IR 05000440/1989021

Safety Insp Rept 50-440/89-21 on 890731-0911.No Violations Noted.Major Areas Inspected:Startup Testing Activities Subsequent to Initial Refuel Outage,Including Core Performance & Reactor Engineering

ML20247F999
Person / Time
Site:	Perry
Issue date:	09/13/1989
From:	Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247F978	List: IR 05000440/1989021 ML20247F975
References
50-440-89-21, NUDOCS 8909180338
Download: ML20247F999 (5)

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U.S. NUCLEAR REGULATORY COW 4ISSION L

REGION III

Report No. 50-440/89021(DRS)

Docket No. 50-440 License No. NPF-58 Licensee: The Cleveland Electric Illuminating Company 10 Center Road Perry, OM 44081 Facility Name: Perry Site Inspection At: Perry, OH Inspection Conducted: July 31 through September 11, 1969 GwK CG h l/

Inspector: Pegg R. Re'sc eske Date

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Approved By: oteP['Pillips, Chief Operational Programs Section Date Inspection Summary Inspection on July 31 through September 11, 1989 (Report NO. 50-440/89021(DRS)

Areas inspected: Routine, unannounced, safety inspection of startup testing activities subsequent to the initial refuel outage, specifically in the areas of core performance and reactor engineering (IP 61702, 61705, 61706, 61707, and 72700).

Results: No violations were identified during this inspection. Although not

. considered to be a negative observation, the inspector noted that the licensee's methodology in several procedures differed from comon industry practice. No significant safety concerns were identified, and the methodology used by the licensee was determined to be generally conservative. The results of the startup and surveillance testing reviewed by the inspector satisfied the Technical Specification f,[f[f,$$bkbbb 0

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DETAILS Persons Contacted S. F. Kensicki, Director, Perry Plant Technical Department (PPTD)

E. M. Root, Manager, PPTD, Operations Support Section (OSS)

K. P. Donovan, Reactor Engineering Unit Lead, PPTD, OSS R. M. Siffler, Shift Supervisor, Operations G. R. Dunn, Supervisor, Compliance U.S. NRC P. L.:Hi'eand, Senior Resident Inspector Perry Plant All of the above persons attended the exit meeting held on August 16, 1989. Other persons were contacted during the course of the inspection, including members of the licensee's operations and reactor engineering staf . Startup Testing and Surveillance The inspection activities focused on specific startup tests and surveillance conducted by the licensee subsequent to the initial refuel outage. The inspector verified through review and discussions that licensee procedures, their implementation, and completed tests, satisfied Technical Specification (TS) Sections 3/4.1, 3/4.2, and 3/4.3. These TS sections dealt with the requirements for reactivity control systems, power distribution limits, and nuclear instrumentation. The following tests and surveillance were reviewed by the inspector and determined to be adequate. Although not considered to be a negative observation, the inspector noted that some procedures were written in a more complex form than necessary to satisfy the requirements, and that common-industry methodology was not always implemented, SVI-B13-T0001, "Insequence Critical Shutdown Margin Calculation,"

provided the method to demonstrate that sufficient shutdown margin l (SDM) existed during the operating cycle, and to satify TS surveillance requirement 4.1.1.a. The test was completed on July 24, 1939, with i insequence control rod withdrawals during the approach to initial

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criticality. The SDM was calculated using' data from the Cycle Management Report provided by the fuel vendor, General Electric Company (GE). The procedure also satisfied TS requirement 4.1. by verifying that a reactivity anomaly did not exist during the first startup following core alteration FTI-A09, " Estimated Critical Prediction," provided guidance for predicting an estimated critical position (ECP) prior to reactor startups. The inspector noted that the licensee relied on engineering judgement to predict the ECP, rather than performing

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i-calculations using control rod notch corrections for-parameters.such j as, moderation temperature, xenon..and core exposure. The inspector .!

reviewed a number of completed ECPs for current and past startups,  !

and determined-that the licensee's predictions were generally accurate and conservativ SVI-B13-T0004, " Reactivity Anomaly Calculation During Mode 1," l provided a method to check for possible reactivity anomalies as the

. core reactivity changed with exposure. The procedure is required to be performed every 1000 Megawatt days (MWD) during power operatio l in accordance with TS 4.1. The reactivity anomaly curve- ]

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provided by GE is used for the verification. The inspector reviewed the procedure and determined that it was adequate. The licensee had not yet performed this procedure by_the end of the inspection perio PRI-TSR, " Technical Specification Rounds," documented the performance )

of TS surveillance. During power operation (greater than 25% core thermal power (CTP)), power distribution limits are monitored and the results documented-(shiftly) using the round sheets. . The thermal  ;

limits are required to be monitored at least daily and verified to satisfy the requirements in TS Sections 3/4.2.1, 3/4.2.2, and 3/4. The inspector reviewed the surveillance completed on August 7-15, 1989, and verified that the results satisfied the acceptance criteri FTI-B05, " Core Heat Balance," provided methods for calculating CTP from a reactor heat balance. Different sources for data collection were available which included computer points and instrument readings. On August 15, 1989, the inspector performed a heat balance calculation using the available instrument readings and the licensee's procedure. The resalt (100% CTP) was in good agreement with the APRM readings and the process computer. The data collection and calculations were performed using fo.m PNPP No. 8348. The inspector observed that the form was confusing to use and also contained typographical errors. The calculational method was that used in the process computer OD-3 program, rather than the simple and more commonly used method of subtracting the calculated total energy in from the energy out. The licensee's method was complex when performed manually; however, a computer program existed which was routinely used to perform the calculations. A revision to the procedure was in draft to correct the typographical and format error SVI-C11-TI006, " Control Rod Maximum Scram Insertion Time," was used to determine the scram times of individual control rods and satisfy TS 4.1.3.2. All rods were satisfactorily tested prior to 40% CTP, utilizing computer generated records of reactor scram data and individual rod scram timin _____---__ _- - - . i

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g._ SVI-C51-T5351, "LPRM Calibration " provided the method for calibrating the Local Power Range Monitors (LPRMs) using the process computer OD-1 and the Traversing In-Core Probe (TIP) System. TS Table 4.3.1.1-1, Note f, required a calibration every 1000 MWD. The TIP system must be operable in accordance with TS 3.3.7.7. During startup from a_ refuel outage, TIP operability and LPRM calibrations are generally performed at a mid-power (40-50% CTP) and again at 100% CTP. The licensee completed the first LPRM calibration on August 7, 1989, at about 40% CTP. Eight LPRM gain adjustment factors (GAFs) were outside the desired band for GAFs after the calibratio A common industry practice for this condition is to either bypass the LPRM or perform a recalibration using OD-2 (specified LPRM calibration). The licensee believed that their TS did not allow the use of an OD-2, and therefore this method was not used. The inspector disagreed.with the licensee's interpretation of the TS, since the associated TS are the same at other BWR plants where the use of OD-2 is proceduralized and routinely used. When LPRM GAFs are outside-the desired band, the licensee, does not, in general, consider the LPRM inoperable. According to the licensee the process computer and the APRM calibration correct for any GAF variations. The inspector believes that minor GAF variations would be corrected for; however, large errors in many LPRM GAFs would effect the APRMs,-especially since the licensee does not routinely adjust the APRM readings to read higher than actual CT On August 11, 1989, during an 0D-1, the licensee experienced problems with the TIP system. TIP machine B was not able to traverse index Troubleshooting identified problems with other indexes, including the common channel, index 10. According to TS, all five TIP machines must be operable when used for LPRM calibrations. The TS does not allow for the use of substitute values which are based on core symmetry. The problems with the TIP machine did not permit a LPRM calibration to be performed at 100% CTP. Furthermore, the problems may not be able to be corrected by the time a LPRM calibration is required by TS. Therefore, the licensee plans to request a TS change to allow more flexibility in TIP system operability, and the use of substitute values, similar to the TS amendments issued February 10, 1988, for LaSalle Units 1 and SVI-C51-T0024, "APRM Gain and Channel Calibration," in part provided the instructions for adjustment of the Average Power Range Monitors (APRMs) during power operation. TS Table 4.3.1.1-1 Item 2, requires the APRMs to be adjusted weekly when above 25% CTP, to within 2% of the heat balance. The licensee's administrative requirements state that an APRM will be adjusted when the as-found reading is greater than 1% different from the heat balance. The inspector reviewed a number of APRM adjustments completed during August 7-11, 1989. On August 11, 1969, with the reactor at 100%

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.CTP,'APRM G was left at.98%, in violation of the licensee's 'l administrative requirements; APRM F was left at 99%, with all other

' APPJis -left or adjusted to .100%. ..In discussions (teleconference) on September-11,.1989, and in-transmitted correspondence (dated i September 8, 1989), the licensee stated that the 1% requirement was' '

to guard against incorrect operator roundoff (i.e., 2.5 rounded to 2.0)'during the weekly surveillance. 'Since the example in question was not the weekly surveillance, but rather a routine adjustment, the APRM was not calibrated. The licensee further stated that the incident was noted during the surveillance review and determined to be of no consequence since the roundoff had been done correctly and no.TS limits were exceeded. Based on the licensee's and inspector's review of other completed surveillance, this example appears to,be an isolated case. .The licensee plans to revise the procedure to delete reference to the 1% requirement, leaving the 2% TS requirement for the adjustment criteria. In addition, the licensee plens to add guidance on rounding off (i.e., 2.1 will not be rounded off to 2.0, and the AFRM will be adjusted).

With regards to APEN calibrations, the inspector further noted that acommonindustrygrxt/,ceistoattempttoadjusttheAPRMstoat or above the actua4 C A although this practice is not generally proceduralized. The itensee stated that their practice was to attempt to adjust the APRM to the actual CTP (heat balance), and if the as-left value happened to be less than actual CTP, the APRM would not be readjusted if the reading met the TS requiremen No violations were identified. The inspector discussed all observations, with the licensee, and determined that no significant safety concerns existe . Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1)-

on August.16, 1989, and summarized the scope and findings of the inspectio The licensee acknowledged the statements made by the inspector, and did not identify any information which may appear in the inspection report as proprietary. A final exit meeting was held on September 11, 1989, via teleconference, to discuss licensee action in response to inspector concerns regarding AFEM calibration _ - _ _ _ _ - _ _ -