ML20057B927
| ML20057B927 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/18/1993 |
| From: | Langstaff R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057B922 | List: |
| References | |
| 50-440-93-18, NUDOCS 9309240156 | |
| Download: ML20057B927 (11) | |
See also: IR 05000440/1993018
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-440/93018(DRS)
Docket No. 50-440
License No. NPF-58
Licensee:
Cleveland Electric Illuminating Company
Post Office Box 5000
Cleveland, OH
44101
Facility Name:
Perry Nuclear Power Plant
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Inspection At:
Perry Site, Perry OH
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Inspection Conducted:
August 22 - 27, 1993
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Inspectors:
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Approved Byg ~ruce L. Burgess (Chief
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Operational Programs Section
Inspection Summary
Inspection on Auaust 22 - 27, 1993 (Report No. 50-440/93018(DRS))
Areas Insoected:
Reactive, announced safety inspection to review two issues
pertaining to emergency operating procedures (EOPs). The specific issues
reviewed were the ability of plant procedures to meet the intent of the
Boiling Water Reactor Owner's Group (BWR0G) guidelines for secondary
containment control and the effects of containment venting upon surrounding
buildings.
Results:
The licensee's recent actions taken to address issues pertaining to
E0Ps were, in general, comprehensive and conservative.
Issues pertaining to secondary containment control as a result of previous
inadequate reviews have been addressed. The licensee's recent review and
subsequent actions were comprehensive in nature.
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9309240156 930917
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Inspection Summary
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Appropriate interim corrective actions were taken in response to concerns
associated with the effects of containment venting upon surrounding buildings.
The most significant concern was the potential to overpressurize the fuel
handling building.
A. violation was identified because potential
overpressurization of the fuel handling building should have been identified
previously. However, no notice of violation will be issued because the
violation is within the scope of an existing violation for which corrective
actions were still ongoing.
Additional engineering analyses were planned in
order to fully address the concerns.
In general, communication and interdepartmental teamwork associated with
resolution of the above issues was considered good.
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REPORT DETAILS
1.
Persons Contacted
Cleveland Electric Illuminatina Company (CEI)
M. Bezilla, Manager, Operations
K. Donovan, Manager, Regulatory Affairs
C. Angstadt, Senior Project Engineer, Perry Nuclear Engineering Dept.
G. Chasko, Operations Engineer, Operations
V. Colacicco, Reactor Operator, PEI Improvement Team
,
W. Colvin, Member, Independent Safety Engineering Group
J. Lausberg, Supervisor, Quality Assurance
J. Messina, Operations Staff Supervisor, Operations
E. Ortalan, Senior Engineer, Perry Nuclear Engineering Dept.
J. Pelcic, Engineer, PEI Improvement Team
T. Rausch, PEI Coordinator, PEI Improvement Team
L. Routzahn, Compliance Engineer, Regulatory Affairs
P. Schuerger, Engineer, PEI Improvement Team
A. Silakoski, Member, Independent Safety Engineering Group
B. Stetson, Unit Supervisor, PEI Improvement Team
A. Widmer, Engineer, Perry Nuclear Engineering Dept.
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U.S. Nuclear Reaulatory Commission (NRCl
e
A. Vegel, Resident Inspector
All of the individuals listed above attended the management exit meeting
held on August. 27, 1993. Other people were contacted during the
inspection including members of the licensee's operations and
engineering staffs.
2.
Action on Previously Identified Items
a.
(0 pen) Open Item (440/91013-04): During an August 1991 inspection
(Inspection Report 50-440/91013), there was no evidence that the-
licensee had modified applicable plant procedures to meet the
intent of the Boiling Water Reactor Owner's Group (BWROG)
Emergency Procedure Guidelines (EPGs) for secondary containment
control.
An inadequate review of existing procedures formed the
licensee's basis for not revising the procedures. As a result of
the inadequate review, the licensee considered existing procedures
to meet the intent of the secondary containment control guidelines'
and the licensee presented this view to the NRC in a October 31,
1991 response to a licensing commitment.
In response to a ,
May 1993 inspection (Inspection Report 50-440/93007), the licensee
performed an additional review and identified that existing
procedures did not meet the intent of the secondary. containment
control guidelines. Applicable procedures were modified to meet
secondary containment guidelines. The 'resulting procedure changes
are discussed in Section 3 of this report.
Specific details
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concerning the review of the secondary containment control
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guidelines evaluated during this inspection are as follows:
(1)
Adeauacy of 1993 Review:
The inspectors evaluated the
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review performed in-1993 and considered the review to be
adequate in both depth and scope.
No concerns were
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identified with respect to the conclusions drawn or
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recommendations made. As a result of the 1993 review, the
licensee determined that existing plant procedures did not
meet, for many steps, EPG guidance for secondary containment
control guidelines and informed NRC Region III on August 13,
1993.
In general, existing procedures lacked specific
operator guidance for when ta enter an E0P flowchart for
reactor pressure vessel (RPV) control, shutting down the
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reactor, and emergency depressurization of the reactor for
conditions outside of the containment structure.
The review
evaluated by the inspectors was documented in the licensee's
draft report " Multi-Discipline Review of How Existing Perry
Instructions Meet the Intent of the BWROG EPG Secondary
Containment Control Guideline," dated August 26, 1993.
(2)
Information Reauested: During discussions held August 30,
1993 and September 3, 1993 between L. Routzahn of Centerior
Energy and R. Langstaff of the NRC, it was agreed to delay
submittal of licensee's evaluation concerning secondary
containment control until issuance of this inspection
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report.
The inspectors requested that the following
information be provided as part of the submittal:
(1) a
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summary of the report developed to determine how existing
instructions met the intent of the secondary. containment
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control guideline; and (2) any corrections to the
conclusions presented in previous submittals concerning
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secondary containment control.
The licensee agreed to
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provide a copy of the final report to the NRC residents
office onsite.
This item will remain open pending receipt
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and review of the requested submittal.
b.
(0 pen) Violation (440/93007-01): The writer's guide for E0Ps was
not appropriate to the circumstances because it permitted
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inconsistent usage of a flowchart symbol. - As a result, operators
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did not use the flow path intended by the E0Ps for steps -
associated with " Emergency Depressurization is Required."
In
correspondence dated August 6, 1993, the licensee committed to
performing an interim change by August 30, 1993 to the E0P
flowcharts to correct the specific example cited by the violation.
During this inspection, the inspectors reviewed the interim change
planned which consisted of identifying the appropriate flowchart
or action leg in addition to the phrase " Emergency
Depressurization is Required" for the affected steps.
No concerns
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associated with the planned change were identified. The licensee
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also committed to performing an E0P improvement program with
completion projected for June, 1994. This violation will remain
open pending review of the licensee's E0P improvement program
effectiveness.
c.
(0 pen) Violation (440/93007-02): Corrective actions for a
previous violation concerning ineffective validation and
verification (V&V) of E0Ps were inadequate. As a result, the
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" unsafe region" of a heat capacity limit curve was not marked
which was contrary to the E0P writer's guide. Consequently, two
operators were not able to correctly identify the " unsafe" region
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of a heat capacity limit curve.
In correspondence dated August 6,
1993, the licensee committed to performing an interim change by
August 30, 1993, to the E0P flowcharts to correct the specific
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example cited by the violation. During this inspection, the
inspectors reviewed an interim change which consisted of marking
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the " unsafe" region of the heat capacity limit curve.
No concerns
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associated with the planned change were identified.
The licensee
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also committed to performing an E0P improvement program with
completion projected for June 1994.
During this inspection,
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another example of ineffective V&V was identified and is discussed
in Section 4.
However, the additional example is considered
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within the scope of a violation for which corrective actions were
still ongoing.
Consequently, no new Notice of Violation (NOV)
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will be issued for this example. This violation will remain open
pending review of the licensee's E0P improvement program
effectiveness.
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3.
Secondary Containment Control
During a review performed at the request of the NRC, the licensee
identified that existing plant procedures did not meet the intent of the
EPG guidance for secondary containment control for many steps of the EPG
guidance.
The review is discussed above in Section 2.a of this report.
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Procedures were revised to meet the intent of secondary containment
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control guidelines and put in place August 16, 1993. No concerns were
identified with respect to the procedure revisions.
Details are as
follows:
a.
Procedure Revisions: The inspectors concluded that the procedure
revisions were sufficient to meet the intent of the secondary
containment control guidelines. The inspectors reviewed procedure
ON1-Nil, " Pipe Break Outside Containment (Unit 1)," which was
revised on August 16, 1993. The revision was made to identify
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maximum safe operating limits and provide appropriate operator
actions in order to meet the intent of secondary containment
control guidelines.
Procedure ON1-017, "High Radiation Level
Within Plant (Unit 1)," and several alarm response instructions
were also revised to reference ON1-Nil for conditions pertaining
to the secondary containment control guidelines.
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b.
Sunnortina Documentation: No concerns were identified with
respect to the methodology used to develop maximum safe operating
limits.
The maximum safe operating limits for areas outside of
containment were developed in order to meet the intent of the
secondary containment control guidelines. The bases for these
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limits were documented by design input record, " Maximum Safe
Operating Limits (Temperature, Water Level, Radiation)," for
procedure ONI-Nil, dated August 13, 1993. Temperature and
radiation level limits were based on existing equipment
qualification information listed in the updated safety analysis
report (USAR). Water level limits were developed based on
walkthroughs of affected rooms to identify the lowest equipment
important to safety not environmentally qualified for. submergence.
c.
Procedure Change Implementation: The inspectors concluded that
implementation of the procedure changes associated with meeting
the intent of the secondary containment control guidelines was
acceptable. Two observations concerning implementation were made
by the inspectors as follows:
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(1)
Although not required by existing administrative procedures,
two independent reviewers performed a verification of the
revised procedure ONI-N11.
In addition, comments obtained
from operators during training were documented.
However,
both the reviewer and operator comments were generated
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subsequent to the revision of ONI-N11.
Consequently, these
comments were not considered for the August 16, 1993
revision. The licensee planned to consider the comments for
future procedure revisions.
(2)
The licensee painted level markings on the walls of affected
rocas to reflect maximum safe water levels. The inspectors
were able to visually locate the level markings.
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No violations or deviations were identified in this area.
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4.
Containment Ventina
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During the licensee review of how existing plant procedures met the
intent of the EPG secondary containment control guidelines, the licensee
identified concerns associated with containment venting and its effects
upon surrounding buildings. The most significant concern identified was
potential overpressurization of the fuel handling building.
An interim
procedural change was made to provide an unobstructed vent path until
additional engineering analyses could be performed to assess the
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concern. The inspectors concluded that the licensee's interim
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corrective actions were conservative and appropriate. The concerns were
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documented by Condition Report (CR)93-178, dated August 17, 1993 and
NRC Region III was informed August 18, 1993. A preliminary
investigation of the concerns was documented in a Management Preliminary
Report (MPA) dated August 19, 1993. A violation was identified because
the potential overpressurization of the fuel handling building should
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have been identified during technical verification of E0P procedures
performed in 1991.
However, no Notice of Violation will be issued
because corrective actions for an existing violation were still ongoing
at the time of this inspection.
Details are as follows:
a.
Potential Overoressurization of the Fuel Handlina Building:
Each
of the containment vent paths specified by the E0Ps vented to the
spent fuel pool in the fuel handling building.
Preliminary
calculations showed that during certain accident scenarios, steam
flow rates during containment venting would be substantially in
excess of the fuel handling building's exhaust ventilation system
capability.
In addition, vesilation system dampers held open
with fusible links could cloo and isolate the exhaust ventilation
system due to high temperatures. Consequently, the potential for
overpressurization of the fuel handling was identified.
The MPA
for CR 93-178 recommended providing instructions to open a roll up
door in the fuel handling building prior to containment venting
thereby providing an unobstructed vent path as interim corrective
action.
Although the concern was self-identified by the licensee, the
potential for overpressurization of the fuel handling building
should have been identified previously.
For example, the vent
paths from the spent fuel pool area were not sufficiently
addressed in correspondence to the NRC dated July 29, 1986, which
submitted the Perry unique analyses for emergency containment
venting.
This submittal did not identify problems associated with
venting using the fuel handling building exhaust ventilation
system.
In addition, the licensee did not identify these concerns
during technical verification of containment vent paths performed
in response to a Severity-Level Ill violation identified in
Inspection Report 50-440/91013. As such, the inspectors
considered the lack of adequate technical verification identified
by tbis concern to be an example of inadequate E0P verification
and validation (V&V).
However, this example is within the scope
of an existing violation concerning ineffective corrective action
with respect to V&V (Violation 440/93007-02).
Consequently, no
NOV will be issued for this example because corrective actions for
the existing violation were still ongoing at the time of this
inspection,
b.
Other Concerns Identified:
In addition to potential
overpressurization of the fuel handling building, several other
concerns were identified by CR 93-178.
However, no additional
interim corrective actions were deemed necessary for the reasons
detailed below. The inspectors considered the licensee's actions
acceptable on an interim basis and did not identify any other
concerns. The additional concerns were:
(1)
Increased radiation levels and environmental conditions
adverse to personnel safety were identified during review of
conditions caused by containment venting into the
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intermediate building. CR 93-178 specifically identified
venting from a surge tank vent as being a concern. However,
the MPA for CR 93-178 noted that there was no need to enter
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he surge tank area during containment venting.
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Consequently, no interim corrective action was deemed
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necessary to address this concern. During review of the
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building's ventilation system, the inspectors identified the
potential for conditions adverse to personnel safety in the
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control rod drive (CRD) pump room from containment venting
due to the interconnection of ventilation ductwork.
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However, E0P related actions in the CRD pump room would
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likely have already been performed prior to containment
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venting, negating the need for additional access by plant
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personnel.
The licensee planned to review this issue
further to assess the potential adverse impact on personnel
safety and equipment.
(2)
The spent fuel pool water level may swell above the building
floor during containment venting and potentially flood lower
elevations. The licensee deemed additional engineering and
operations review necessary to assess this concern.
Consequently, no interim corrective action was deemed
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necessary to address this concern.
(3)
Previous calculations for determining the primary
containment pressure limit did not consider the back-
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pressure against containment venting caused by the head of
water in the spent fuel pool above the point of venting.
No
interim corrective action was deemed necessary because other
calculations demonstrated sufficient containment vessel
capacity exists to accommodate such back-pressure.
The
licensee planned to revise the calculations for determining
the primary containment pressure limit to consider back-
pressure effects.
c.
Planned Enaineerina Analyses: To fully address the above concerns
associated with containment venting, the licensee planned to
perform additional engineering analyses. The licensee anticipated
completing the necessary analyses by the end of December,1993.
The inspectors requested the licensee to submit the following
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information upon completion of the analyses:
(1) a summary of the
engineering analyses results and planned corrective actions; and
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(2) any necessary corrections to the Perry unique analysis for
emergency containment venting previously submitted to the NRC.
The licensee's response will be tracked by an inspection followup
item (440/93018-01).
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d.
Procedure Chance implementation:
The licensee revised an E0P
support procedure on August 22, 1993, to provide instructions for
opening a roll up door in the fuel handling building to provide an
unobstructed vent path from the spent fuel pool area.
The
procedure revised was section 7.1, " Preparation for Containment
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Venting," of procedure PEI-SPI, "Special Plant Instructions." The
inspectors concluded that implementation of this procedure change
was acceptable.
Specific comments are as follows:
(1)
The inspectors considered the procedure revision acceptable
in providing an unobstructed vent path from the fuel
handling building. However, the licensee took credit for
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filtering by the exhaust ventilation system in their
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licensing submittal concerning emergency containment
venting, dated July 29, 1986. This filtering is bypassed
when the door i.s used as a vent path. The licensee agreed
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to address this issue, if necessary, depending upon.the
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final resolution for containment venting and the concern
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associated with overpressurization of the fuel handling
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building.
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(2)
No concerns were identified during a walkthrough of the
revised procedure with a non-licensed operator.
No
procedural nomenclature discrepancies were identified.
The
inspectors noted additional lighting had been provided in
the area near the roll up door.
(3)
V&V of the revised procedure was good. Comments generated
during V&V were indicative of a thorough review and were
properly dispositioned.
For example, minor problems
associated with manual operation of.the roll up door were
identified during V&V and appropriate maintenance work was
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initiated.
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(4)
Two minor discrepancies associated with the revised
procedure were identified. The licensee planned to address
these discrepancies as part of their E0P improvement
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program.
The discrepancies were
(a)
Line spacing in the revised procedure was not in
accordance with that specified by the support
procedure writer's guide, attachment 2, " SPI Writers
Guide," to procedure PAP-0524, " Development of Plant
Emergency Instructions," Revision 0.
However, the
inspectors considered the line spacing used to provide
greater readability and to be a considerable
improvement over that specified by the writer's guide.
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(b)
Two abbreviations, "CAS" and "SAS," were used in the
revised procedure which were not listed as approved
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abbreviations by PAP-0524.
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5.
Communications and Interdepartmental Teamwork
The E0P related revisions provided an opportunity for the licensee to
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demonstrate effective communications and interdepartmental teamwork
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under time restraints.
In general, the inspectors considered
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communications and interdepartmental teamwork to be good.
Cooperation
between operations and engineering was evident.
However, such
cooperation was expected because the E0P improvement program was planned
as a multi-disciplinary effort with operations as lead.
Specific
observations were as follows:
a.
Monitorina of Radioactive Release Points:
No followup action was
initiated with appropriate personnel to address the feasibility of
monitoring a potential release through the fuel handling building
roll up door.
For interim corrective action, not having
provisions for monitoring such a release was acceptable because
the site emergency plan addressed unmonitored releases.
However,
because monitoring such a release is desirable, the inspectors
considered additional discussions with appropriate personnel to
address the feasibility of monitoring warranted.
The licensee
agreed to review the issue further.
The inspectors recognized
corrective actions were still in progress at the time of the
inspection and that additional review and evaluation of this issue
was planned,
b.
System Engineer Knowledge:
The system engineer for the fuel
handling building ventilation system was not fully aware of the
issues discussed by CR 93-178.
The inspectors recognized that the
individual did not require an immediate knowledge of the condition
report because operability of the ventilation system was not an
issue nor was he directly involved in the engineering analyses
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beir,g performed. However, considering the significance of the
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issue and that the ventilation system was affected by it, the
inspectors were surprised that the individual was not more aware
of the issues discussed by the condition report.
c.
Role of Security:
In addition to operations personnel, security
personnel had a role in performance of PEl-SPI, Section 7.1.
Based on an interview with a security shift supervisor, the
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inspectors concluded that security's knowledge and understanding
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of their role to support E0P implementation was good.
d.
Trainino: Training provided to operators for the procedure
changes associated with both meeting the intent of the secondary
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containment control guidelines and providing and unobstructed vent
path for containment venting was good.
For each change, operators
were briefed for approximately a half hour prior to coming on
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shift.
Supplemental information such as reasons why the changes
were being made was provided.
Two of the training sessions were
observed by other inspectors and were considered to be good.
No violations or deviations were identified in this area.
6.
Inspection Followup Items
Inspection followup items are matters which have been discussed with the
licensee, which will reviewed further by the inspectors, and which
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involve some action on the part of.Jbe NRC or licensee or both.
An
inspection followup item was disclosed during this inspection and is
discussed in Section 4 of this report.
7.
Exit Meetina
The inspectors met with licensee representatives (denoted in
Paragraph 1) on August 27, 1993.
The inspectors summarized the purpose,
scope, and findings of the inspection and the likely informational
content of the inspection report.
The licensee acknowledged this
information and did not identify any information as proprietary.
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