IR 05000440/1987019

Safety Insp Rept 50-440/87-19 on 870831-0904.Violations & Deviations Noted.Major Areas Inspected:Electrical & Instrumentation Corrective & Preventive Maint Activities, Review & Followup of LERs & Training

ML20235U150
Person / Time
Site:	Perry
Issue date:	10/07/1987
From:	Falevits Z, Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235U100	List: IR 05000440/1987019 ML20235U097 ML20235U126 ML20235U135
References
50-440-87-19, NUDOCS 8710130385
Download: ML20235U150 (9)

Text

- - - - _ _ _ _ - - - _ _ _ _ _ _ . _ _ _ - - _ _ - . _ _ _ _ _

.

. .-

a

~

I U.S. NUCLEAR REGULATORY COMMISSION

REGION III

. Report No. 50-440/87019(DRS)

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

,

Licensee: Cleveland Electric Illuminating Company-Post Office Box.5000 C.leveland, OH 44101 Facility Name: Perry Nuclear Power Plants, Uni Inspection ~At: . Perry Site, Perry, Ohio Inspection Conducted: August 31 through September 4, 1987 Inspector:

kh h k.'Falevits l I ~)

,

'

Date

'

M Approved By: R. N. Gardner, Chief IDd'b Plant Systems Section Date Inspection Summary Inspection on August 31 through September 4, 1987 (Report No. 50-440/87019(DRS)) '

Areas Inspected: Routine, unannounced safety inspection of electrical and instrumentation corrective and preventive maintenance activities;. review and followup of Licensee Event Report's (LERs); review of Electrical Separation in RPS panels; and training (62704, 62705, 92700, 41400).

Results: Of the areas inspected, no violations or deviations were identifie in two areas. One violation with two examples (Paragraph-2.b - failure to i review outstanding and late Repetitive Tasks (Preventive Maintenance), and

'

Paragraph 4.a.(2) failure to ensure that monthly reviews of Lifted Leads, -;

Jumpers and Electrical Devices (LLTED) are performed) and one deviation >

(Paragraph 4.a.(1) - failure to adhere to a commitment made in correspondence with the NRC) were identified in the remaining areas.

l l

.

)

i Nk SDO k

I

l-N . . ..

. _ _ -

I i

.

i DETAILS Persons Contacted

'

Cleveland Electric Illuminating Company (CEI)

• C. M. Shuster, NED Manager-

• Lyster, Operations Manager

• L. Higaki, GSE/MMQS

• Green, GSE/EDS

• D. Walrath, GSE/EPSS

• Oleksiak, Jr., Lead Maintenance Supervisor

• Meinke, Lead I&C Supervisor

• P. Muffitt, Associate Operations Engineer

• R. Kanda, Jr., GSE Instrumentation and Control

• W. D. Browwlee, C71 RSE

• G. R. Anderson, Unit Lead Engineer S. Kensicki, Technical Superintendent L. Terchman, Maintenance Planning Supervisor D. J. Takacs, GS Maintenance Section R. DeVries, Lead I&C Planner R. A. Newkirk, GSE Technical

• S. Ferrell, Operations Engineer

• D. Dunn, Compliance Engineer

• Denotes the persons who attended the exit meeting on Septe....a r 4, 198 In addition to those listed above other licensee and contractor personnel were contacted during this inspectio . Review of Electrical and Instrumentation Corrective and Preventive Maintenance Activities The purpose of this inspection vas to ascertain whether corrective and preventive maintenance activities relative to electrical and instrumentation components and systems were conducted in accordance with licensee-approved procedures, instructions, and latest drawings; that maintenance activities were p?rformed by preplanned schedules and as required to maintain the unit its safe operating condition; and that the procedures, instructions, and drawings used met the requirements of technical specifications, regulatory guides and industry codes and standards committed to by the licanse The inspector attempted to observe selected safety-related electrical and instrumentation maintenance activities in progress, however, no such activities were schedules to be performed during this inspection perio Observation of a Functional Surveillance Test On September 2, 1987, the inspector observed a monthly channel functional surveillance test performed on the Scram Discharge

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

Volume Water Level High loop using instructions SVI-CII-T0245-B, Revision 2. The inspector verified that the activity was conducted in accordance'with approved procedures and by preplanned schedules; that administrative and operational personnel approvals for removing the loop from service and returning it to service were given; that provisions for ensuring that limiting conditions for operation (LCO) contained in the technical specifications were identified and satisfied during the test; that appropriate acceptance criteria,.such as performs sign off and verifies sign

'

off were contained in the test; that measurement and equipment identification numbers and calibration dates were used; and that !

qualified personnel performed the activity. The functional test )

was completed satisfactorily, no deficiencies or Jeviations were J observe b. Review of Maintenance Procedures, Work-Orders and Surveillance The. inspector reviewed the licensee's system used to plan and organize maintenance activities and to ensure that the work is done effectively and in compliance with all set requirement <

l

!

(1) Preventive Maintenance Preventive maintenance activities .t Perry are performed with Administrative Procedures and Instructions and are governed by Procedure PAP-0906, " Control of Maintenance Section Preventive Maintenance" and Procedure PAP-0903, " Repetitive Task Program."

The inspector selected a number of repetitive electrical task forms for review to determine if preventive maintenance activities on safety-related components are properly scheduled, performed and controlled; and that timely completion of all tasks is achieved before the task reaches its latest due dat The inspector conducted interviews with maintenance personnel of various seniority level Licensee personnel noted that the preventive maintenance program at Perry is designed to anticipate and prevent equipment failure and degradation, thereby, increase equipment life and its performance. During this review the inspector noted that numerous repetitive tasks went beyond the latest due date and the allotted grace period without being performed or reviewed for possible impact on safety. For example, repetitive task No. R85-003699 which required the performance of general maintenance on safety-related MCC EFIA07 specified a due date of September 5, 1986 and a latest due date of October 11, 1986 plus a grace period of ten percen Review of this item indicated that this task was transmitted by the planners to the maintenance department on September 4, 198 As of September 4, 1987, no action was taken to perform this task. j Further, Procedure PAP-0906, " Control of Maintenance Section t Preventive Maintenance" required in Section 6.62 that if a late 1

-

_-

.

.

.

task is safety related, the task form shall be sent to the appropriate PPTD responsible system engineer for review. The engineer shall review the reason for. rescheduling the task and, if agreeable, sign his name, badge number, date, and return the task form to the Maintenance Section Repetitive Task Planning Group. Furthermore, the procedure noted that the signature of the PPTD responsible system engineer indicates that he has been advised, is aware of the rescheduling of the task, and agrees with the reason for rescheduling and time frame. None of the above was carried out with respect to task No. Rd5-00369 Further examination of additional task forms indicated that the identified problem existed with the following two outstanding and late tasks: No. R85-000145, latest due date June 21, 1987 plus five percent grace period, (required that maintenance be performed on limitorque valve operator on Valve E12-F006A) and

.

No. R86-004208, latest due date May 14, 1987 plus ten percent grace period, (required that maintenance be performed on .

4.16KV ESF DIVI BUS EH11 breaker EH1106).

During discussions with the responsible PPTD engineer, the engineer stated that he had not reviewed the above late tasks for rescheduling purposes and that since he had not agreed to reschedule these tasks they should have been performed on tim The inspector was informed that the licensee had recentl completed an outage in which some of these overdue maintenance activities could have possibly been accomplishe The inspector noted that as of August 31, 1987, the total number of outstanding (late) mechanical and electrical tasks was 557. The inspector expressed the concern that preventive maintenance activities scheduled on safety-related components are permitted to become excessively late without the benefit of a review for safety significance and an analysis by engineering to determine if failure to perform the scheduled maintenance-in a timely manner would compromise the safe operation of the plan The NRC inspector informed the licensee that failure to conduct a review of late tasks as required by Procedure PAP-0906 is an example of a violation to the requirements of 10 CFR 50, Appendix B, Criterion V (440/87019-01A(DRS)).

(2) Corrective Maintenance Corrective maintenance activities at Perry are performed and .

controlled by administrative procedures such as PAP-0902 " Work Request System" and PAP-0905 " Work Order Process."

The form used to identify the need for corrective maintenance on systems, equipment or components is the Work Order which is generated by a Work Reques ,

-_

.

.

The inspector selected the following completed safety-related electrical and instrumentation Work Orders '90) for review:

W0 870007140 dated August 17, 1987 WO 870007292 dated August 22, 1987 WO 870007304 dated August 22, 1987 W0 870007395' dated August 26, 1987 ,

'

WO 870007145-dated August 18, 1987 WO 870007230 dated August 20, 1987 W0 870007285 dated August 21, 1987 WO 870007481 dated August 29, 1987 The review identified the following concerns:

• The QA inspection report in W0 870007285 contained check marks in both the accept and reject boxes under inspection j result The QA inspection checklist was marked unsatisfactory by Item 5 (materials used) and by Item 8 (work performed meets acceptance criteria).

The Troubleshooting Log specified that performance of I ICI-C-E51-1 to verify circuit operation is needed to correct the RCIC speed sensor problem.

i No documented evidence was available for reviews to indicate that the identified deviations or concerns noted l in the WO have been addressed and satisfactorily resolve * WO 870007145 - Troubleshooting Log stated "It appears piping runs are not sloped enough and a vacuum is put on low side when water drains." No documented evidence was available for review to indicate that this concern had been addressed.

l

! * W0 870007230 - Troubleshooting Log stated " computer point appears to be scaled for 0-6% vice 0-30%, (Steps 33-35).

Noted long system stabilization period when span selecte Long overshoot and s 30-45 minutes return time." No documented evidence was available for review to indicate that these concerns have been addresse The inspector informed the licensee that it is apparent that corrective actions to potential problems and concerns identified in the Work Orders were not documented in the work packages and it was not evident that they have been addressed and resolved in all case During the review of this issue and during interviews of licensee personnel, the inspector was informed I verbally that the noted concerns have been or will be addressed, f however, corrective actions for the concerns were not documented i or referenced in the WO package The inspector was informed

l

___

!

l

l

.

that during a previous inspection conducted by the NRC several weeks prior to this inspection, similar concerns were identified by another NRC inspector. This item is considered unresolved pending licensee action and NRC review (440/87019-02(DRS)).

I Review and Followup of Licensee Event Report i The inspector performed an onsite followup inspection of the LERs listed I below to determine whether the root causes of these events have been l correctly determined and whether the corrective action taken.was adequate l in correcting the problem and in preventing recurrence and meeting l

regulatory and industry requirements.

!

' (Closed) LER No. 87-042-00 (440/87042-LL): A Reactor Protection System, Electrical Protection Assembly (EPA) breaker tripped resulting in the unexpected closure of the outboard Main Steam Isolation Valves (MSIV) which resulted in a reactor scram. The licensee determined that the root cause for the breaker trip was a failed component of an EPA logic card. GE performed a failure analysis on the EPA logic card and concluded that the failure was random in natur The root cause of the MSIV closure and resultant scram was due to the design error of the power supplies- for the MSIV pilot valve .

solenoids. It was found that both the A and B solenoids for each outboard MSIV were powered from the same RPG bus (Bus A), and that the inboard MSIV solenoids were powered from RPS Bus B. Therefore, MSIV closure resulted when normal RPS power was lost to both solenoids on each outboard MSIV. The root cause of this error was the architect /engnieer Gilbert Commonwealth failure to incorporate a GE design change into site drawings and the licensee's failure to detect this error during testin The inspector reviewed licensee corrective action which included replacement of the EPA cards for the normal RPS B power supply.

I The power supply configuration to the inboard and outboard l MSIV solenoids was modified to preclude an MSIV isolation due to loss of a single RPS power suppl The inspector reviewed the associated design drawings and change documents and conducted a field inspection of the completed wor Corrective actions taken by the licensee appear to be adequat No deficiencies were noted. This LER is close (Closed) LER No. 87-043-00 (440/87043-LL): The standby train of the Annulus Exhaust Gas Treatment System (AEGTS) started automaticall The licensee determined the cause of this event to be instrument setpoint drift of the IM15-N061B low differential pressure switc c-- -_ __ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ --

_ _ _ - _ _ __

e

..

.

The' inspector reviewed Work Order 87005093 which was used to implement the corrective action which included the calibration and set point change for the differential pressure switc No deficiencies,were noted. This LER is close . Review of Licensee Commitment to Provide Improved Electrical Separation in RPS Panels ,

) During a previous inspection, the NRC staff noted that within RPS panels H13-P691, P692, P693 and P694 acceptable isolation and separation was not provided. Specifically, the isolation concern was divisional contact to contact isolation at relays K7A, B, C and .' The separation concern involved intruder divisional wiring in the above panels which is contrary to the guidelines of Regulatory Guide 1.75 or the commitments provided in Perry FSAR Chapters 7 and Consequently, in a June 20, 1987 letter, the licensee committed to install a permanent barrier between the intruder divisional wiring and the predominate panel wiring prior to startup.following the July 12, 1987 outag (1) During this inspection the inspector performed a visual. field .

review of panels H13-P691, P692, P693 and P694, to determine if corrective action taken by the licensee to resolve this issue was adequat The following observations were made:

(a) All four RPS panels contained temporary test conductors which were terminated to the scram solenoid contactor relay C71-K14A-H. The scram contactors junction box metallic covers were missing, thereby, creating a divisional separation violation inside the pane (b) Metallic Junction box in panel H13-P692 (terminal strips EE and FF) had its metallic cover open. This box contains wirings of the opposite RPS Channels and must stay cicsed to comply with RPS separation criteri (c) Separation violation of conductors terminated to relays C71-K49 . . . , inside the RPS panels was note (d) Panel H13-P693 contained a blue conductor exiting flexible conduit "F" and entering conduit "f" violating

.the separation criteri In addition, Nonconformance tag NR 0QC2007, dated March 19, 1985 was still hanging on a relay inside the panel although the NR had been close (e) A number of additional areas were noted to contain wiring of different divisions in the same RPS pane The licensee informed the inspector that all identified potential separation problems will be reviewed and corrective actions will be taken to resolve the separation-concerns. The inspector informed the licensee that failure to meet the commitments delineated in the June 20, 1987 letter is considered to be a deviation (440/87019-03(DRS)).

g 7

'

1:

..

. ,

L (2) A followup review of the temporary test leads indicated that they were installed at the scram contactors in November 1985 as documented in LLJED Tag Order 15-92 Procedure PAP-1402, Revision 4, entitled '" Control of Lifted Leads, Jumpers, Temporary Electrical. Devices . . ." requires in Section that "the General Supervising Engineers (GSEs) shall assure that a monthly review of all LLJED's under their jurisdiction

/ is conducted." Examination of the reviews conduced to'LLJED-Tag Order No.15-923 since November 1985, revealed that the required monthly review was not performed in the months of April, June and November, 1986 and in the month of May, 198 In addition, the monthly technical reviews that were performed were denoted by the reviewers by dating and initialing anywhere on the Tag Order Log sheet. This made it extremely difficult to determine whether the monthly reviews were accomplished in a timely manner. The licensee informed the inspector.that'a new form will be attached to the LLJED log to clearly doCJment the signatures of the technical reviewer Based on the above, the inspector informed the licensee that failure to conduct the required technical reviews on a monthly g basis as required by the procedure is another example of a j violation to the requirements of 10 CFR 50, Appendix B, '

Criteria V (440/87019-018(DRS)). The inspector examined the proposed actions initiated to remove or replace the temporary leads in the RPS panels. Engineering Design Change Request (EDCR) No. 860234', dated March 7, 1986, proposed the permanent installation of the scram contactors to test Jacks, however, i this design was rejected by engirieering. On October 1, 1986, GE issued g' ' FDDR KLI-6474 which proposed the installation of , test connection lugs where needed to perform the surveillance testing. This FDDR has not been implemented. In addition, Work Order 870006206, Revision 1, dated July 28, 1987 has been written to completely remove the test leads from the RPS panel At the conclusion of this inspection, the licensee informed the inspector that the test leads will be removed and covers put back in November 1987. The inspector wf11 follow up on this issue during a future inspectio . Training

,

'

The effectiveness of the licensee's training program was reviewed by the

'

inspector during the witnessing of the licensee's performance of a surveillance activit Personnel appeared to be knowledgeable'of the

, tack being performe No violations or deviations were identifie l

--_ - - _ - . __ __ - _ _

i

. 1 i

!

6. Unresolved Items An unresolved item is a matter about which mors information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. An unresolved item disclosed during this inspection is discussed in Paragraph 2.b(2).

7. Exit Interview The Region III inspector met with licensee representatives (denoted under Paragraph 1) at the conclusion of the inspection on September 4, '.98 )

The inspector summarized the purpose and findings of the inspect.)n. The l licensee acknowledged this information. -The inspector also discussed the

'

likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not' identify any such documents / processes as proprietar I i

!

i l

I i

)

l i

!

l

i a