IR 05000440/1990004

Insp Rept 50-440/90-04 on 900305-08,0416-19,0620-22 & 0702. No Violations Noted.Major Areas Inspected:Licensee Actions Re off-gas Sys Operation

ML20055G659
Person / Time
Site:	Perry
Issue date:	07/20/1990
From:	Danielson D, Liu W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055G657	List: IR 05000440/1990004 ML20055G656
References
50-440-90-04, 50-440-90-4, NUDOCS 9007240038
Download: ML20055G659 (9)

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O. S. IlUCLEAR REGULATORY COMMISSION REGION 111 Report No.: 50-440/90004(DRS)

Docket No.: 50-440 License No, NPF-58 Licensee: The Cleveland Electric 111uminating Company 10 Center Roa'l Perry, OH 44081 Facility Name: Perry Nuclear Power Plant inspection At: Perry, OH 44081 Inspection Conducted: March 5-8; April 16-19; June 20-22; and July 2, 1990 .

/n Inspecto : '

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.C.L'iuf Date Approved By: Il 20/ C 3 D. 41. Danielson,IChief D' ate'

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Materials and Processes Section a

inspection Suninary

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Inspection from March 5 through July 2, 1990 (Report No. 50-440/90004(DRS))

! Treas Inspected: Special inspection of licensee actions associated with the

off-gassystemoperation(37701).

Results: No violations or deviations were identified. During the course of the inspection, the following strengths and weaknesses of licensee activities pertaining to the off-gas system operation were noted:

Strengths

There appeared to be a high degree of licensee management involvement in all aspects of corrective action programs to improve the system operatio The licensee's engineering staff appeared to be. technically competent and well motivate Root cause evaluations by the licensee identified a significant number of problems which had caused adverse effects to the system operatio PDR Q ADOCK 05000440 PDC

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Weaknesses 4* -Anumberof'poorengineering7designsweref$und[in;theoriginaldesignof:

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- In'.a_few instances,. inadequate l procedures;were foundLfor the system;

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DETAILS Persons Contacted The Cleveland Electric illuminating Company (CEI)-

• R..Stratman, General Manager

• S. Kensicki, Director

-*V. Concel, Manager /SES

• W.~Coleman, Manager /QAS

• T. Remick, -Task Force Chairman

• B. Nelson, HVAC Lead

• G. Osborne, System Engineer-

+*C; Elberfeld, Operations- Analyst-

• J. Grimin, Plant Chemist

• C. Page, Staff Member /ISEG 5

• F. Moore, HVAC Engineer H. Hegrat, Compliance Lead Nuclear Regulatory Consnission (NRC)

P. Hiland, Senior Resident inspector

• G. O'Dwyer,_ Resident inspector

• Denotes those attending the exit interview on June 22,-1990, at th .

Perry Nuclear Power Plan + Denotes the person participating in the telephone exit conference call

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on July 2,199 . Background Information

. Between September 1988 and January 1990,- a total of 14 major events pertaining to off-gas system operation occurred. Although no-Technical i Specification violations were identified as a result.of- these events,_.the licensee management has fully realized the seriousness of the off-gas problem and has worked promptly to correct the situation. An Off-Gas Task Force was formed by the licensee on January 5,1990,,toTreview and evaluate all aspects of the system operation. This task force consists of members ,

from most of the plant and engineering sections and:has_ recommended a-series of. changes to improve the' system operatio Following is a- summary of the 14 events: September 4, 1988 Charcoal fire caused by a hydrogen detonation' due to inadequate training of operating personnel:(CR 88-215).

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. Septembr[16,'1988-Charcoal fire caused by a hy'drogen detonation due to inadequate training of-operating personnel (CR 88-226), October 14, 1988T Loss of dr r/ chiller loop sea 1Ldue'to a lack of procedural control l (CR 88-251 November 19, 1988-  ;

- Loss- of. dryer / chiller loop seal due. to a lack of' procedural control

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l(CR 88-278). December 21,--1988-

.t Dryer isolation valve failed to open. causing loop-seals to blow- [

tout. The failure was- due to the presence of the valve's lockin collars (CR 88-306). . February 2,1989 ,

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Loss of holdup line ' loop seal due to leakage of the drain valve :

(CR89-055) February 14, 1989-Loss of prefilter loop seal due to leakage of'the drain valve-

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(CR89-055). October 16,1989

' Loss of dryer / chiller loop seal due to-leakage of-the: drain valv (CR 89-366). ,

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1.- December 7,1989 :

Loss of d er/ chiller loop seal due to leakage of the drain valve

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l (CR 89-417 . i a December 28, 1989'

Loss of dryer / chiller loop seal due to failure of the pressure l control' valve (CR 89-437).

k.; December 29, 1989 j l

Loss.of failure todryer open/(CR chiller loop).. seal due to the regeneration lineup valve 89-438 "

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1.- January 1, 1990 .i Loss of holdup line loop seal due to leakage of the drain valve (CR 90-002). January 7, 1990  !

Reverse flow of process gas into the condenser where it was exhausted-by the mechanical vacuum pumps. This was due to a lack of procedural control for closing the isolation valve (CR 90-006). January 31, 1990

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Loss of cooler condenser loop seal due.to pressure / flow perturbation caused by introducing = water into the off-gas process stream (CR

.90-019).

3. Task Force Activities The goal of the Task Force was to increase the reliability of the '

off-gas system operation.- This includes all a pects and components ,

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of the system and those subsystems needed for=its proper '

. performanc The functions of the Task Force are:

To review-all design changes, setpoint. changes,-and procedure changes pertaining to the off-gas syste '

To participate in major preplanned system operations and $

corrective action '

To recomend short and long term. corrective actions to improve ,

the. system operatio i The Task Force will be active for a minimum period of.12 months and I is to be-re-evaluated on a periodic basis thereafter, until plant management is satisfied with the system operation.- Problems Identified Resulting From Root Cause Evaluation The following problems were identified'as a result of the root cause evaluations by the licensee: Loop seal-drain valve leakage due to poor material used in the originaldesign(CR89-417). Barton level switches at the holdup pipe, cooler condenser, and prefilter' loop seal piping were not working properly (CR 90-048 and CR89-055).

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~ Loop seal configuration at the_ dryer skid revealed inadequate desig consideration due to. lack of-level instrumentation-(CR 89-438), The-pressure control valve at the dryer skid was incorrectly designe (CR89-417) The level instrument at th'e holdup loop seal piping was incorrectly-designed in 1987 (CR 90-048), The original' loop seal config'uration at the holdup pipe, cooler condenser, and prefilter was incorrectly designed due to the potential forsiphoningeffectstodraintheentire'loopseal-(CR89-055). Inadequate. procedures were found:

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(1) Improper operation of the intercondenser loop seal drain valve closure (CR90-006).

(2) Improper . isolation and filling of the_ loop _ seal prior to -

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I commencing a regeneration cycle at the dryer skid-(CR 89-438). Inadequate training of operating. personnel.(CR 88-215 and CR -l 88-226). l

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5. Corrective Actions That Have Been Completed j The following corrective actions are intended to resolve portions of the j problems identified in the previous paragrap j i Cut and- cap the dryer / chiller loop. seals downstream of the drain valve l to stop leakag !

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l Add a stainless valve disk in the' holdup pipe loop seal drain valve 9 to stop leakag Repair-prefilter loop seal drain valve to minimize: leakag i Add additional charcoal to the'adsorber vessels to increase delay l time, j

! Replace the pressure control valves on both of the dryer skid .

i Continue to replace the heaters on the vault refrigeration air- l handling unit Dryer skids are now operated in manual instead of automati A-procedure change was made to isolate and fill:the loop seal prior ,

to commencing a regeneration cycle at the. dryer skid ! A procedure change was made to ensure that the intercondenser loop seal drain valve is closed at the correct tim ,

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6. Corrective Actions to be implemented During the Upcoming Refueling Outage ,

(Will Start in September 1990)  !

The followino corrective actions are additional efforts not only to resolve the problems identified in Paragraph 5, but also to improve the system operatio i Add level switches to the dryer / chiller loop seals (DCP 88-347 and DCP 90-007), Replace the existing level switches at the holdup pipe, cooler condenser, and the prefilter loops seals with the new and more '

reliable level switches (DCP 90-011). {

Restore the adsorber charcoal beds which were damaged by the j hydrogen detonations (DCP 89-213, for 12A and B charcoal beds). j

. Add the stainless steel valve disks to the cooler condenser and prefilter loop seal drain valves to stop leakage (Work Orders !

90-1125and90-1126), Replace Fisher 3-way actuator on the vault refrigeration brine !

bypass valve to reduce the level of vibration (DCP 90-039). I Continue changeout of vault refrigeration air handling unit heaters-formoreeffectiveoperation(DCP89-222). Remove dryer skid valve locking collars to increase operation efficiency (DCP 87-343).

7. General Electric Loop Seal Study 1 The NRC inspector held discussions with licensee representatives j regarding the evaluation of the GE loop seal study. The inspector noted ,

that: i The GE loop seal study had been reviewed and evaluated by:the !

licensee during the month of March 199 i The intent of the GE recommendations will be essentially incorporated i and implemented in the action plan during the upcoming refueling outage (DCP88-347andDC)90-011).

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8. Licensee's Future Efforts The following future-action plans are considered as enhancement programs for the system operation: j Feasibility study for "an ambient temperature system" so that the charcoal absorbers.can be operated at higher temperatures instead of 3 the current zero degree temperatur . a

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, Evaluation of decreasing the condenser air in-leaksge rate to reduce ,

the duty on system components and drains, j i Evaluation of operating the steam jet air ejectors at lower pressures, to reduce the offsite releas i Evaluation of a possible single train operation of the absorber ;

beds. The absorber beds of botii trains are currently in us Evaluation of adding off-gas parameters to emergency response i informationsystem(ERIS)toprovideamorehumanfactoreddisplay for the operator . Evaluation of Barton Level Switches in Safety-Related Applications During the course of the inspection, the NRC inspector noted that the Barton level switches, used in the off-gas system, experienced a variety 1 of problems in terms of performing their intended function. Consequently, !

the NRC inspector requested that an evaluation be performed to determine 4 whether the Barton level switches used in safety-related-applications have any negative impact on system operatio The licensee's response to the above concern was documented in a memorandum dated June 27, 1990. The memorandum concluded that only four safety-related level switches exist at the plant and there was no .

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evidence that these instruments had caused a negative impact.on system !

operation. The matter is considered close '

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1 Status of System Operation

The system has continued to perform well and no events or transients have occurred since February 1990. The future activities of the Off-Gas Task Force have not changed from those delineated in Paragraph 3. The major activity will be to monitor system performance after the modifications j v are implemented in the upcoming refueling outag . Conclusion The off-gas system performance has improved since February 199 i This is, in part, due to the completion of the short term corrective actions taken by the licensee. All of the long term items as delineated in Paragrapn 6 needed to correct the system's problems are to be implemented during the upcoming refueling outage which will start in September 1990. By that time, the system operation is expected to be substantially improve :

1 Exit Interview The inspector met with licensee representatives denoted in Paragraph 1 ,

during and at the conclusion of the onsite-inspection on June 22, 199 The inspector also contacted licensee representatives via telephone 8 ,

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denoted in Paragraph:1,-.on July 2,1990,k to discuss the evaluation ofi Barton level switches and future worktactivity of.the Off-Gas Task Force pertaining to off-gas system operations.. The _ inspector summarized the >

scope and results of the inspection and discussed the likely content of d this inspection. report. The licensee acknowledged the:information and -

did not indicate that any of the informationLdisclosed during the-inspection could be considered proprietary in.' natur ;

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