IR 05000440/1993015

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Enforcement Conference Rept 50-440/93-15 on 930720.Areas Discussed:Apparent Violations Involving Failure to Adequately Identify & Correct Conditions in Drywell, Containment & Suppression Pool to Preclude Fouling
ML20046B217
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 07/23/1993
From: Lanksbury R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20046B214 List:
References
50-440-93-15-EC, EA-93-176, NUDOCS 9308030319
Download: ML20046B217 (33)


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U. S. NUCLEAR REGULATORY COMMISSION REGION III.

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Report No.

50-440/93015(DRP)

EA 93-176

Docket No. 50-440

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License No. NPF-58 Licensee:

Cleveland Electric Illuminating Company

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Post Office Box 5000 Cleveland, OH 44101

t Meeting Conducted:

July 20, 1993 Mseting Location: Region III Office 799 Roosevelt Road Glen Ellyn, IL 60137 Type of Meeting:

Enforcement Conference Inspection Conducted:

Perry Nuclear Power Plant May 1 through June 23, 1993 Inspectors:

D. Kosloff A. Vegel Approved By:

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} M -U JR /D. Lanksfury, Chief Date

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Reactor Projects Section 3B Meeting Summary

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Enforcement Conference on July 20. 1993 (Report No. 50-440/93015(DRP)

i Areas Discussed: Two apparent violations identified during the inspection

were discussed along with the corrective actions taken or planned by the-

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licensee. The apparent violations involved the failure to adequately identify I

and correct conditions in the drywell, containment, and suppression pool to

preclude fouling and deformation of emergency core cooling system strainers; and the failure to have an adequate procedure to test the "B" residual heat

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removal pump.

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DETAILS

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Persons Present at the Enforcement Conference Centerior Service Company D. Shelton, Senior Vice President - Nuclear R. Stratman, Vice President - Nuclear, Perry D. Igyarto, Plant Manager, Perry Nuclear Power Plant (PNPP)

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R. Schrauder, Director, Perry Nuclear Support Department K. Donovan, Manager, Licensing and Compliance Section, PNPP N. Bonner, Director, Perry Nuclear Engineering Department H. Hegrat, Supervisor, Compliance Unit, PNPP D. Cobb, Superintendent of Plant Operations, PNPP K. Phyfer, Public Affairs U. S. Nuclear Regulatory Commission J. Martin, Regional Administrator, Region III E. Greenman, Director, Division of Reactor Projects, Region III J. Hannon, Director, Project Directorate III-3, Nuclear Reactor Regulation (NRR)

L. Greger, Chief, Reactor Projects Branch 3, Region III B. Berson, Regional Counsel, Region III R. Lanksbury, Chief, Reactor Projects Section 3B, Region III F. Jablonski, Chief, Maintenance and Outage Section, Region III

D. Kosloff, Senior Resident Inspector, Region III J. Hopkins, Project Engineer, Region III R. Stransky, Project Manager, NRR J. Hickman, Strainer Project Manager, NRR

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M. Bielby, BWR Examiner, Region III P. Pelke, Enforcement Specialist, Region III E. Duncan, Reactor Engineer, Region III 2.

Enforcement Conference An enforcement conference was held in the NRC Region III Office on July 20, 1993. This conference was conducted as a result of the findings of an inspection conducted from May I through June 23, 1993, in which two apparent violations of NRC regulations were identified.

Inspection findings were documented in inspection report (IR) 50-440/93011(DRP), dated July 12, 1993.

The purpose of this conference was to discuss the violations, root causes, contributing factors, and the licensee's corrective actions.

During the enforcement conference, the licensee discussed the two apparent violations. The licensee's presentation covered the event investigation, safety significance, causes, and corrective actions.

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In addition to the factual information documented in IR 50-

440/93011(DRP), the licensee's presentation indicated that fouling problems had been identified during pre-operational testing.

In addition to the corrective actions documented in IR 50-440/93011(DRP), the licensee's presentation indicated that the following additional corrective action had been taken:

Specific individuals were counselled.

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A site-wide memorandum which addressed the importance of plant cleanliness was issued.

The reporting process for items dropped into the suppression was

reaffirmed.

Signs were posted to increase personnel awareness of the

importance of suppression pool cleanliness.

  • Containment cleanliness conditions were evaluated by BWR-6 peers.

The plant startup instruction was revised to require a containment

and drywell inspection by the shift supervisor prior to startup.

  • The repetitive task for the installation and removal of the drywell and containment ventilation system roughing filters was revised.

In addition to the corrective actions documented in IR 50-440/93011(DRP), the licensee's presentation indicated that the following additional corrective action were planned or under consideration:

An emergency operating procedure for the monitoring and

backflushing of ECCS strainers.

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Improvements to residual heat removal instrumentation and the

addition of remote indication.

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Suppression pool cover enhancements for use during outages.

  • Improved use of strippable coating in the containment and drywell.

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Submarine use for suppression pool inspection and cleaning.

Improved work practices.

Improvements to the suppression pool cleanup system.

  • An evaluation of suppression pool thermal stratification effects.
  • Personnel training to the improved cleanliness requirements.
  • An audit of the incident response team's corrective actions.
  • A review of the pre-operational test program for lessons learned.

A review of the Operating Experience Review program's

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effectiveness.

A copy of the licensee and NRC presentation is attached to this report.

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Attachments:

As stated

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Donald C. Shelton - Sr. Vice President, Nuclear Robert A. Stratman - Vice President, Perry David P. Igyarto - General Manager, Perry Nuclear

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Power Plant Department Robert W. Schrauder - Director, Perry Nuclear Support Department

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Neal L. Bonner - Director, Perry Nuclear Engineering Department Kevin P. Donovan - Manager, Licensing and

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Compliance Section

Donald K. Cobb - Superintendent of' Plant Operations Henry L. Hegrat - Supervisor, Compliance Unit

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CENTERIOR STRAINERFOULING

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Donald C. Shelton - Sr. Vice President, Nuclear Robert A. Stratman - Vice President, Perry David P. Igyarto - General Manager, Perry Nuclear

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Power Plant Department

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Robert W. Schrauder - Director, Perry Nuclear

Support Department i

Neal L. Bonner - Director, Perry Nuclear Engineering Department l

Kevin P. Donovan - Manager, Licensing and

Compliance Section i

Donald K. Cobb - Superintendent of~ Plant i

Operations Henry L. Hegrat - Supervisor, Compliance Unit i

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LENTERIOR STRAINER FOULING e-

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i Donald C. Shelton - Sr. Vice President, Nuclear Robert A. Stratman - Vice President, Perry David P. Igyarto - General Manager, Perry Nuclear Power Plant Department

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Robert W. Schrauder - Director, Perry Nuclear Support Department Neal L. Bonner - Director, Perry Nuclear

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Engineering Department

Kevin P. Donovan - Manager, Licensing and Compliance Section i

Donald K. Cobb - Superintendent of Plant Operations Henry L. Hegrat - Supervisor, Compliance Unit

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CENTERIOR

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STRAINERFOULING

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Sequence of Events Strainer Cleanliness History

Fouling problems identified during pre-operational testing

Strainers flushed of " soft crud" during RFO1 (1989)

Strainers not inspected or cleaned

in RFO2 (1990)

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STRAINER FOULING e herurrmon

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Sequence of Events l

Refueling Outage 3 - May 1992

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Significant strainer fouling

identified on videotape i

Not identified as challenge to e

operability

Strainer deformation overlooked

Strainer cleaning deferred to

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after startup

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CENTERIOR

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STRAINER FOULING e-24 i

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Sequence of Events

Mid-cycle Outage - January 1993 i

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Cleaned containment side of pool

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Strainers cleaned RHR A and B strainers damaged

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design

Review of past OPERABILITY initiated

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STRAINERFOULING Ce

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Sequence of Events

Service //ater Outage - March 1993

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RHR B strainer again damaged

OPERABILITY review completed

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e RHR B 72-hour test performed

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-Inadequate work order

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-Identified high fouling rate Operations Manager formed incident

Response Team

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Strainers replaced with new design

Drywell, containment, and suppression pool cleaned

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STRAINER FOULING e-

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Causes i

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e Personnel Performance Deficiencies

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Program Deficiencies j

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Design Deficiencies

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Causes i

Personnel Performance Deficiencies e

communications Housekeeping practices

Inspection practices

Sensitivity to cleanliness

effects on OPERABILITY Compliance with written

requirements Questioning attitude

Management involvement

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Causes

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Program Deficiencies Housekeeping procedural e

requirements Insufficient detail in repetitive e

task

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address strainer performance j

Operating instructions did not e

monitor RHR pump suction j

pressure No formal program in place to

detect presence of fibrous material in suppression pool

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Causes Design Deficiencies Design for drywell and containment

cooling systems included installed roughing filters

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Marginal strainer design

!4 Original design did not address l

need for backflush

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Corrective Actions Actions Taken - Personnel l

Specific individuals counselled

Site-wide memorandum addressed importance of plant cleanliness Reaffirmed reporting process for

items dropped into suppression pool Signs posted to increase personnel

awareness Personnel a

REGION 111 PERRY ENFORCEMENT CONFERENCE July 20,1993 10:00 A.M. (CDT)

EA 93-176 REPORT NUMBER 50-440/93011 REGION lil OFFICE 799 ROOSEVELT ROAD, BUILDING 4 GLEN ELLYN, ILLINOIS

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CHRONOLOGY OF SUPPRESSION POOL (SP)-

STRAINER FOULING

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4/15/93 Unsuccessful run of RHR B performed.

4/16/93 Confirmatory Action Letter 93-007 issued.

4/17/93 24-hour RHR B run performed, l

strainer deformation noted.

4/19/93 Licensee determined strainers may not meet design requirements.

5/19/93 RHR B testing performed, debris on RHR B strainer observed.

5/25/93 All ECCS systems tested with new strainers.

RI identified drywell/ containment debris.

5/26/93 All ECCS strainers declared operable.

5/27/93 Ris reinspected drywell.

5/31/93 Ris reinspected containment.

6/2/93 Plant restarted.

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CHRONOLOGY OF SUPPRESSION POOL (SP)

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STRAINER FOULING

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7/17/89 Poor SP cleanliness identified.

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5/22/92 Strainer fouling and debris in SP videotaped.

t 7/31/92 WR initiated to clean RHR strainers post

outage.

9/3/92 Licensee decided strainer cleaning should be performed in an outage and deferred

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cleaning.

1/8/93 Forced outage commenced due to leaking fuel.

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1/16/93-RHR strainer deformation noted.

NRs 1/19/93 initiated and strainers cleaned and dispositioned temporary use-as-is.

1/22/93 RI noted strainer NR.

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2/12/93 During SP cleaning strainer cracks noted; i

strainers replaced.

3/11/93 Plant restarted.

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3/26/93 Forced outage commenced for SW pipe break.

4/14/93 Strainer fouling identified.

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PERRY ENFORCEMENT CONFERENCE

Agenda July 20,1993 INTRODUCTION AND OPENING REMARKS:

Edward G. Greenman, Director, Division of Reactor Projects

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NRC OVERVIEW:

Edward G. Greenman, Director, Division of Reactor Projects CHRONOLOGY OF EVENTS:

Don Kosloff, Senior Resident Inspector, Perry i

SUMMARY OF APPARENT VIOLATIONS:

Don Kosloff, Senior Resident inspector, Perry LICENSEE PRESENTATION AND DISCUSSION:

Cleveland Electric illuminating Company NRC FOLLOWUP QUESTIONS CLOSING REMARKS:

John Martin, Region ill Administrator i

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i APPARENT VIOLATION i

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10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, l

requires, in part, that measures be established to assure that

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conditions adverse to quality are promptly identified and~

corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude l

repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action shall be documented and reported to appropriate levels of management.

CONTRARY TO THE ABOVE

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On July 17,1989, and May 22,1992, following the

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identification of debris in the suppression pool, and on May 22,1992, following observation of debris on the RHR

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"A" and "B" strainers (a significant condition adverse to quality) the licensee failed to promptly identify the cause

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for the poor cleanliness of the suppression pool N

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strainer fouling and failed to take adequate corre action to prevent repetition by cleaning the so;;

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pool. The strainer deformation and fouling was.

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documented and reported to the appropriate levels of management.

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Subsequent to the identification on January 16,1993, of i

strainer deformation and in February 1993 of the strainer fouling phenomenon (significant conditions adverse to quality) the licensee failed to identify the presence of fibrous material in the suppression pool as the cause of the condition and failed to take adequate corrective action to prevent repetition by removing the fibrous material from the suppression pool, drywell, and containment. This

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resulted in the recurrence of the RHR "B" strainer fouling and deformation identified on April 14,1993.

The apparent violations discussed in this enforcement conference are subject to further review and may be subject to change prior to any resulting enforcement action.

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Prior to May 25,1993, the licensee failed to take

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adequate corrective action to prevent repetition of fouling of the ECCS suppression pool suction strainers (a significant condition adverse to quality) in that additional

debris was not identified or removed in the drywell and in the containment rattle space.

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i The apparent violations discussed in this enforcement conference are subject to further review and may be subject to change prior to any

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resulting enforcement action.

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APPARENT VIOLATION i

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10 CFR Part 50, Appendix B, Crit ~erion V, Instructions, Procedures and Drawings requires in part that activities

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affecting quality be prescribed by documented instructions,.

procedures or drawings of a type appropriate to the circumstance. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been

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satisfactorily accomplished.

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CONTRARY TO THE ABOVE On April 15,1993, Work Order (WO) 930011944, for an

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activity affecting quality, was not appropriate to the circumstances in that it did not specify appropriate suction

pressure values or what action to take upon the receipt of abnormal values.

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i The apparent violations discussed in this enforcement conference are

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subject to further review and may be subject to change prior to any resulting enforcement action.

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