IR 05000440/1996015

Enforcement Conference Rept 50-440/96-15 on 961011.Major Areas Discussed:Apparent Violations Noted Re ECCS Being Inoperable & Corrective Action Issues

ML20129H461
Person / Time
Site:	Perry
Issue date:	10/25/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129H446	List: IR 05000440/1996015 ML20129H442
References
50-440-96-15-EC, NUDOCS 9610310304
Download: ML20129H461 (35)

Text

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l U.S. NUCLEAR REGULATORY COMMISSION REGION lil

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Docket No: 50-440  !

License No: NPF-58

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Report No: 50-440/96015(DRS) l l

Licensee: Cleveland Electric lliuminating Company Facility: Perry Nuclear Power Plant Location: Parmly at Center Road Perry, OH 44081 Date: October 11,1996 ,

Inspector: Eric Duncan, Reactor Engineer Approved by: M. A. Ring, Chief, Lead Engineering Branch Division of Reactor Safety Meetina Summarv l

Four apparent violations identified during the inspection were discussed, along with the corrective actions taken or planned by the licensee. Two of the apparent violations involved technical specification limiting condition for operation action requirements which were exceeded. One of these involved a 45 hour5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> period where the emergency closed cooling system was inoperable, and the actions required by Technical Specification 3. were not completed. The remaining two apparent violations involved corrective action issues, in one case corrective actions were neither timely nor adequate to address a leaking safety-related motor-operated butterfly valve. In a second case, corrective actions failed to correct an adverse condition regarding the ability to operate safety-related control room complex chillers at low lake temperature PDR ADOCK 05000440 g PDR ._

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Report Details Persons Present at Conference Centerior Service Company

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L. Myers, Vice President, Perry N. Bonner, Director, Perry Nuclear Engineering Department W. Kanda, Director, Perry Nuclear Assurance Department R. Collings, Director, Perry Quality Assurance Department F. Kerney, Plant Operations Superintendent, Perry

H. Oates, Design Engineer, Perry U. S. Nuclear Reaulatorv Commission W. Axelson, Acting Deputy Regional Administrator, Rlli G. Grant, Director, Division of Reactor Safety, Rlli M. Ring, Chief, Lead Engineering Branch, Rlli R. Lanksbury, Chief, Division of Reactor Projects, Rlli D. Kor.loff, Perry Senior Resident inspector J. Hopkins, Perry Project Manager, NRR B. Burgess, Enforcement Director, Rlli P. Pelke, Enforcement Specialist, Rlli B. Berson, Legal Counsel, Rlll Pre-decisional Enforcement Conference A Pre-decisional Enforcement Conference was held in the NRC Region lli Office on l October 11,1996. Apparent violations of NRC regulations were discussed. The i inspection findings were documented in NRC Inspection Report No. 50-440/96008, which was transmitted to the licensee by letter dated September 27,1996. The purpose of this conference was to discuss the apparent violations, root causes, contributing factors, and the licensee's corrective cction The licensee's presentation included a discussion of the apparent violations, their safety significance, the circumstances which caused the apparent violations, and an outline of corrective actions taken or planne The NRC representatives questioned the licensee to clarify the extent of the licensee's investigation and corrective action A copy of the handouts used during the presentation is attached to this repor Attachment: As stated

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Perry Xuclear Power Plant . - =

Pre-Decisional Enforcement Conference Presentation to the U.S. Xuclear Regulatory Commission

October 11,1996

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Discussion Topics

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Introduction Lew Myers i

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Emergency Closed Cooling (ECC) Russ Kearney System Overview

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ECC Valve Leakage Neal Bonner/

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Russ Kearney ;

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ECC System Temperature ~ Control Harry oates Modification

Corrective Action Program Issues Rick Collings/

Bill Kanda

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Summary Lew Myers

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Introduction '

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Both issues involve the Perry Emergency Closed Cooling system; however, the circumstances are unrelate .

Opportunities to understand the issues and take correc~tive actions did exis !

History of corrective action issues are well documente *

The implications of management controls were significan *

The potential loss of the Emergency Closed Cooling system was significant; however, after both issues were identified, risk was minimize .

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Desired Outcome g_

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Obtain a common understanding of the fact :

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Provide a common understanding that timeliness of both issues was appropriate for the known design base L

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Provide a common understanding of the safety significanc Provide assurance that the Perry Management Team is dedicated to identification, communications, and prompt corrective actions for i station problem The NRC will determine that escalated enforcement is not necessary for these issue Page 5

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-i ECC System Overview

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i Russ Kearney

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e i-i ECC Valve Leakage

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Presented by:

Neal Bonner Russ Kearney i

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ECC Valve Leakage '

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Sequence of Events t

Safety Significance

• Root Causes

Corrective Actions

Issue Summary Page 9

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Sequence of Events

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7/1/93 ECC "A" surge tank overflowe Temporary Instruction (TXI) - 162 written to determine source and rate of i leakag *

7/1/93 Motor operated butterfly valve OP42-F0295A determined to be leaking greater than 250 gpm. This was the first leak test performed on this valv Valve OP42-F0295A adjusted and retested; returned to zero leakag .

Field Clarification Request (FCR) 17843 initiated to determine allowable ECC system leakagerat i

7/6y@3 Condition Report (CR)93-132 initiated (first day after Holiday weekend); determined to not be a Technical Specification violatio *

7/7/93 CR 93-132 initially determined by Regulatory Affairs Section to not be ,

reportable; the scenario necessary for ECC train / system inoperability was not known at that tim .

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8/25/93 CR 93-132 root cause investigation completed. Initial cause investigation inadequate; independent external review of reportability being performe /1/93 CR 93-132 inve'stigation approved by Engineering managemen :

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12/15/93 External review received which determined ECC could have failed to i

meet its safety function under certain design basis scenario '

12/30/93 Issue was reported to the NRC as a loss of safety function of the ECC  :

system after internal review of contractor's report and a historical reconstruction of issue sequenc *

7/23/94 LER 93-021, " Loss of Safety Function for Emergency Closed Cooling System A," was issue i

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Safety Significance

Scenario assumption Loss of Offsite Power (LOOP)/ Loss of Coolant Accident (LOCA)- Nuclear Closed Cooling (NCC) unavailable due to loss of stub bu Division 2 diesel generator inoperable - ECC "B" fails to functio Make-up capability unavailabl ,

ECC system was only vulr .rable for approximately 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> due to Emergency Service Water (ESW) work. During a portion of this time, ESW was only " administratively" inoperabl Probability Safety Assessmen LOOP /LOCA-5x104

- LOOP /LOCA coincident with division 2 diesel generator inoperability - 1.6x10-7

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NOTE: ECC "A" would have isolan:1 during LOOP /LOC l Y

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Root Causes

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Initial review and classification of ECC/NCC isolation valve (0P42-F0295A) was as an ASME Code,Section XI, Category "B" valv Subsequent evaluation and review of FCR 17843 failed to adequately address design bases leak requirement The need to reclassify the valve was recognized; however, this action was not adequately resolved in the CR evaluation and corrective action *

Improper Settings of ECC/NCC isolation valve (0P42-F0295A).

Combination of personnel error and weak procedural direction for setting MOV limit switches and mechanical stops in 1993. This maintenance was performed to correct a previously identified concer Leakage test was not performed since leakage criteria had not been  !

establishe Page 13

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Root Causes (cont.)

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ECC leakage corrective action issue '

FCR evaluation was inappropriately used as design inpu ;

Inadequate initial work history review (extent of condition).  ;

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Flawed cause analysis aid inadequate management revie Work and corrective action backlogs adversely affected the timeliness of some action ;

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Corrective Actions

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Actions Taken Prior to July 199 Reviewed other safety-related systems for similar conditions, reviewed wcrk/ testing history, and ensured properly set limit switches. No other similar concerns were identifie Appropriate Maintenance personnel trained; lessons learned were shared with site personne Post-maintenance testing practices have been, and continue to be, enhanced; ,

procedural direction wu revise FCR processes and controls revise Valve has been leak tested within frequency specified for Category "A" valves as a result of Generic Letter 89-10 and preventive maintenance activitie Actions to reduce backlogs were implemente Page 15

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Corrective Actions (cont.) '

Other corrective actions taken since issue identification in July 199 Valve leakage criteria has been establishe The In-Service Testing program has been revised to identify these valves as Category "A." Associated testing procedures are being revise i The applicable Alarm Response and Off-Normal Instructions have been j revised to delineate required operator action !

An extent of condition review is being re-performe ;

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Issue Summary

Self identifie *

Actions taken at the time were reasonabl *

Corrective actions have.resulted in improved

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Engineering processe Risk significance was minimize Page 17 l'

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.i ECC Temperature Control Modification

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ECC Temperature Control Modification

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Sequence of Events

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2/86 Control Complex Chiller trips on low refrigerant temperature due to low  !

lake water temperature t

4/86 Design Change Package (DCP) 86-0224 initiated to alleviate low lake water temperature concern *

2/94 - 3/94 During Residual Heat Removal system heat exchanger '

performance testing, with ESW system flow reduced by the 3" by-pass line, the ECC system temperature is observed drifting below 55 oF. LER 94-05 submitted as a condition prohibited by Technicsl Specifications and as any condition that alone could have prevented the fulfillment of the safety functio t i

The 3" diameter bypass line sizing calculation did not consider minimum heat load Operator guidance was established to throttle ESW flow using the 3 inch bypass valv A modification (i.e., DCP 94-0027) was initiated to control ECC system temperatures ,

with varying lake water temperature l t

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Sequence gf Events (cont.)

10/94 Design approach shifted from ESW flow control to ECC flow control. It was determined that from a safety perspective, modification should not be installed while the plant was on-line. LER was revise *

$95 DCP 94-0027 was issue Calculation P42-30 concluded that with minimum or no ECC loads, the valve will by-  ;

pass 90% of system flow with stable contro '

10/95 DCP 94-0027 was revised to incorporate TXI-0230 as the post modification test. Precautions were delineated to prevent temperature from dropping below 55 o *

2/96 - 3/96 DCP 94-0027 implemente i

3/96 Following installation of DCP 94-0027, the ECC system was operating with no system loads, and full ESW system flow, when temperature was i observed to be decayin Flow induced (vortexing) heat transfer at the heat exchanger discharge piping, coupled with potential convective heat losses, resulted in the deca The effect of this phenomena was not expected nor assumed in calculation Page 21 ,

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had been running for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to cool the static water .

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m Safety Significance .

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Concerns do not exist during normal or accident configuration ;

Adequate heat load is available when system is in normal line-up and when  !

required to perform its safety functio '

The testing configuration is the only line-up during which the ECC . ,

temperature control modification may not perform its function; low lake '

water temperature also require The rate of temperature decay is slow relative to the normal duration (i.e., less than 30 minutes) in which the test evolution occur ;

Operator actions ensured the system remained operable throughout  ;

the fifth operating cycle, while the design process proceeded in a  ;

controlled and scheduled manne :

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Root Causes

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Heat transfer mechanisms associated with the new ~

configuration were not recognized as being significant during design development / revie ;

TXI-0230 failed to confirm the adequacy of the desig Design assumptions inherent to the design of the modification  !

were not confirmed by post modification testin ;

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Procedural direction has been developed to avoid challenging the ECC system.

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Additional actions are being evaluated: '

Post-modification testing development methodology is being evaluate '

Control Complex chiller setpoint evaluation is being performe i t

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Issue summary

Selfidentifie ,

Risk significanc ,

Condition only existed during testing configuration '

Actions taken were reasonable. Modification did evaluate the ECC system against all potential plant configurations, including those present during periodic testin *

The modification has improved system performanc .

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Corrective Action Program Issues

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i Presented by: l Rick Collings Bill Kanda i

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t Corrective Action Program Issues

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Identified weaknesses in the program are well documented (1992-1993).

Inconsistencies in program utilization and problem identificatio ,

Root cause determinations were sometimes incomplete or incorrec .

Not fully effective and timely in correcting problem ,

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Corrective Action Program Issues (Cont.)

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Improvement actions initiated starting in Fall 199 Perry Course of Action / Perry Plan for Excellenc Post modification / maintenance test manua Change in documentation threshold and management expectation Complete revision / approach to Corrective Action progra Root cause and extent of condition emphasized, including additional formal root cause analysis trainin Establishment of a Corrective Action Review Boar Site and industry experience reviews integrated into proces Trend analysis and categorization proces .

Performance indicators establishe Page 30

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Summary

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Ensure a common understanding of the facts, including the timeliness of actions associated with the Emergency Closed Cooling / Nuclear Closed Cooling valve leakage, which was based on what was known at the tim Use of the Technical Specifications during the time of the issue did not result in entry into the action statement, due to the failure of the design to recognize that the isolation ,

valves should be considered Section XI Category "A" valves. Prompt actions were taken to properly set the limit switches and leak rate tests have been, and continue to be, performe During the time period in question, the Emergency Closed Cooling system would not ,

have failed without a design basis scenario, which includes a LOOP /LOCA and a loss of the division 2 diesel generato *

Emergency Closed Cooling temperature control modification implementation was timely. This modification did improve the operations of the control room '

chiller syste *

Opportunities existed to identify both issues. Consideration should be given for self identification, time frame, and corrective actions taken for each issu *

The Perry Management Team is dedicated to prompt identification, communication, and corrective actions for station problem ,

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