IR 05000440/1993001

Discusses Insp Rept 50-440/93-01 on 930501-0623 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $200,000.Enforcement Conference Held on 930720 to Discuss Violations

ML20056G640
Person / Time
Site:	Perry
Issue date:	08/31/1993
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Shelton D CENTERIOR ENERGY
Shared Package
ML20056G641	List: IR 05000440/1993001 ML20056G642
References
EA-93-176, NUDOCS 9309070005
Download: ML20056G640 (6)

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[puc UNITE 3 STATES NUCLEAR REGULATORY COMMISSION 8 o REWON iil f E 799 ROOSEVELT ROAD k I GLEN ELLYN. ILUNOIS 60137-5927

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• • • +' August 31, 1993 Docket No. 50-440 License No. NPF-58 l EA 93-176

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Centerior Service Company ATTN: Mr. D. C..Shelton i Senior Vice President-Nuclear - Perry c/o The Clevelbnd Electric i Illuminating Company '

-10 Center Road '

-Perry, OH :44081 '

Dear Mr. Stratman:

SUBJECT: PERRY NUCLEAR-POWER PLANT NOTICE OF. VIOLATION AND PROPOSED IMPOSITION OF CIVIL l PENALTY - $200,000 {

(NRC INSPECTION REPORT.NO. 50-440/93011(DRP))

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This refers-to the inspection conducted during the period of May 11 through June 23,-1993, at Perry Nuclear Power Plant. The inspection' reviewed the circumstances surrounding fouling and

. deformation of the Residual Heat Removai (RHR) suction strainers.

The' report documenting this-inspection was sent to you by letter dated July 12, 1993. An enforcement, conference was held on July 20, 1993, .and a report summarizing the conference was sent to you by letter dated July 26, 1993.

During the first refueling outage in 1989, you identified that the~ cleanliness of the suppression pool was poor, and the RHR A and B strainers were flushed of debris. .On May 22, 1992, during the third refueling outage, you again found the RHR A and B  !

suppression pool strainers fouled and excessive debris on the

. suppression poo' "'oor. However, the' effects of this fouling and v debris?on operabL.ity of the RHR system was not adequately l evaluated, nor were the strainers or suppression pool cleaned  ;

!- prior to plant startup in. June 1992. After operating with the l l fouled. strainers for approximately 7 months, your staff cleaned 1 L lthe strainers and the containment side of the suppression pool i L .during the'mid-cycle outage which began in January 1993. After

[ cleaning:the strainers, you found that they were deformed and l : cracked.. Therefore, in February 1993 you replaced them prior to i 'startup.' However, despite the fact that video tapes of the i

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original strainers showed that the debris that was removed from the stainers had been entangled with fibrous material, you failed to determine the source of that fibrous material. ,

l As a result of the service water pipe rupture and subsequent l reactor scram in March 1993, the RHR B pump was operated for approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> in the suppression pool cooling mode. The

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i RHR B strainer was later found to be again. fouled and deformed.

l The material fouling the RHR B strainer was subsequently i

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l identified as predominately filter media from the drywell l ventilation system. On April 19, 1993, your. engineering l evaluation determined that excessive differential pressure across

! the RHR A and B strainers could have compromised the ability of

!. the RHR-system to perform its required 100 days of post loss-of- ,

coolant accident cooling. -

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In response to NRC Confirmatory Action Letter RIII-93-007 dated -

April 16, 1993, you committed to ensuring acceptable levels of cleanliness in the suppression pool and in the containment and '

l drywell (which directly affect suppression pool cleanliness)

prior to plant startup. However, during an NRC inspection on May 25, 1993, substantial cleanliness discrepancies were identified in the drywell and containment even though your cleanup of these areas was essentially complete. The items )

identified had the potential for significant fouling of the i strainers had they fallen into the suppression pool.

t Section I of.the enclosed Hotice of Violation and Proposed Imposition of Civil Penalty (Notice) describes a violation involving (a) the failure to take appropriate corrective action following identification of debris in the suppression pool on L July 17, 1989, and May 22, 1992, and following observation of RHR A and B strainer fouling on May 22, 1992; (b) the failure to identify and remove fibrous material from the suppression pool, l

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drywell, and containment following the identification of the RHR A and B strainer deformation on January 16, 1993, and identification of debris entangled with fibrous material on the strainers in February 1993; and (c) the failure to adequately l clean.the'drywell and containment to your acceptance standards I

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developed in-response to Confirmatory Action letter RIII-93-007.

This violation resulted from your failure to promptly recognize, l adequately assess (including an appropriate operability l determination), and correct the fouling, deformation, and

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cracking of the RHR strainers and the unacceptable level of cleanliness of the suppression pool. Additionally, management '

involvement in identifying and eliminating the source of fibrous materials in the suppression pool was inadequate. Finally,

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management coordination of the cleaning activities in the drywell and containment was insufficient. The potential safety consequence of the violation'is that as a result of debris in the l

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drywell, containment, and suppression pool, the RHR A and B strainers became fouled beyond their design basis such that the RHR system may not have been able to provide long term cooling for the design assumed 100 days of continuous post loss-of-coolant accident operation without operator intervention.

The failure of your personnel to quickly recognize the safety significance of suppression pool cleanliness is of particular concern in light of the serious safety consequences of strainer fouling and prior NRC and industry notifications addressing this r.rtter. The repeated missed opportunities to identify and correct unacceptable suppression pool cleanliness conditions and to fully and effectively implement all of your corrective actions after the conditions had been identified reflect weaknesses in your ability to promptly identify and correct conditions that could degrade operability of plant safety equipment, a significant failure to effectively communicate your management expectations to supervisors and workers and to assure those expectations are properly implemented. In addition, your failure to assure proper cleanup of the containment and drywell is of particular concern given your commitments to the NRC and the resulting high visibility of this activity within your company, as well as your substantial commitment of resources.

At the enforcement conference we acknowledged your most recent corrective actions for the violations, including the programs and initiatives you are undertaking to improve performance at Perry.

While you now appear to be taking appropriate steps, proper oversight by you and your management-team is needed to assure that the desired results are achieved. Many of these programs and initiatives involve changes in the operating philosophy of the organization. The success of these changes depends on the ability of you and your management team to maintain a proper safety focus, to instill sound safety values at all levels of the organization, performance.

and to translate those values into improved plant The violation' represents a significant failure to take corrective actions which resulted in the RHR system being degraded to the extent that it may not have been capable of performing its accident response function. Therefore, in accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, this-violation has been categorized at Severity. Level III.

To emphasize the need for appropriate operability determinations, and prompt recognition, adequate assessment, and correction of nonconforming conditions, I have been authorized after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research to issue the enclosed Notice of

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Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $200,000 for the violation described in the Notice.

The base value of a civil penalty for a Severity Level III

violation is $50,000. The civil penalty adjustment factors in the Enforcement Policy were considered.

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l The base civil penalty was escalated 50 percent becaus2 the NRC

identified the violation. The base civil penalty was mitigated l 50 percent for your comprehensive corrective actions as presented l at the enforcement conference. The base civil penalty was l escalated 100 percent.for your poor past performance. In the L most recent SALP 12 report covering the period of November 1, l 1991,-through January 31, 1993, Safety Assessment and Quality

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Verification was rated Category 3. The areas of Maintenance and Surveillance, and Engineering and Technical Support were rated :

Category 2, but declining trends were noted in each area.

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Furthermore, you were cited for a Severity Level III violation with a civil penalty (reference EA 91-118, dated October 30, 1991), and several Severity Level IV violations in the past two :

years, dealing with ineffective management control and oversight, ;

and engineering related problems. Additional escalation of 100 '

percent was applied for the opportunity to identify the problem l provided by the issuance of NRC Information Notice 92-71 " Partial

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Plugging of Suppression Pool Strainers at a Foreign BWR" on l September 30, 1992. The base civil penalty was further escalated I

100 percent for duration. The significant potential for the RHR system not being able to perform its intended safety function existed from initial plant startup until March 1993. The other adjustment factor in the Policy was considered and no further adjustment to the base civil penalty is considered appropriate. j Therefore, based on the above, the base civil penalty has been increased 300 percent.

Section II of the Notice describes a violation not assessed a civil penalty involving an inadequate work order for performing a test run of RHR pump "B" on April 15, 1993.

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You are required to respond to this letter and should follow the j

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instructions specified in the enclosed Notice when preparing your response. In_your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of l

! future inspections, the NRC will determine whether further NRC l l

' enforcement action is necessary to ensure compliance with NRC regulatory requirements.

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"

a copy of this letter, its enclosure, and your responses will be l placed in the NRC Public Document Room.

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Centerior Service Company -5-The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No.96-511.

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.f/42f John B. Martin

Regional Administrator Enclosure:

Notice of Violation and Proposed *

Imposition of Civil Penalty cc w/ enclosure:

R. A. Stratman, Vice President, Nuclear R. W. Schrauder,_ Director, Nuclear Services Department D. P. Igyarto, General Manager, Perry Nuclear Power Plant K. P. Donovan, Manager, Licensing and Compliance Section N. L. Bonner, Director, Perry Nuclear Engineering Dept.

H. Ray Caldwell, General Superintendent Nuclear Operations Licensing Fee & Debt Collection Branch ~

Resident Inspector, RIII Terry J. Lodge, Esq.

James R. Williams, State of Ohio Robert E. Owen, Ohio Department of Health A. Grandjean, State of Ohio Public Utilities Commission

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Centerior Service Company DISTRIBUTION:

PDR SECY

,- CA JTaylor, EDO JSniezek, DEDR JLieberman, OE LChandler, OGC JGoldberg, OGC TMurley, NRR JPartlow, NRR Enforcement Cdordinators RI, RII, RIV, RV

, FIngram, GPA/PA DWilliams, OIG *

BHayes, OI EJordan, AEOD

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State of Ohio RAO:RIII SLO:RIII PAO:RIII IMS:RIII

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