IR 05000440/1990013

Insp Rept 50-440/90-13 on 900625-0802.Violation Noted.Major Areas Inspected:Completed & in-progress Design Changes, Including Licensee Program for Controlling Temporary Mods

ML20059B488
Person / Time
Site:	Perry
Issue date:	08/21/1990
From:	Langstaff R, Lougheed V, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059B481	List: IR 05000440/1990013 ML20059B480 ML20059B483
References
50-440-90-13, NUDOCS 9008290113
Download: ML20059B488 (12)

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i U. S.' NUCLEAR: REGULATORY COMMISSION-

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REGION'111 1 F

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. Report No.: 50'-440/9'0013(' IRS)

E -Docket:No.: ' 50-440 License No.-HPF-58-

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, . Licensee: The Cleveland E;ectric 111uminating Company '

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10 Center Road

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Perry, 0Hf 44081 Facility Name: Perry Nuclear Power Plant - Unit 1

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Linspection At: Perry, OH' 44081 -

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Inspection Conducted: . June 25 through Augu .t 2,1990 ]

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g Inspectors:-

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sw b fdy g/z/[fd -

Peggy; R./ RescheYks Da te/ '

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'V.Fa[,r/c~iaL6ugheed Dard/

7 /Yf0 Ronold-AfLangstfrff Dath '

y;" , 41 I /h,6 Approved By: . Monte P. Phillips, Chief

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Date' l Operational Programs'Section  !

t b , Inspection Summary '

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' Inspection:on June 25 through August 2,-19901(Report No. 50-440/90013(0RS))' d Areas Inspected: Routine, unannounced safety inspection of completed and ,

in-progress-design changes (IP 37700). Also included in this. inspection was y

< a review of the licensee's program for controlling. temporary modifications. . 1 Results: .Two.previously identified violations were closed. Two open items d resulting from the DET inspection were also closed. One violation (with two j k .

examples) was identified for fr. lure to satisfy the requirements of 10 CFR g 50.5 l

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~ Based'on the modifications _ reviewed by the inspectors,.the_ licensee wast

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a_dequately' implementing design changes, with_ exceptions.in the. areas of: -

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, documentation and safety evaluations. ; During review of the ' Design' Change - ,

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' Packages (DCPs). the' inspectors'noted that documentation: appeared to be: wea P 4 information such as work orders, condition. reports and- l

o for example Licensee Event. Reports supporting (LERs), was not always referenced Lin-the packag [

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' Additionally,,the description and .justific'ation for the modifications were 'not ,

, well documented. As:d~ result,.it was difficult to determine the purpose'of the- J

' modification without 61scussing;it with the res'ponsible engineer This.coul .

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, result _in future negation'of the modifications purpose,._A positive observation-

% , 'made' by'the inspectors was that the engineers were generally very knowledgeable

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of theirLsystems.

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Based on the review of the licensee's temporary modificatiin program an q' installed Mechanical Foreign Items / Lifted Leads, Jumpers, and Temporary ]i Electrical Devices (MFI/LLJED), the inspectors determined thLt the program was q f 1 ' adequately contro111ng' temporary modifications. The MFl/LLJiDs.'were also weak

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o in regard to identification of supporting documentation and performance of T 10 CFR 50.59 applicability check .

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.The licensee's program and a large sampling of-10 CFR 50.59 applicability ~i checks -and safety evaluations' was reviewed. The inspectors noted that the ,.

procedure provided excellent-guidance; however,: implementation. appeared!to b y m we a k.- One' violation was. identified (Paragraphs'3.1 and 3.m) with.twoiexamples '

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cof' f ailure to: satisfy the~ requirements of 10 CFR 50.59. The two; examples

were associated with DCPs, t The

safety significance.of the violation wa considered minor since no unreviewed safety questions existed. "There appeared: ,

to be two weaknesses in the' licensee's implementation of the safety evaluation-

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program:-(1) The focus' of the applicability' check was very narrow which resulted in failure to reference / review all applicable sections of the USAR.:  ;

_, Since each discipline performed its own applicability check / safety evaluation', 1

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changes affecting system interfaces and those which crossed. discipline boundaries' ;

. _ may not be ' addressed; and '(2) The focus was generally 'on physical changes to 4 1the USAR (text drawings) which'resulted in failure.to address'a11Laspectstofj ;

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the facility changes. The majority of. the safety evaluations' were performedtas a - j result of a physical change.to the USA }

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!/M , ' DETAILS

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ClevelandElectric111uminating-Company (CET)- l

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-R.'LStratman, General Manager- i J. Emloy, Operations Engineer-

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J.lEppich, Manager - MDS/PNED

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D. Green,: Manager.- EDS/PNED H. Hegrat, Operations Engineer j

rL T. Hogan, Operations. Engineer jl g . S. Kensicki, Director -_PNED ,

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J. Lausberg, Supervisor,- Technical Quality - PNAD S. Moffitt,. Manager - PNED/SES- ;l R..Neuendorf, Senior Project Engineer-- EPSS _i R. Newkirk, Manager, Licensing and Compliance {

T. Rood, Operations Instrument Lead  !

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B.JWalrath, Manager'- EPSS/PNED ^:

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All of-the above-individuals, attended the exit meeting held on p July 20, 199 ,

Others contacted'duringLthe course of the inspection included' members-of' l-the licensee's system / design engineering, operations,'and technical staffs.: 3 2. . Licensee Action'on Previously Identified items 4

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-a., -(Closed). Violation (50-440/89012-03(DRS)): Failure to perform local ..  !

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(leak rate tests (LLRTs) on a flange in the Residual' Heat-Removalz(RHR)'; J

- system. Thelicenseehas.initiatedamodification(DCP'890224)-toc j

' provide testing capability of the flange. 'This . item is. considered -

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si close ,9

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- (Closed) Violation (50-440/87022-01(DRS)): Failure'to perform the'

required 10 CFR 50.59 safety evaluation for temporary modification 3

.LLJED 1-87-077. The licensee had incorrectly determined via a-m 10' CFR D.59 applicability check that a safety evaluation was not 1

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. required. As detailed in.the response to the-violation (date ';

March 30',1988), the licensee subsequently performed a safety: evaluation- :

and concluded that no unreviewed safety questi.on existed. . This item is considered closed, (Closed) Open Item'(50-440/89022-20(DRP)): As detailed-in Sectio .

3.6.1.3 _of the Diagnostic Evaluation Team (DET) Report dated'May' '

? 1989, the licensee relied heavily on contractor support within-

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selected areas of the Perry Plant Technical Department (PPTD) and the 1 NuclearEngineeringDepartment(NED). The DET expressed concern  ;

that a- rapid reduction in contraccor suppor t could adversely impact i!

the licensee's ability to accomplish engineering support tasks. The

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L>r- *m licensee initially responded to that concern inLa letter dated _ ,;

8mM  ? July?29,1969s(PY-CEI/NRR-1043L); The licensee submitted-' ant - ..

F7 additional response to the subject item in ailetter dated October 11, '

Lb, 1989(PY-CEI/NRR-1071L). The item remained open pending-NRC review N '

.of1the licensee's five-year plan for engineering support. sTh _

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cinspectors held' discussions with the. licensee regarding: the trend'in >

staffing' levels, and the current and planned, staffin  :.

' Licensee statistics indicated.that (as of< June'1990)gthe change ._ _

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anticipated, l consultant reduction levels we.e notias significant as previously 1 forecast, and that several consultants were rolled over into CE l

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For example, the manning levels from January 1989. to June 1990, .,

.- showed a~51.6% reduction of-consultant staffing for both NED and j 00 -  :'12.5%.

PPTD;1 This however, . total hiring reductions for both ' sections only'. decreased by , 1 3 . reflected of former consultants as permanent 4

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. employees. .Further, the steady reduction.of staff has had minimal y (: impact on the completion of activities. associated with preparation,  ;

for refueling activities. The five-year plan was near compl_etion and- 1

, no changes. in staffing were planned for the remainder of; the~ yea i!

This=itemLis-considered close .

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d.; (Closed) Open Item (50-440/89022-21(DRP)): As detailed in Section: 1,

& T 6.4.1_of:the DET Report, the licensee had not. established a lo'ng, '

term implementation schedule to reduce the nuuber of_ outstandin !

C' DCPs. The licensee res 1 L 1989 (PY CEI/NRR-1043L)ponded.to . -The response. this item stated in a'DCP that_a letter'

review dated July 129, 1

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committee hod been created and that prioritiesthad been establishe N Further, results from that effort would:be factored into-their five-year plan. (With.possible minor scope changes, the licensee has '

l nearly_ completed five-year planning of. design change work.~); This ,

item remained open pending LNRC

review of the. licensee's five-year -!

plan -The inspectors reviewed the draf t of the Perry Nuclear-- 4 Engineering Department (PNED)slong-Range Plan (five; year: plan), dated M , LJuly;2;'1990. The~ Plan identified 650 modifications not implemente 'i as of June 19, 1990.. Of: this number,3 315 modifications were' planned . -

to be performed during Cycle _5 or later .(not assigned-in the five-yea '

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plan). The inspectors determined that delay'of implemen.tation.ofi

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these DCPs was acceptab'le. -This item is considered close ]3

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Permanent Plant' Design Changes . "l

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The inspection' focused on the implementation of desi

.a selective review of-the' associated documentation (gn changes e.g.,110'CFR 50.59and' included:

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evaluations, design calculations, testing criteria and results, procedure .

./ and drawing = u) dates)', and verification of the installation. Discussions- -l f"' 'were held. wit flicensee staff involved in the modifications, which included

- system / design engineers, and project and operations personnel. The j

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licensee's modification program was controlled by PAP-0301', " Design

, Modification Process";iNEDP-0301, " Design Control Program"; and NEl-0357, l

" Design Change Packages". The. inspectors reviewed a sampling of safety  !

-and nonsafety-related design change packages (DCPs)' closed in 1989 or 1 1990. A sampling of open DCPs being performed during the inspection or  ;

scheduled to be performed in the upcoming refueling outage was also i

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reviewed. The following.DCPs were reviewed by the inspectors and no concerns were identified unless otherwise note , 4 I

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 ,f a .1 :DCP 870274, Addition of-Radiation Barrier Around E12 Pipe Elbow'Below:

U '> Valve.E12-F066A: p - _

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auxiliary building walls and floorEat the 568' elevation.y-The .

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barrier was necessitated by high radiation: levels from:the' residual

   : heat removal (RHR) pi l e-during shutdown ~ cooling operations. The RHR pipe was situated next to'a radiation detector, which alarmed'
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frequently'due to crud buildup -in the-RHR line at'an elbow. ?The'

   = solution to the concern was to buildLa barrier, which was comprise ,

of lead bricks, from the floor up to azheight of'approximately 5 feet,laround the RHR pipet The. barrier surrounded the pipe on.thre sides, with the auxiliary building wall forming the fourth. side of: thel box. .The wall itself was considered to perform no; safety function.:

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However, it was designed to withstand seismic forces suchcthat it 6 would not fall on either the RHR. pipe ~or;the radiation monitor. T he' -

   . inspectors rev_iewed the1 seismic ~ calculations for the box as well as the installed: configuration and concluded that'the modification was-acceptabl ~. DCP 880075, E12-F006A, B,'and E-12-F024A, B Interlock  i_

This modification provided an interlock between E12-F006A, B (RHR-

   . shutdown cooling suction valves) and E12-F024A, B-(RHR flow test return line< valves) such that the F024 valves could not be opened ~if ,
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the'F006 valves were open. Prior to the modification,' operator erro 'l could result in opening'of the F024 valves while the F006 valves: i were open, resulting in a- flow path from the reactor vessel to the suppression pool. Tne possibility'ofz such a flow path, and j

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1 consequences-thereof, were' discussed in NRC Information. Notice _N .-- c.c iDCP1880292, Addition of.Two Manual Isolation < Valves-on the Lower y Containment Airlock Air- System to Allow. for Independent Testing f g of an-Individual Airlock Door-- 1 i j

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The licensee utilized an inflatable seal system on the airlock doors ' O in order to ensure containment integrity. The sealsiwere provided : n with air from the instrument air system. .The inner and outer doors +i , of the lower airlock were both; fed through a'. single air .line; which 1 splits at' the airlock barrel. Prior'to.the modification, there was 1 no way to isolate the air supply to o'neLof the two doors-(such a J for maintenance or-testing). .The modification added two isolation- l vilves, one in each air line just after the lines spli These-

%   valves were normally open. Closure of the valves would result i #  eventual-depletion of the. seal accumulators, which would cause.a Low q Seal Pressure alarm in'the main contro'l. room. The valves could-only 1
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  - DCP 890224, Addition of Bonnet Vent Flanges to Allow  !

Performance of LLRTs During~ performance of the Integrated Leak Rate Test (ILRT) during ]; w

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  .- a flange.on.a RHR; relief. valve-(E12-F055A). Subsequent review by-  ,

e 'the NRC inspectors witnessing %e -ILRT revealed that= these flange , N,'w -were not receiving local leak rate: tests-(LLRTs) as required by-10- :l w ' CFR 50; Appendixid. Failure to perform LLRTs on the flanges was: . a; violation (see. Paragraph 2.a.above). Theilicensee found.that-the ' b configuration did not allow' testing.of"the flange,-.other than by-  ;

% 4  performance of an ILRT. Completion of this! modification would allow; ;

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l proper testing of the flange in compliance'with Appendix i

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e.- 'DCP 900141,.' Replace Existing Overload Relay and Heaters with j Correctly Sized Ones

,   This modification.was a reactive change to resolve a: problem occurring.' j
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fin the rknt:; a control rod drive.(CRD)! auxiliary lube oil pump was- i

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repeatedly- tripping on thermal overload. . The initial- field change 11 request dated February 1990, noted that'there was a discrepancy ' ,- between what was called for on the drawing and'what was installed in-s -the field' This was subsequently cvaluated by engineering and found to.be acceptable. A second field change request dated;May 1990, was

.i  _ issued when.the pump continued to trip. At'that time, engineering . 4 prepared lthe'DCP to correct the overload relay to the size specified-on the drawing. The overload heaters were changed to the correct-~ .
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  : size for the new relays. The pump continued to trip on overload, and' j 1n June 1990, the . licensee effectively bypassed,the overload relays ~ ^

) Y by installing greatly oversued heater coils as temporaryDchanges'and  ; depending on fuses to providt overload protection.~ Engineering 3' revised.the DCP to upsize the heater coil used;.however, this revision - ihad:not been installed. The~ licensee was= exploring other root causes j for the overload trip

       > DCP 891073, Replacement of Nitrogen Supply System'1/2" Globe  a
,  ? Valves Upstream of Quick Disconnect Fitting Inside Containment J '
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This modification replaced isolation valves and added vent lines to the'. nitrogen supply system. 'The' inspectors reviewed the modification, '

  -package, and the 10 CFR 50.59 safety evaluation.- This modificatio was acceptable,     j DCP'870791, Replacement of Starting Air Receiver Tank Relief Valves  '

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This modification affected the relief valves for the diesel generator air start receiver tanks by re-orientating the relief valves from a horizontal position to a vedical position, modifying two . nonsafety-related piping sepicrts near the relief valves, and- replacing "l

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+  time of-the'inspe'ction, all of the modification work had been performed except for the actual replacement of the relief valves which was
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scheduled for the refueling outage.

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Temporary inoperability of, a diesel gencator had-occurred due to-loss of starting air from inadvertent actuation of the relief-valves.-

  -(Condition- Report CR-89-06). - The root cause analysis performed to-
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determine the causes behind the loss of air su rt capability was-

  , good. In addition to personnel error, the-root cause analysis also identified design deficiencies and inadvertent system interactions due to nonsafety-related piping. This modification was initiated to
  ' eliminate the design deficiencies and inadvertent system interactions
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identifie DCP 890133/870526, Motor Control Center Control Power Transformer Secondary Fuse Size Modification

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These DCPs '(each consisting of numerous partial modification packages)~ replaced time delay fuses with a smaller size non-time delay type in 480 volt motor control center (MCC) control power transformer (CPT) s circuitry. The modification involved the Division 1 MCC for power to the safe shutdown buses and control room isolation valves, and

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all Class 1E AC active starter compartments. The purpose for the change was to provide adequate CPT overcurrent protection to prevent secondary side short circuits and subsequent MCC cubical electrical-fires. The design problem had been identified as the cause of past events in which blown fuses resulted in catastrophic failure Calculations were performed by the licensee to estimate the new fuse size and to verify coordination with Appendix R requirement DCP 890052, Traversing In-Core Probe (TIP) Drive Platform - flodification

  .This modification reinforced the'TIP drive platform and lashed down j   the drive units on the platform, which allowed for the permanent removal of the pool swell shield cover plates. Prior to this in  modification, the lower drive units were not accesrible for maintenance
"'  when the plant was in operational Modes 1, 2, and J. Calculations were performed by the licensee which verified that the reinforced platform could withstand the loads imposed by a-postulated pool swell even DCP 870428A, Addition of Fused Disconnect Switches to Circuits-Passing Through Containment Electrical Penetration This modification provided short circuit protection to circuits passing.through containment penetration 1R72-S029 by adding fused-disconnect switches. The associated conduits and supports were also insta' ed. The circuits provided 480 volt power to the reactor
 ,  built .g for miscellaneous power requirements (e.g., welding).

- . DCP 860582, Alternate Rod Insertion Valve Position Indication This modification replaced 24 resistors in the redundant reactivity control system panels in the control room. The new resistors were of a higher dropping value which decreased th current drawn by the indicating lamps. The change was done in ader to extend lamp lif ! l'

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This modification removed 1 a test relay 3etween the-reactor prctection 1

  ! system (RPS): and the main steam. isolation-valves (MSIVs).

- Additionally, it' altered the power sources for the MSIV. indicating lights-in'the- i main' control room.. . Prior to the modification, either the inboard :[

  (RPS "A"):or outboard (RPS "B") MSIVs would open on failure of the
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  . respective bus _(failure of b'oth buses would close-all-the. valves), a All MSIV indicating ~ lights (inboard and outboard) were originally  

powered from-RPS bus "A". The modification: changed this such that' d half of the indicators were powered from bus "A" and the other half'

  .from bus "B"'. This modification was performed as the result at~an,  i event in which a MSIV opened from failure of a jumper during a;  3 surveillance test. This event was described.-in the licensee condition ,

report (CR)88-037'andLicenseeEvent. Report (LER)88-008. -The~ root- :I

  :cause of the' event was attributed to poor jumper connection l Following the-event,-the licensee contacted the vendor and found that' -!

the MSIV opening was per the NSSS vendor's, General Electric (GE),

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standard BWR-6 design., GE-did not feel that any design change wa ;

  'necessary because of this event. Nevertheless, the licensee decided'

to remove the relay between RPS and the MSIV control swit-h surh thac _ the MSIVs would not open on RPS bus failur Thetlicensee . performed a 10 CFR 50.59 applicability check and concluded that no safety evaluation was required. The applicability check

  . listed USAR Sections ' 6.7 (MSIV Leakage Control. System), 7.2- (RPS), . d and-8.3;1.1.5,(AC Power Supplies) as having been reviewed.._.The
  ; inspectors reviewed the above sections as well.as Section 5.4.7'  :
  (MSIVs) and 15.2.4 (MSIV~ Closure). .The inspectors concluded that  i
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  -descriptions of the MSIVs, MSIV failure modes, and RPS operation  3 *

l(including interactions with, and testing of the_MSIVs) were such

that the conclusion that this modification did not constitute a Lchange to the plant as described in the USAR was incorrect.- This-

  'was discussed.with the licensee and-it was agree _d that a safety .  ,

evaluation should have been performed.- The licensee performed the  ;

l safety evaluation prior to the conclusion of the-_ inspection'. c; Based j~ on the inspectors' review of the safety evaluation, no'unreviewed safety question resulted from this modificatio , I 10 CFR 50.59(b)(1). requires that a safety evaluation be performed'

,   for any modifications made to the facility _as described in the USAR to determine that no u'nrevlewed safety question exists. The failure-to perform a safety evaluation, as described above, is considered to -

be an example of a violation (440/90013-01a(DRS)). In addition, the inspectors-noted that the modification left the , licensee open for repeat incidents, such as the one which initiated'  ;

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  .the modification: in order to perform a required MSIV surveillance test (SV1 B21-T1404A-D)~, a jumper woulo have to be installed in place of the removed relay. Since the initiating event dealt with jumpe connection failures, the need to install a jumper to perform the

surveillance increased the probability that a test failure would occu .!

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The-inspectors reviewed the work packages and revised surveillance'

 . procedures and had no further-concerns with this modification, DCP 880068, Emergency Service Water /RHR Heat Exchanger Inlet and-Outlet Valves This modification provided an interlock between the ESW pumps' and the RHR heat exchanger inlet and outlet valve Prior to the modification, the valves did not automatically open upon-start of the ESW pumps. The ESW-pumps were designed such that the major load was on-the RHR heat exchangers. Running the ESW pumps-without opening the valves resulted in pump net positive suction = head (NPSH)-problems, as documented-in_CR-87-145.. Therefore, the. licensee determined that the valves should receive an "open" signal any, time-the ESW pumps star The licensee originally only reviewed Section 9.2 of the USAR which discussed operation of the ESW system. Based on review of this section, it was concluded that no change to the plant as described'

in the USAR existed. This noMification package was reviewed by the NRC Di6 gnostic Evaluation Teah.(report dated May 1989), who note that USAR Section 7.3.1.1.6.b required revision as a result of this codification. Therefore, a safety evaluation was performe During this inspection, the safety evaluation was reviewed. -Th inspectors noted that the safety evaluation only addressed the impact? of the change on' the ESW system. The effect on the RHR heat exchangers or the RHR system as a whole was not addressed. The inspectors further noted that-the USAR stated that the RHR heat exchangers were - to be flushed and put in demineralized water'layup whenever RHR was in standby (such as during normal operation). The USAR also discussed the possibility of corrosion 10 the RHR heat exchangers and the subsequent effect on their heat removal capability during an acciden During-discussions with the licensee.-the inspectors learned that the ESW system was running almost continuously. Based on this, the- _ inspectors questioned the adequacy of the safety evaluation in regard to the RHR heat exchangers, especially in regard to the potential for increase in the probability of a malfunction of-equipment important to saf ety. The licensee agreed to revise the safety evaluation to-consider the effect of the modification on the RHR heat exchanger CFR 50.59(b)(1) requires that licensees provide the basis by which they conclude that no unreviewed safety question exists. By-failing.to address the consequences of this modification upon the RHR heat exchangers, which are required to operate for safe shutdow of the plant following an accident, the basis for'this conclusion was not demonstrated. This is considered to be another example of a violation (440/90013-01b(DRS)). Further discussions, via teleconference, were held with licensee representatives on July 25, 1990. A revised 10 CFR 50.59 applicability check and safety evaluation was received and reviewed by.the inspectors on August 2, 1990. Based on the inspectors' review of the evaluation, no unreviewed safety question resulted from this modificatio +

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wqp%* f- - Based on thefmodifications revic 'ed by the inspectors,x theflicensee. was; 3y , _ adequately-implementing ^designich: 1es, withfexceptions in the areas of5 . NA A ,* ' documentation!and: safety. evaluations. Paragraph 5 discusses concernsi h) 4,, , - iidentified with-implementation of ? the safety' evaluation program._ Duri.ngi

  ' l review of-the'DCPs, the; inspectors.noted that documentation sppeared to be-
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reports, and LER$, were not always referenced ia the package. - Additionally,

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   ;the. description and justification for the modification were not well:  ,
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documented 6 As a- result, it was difficult to determine;the purpose of. the; ' k< modification without discussing,it with the responsible engineer.;lThisJ f' 6 could result in-future negation of;the. modification package,7should;the responsible engineer no longer be available. A positive" observation made- ,

w * by the inspectors was- that the' engineers were generally very knowledgeable ' ' f< of their system . .t

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s Oneviolationwasidentifiedi'nParagraphs1.candm.above-(two' examples),

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y for failure to- satisfy the. requirements of 10 CFR 50.5 f , ' U ,4 <'. l . lemporary' Modifications 4 ,

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<? 'a   The inspectors reviewed the licensee's -procedure for' controlling temporary 6    modifications, Administrative Procedure. PAP-1402,." Control of; Lifted  i
   !; Leads, Jumpers, Temporary? Electrical Devices and Mechanical Foreign 1
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Items." The procedure-applied to temporary installation and removal a . 1 mechanical foreign itemsn(MFIs) and lifted leads, jumpers, and electrical' ] devices (LLJEDs); Each MFI/LLJED required a tag order (description', j-installation / removal:information, reviews and approvals), a: technical? q

?    evaluation, and a~ 10 CFR 50.59 applicability check. Periodic reviews and;  1 7 audits were conducted by the' licensee for the installed temporary _
 ;c6   modifications.. The inspectors 1noted that-the licensee had established a:

program to reduce-the number = of ' installed MFI/LLJEDs, and: held periodici meetings to discuss; status 'and priorities. In addition, the licensee was-considering ' changing,the procedure'to-not allowL(orilimit) the use of at

   'MFl/LLJE0 if,the: change was' planned to-be made: permanent.-
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   .The inspectors reviewed a :large sampling of- tagforders- for the' installed  1 MFI/LLJEDs. Approximately 100 were currently insta_11ed,;with a sfew dating -  ,
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back:to'1985. The inspectors noted that many of the MFI/LLJEDS were to be ] made: permanent modifications; Based on this review, the.: inspectors

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u i sdetermined that the licensee's program was adequately controlling temporary  ; modifications. Identification of supporting:information was considered -j weak for temporary modifications as well' as DCPs. L Concerns were also t l

.a   identified regarding the 10 CFR 50.59 applicability checks .andie' discussed  j w

u in. Paragraph j

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No violations were identified in this area, i W . l R . Safety. Evaluation I J l10.CFR 50.59 applicability checks and safety' evaluations were conducted ' under PAP-0305 'and NEl-0332, " Safety Evaluations." The program required 1

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r' b that _ applicability checks be performed for 'all: DCPs an'd MFl/LLJEDs. to-

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determine:if a safety evaluation was necessar Each affected discipline-

 -electrical, mechanical, structural, fire protection,. security,
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 -(e.gh,wasrequiredtoevaluatetheproposedchangeasitappliedtotheir et specific area, and document the results on the applicability chec Questions to be responded to and justified included: "Was there a change to the plant as described in the USAR?" A positive answer to any of the- -

five questions required aL safety evaluation to be performed to determine  ! if an unreviewed safety question existed. Safety evaluations were reviewed 'l and approved by the Plant Operations Review Committee (PORC). The inspectors noted that Attachments _4 and 5 of the procedure provided excellent guidance for performing the applicability checks and; safety j evaluations. Persons performing the procedure were required to be trained y dnd-qualifie The inspectors reviewed the 10 CFR 50.59 applicability checks and' associated [ safety evaluations for the thirteen (13) DCPs described in Paragraph 3, j!

. numerous temporary modifications (Paragraph 4), and for an additional eighteen (18) DCPs: issued'in late 1989 or during 1990. Paragraph- identified 'an example of 'a violation for failure to perform a safety 1 evaluation due to the incorrect determination that the modifications did not' constitute a change to the USA Paragraph 3 m. identified anothe , example of the violation for failure to adequately address the consequences i of a modification on system interfaces. Although a safety evaluation was performed for this modificaticr., it was not originally sufficient to conclude that no unreviewed safety question existed. In addition to the  !' violation, the following examples were identified which were representative: of a weakness in the licensee's program: (1) the applicability check for a change to a control switch for service water traveling screens did not ;4 address the USAR section on-service water; (2) the applicability check for I two temporary modifications and a DCP which installed replacement components' ; addr'essed the different size and material used by stating that the bill.of

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i materials was not listed in the USAR, while the'.USAR section of the

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replacement components was not a'ddressed; and -(3) the applicability-check for DCP 900141 concluded that a change in thermal overload heater size did

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I1 _ not require a 10 CFR 50.59 safety evaluation'because thermal overloads still- j

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protected the heaters. However, the effect:of- changing the heater size : [ on the protection provided was not addressed. Although the inspectors j agreed that no safety evaluation was required because only Class 1E motor i control centers (MCC) were discussed in the USAR and this modification was  !

 ' for-a nonsafety-related motor in a nonsafety-related MCC, they were  !

concerned that this reasoning could have resulted in no safety evaluation l being conducted if the modification had been performed on a motor in a Class 1E MC l

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Based un the inspectors review, there appeared to be two weaknesses in the licensee's implementation of the safety evaluation program: 1 a

 (1) The focus of the applicability checks was very narrow which resulted in failure to reference / review all applicable sections of the USA Since each discipline performed its own applicability check / safety evaluation, changes affecting system interfaces and those which crossed -discipline boundaries may not be addresse :

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O i  ;,, J2) FThe focus was: genera 11yLon physical ch'anges to-the USAR (iext',-  ! if ~; . 4 drawings,";etc;)'which r'esulted..in' failure to address all: aspects o j F , 'the item. changed. The majority:of- thelsafety evaluations were 'l L  ; performed as;a result ofla;pbys: cal change,to the CRA , s- ,. 4

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6 The; inspectors 1h' eld discussio'ns with tne. licensee regarding these' concerns - ' y

:     , The licensee has an ongoing effort to improve;theisafety: evaluation' program.=   :!
<   M-  Recently,'an: interface review had been implemented.t . Further, the licenseet   1
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i was planning =to revise the~ program to reflechthe guidance in.N. SAC 125.)

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;:     o0ne violation related to^this area-?was discussed'in paragraph 3. The:    ,

E , violation was' considered to~ be 'of- minor safety significance"since no H :unreviewed safety'. questions existed. A weakness in;theLimplementation.of;_

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l E the safetyf evaluation program was identifie .! R ,

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Exit Heeting

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  +          j Thebinspectorsmetwith'the.licenseerepresentatives(denotedinParagrapk   (
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    .a 1)1on: July l20,11990L Theli_nspectors summarized the scope and. findings of   1 (i     the' inspection. 'The-licensee acknowledged _the. statements made by the-
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h"# ' l inspectors with1 respect to the vtolttionsand other concerns. The-inspector O ;also discussed the.likely informational: content of the inspection report y

    ,;with regard to;. documents or processes reviewed by the-inspectors'during--   j
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Ethe inspection and the;1icensee:did not identify,any such documents / processes V ,

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as proprietary. ' Further discussions, via. teleconf erence, were held with - p' 11icensee representatives on July 05, 1990, regerding the.vioictio . i , iAdditional information delated to the' violation was. received and revie n 4

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by the; inspectors on August 2', 199 l% ,- .l

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