / Time
Site:	Perry
Issue date:	09/07/1989
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247G927	List: ML20247G921 ML20247G929 ML20247G934
References
50-440-89-22, NUDOCS 8909190171
Download: ML20247G934 (10)

See also: IR 05000440/1989022

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/89022(DRP)

Docket No. 50-440 License No. NPF-58

Licensee: Ci reland Electric Illuminating Company

Post Office Box 5000

Cleveland, OH 44101

Facility Name: Perry Nuclear Power Plant, Unit 1

Inspection At: Perry Site, Perry, Ohio

Inspection Conducted: August 7-23, 1989

Inspector: P. L. Hiland

Approved By: M. A. Ring, Chief

Reactor Projects Secti n 3B

W f!7/77 '

/ Date

Inspection Summary

Inspection on August 7-23,1989 (Report No. 50-440/89022(DRP))

Areas Inspected: Routine, unannounced safety inspection by the senior resident

inspector of licensee response to the Diagnostic Evaluation Team Report of the

Perry Nuclear Power Plant dated May 1989. The inspection performed consisted

of reviewing the licensee's response to the DET report which was provided in

letter PY-CEI/NRR-1043L, dated July 29, 1989.

Results: Of the area inspected, three violations were identified. The first

concerned the licensee's failure to take corrective action for a previous

violation involving control of unit staff overtime (paragraph 2.c). The second

violation concerned the licensee's failure to control manual thrcttle valve

positions (paragraph 2.g). The third violation concerned inadequate performance

of a surveillance instruction (paragraph 2.0).

Three unresolved Items were identified that require additional review to

determine if a violation existed (paragraphs 2.k, 2.n, and 2.p). Fifteen

Open Items were identified, one of which (paragraph 2.t) required an additional

response from the licensee. These open items were initiated to followup the

licensee's actions as stated in their response to the DET report.

All of the above items were receiving management attention; however, the

violation resulting from failure to control unit staff overtime is a repetitive

violation for which the licensee's previous corrective action was ineffective.

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l. DETAILS

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1. Persons Contacted

a. Cleveland Electric Illuminating Company (CEI)

• G. Dunn, Compliance Engineer (NSD)

• M. Gmyrek, Manager, Operations Section (PPOD)

*R. Newkirk, Manager, Licensing and Compliance Section (LCS)

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• K. Pech, Manager, Technical Section (PPTD)

• F. Stead, Director, Nuclear Support Department (NSD)

b. U.S. Nuclear Regulatory Commission

• P. Hiland, Senior Resident Inspector, RIII

• Denotes those attending the exit meeting held on August 23, 1989.

2. Followup of Licensee Response to DET Report For Perry Nuclear Power Plant

(92701, 92700)

By letter dated May 30, 1989, the Executive Director for Operations,

Mr. Victor Stello, Jr., forwarded the Diagnostic Evaluation Team (DET)

Report for the Perry Nuclear Power Plant to the licensee. That letter

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requested the licensee to evaluate the report and provide a written

response. Letter PY-CEI/NRR-1043L, dated July 29, 1989, provided the

licensee's evaluation and response to the DET report. During this

report period, the inspector reviewed the licensee's response and

identified the following items:

a. Equipment Problem Resolution

As detailed in Sections 3.1.2, 3.2.5, and 3.6.2 of the DET inspection

report, a number of equipment problems were identified during the

licensee's first operating cycle. The licensee responded to that

issue by detailing the number of work items and design changes that

had been completed during the first operating cycle and during the

first refueling outage. The licensee stated that utilization of their

quarterly maintenance schedule would serve to maintain the backlog of

corrective maintenance items low.

The inspectors will monitor the licensee's performance to adequately

resolve equipment problems in accordance with their quarterly

maintenance schedule. This item will be tracked as an Open Item

(440/89022-01(DRP)).

b. Human Relations / Personnel Performance

As detailed in Sections 3.1.7 and 3.1.8 of the DET inspection report,

several issues were considered to have had a negative influence en

personnel perfortnance. The licensee responded to this issue by

stating the actions that had been tsken and were planned to be taken

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to improve personnel performance. Those actions included a review of

job descriptions, supervisory training, development of a career

opportunities progran, and creation of a Human Resource Council.

The inspectors will review the actions taken by the licensee to

l improve human relations as an Open Item (440/89022-02(DRP)).

c. Operator Overtime

As detailed in Section 3.2.2 of the DET inspection report, licensee

management oversight of operator overtime was ineffective. A licensee

audit identified nine instances where overtime guidelines had been

exceeded without prior approval. The licensee's failure to comply

with Plant Administrative Procedure (PAP)-0110, " Shift Staffing and

Overtime," was the subject of a Notice of Violation (440/88012-02(DRP))

issued following an Operational Safety Team Inspection (OSTI)

conducted in March 1988. In addition, the inspectors noted through

review of Action Request 0002 (Audit No. 89-12), dated July 13, 1989,

additional instances of failure to comply with PAP-0110. The licensee

responded to Notice of Violation 440/88012-02 via letter

PY-CEI/NRR-0926L dated October 19, 1988. In that response the

licensee identified the cause for the violation to be personnel error

and the corrective action to prevent recurrence was to remind

supervisors of their responsibility to implement the requirements of

PAP-0110. 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action,"

requires in part that measures shall be established to assure

conditions adverse to quality are promptly identified and corrected.

Failure of the licensee to correct the deficiencies identified in

the control of unit staff personnel overtime is a Violation

(440/89022-03(DRP)).

d. Operator Aids

As detailed in Section 3.2.2 of the DET inspection report, control

of " operator aids" was found to be ineffective. The licensee's

response stated that the specific items discussed in the DET report

were corrected. In addition, the licensee stated that a walkdown of

all in plant control panels would be completed by December 31, 1989.

The inspectors will review the results of that walkdown and perform

independent plant walkdowns to confirm the adequacy of the ~

licensee's actions as an Open Item (440/89022-04(DRP)).

e. Performance Standards of Nonlicensed Operators

As detailed in Sections 3.2.2 and 3.2.8 of the DET inspection report, i

adequate performance standards for non-licensed operators were not  ;

established. The licensee responded to this item by providing a j

seven point Action Plan that was to address the adequacy of '

performance standards for non-licensed operators by September 1989.

The inspectors will review the actions taken by the licensee to

improve performance standards of non-licensed operators as an Open

Item (440/89022-05(DRP)). 1

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f. Emergency Instructions

As detailed in Sections 3.2.2 and 3.2.4 of the DET inspection report,

the Perry Emergency Instructions were considered difficult to use.

The licensee's response to this item stated that improvements to the

Perry Emergency procedure format were ongoing and that additional

" Human Factor" improvements would be evaluated during incorporation of

the latest revision to the Emergency Procedure Guidelines scheduled

for July 1990. The inspectors will review the licensee's evaluation

of " Human Factors" after incorporation of the latest revision to the

Emergency Procedures Guidelines in July 1990 as an Open Item

(440/89022-06(DRP)).

g. Manual Throttle Valve Positioning

As detailed in Section 3.2.3 of the DET inspection report, the

administrative control of manual throttle valve positioning was

inadequate. 10 CFR 50, Appendix B, Criterion V, requires in part

that activities affecting quality shall be prescribed by documented

instructions. Failure of the licensee to provide adequate instructions

to assure throttle valves in the Emergency Closed Cooling, Essential

Service Water, and Residual Heat Removal systems were restored te

their required throttled position following performance of a

surveillance or test is a Violation (440/89022-07(DRP)). The

licensee's response to this item stated that a locked throttle valve

program was implemented and that system valve lineups were revised to

identify locked throttle valves. In addition, the licensee was to

review all Surveillance Instructions (SVIs) to verify that system

restoration lineups reflected the correct position of manual throttle

valves. The inspectors were informed by the licensee that review of

SVIs was to be completed by December 31, 1989.

The corrective actions noted above and detailed in the licensee's

response to the DET inspection report were adequate to address the

subject violation of 10 CFR 50, Appendix B, Criterion V, and a

further response is not required. However, this item will remain

open pending the inspector's review of completed corrective actions.

h. Implementation of Corrective Actions

As detailed in Section 3.2.8 of the DET inspection report, not all

of the licensee's recommended corrective actions following a 1988

"special evaluation" were implemented. The licensee's response

stated that a re-evaluation of their recommended corrective actions

from that "special evaluation" would be performed and any new items

would be implemented by December 31, 1989. The subject of the

licensee's re-evaluatice ind implementation of any additional

corrective actions to their "special evaluation" is considered an

Open Item (440/89022-08(DRf)) pending the inspector review of

completed licensee action.

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i. Manual Valve Testing and Preventive Maintenance

As detailed in Sections 3.3.3 and 3.4.1 of the DET inspection report,

several manual valves which provided an accident mitigation function,

were not tested nor were adequate preventive maintenance requirements

imposed. The licensee's response stated that a review of their

manual valve preventive maintenance program was performed. The

results of that review were to be entered into the licensee's scope

for preventive maintenance activities. In addition, the licensee

stated that manual valves manipulated within the Plant Emergency

Instructions were incorporated into their Pump and Valve Inservice

Testing Program Plan. The subject of testing and performance of

preventive maintenance on manual valves is considered an Open Item

(440/89022-09(CRD)) pending the inspector's review of the licensee's

completed actt'a,

j. Equipment Tret< Enalysis

As detailed in Section 3.3.6 of the DET inspection report, the

effectiveness of equipment trend analysis based on maintenance

history was diminished due to incomplete maintenance history records.

The licensee's response stated that their reliability information

tracking system (RITS) would improve equipment trending. The RITS

program was to be operational during the fourth quarter of 1989. The

subject of equipment trend analysis is considered an Open Item

(440/89022-10(DRP)) pending the inspector's review of the

implementation of the RITS.

k. Post Maintenance Testing of SLC System

As detailed in Section 3.3.' of the DET inspection report, the post

maintenance test of Standby Liquid Control (SLC) system valve F001A

was inadequate. The licensee's response stated that adequate

administrative controls existed to assure the proper review of post

maintenance testing prior to returning the SLC system to service.

The subject of adequate post maintenance testing on SLC valve F001A

is considered an Unresolved Item (440/89022-11(DRP)) pending the

inspector's review of the administrative controls that were in place.

1. Check Valve Testing

As detailed in Section 3.4.1 of the DET inspection report, closure

testing of various check valves was not specified by current

administrative procedures. The licensee's response stated that

their Inservice Test Program (as noted by the DET) was undergoing

revision at the time of the DET inspection. The revised test program

added additional requirements to 189 check valves. However, the

inspectors noted that check valve E51-F011 was not required to be

tested for Alternate Position Verification (AP). The subject of

check valve E51-F011 not required to be AP tested is considered an

Open Item (440/89022-12(DRP)) pending the inspector's review of the

licensee's testing criteria.

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m. ' Guidance on Erratic or Abnormal Valve Actions

As detailed in Section 3.4.1 of the DET inspection . report, no written

guidance or criteria existed'for identifying erratic or abnormal

valve action. The licensee's response to this item incorporated a

note in their IST Administrative procedure to_ notify the Lead ISI

Engineer of erratic or abnormal valve operation. However, it was' not

clear to the inspectors that adequate and specific criteria had been

established. The subject of guidance on Erratic or Abnormal Valve

Actions during testing is considered an Open Item (440/89022-13(DRP))

pending the inspector's review of the licensee's implementation of-

the revised guidance.

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n. Pump Test Criteria

As detailed in Section 3.4.1 of the DET inspection report, the

licensee revised ESW pump test criteria less conservative than

required by ASME Section.XI. The licensee's response stated that

revised pump test criteria were performed under.a formal documented

program as permitted by ASME Code Interpretation XI-1-79-19. ..However,

the inspectors were not provided with adequate technical justification

to revise pump test criteria. The subject of revising pump test

criteria based on an adequate and documented basis is considered an

Unresolved Item (440/89022-14(DRP)) pending the inspector's further

review of the licensee's documented basis for revising pump test

criteria.

o. Inadequate Surveillance Test

As detailed in Section 3.4.1 of the DET inspection report, position

indicator testing required for vacuum breaker valves '1M16-F020A and

' F020B was not performed properly on February 20, 1989. The licensee's

response stated that the test was correctly reperformed. 10 CFR 50,

Appendix B, Criterion'V, requires that activities affecting quality

shall be accomplished in accordance with instructions. Sailure of

the licensee to accomplish drywell vacuum breaker testing in

accordance with Surveillance Instruction (SVI)-M16-T2001 is a

Violation (440/89022-15(DRP)).

p. Vacuum Breaker Surveillance Test

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As detailed in Section 3.4.2 of the DET inspection report, the

inspectors concluded that Surveillance Instruction (SVI)-M16-T0414

was technically deficient. That surveillance instruction directed

that drywell vacuum breaker relief valves be opened first with their

power operators before relief settings were measured and verified.

Opening the drywell vacuum breakers prior to collecting "as-found"

data appeared to invalidate the test. The licensee's response to

this item stated that the "as-found" setpoint of the drywell vacuum

breakers was not adversely impacted by first opening the valves with

their power operators. The inspectors will review the licensee's

response with the staff to evaluate its acceptability. The subject

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. of adequate' testing of drywell ' vacuum breakers is considered an

Unresolved Item (440/89022-16(DRP)) pending further review of the

. licensee's response.

q. Work Package Rejection Rate

As detailed in Section 3.5.4 of the DET inspection report, the

inspectors concluded that the continued large. rejection rate in

7 final work packages was due.to a lack of management attention. The

inspectors will continue to monitor the licensee'sl action with regard

l to improving' final work order packages. The subject of final work

order package rejection rate is an Open Item (440/89022-17(DRP))

pending the. inspectors review of licensee actions.

r. Root Cause Analysis Program

As detailed in Sections 3.5.7 and 3.6.8 of the DET inspection report,

.the inspectors concluded that several weaknesses in the licensee's

root cause analysis program existed. The licensee's response to this

item detailed their initiatives to assure better root cause. analysis.

The subject of.the licensee's initiatives to improve their root cause

analysis program is considered an Open Item (440/89022-18(DRP))

pending the inspector's review of the effectiveness of implementing

those initiatives.

s. Independent Safety Engineering Group (ISEG)

As detailed in Section 3.5.8 of the DET inspection report, the

inspectors concluded that the ISEG had limited effectiveness due to

a lack of adequate management attention and support. The licensee's

response-to this item stated that a revised ISEG charter was developed

'to correct problems noted with management support of the ISEG. .The ,

licensee stated that their revised ISEG charter would be in place in J

1989. The subject of ISEG effectiveness is considered an Open Item

(440/89022-19(DRP)) pending the inspector's review of actions taken

by the. licensee.

t. Contractor Support

As detailed in Section 3.6.1.3 of the DET inspection report, the

inspectors expressed a concern that, since selected areas in the

Nuclear Engineering and Plant Technical departments relied heavily

on contractor support, a rapid reduction .in contractor support could

adversely impact the licensee's ability to accomplish engineering

support tasks. The licensee's response to this item stated that a

five year plan was under development and that any reductions in

staffing size would be consistent with the goals of that five year

plan. The inspectors advised the licensee that their response to

this item was general in nature and did not explicitly discuss

actions that would be taken to minimize the impact of rapid contractor

support reduction. The inspectors requested and the licensee agreed

to provide an additional response to this item. The subject of

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contractor support is considered an Open Item (440/89022-20(DRP))

pending receipt and the inspector's review of the requested additional

information,

u. Design Change Packages

As detailed in Section 3.6.4.1 of the DET inspection report, the

inspectors estimated that about 500 Design Change Packages (DCPs)

would be outstanding at the beginning of the second cycle. The

inspectors noted that the licensee did not have a long range

implementation schedule to reduce the number of DCPs. The licensee's

response to this item stated that a DCP review committee had been

created and that priorities had been established on issued DCPs as

well as those under development. The licensee further stated that

the results of that effort would be factored into their'five year

plan scheduled to be issued in September 1989. The subject of DCP

implementation schedule is considered an Open Item (440/89022-21(DRP))

pending the inspectors review of the licensee's plan for implementation.

3. Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether it is an acceptable item, a violation or a

deviation. Three unresolved items were identified in Paragraphs 2.k.,

2.n., and 2.p.

4. 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. Fifteen

(15) open inspection items disclosed during the inspection are discussed

in Paragraph 2.

5. Exit Interviews (30703)

The inspectors met with the licensee representatives denoted in Paragraph 1

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throughout the inspection period and on August 23, 1989, The inspector

l 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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Inspection Report 50-440/89022

Appendix

OET Eval. OET RIII

Results Details Followup

Paragraph Paragraph Action Items

2.1.1.1 3.1 None

.2 3.1.2 01 89022-01

.3 3.1.3 None

.4 3.1.4 None

.5 3.1.5 (3.2.2) 01 89022-04

.6 3.1.5 None

.7 3.1.7 01 89022-02

.8 3.1.7 (3.1.8) OI 89022-02

2.1.2.1 3.2.2 NOV 89022-03

OI 89022-04

.2 3.2.2 (3.2.8) 01 89022-05

.3 3.2.2 None

.4 3.2.2 01 89022-04

.5 3.2.2 (3.2.4) OI 89022-06

.6 3.2.3 NOV 89022-07

.7 3.2.5 OI 89022-01

.8 3.2.6 None

.9 3.2.7 None -

.10 3.2.8 OI 89022-08

.11 3.2.9 None

2.1.3.1 3.3.1 None

.2 3.3.3 (3.4.1) 01 89022-09

.3 3.3.3 None

.4 3.3.4 None

.5 3.3.5 (3.6.5.3) None

.6 3.3.6 OI 89022-10

.7 3.3.7 UI 89022-11

2.1.4.1 3.4 None

.2 (1-6) 3.4.1 01 89022-12

01 89022-13

UI 89022-14

.3 (1-4) 3.4.1 NOV 89022-07

NOV 89022-15

.4 3.4.1 None

.5 3.4.1 None

.6 3.4.1 NOV 89022-15

.7 3.4.2 UI 89022-16

.8 3.4.3 None

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Inspection Report 50-440/89022

Appendix (Continued)

DET DET RIII

Eval. Details Followup

Paragraph Paragraph Action Items

2.1.5.1 3.5.1 None

.2 3.5.2 None

.3 3.5.3 None

.4 3.5.4 OI 89022-17

.5 3.5.5 None

.6 3.5.6 None

.7 3.5.7 01 89022-18

.8 3.5.8 OI 89022-19

.9 3.5.8 None

2.1.6.1 3.6 01 89022-18

.2 3.6.1 01 89022-20

.3 3.6.1 None

.4 3.6.1 None

.5 3.6.2 None

.6 3.6.2 OI 89022-01

.7 3.6.2 None

.8 3.6.2 None

.9 3.6.3 None

.10 3.6.4.1 OI 89022-21

.11 3.6.5 None

.12 3.6.6 (3.6.7) None

.13 3.6.8 OI 89022-18 -

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