ML20059E503

Forwards Results of on-site EQ Review of Related Info at Plant in Support of Staff Task Action to Identify & Address Existing EQ Issues & Concerns.Encl 1 Provides Results of Staff Review.Encl 2 Provides Draft Ltr to Transmit Info

ML20059E503
Person / Time
Site:	Perry
Issue date:	01/06/1994
From:	Mccracken C Office of Nuclear Reactor Regulation
To:	Hannon J Office of Nuclear Reactor Regulation
References
TAC-M85648, NUDOCS 9401110223
Download: ML20059E503 (8)

Text

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. L January 6, 1994 Docket No. 50-440 MEMORANDUM FOR: John N. Hannon, Director Project Directorate III-3 Division of Reactor Projects III/IV/V FROM: Conrad E. McCracken, Chief Plant Systems Branch Division of Systems Safety and Analysis

SUBJECT:

RESULTS OF THE ON-SITE EQ REVIEW AT THE PERRY NUCLEAR POWER PLANT (TAC M85648)

During the period from December 13 through December 17, 1993, James Tatum and Christopher Gratton of my staff, along with Frank Quinn of SCIENTECH (an NRC contractor), performed an on-site review of EQ-related information at the Perry Nuclear Power Plant in support of the staff's task action plan to  :

identify and address existing EQ issues and concerns. The purpose of this review was to gather information and not to assess licensee compliance with NRC regulations. The results of the staff's review is included as Enclosure 1, and Enclosure 2 provides the contents of a draft letter that may '

be used for transmitting this information to the licensee.

If you should have any questions regarding the review that was conducted at Perry, please contact Chris Gratton of my staff at 504-1055.

NdSi9!10dby Conrad E. McCracken, Chief Plant Systems Branch Division of Systems Safety and Analysis

Enclosure:

l As stated Distribution:

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Enclosure 1 NRC STAFF ON-SITE REVIEW 0F EQ INFORMATION AT THE PERRY NUCLEAR POWER PLANT 1.0 INTRODUClION As a result of the staff's activities related to license renewal, environmental qualification (EQ) was identified as an area that required further review. A major concern in this regard was whether the EQ .

requirements for older plants (i.e., those with EQ programs developed under 00R Guidelines or NUREG-0588, Category II, requirements) were adequate to support license renewal. Consequently, the staff concluded that differences in EQ requirements between older and newer plants constituted a potential generic issue which should be evaluated for backfit independent of the license ,

renewal activities.

Separate from the activities supporting license renewal and in response to issues that were raised by the Office of the Inspector General (0lG) in a report dated August 12, 1992, the NRC staff conducted an assessment of fire protection requirements. The staff's report dated February 27, 1993, 1 identified a number of weaknesses and made wcific recommendations for improving the NRC fire protection program. ln view of the weaknesses that were identified, the staff concluded that other NRC programs such as EQ should also be reviewed to identify and correct any programmatic weaknesses that may exist.

Consequently, the NRC established a task action plan for identifying and addressing 1: sues and concerns that currently exist in the area of EQ. One element of this task action plan involves a number of site visits by the staff -

to gather first-hand information on EQ and to discuss current issues, problems and trends with nuclear power plant personnel. It is emphasized that the purpose of these site visits is not to assess licensee compliance with NRC

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regulatioas.

The Perry Nuclear Power Plant (PNPP) was the first plant selected for the staff's on-site EQ review activity. The review was performed from December 13-through December 17, 1993, by James Tatum and Christopher Gratton of the NRC, Office of Nuclear Reactor Regulation, and by Frank Quinn of SCIENTECH, an NRC contractor. This report is a brief summary of the on-site review activity .

1 that was conducted. and serves to document the results of the staff's efforts in this regard.

2.0 BACKGROUND

INFORMATION RELATIVE TO THE PERRY NUCLEAR POWER PLANT l The PNPP is operated by the Cleveland Electric Illuminating Company et al (CEI or the licensee), and the plant began ccmmercial operation on November 18, 1987. The power source is a boiling water reactor (GE type 6) rated for 3579 Megawatts Thermal, which is enclosed by a Mark 3 containment. PPNP's construction permit was issued on May 3, 1977; therefore, the more recent EQ guidance of IEEE Standard 323-74 and NUREG-0588 (Category I), are~ applicable  ;

to Perry.

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3.0 REVIEW DETAILS The staff's on-site review activity is directed toward gathering EQ-related I information in support of a generic programmatic review, and it is the staff's desire to promote an atmosphere of cooperation and support during each of the site visits. The staff's review plan calls for gathering information through licensee presentations, discussions with plant personnel, and document review.

3.1 Licensee Presentations As part of the review team's orientation to the Perry EQ program, the licensee 4 presented specific information relevant to Perry and provided a tour of EQ components located in accessible areas inside containment. The licensee's presentations covered the results of an EQ audit, EQ-related problems that  :

were uncovered during a recent walkdown of harsh environments, involvement with industry groups, administrative procedures, training programs related to >

EQ, and a discussion of a cable condition monitoring program that was established as a commitment at the time when Perry was licensed. ,

fhe licensee's tour of accessible areas of containment concentrated on those areas with safety-related electrical equipment that was qualified for harsh ,

environmental conditions. Equipment that was specifically highlighted during the tour included, for example, Target Rock valves, motor operated valves '

(Limitorques), temperature detectors, ASCO solenoid valves, Rosemount transmitters, and associated electrical cables.

3.2 Discussions with Plant Personnel Over a three day period, the EQ review team participated in group discussions about EQ issues with station personnel from the engineering, maintenance, ,

operations, and training organizations (see Table 1). The purpose of these  !

discussions was to learn about programs that had been established for Table 1 Discussion Groups Number of Functional Area:

Participants:

Quality Control 3 ,

Probabilitistic Risk Assessment 2 i Operations 3 Electrical and Mechcnical Design Engineering 4 Systematic Maintenance Optimization 3 Field Engineers (Plant Maintenance) 2 Systems Engineering Section 4 Control Room Personnel - Shift Technical Advisors 2 MOV Group 4 Maintenance and I&C Planners 4 Site Training 2

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implementing and maintaining equipment qualification, and to learn about -

specific problems and concerns that existed as a result of EQ requirements and how those problems and concerns were being addressed. In general, station -

personnel appeared to be very aware of EQ requirements and appeared to be sensitive and inquisitive about conditions in the plant that could impact the '

environmental qualification of safety-related electric equipment.  ;

3.3 Document Review  :

The review team examined the Perry EQ Master List, procedures applicable to  ;

EQ, and 70 Auditable File Packages (AFPs) for safety-related electric ,

equipment. The AFPs were well organized and maintained, and listed information such as the equipment type, manufact er, model number, qualified life, and maintenance interval. The AFPs also ontained specific vendor ,

information and any notices that were applicable to each item.

3.4 Results i Based on the information that was obtained at Perry during the on-site EQ review, the staff found that a number of program elements and practices seemed j to be important for establishing and maintaining equipment qualification. The ,

staff also learned about some of the EQ-related problems and concerns that currently exist. .j Noteworthy EQ-Related Program Elements and Practices:

- Periodic EQ training for engineers, craft personnel, and managers / supervisors (the existing program at Perry was being updated at i the time of the site visit).  ;

Well organized and maintained qualification file packages. The licensee  !

maintains a complete Auditable File Package for each equipment type, which contains equipment qualification information, including vendor information and notices; and the packages are kept up-to-date. ]

Cable monitoring program in harsh environments (this program is a Perry licensing commitment). During construction, representative samples of spare cables were installed for future monitoring / testing at five-year.  ;

intervals. . Sufficient spare cable was installed to allow testing to be performed over the entire 40-year life of the plant. The cable i monitoring program includes provisions for trending temperature and j radiation conditions in the vicinity of the spare cables.

- Harsh and mild environment temperature and radiation monitoring. As a .I result of hotter-than-expected conditions in the upper drywell, the l licensee recognized a neeri to monitor actual plant conditions and to j adjust equipment qualified life accordingly. Although the upper drywell o problem indicated a need to shorten qualified life, with sufficient l supporting data it may be possible to extend qualified life in other areas where environments are not as severe ar initially expected.

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- Pre-startup walkov -s of EQ equipment in harsh environments. Areas that are typically not accessible during plant operation are specifically flagged for this walkdown by the licensee.

- Use of training aids for the maintenance and inspection of EQ equipment.

The licensee maintains a collection of EQ components for use as training aids. These training aids are easily accessible to QC inspectors and maintenance workers to assist them in their duties.

- Steam leak checklist geared to evaluating EQ concerns. The licensee has established a steam leak check list as a vehicle for evaluating the effects that steam leaks may have on EQ.

- Administrative practices that highlight EQ-related maintenance and testing activities. For example, the repetitive maintenance task cards distinguish between EQ and non-EQ equipment.

Centrally locating the various sealing requirements for EQ equipment.

The licensee has developed two specifications that state the sealing requirements for all EQ equipment used in the plant. One of the specifications is for Limitorque motor operators and the other specification is for all other EQ equipment.

Use of experts outside the Perry organization to participate in the biannual EQ review. The use of other experts outside the Perry organization can be very helpful in getting a fresh, independent review of programs and practices.

- Use of industry data and site-specific data in evaluating the performance of EQ equipment. Various reports in this regard are reviewed by the licensee on a quarterly basis and prior to plant startup from an outage, such as the Component failure Analysis Report (industry report) and the High Frequency Failure Report (site-specific).

Maintenance optimization program. The licensee has established a program to determine the appropriate intervals for performing maintenance on components. While it is important to ensure that EQ equipment is receiving the periodic maintenance that is needed, it is also important to realize that maintenance that is performed too frequently can have some adverse effects on plant operational cafety.

For example, an increased burden is placed on operations and maintenance personnel, there are more opportunities for errors to occur, and equipment availability can be reduced. This program is currently on hold at Perry while actions are being taken to implement the requirements of the maintenance rule.

Periodic maintenance activities classified as " required" vs. "related" to alleviate potential scheduling problems. The licensee attempts to distinguish between maintenance activities that are specifically required for maintaining EQ equipment in an operable status from those activities that are not specifically required to maintain the ,

equipment's qualification; for example, " good practices" that are cited

3 in vendor's manuals. For maintenance requirements that are not specifically required for EQ, the licensee allows some flexibility in scheduling the repetitive maintenance task.

Use of a Preventative Maintenance Feedback Form designed to document the condition of parts replaced during repetitive maintenance. This provides a mechanism for periodically documenting the condition of equipment that may be important for future EQ considerations.

Integration of risk analysis results into maintenance programs. The licensee is currently ranking the importance of systems based on PRA results so that this information can be used in implementing the maintenance rule requirements. This information can also be helpful in identifying and sensitizing people to the really risk-significant EQ equipment that is installed in the plant.

Problem Areas / Areas of Concern Expressed by Plant Personnel:

Extension of maintenance intervals (similar to what is typically allowed for Technical Specification surveillance requirements) is not allowed for EQ repetitive maintenance, even though the " qualified life" that has been established is speculative. This can create a hardship for -

licensees in scheduling repetitive maintenance too often in order to avoid mid-cycle shutdowns or by requiring specific evaluations for each component on a case-by-case basis as the situation arises.

Commercial grade dedication of components was identified as a problem for some EQ equipment; especially individual pieces of vendor-supplied, skid-mounted equipment. Digital equipment upgrade was also cited as a potential problem for EQ equipment. Although these are specific areas that are currently under review by both the NRC and the industry, it is important to recognize that there may be some specific needs with regard to EQ in resolving these issues.

Lack of cooperation from vendors of qualified equipment was cited as a potential operational hardship. Station personnel indicated that some vendors no longer supply " qualified equipment," and others have tightened maintenanco requirements and restricted the type of maintenance that licensees may perform without voiding EQ warranty provisions.

4.0 CONCLUSION

S The review team found that plant personnel at Perry were very open and receptive to the NRC visit, and expressed no reservations in sharing plant practices and experiences. Consequently, the on-site EQ review at Perry was very worthwhile and productive, helping the NRC staff to better understand and appreciate the programs and practices being implemented in order to satisfy EQ requirements, and also highlighting some of the problems and concerns that '

currently exist. The information obtained during the Perry site visit is v3ry useful and will be factored into the staff's generic programmatic review of EQ.

i Enclosure Boiler Plate Letter - Contents  !

During the period from December 13 through December 17, 1993, the NRC performed an on-site review of EQ-related information at- the Perry Nuclear Power Plant in support of the staff's task action plan to identify and address existing EQ issues and concerns. The purpose of this review was not to assess compliance with NRC regulations, but rather to gather information that is critical to the staff's ongoing EQ review. Due to the support and cooperation that was afforded by plant personnel at all levels, the time spent by the NRC staff at Perry was very productive and worthwhile. We appreciate very much the time and effort that was spent by your staff in assisting us in this  :

effort. The results of the staff's EQ review is enclosed for your )

information.  ;

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In addition to the standard distribution for Perry, please include the following addressees on the cc list:

George Wu, NUMARC  :

1776 Eye St. NW Suite 300 -

Washington DC 20006-3706 William Horin Winston and Strawn, NUGEQ 1400 L Street, NW r Washington DC-20005-3502 Timothy Boss Perry Nuclear Power Plant, W-245 10 Center Rd.

Perry, OH 44081 ,

Hugh Geiston Nuclear Electrical \l&C Florida Power Corporation -

P.O. Box 219 Crystal River, FL 34429 Bob Smith Duke Power Corp. l 422 South Church St.

Charlotte, NC 28201-1006 i

Gary Eldridge  !

Niagara Mohawk Power Corporation i 301 Plainfield Rd.

Syracuse, NY 13212 1

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. y, DISTRIBUTION:

TMurley/FMiraglia MRubin, SPSB WRussell AEl-Bassioni, SPSB AThadani NSaltos, SPSB MVirgilio TSpeis, RES CMcCracken LShao, RES GHubbard JCraig, RES JTatum MVagins, RES CGratton JVora, RES ADummer SAggarwal, RES CRossi, DRIL ASerkis, RES JHopkins, PDIII-2 CAntonescu, RES L01shan, PDIII-l HRathbun, RES PShemanski, PDLR CBerlinger, EELB -

EWeiss, EELB FBurrows, EELB JWermiel, HICB AMarinos, HICB '

HGarg, HICB ,

Docket File SPLB EQ File NRC PDR ,.

' Central Files-Frank Quinn, Scientech Inc.

11821 Parklawn Dr. Suite 100 Rockville MD 20B52 l

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