ML20043H499

LER 90-012-00:on 900522,loose Matl,Consisting of Masslin Cloths & Stepoff Pad,Discovered in Upper Containment.Caused by Failure to Follow Procedures.Loose Items Removed & Cleanliness Procedures revised.W/900621 Ltr

ML20043H499
Person / Time
Site:	McGuire
Issue date:	06/21/1990
From:	Mcconnell T, Sipe A DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-012-02, LER-90-12-2, NUDOCS 9006260026
Download: ML20043H499 (8)

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(704)8754000

, * , . " , Duke.htcGuire 1%urtNuclear Company Station '

I2700 flagers Ferry Road flunternille, NC28018 8983 DUKE POWER June 21,'1990' I

U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

Subject:

McGuire Nuclear Station Unit 1 l

Docket No. 50-369 Licensee Event Report'369/90-12 Gentlemen:

Pursuant to 10 CFR 50.73 Sections (a)(1) and (d), attached is Licensee Event Report 369/90-12 concerning loose material found in upper containment during unit operation. This report is being submitted in accordance with 10 CFR .

50.73(a)(2)(f). This event is considered to be of no significance with respect to l the health and safety of the public. l l l 1

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-Very truly yours, j

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k T.L. McConnell l DVE/ADJ/cbl Attachment xc Mr. S.D.-Ebneter American Nuclear Insurers Administrator, Region II c/o Dottie Sherman, ANI Library l U.S. Nuclear Regulatory Commission The Exchange, Suit 245 101 Marietta St., NW, Suite 2900 270 Farmington Avenue Atlanta, GA 30323 Farmington, CT. 06032 INPO Records Center Mr. Darl Hood

1. Suite 1500 U.S. Nuclear' Regulatory Commission 1100 Circle 75 Parkway Office of Nuclear Reactor Regulation

? Atlanta, GA 30339 Washington, D.C. 20555 M&M Nuclear Consultants Mr. P.K. Van Doorn I 1221 Avenue of the Americas NRC Resident Inspector l New York, NY 10020 McGuire Nuclear Station 9006260026 900621 4

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bxc B.W. B11nei L.G. Bost.

J.S. Warren-R.L. Gill'-

C.L. Hartzell (CNS)'

R.S. Matheson (ONS)- 1 P.R. Herran-- 1' S.S. Kilborn'(W)-

R.E. Lopez-Ibanez l M.A. Mullen R.O. Sharpe (MNS)

.G.B. Swindlehurst-K.D. Thomas M.S. Tuckman' l- L.E.! Weaver R.L.. Weber

~J.D.:Wylie (PSD)

J.W. Willis QA Tech. Services'NRC Coordinator (EC 12/55)

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"'. Loose Material Was Located In Upper Containment During Unit Operation Because Of An Inappropriate Action SVENT DAf t (S) LtR Nuts 04R 16) Rt* ORT DAf t (7) OTHER f ACitifill INVOLV40181 MONTH DAv yt A81 vtAR %V$

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Loose uterial was discovered in the Unit 1 Upper Containment on May 22, 1990 at l 1100. Unit I was !n Mode 1 (Power Operation) at the time of the event discovery.

l Unit I had entered Mode 3 (Hot Standby) on May 14, 1990 at 1339. The loose material present in containment resulted in a surveillance requirement of Technical Specification 3/4.5.2 not being met. The loose material was immediately removed. Subsequently, an inspection was conducted of the Unit 1 lower containment outside of the crane well. No loose material was found. This event is assigned a cause of Inappropriate Action resulting from Failure to Follow Procedure. This event will be covered with appropriate personnel.

Applicable procedures will be reviewed and changed as necessary.

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l l EVALUATION:

L Background i

Technical Specification 4.5.2 e requires: "Each Emergency Core Cooling System i (ECCS) subsystem shall be demonstrated operable by a visual inspection which

! verifies that no loose debris (rags, trash, clothing, etc.) is present in the g' containment which-could be transported to the Containment Sump and cause i restriction of the pump [EIIS:P] suctions during LOCA conditions." This visual l inspection shall be performed:

1) For all accessible areas of the containment prior to establishing containment integrity, and l

2) Of the areas affected within containment at the completion of each containment entry when containment integrity is established."

l l Technical Specification 4.5.2 is applicable in Mode 1 (Power Operation), Mode 2 I l (Startup), and Mode 3 (Hot Standby). l l

The operability of two independent ECCS subsystems ensures that sufficient l

. emergency core cooling capability will be available in the event of a LOCA assuming the loss of one subsystem through any single failure consideration.

I> Either subsystem operating in conjunction with the accumulators (EIIS:ACCi is j

. capable of supplying sufficient core cooling to limit the peak cladding 1 temperatures within acceptable limits for all postulated break sizes ranging from d the double ended break of the largest Reactor Coolant (EIIS:AB) system cold leg I pipe downward. In addition, each ECCS subsystem provides long-term corc coolin;;

capability in the recirculation mode during the accident recovery period.

Description of Event 1

On May 11, 1990, Quality Assurance (QA) personnel and Janitorial Service (K-MAC) l l

personnel performed a cleanliness inspection of upper and lower containment. The 1

inspection was performed in preparation to enter Mode 4. Procedure l PT/1/A/4600/03F, Containment Cleanliness Inspection, was used to document inspection of the following areas in upper and lower containment: upper ice condenser [EIIS:COND], top of ice condenser, operating deck level, refueling i L cavity,' top of the steam generator [EIIS:SG) and pressurizer [EIIS:PZR) l l ,

enclosures, lower ice condenser, seal table area, steam generator and enclosures, cold leg accumulator rooms, lower containment ventilation air handling unit

[EIIS:AHU) rooms, pipechase and around the reactor coolant [EIIS:AB) loops. QA personnel signed _off the procedure steps and the containment cleanliness l acceptable step in the Mode 4 checklist of procedure OP/1/A/6100/01, Controlling L Procedure for Unit Startup. (This procedure step does not specifically require i signof f by QA personnel.) This procedure also contains a step specifically l L requiring QA's signature for QA containment cleanliness acceptability, j Unit 1 entered Mode 4 on May 12 at 1137. On May 14 at 1339, Unit 1 entered Mode l 3. On May 22 at 1100, a Radiation Protection (RP) technician discovered the go~. ..... m , i,.. . ..... - ,

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0l0 l3 or l6 TEXT te mene esse e reeweg ese adulgener MIC #enn m W (In following unsecured items in upper containment: 2 rope stanchions, 1 stanchion base, a housekeeping log podium, a stepoff pad and 2 packs of masslin cloths.

The RP technician informed an Operations technician and these two individuals removed all of the items they could-carry when they exited containment. The RP l technician reported the problem to RP supervision and the Operations technician reported the problem to the Shift Manager. The Shift Manager contacted the Reactor Building Coordinator (RBC) and requested that the situation be investigated.

The RBC entered upper containment to inspect for items that should not be there. .'

He identified three additional stepoff pads which were taped down, a 2 foot section of handrail that was not secured and several RP signs taped to the handrails around the refueling cavity. The RBC worked with RP personnel to remove these items and the remaining loose items identified by the RP technician ~

i and the Operations technician.  ;

Technical Specification Surveillance Requirement 4.5.2 e was violated on May 14 at 1339'when Unit 1 entered Mode 3. Also, the Technical Specification requiring ECCS operability (Technical Specification 4.5.3.1) was violated on May >

p 12, 1990 when Unit 1 entered Mode 4, Conclusion 4 During an outage, the RBC monitors the cleanliness of the Reactor Building. Work groups are contacted to remove items left behind throughout the outage. If the responsible work group can'not be identified for specific items, the RBC removes the items. K-MAC personnel are requested to clean whenever it is necessary.

L Prior sto the performance of the Containment Cleanliness Inspection, RP personnel l generate a list of items that will be left in lower containment but will be removed prior to unit startup. RP personnel give the list to the RBC and/or QA personnel. RP personnel have never generated a list of items remaining in upper l containment in the past because they did not see a need for it. This practice lx will be evaluated and incorporated as necessary into the Containment Cleanliness Inspection procedure for upper and lower containment.

This incident is assigned a cause of Inappropriate Action for failure to follow procedure. QA personnel did not document loose material located in upper containment on Enclosure 13.1 as required by the containment cleanliness

' inspection procedure. The acceptance criteria of the procedure reads: "No loose material is present in containment which can be transported to the containment sump and.cause restriction of the ECCS pumps suction during accident conditions."

QA personnel performed the Housekeeping Inspection of containment just prior to the Unit entering Mode 4. Generally, it takes approximately another 8 to 10 days before the Unit goes on line. During this time period, numerous entries are made into containment. Once the Unit enters Mode 4, anyone who enters the Reactor Building must meet the requirements of Station Directive 3.1.8, Access to the Reactor Building. Personnel are responsible for ensuring that the area in which they worked is left clean; i.e., no loose debris is present which could be transported to the containment sump. The Reactor Building closeout checksheet documents that this requirement has been met. The checksheet should be completed by each work group and returned to the Shift Manager. From the time the Unit g cau au ....cro nu o.u s mom

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. m .amme nenw amew nn enters Mode 4 until the Unit is on line, numerous entries are made into the Reactor. Building. RP personnel maintain established radiation control zones (RCZs) and/or establish new zones as localized " hot" spots are identified. As required by RP procedures, RP personnel maintain maps of these areas. It-has been the opinion of the site QA group that RP personnel, based on RP requirements, identify and mark RCZs and then remove material when it is no longer needed. QA personnel believed that RP personnel would remove their items

. prior to startup of the unit. QA personnel stated that their focus while performing the procedure was to identify maintenance generated items left from the outage and they did not look for "RP" type items. This mindset led to the failure to follow procedure.

A review of the Operating Experience Program (OEP) Data Base for the previous 24 months prior to this event revealed five LERs involving TS violations because of Inappropriate Action resulting from failure to follow procedure. These LERs were l 369/89-16, 370/89-08, 370/89-13, 369/90-03, and 369/90-05. However, the events involved different equipment and administrative controls. The corrective actions were specific to those five events and would not have prevented this event from occurring; therefore, this event is not considered recurring.

The problem of TS violations because of Inappropriate Actions resulting from I failure to follow procedure is recurring.

The problem of loose material in containment is considered to be recurring. QA  ;

Departmental Audit NP-89-21 (MC) conducted during the period of June 17, 1989 '

through August 18,-1989 identified the following follow-up item:

" Housekeeping and material control practices observed in threa areas of.the plant, considered to increase the potential of adversely affecting the safe operation of plant equipment."

One of the areas cited was the Unit 1 Reactor Building Operating Deck. Unsecured mop heads were being used for spill control on the operating floor adjacent to the refueling canal. RP personnel and K-MAC personnel had positioned the mop heads to contain condensation that was collecting to prevent the spread of contamination. Unit I was in Mode 1 at the time of discovery.

During this investigation, it was determined that the follow-up item identified in the QA audit had not been reported to the NRC as required by the LER rule (10CFR50.73). Corrective actions taken in response to the follow-up item were: I

1) The identified mop heads in Unit 1 Containment Building were removed immediately.

2) Station Directive 3.1.8 was reviewed to assure requirements for the recorded entry of each individual and the accountability of all materials. i l

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3) Management requested a review of these controls with employees through regular supervision meetings to emphasize the importance of no loose materials in the Containment Buildings during operational modes.

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4) An INFORM (Information Needed For McGuire) Bulletin was issued to all-l station personnel highlighting changes to Station Directive 3.1.8 and re-emphasizing housekeeping responsibilities for the Reactor Building.

This event is not reportable to the Nuclear Plant Reliability Data System (NPRDS).

There were no personnel injuries, radiation overexposures, or uncontrolled

• releases of radioactive material as a result of=this incident.

CORRECTIVE ACTIONS:

i_ Immediate: 1) Operations and RP personnel and the RBC removed the loose

! items from upper containment.

Subsequent: 1) Operations and RP personnel entered lower containment outside the crane wall and inspected for loose material.

l f 2) This event was discussed with the personnel involved.

Planned: 1) This event will be reviewed with appropriate QA personnel.

2) Integrated Scheduling (IS) and Operations personnel will obtain specific guidance as to what items may remain in containment and what methods are acceptable'to secure items remaining in containment.

3) IS personnel will discuss this event with the Shift Managers to ensure that consistent requirements are applied.until the guidance from planned corrective action 2 is determined and can be implemented.

4) OPS, QA, IS and RP personnel will revise-procedure PT/1/A/4800/03F, Containment Cleanliness Inspection, to provide a clear understanding of the responsibilities of all station groups pertaining to performing the procedure.

IS personnel will evaluate changing Station Directive 3.1.8,

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Access to The Reactor Building, based on the results of planned corrective action 2.

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6) Operations personnel will evaluate changing procedure PT/1/A/4800/03F, Containment Cleanliness Inspection, based on the results of planned corrective action 2.

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SAFETY ANALYSIS

} 1e Final Safety Analysis Report Section 6.5.2 describes the containment sump . I structure. The containment sump structure consists of an outer trash rack made of stainless steel grating to prevent large debris f rom reaching the inner screen (EIIS:SCN). A fine mesh screen is provided to prevent particles larger than 0.206 inches in diameter from passing through.

1 Dense debric (specific gravity greater than 1) settles before reaching the i containment sump structure. There is an approximate minimum time of twenty minutes for particles to settle during a LOCA before any suction is taken from the sump. This twenty minutes also allows the water level to rise above the l coverplate, thus preventing floating debris f rom blocking the screen, i Items identified in this event which could have possibly entered the containment sump and caused restriction are the canvas, the scepoff pads, the tape and the u.asslin cloths. The other items were of sufficient weight and size that it is unlikely they would have been transported to the containment sump during LOCA conditions.

t At no time during the period the loose material was in upper containment were the-i ECCS subsystems required. No events occurred which challenged the ECCS

. subsystems to perform their safety functions.

The health and safety of the public were not affected by this incident.

s NXC FORM 344A 'U'8' GPC' 1188 -120 ~ 984 800 D e 83J *a