ML20212A372
| ML20212A372 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/16/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212A368 | List: |
| References | |
| NUDOCS 9710230281 | |
| Download: ML20212A372 (60) | |
Text
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4 U. S. NUCLEAR REGULATORY COMMISSION -
REGIONlil Docket No:
50-440 License No:
NPF-58 Licensee:
Centerior Service Company Facility:
Perry Nuclear Power Plant Date:
October 7,1997 Location:
Region lli Office 801 Warrenville Road Lisle, IL 60532-4351 Type of Meeting:
Predecisional Enforcement Conference inspection:
December 21,1996 - February 3,1997 July ?1 - August 27,1997 l
Inspectors:
D. Kosloff, Senior Resident inspector i
M. Miller, Reactor Engineer Approved by:
Mark Ring, Chief, Lead Engineers Branch Division of Reactor Safety Meeting Summarv Predecisional Enforcement Conference on October 7.1997 Areas discussed: Apparent violations identified during the inspections were discussed, along with the corrective actions taken or planned by the licensee. The apparent violations involved a safety evaluation that failed to identify an unreviewed safety question and inadequate reactivity
' control.
9710230281 971016 PDR ADOCK 05000440 G
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Report Details 1.
Persons Present at Conference Centerior Service Company L. Myers, Vice President, Nuclear H. Bergendahl, Director - Nuclear Services R. Collings, Manager - Quality Assurance D. Gudger, Compliance Engineer H. Hegrat, Manger-Regulatory Affairs T. Henderson, Compliance Supervisor W. Kanda, Plant Manager M. Kuntz, NSSS System Engineer J. Powers, Manager - Design Engineering R. Schrauder, Director - Engineering H. Stevens, Manager - Nuclear Safety - Davis Besse U. S. Nuclear Regulatory Commission A. Beach, Regional Administrator B. Berson, Regional Counsel H. Clayton, Director, Enforcement and Investigations Coordination Staff M. Dapas, Acting Deputy Director, Division of Reactor Projects J. Grobe, Acting Director, Division of Reactor Safety i
J. Hopkins, Project Manager D. Kostoff, Senior Resident inspector, Perry M. Miller, Reactor Engineer, Division of Reactor Safety M. Ring, Branch Chief, Division of Reactor Safety G. Wright, Branch Chief, Division of Reactor Projects ll.
. Predecisional Enforcement Conference On October 7,1997, a Predecisional Enforcement Conference was conducted in the NRC Region ill Office in Lisle, Illinois, The conference was to discuss apparent violations of NRC requirements related to a safety evaluation that failed to identify an unreviewed safety question (EA 97-430) and inadequate control of reactivity (EA 97-047) at the Peny Plant.
Both the licensee and the NRC agreed tnat the safety evaluation failed to identify an unreviewed safety question. However, the licensee based the conclusion on a reduction in the
. margin of safety. The NRC concluded that an unreviewed safety question existed due to the increased potential of operator error and increased radiological dose to operators.
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The licensee continued a discussion of the corrective action for the inadequate control of reactivity. The original enforcement conference was held on April 18,1997. However, due to an extensive number of issues discussed, the corrective actions for this issue were not fully addressed at that time.
A single handoul was provided to address the two issues stated above, in addition, the licensee provided a handout for a management meeting presentation; however, the material was not discussed at the meeting.
The NRC informed the licensee that the information provided would be used to determine what enforcement action, if any, would be taken in response to the apparent violations and that the enforcement decision would be transmitted under separate correspondence. A copy of the licensee's handouts are attached to this report.
Attachments: As stated i
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Perry Nuclear Power Plant I!
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4 Presentation to the U.S. Xuclear Regulatory Commission October 7,1997 CENTERIOR ENERGY Page1
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OverallIntroduction
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Introduction Lew Myers Emergency Closed Cooling System Safety Evaluation
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Reactor Recirculation Flow Control Valve Corrective Actions Overall Summary Lew Myers Page 2
Perry Nuclear Power Plant I
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Emergency Closed Cooling System Safety Evaluation October 7,1997
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CENTERIOR ENERGY Page 3
DiscussionTopics m=====335_ ___
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Introduction Lew Myers Purpose / Desired Outcome Lew Myers Emergency Closed Cooling System Safety Evaluation (SE)
Robert Scluauder AdditionalInformation Requested Jim Powers 10 CFR 50.59 Safety Program Bill Kanda Summary Lew Myers Page 4
e Purpose
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Discuss Emergency Closed Cooling (ECC) system Safety Evaluation (SE)
Provide additional information on ECC Temperature Control Valve (TCV) modification SE corrective actions Discuss additional information requested Discuss safety reviews Discuss actions to identify Unreviewed Safety Questions (USQs)
Page 5
Desired Outcome
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Achieve a common understanding of the facts, root causes and corrective actions l
Acknowledge missed opportunities occurred Establish confidence that future occurrences will be prevented j
Achieve an understanding of the differences and extent of condition Reconfirm the Perry Management Team's commitment to safe reliable operation and full compliance with all regulations Page 6
' ECC System Surge Tank Emergency l
Make-up Capability SE i
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l History Causal Factors Corrective Actions Significance Page 7 l
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' ECC System Surge Tank Emergency Make-up Capability SE reumm>
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l History July 1,1993, identified ECC system leakage July 17,1993, performed Field Clarification Request (FCR)
Established allowable ECC valve leakage based on maintaining system operability June 1.995, incorporated valve leakage acceptance criteria into procedure 50.59 applicability check did not determine a change to the USAR August 28,1996, identified procedure's acceptance criteria was not as described in the USAR Page8
ECC System Surge Tank Emergency Make-up Capability SE reuem
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September 1996, identified valve leakage following maintenance October 21,1996, dispositioned Non-Conforming Condition (NCC) as permanent "use-as-is" Performed 50.59 safety evaluation March 3,1997, incorporated operability determination into the USAR April 22,1997, NRC Design Inspection questioned SE Under Office of Nuclear Reactor Regulation review Page9
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4 ECC System Surge Tank Emergency Make-u p Ca:pability SE neumes, xwwww
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September 1996, identified valve leakage following i
maintenance l
October 21,1996, dispositioned Non-Conforming Condition (NCC) as permanent "use-as-is" Performed 50.59 safety evaluation March.3,1997, incorporated operability determination into tlie USAR April 22,1997, NRC Design Inspection questioned SE Under Office of Nuclear Reactor Regulation review I
Page 9
ECC System Surge Tank Emergency Make-up Capability SE (continued)
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June 5,1997, plant forced outage NRC characterized issue as potential USQ ECC valves tested and leakage found to be within USAR limits August 11,1997, re-reviewed SE and confirmed change to the USAR involved a USQ Page 10 l
' ECC System Surge Tank Emergency Make-up Capability SE (continued)
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7 ymnt qww.1 Causal Factors Focus on design, operability, and technical evaluations versus licensing basis
- Standard Review Plan allowed versus Safety Evaluation Report Too focused on the technical adequacy and operability Independent review function inhibited due to familiarity of issues Page 11 m_ _
ECC System Surge Tank Emergency Make-up Capability SE (continued)
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Corrective Actions Taken ECC boundary valves leak tested and ECC system verified to be within USAR limits Returned plant configuration to design / licensing basis
- ECC System Surge Tank Emergency Make-up Capability USAR change
- Revisedapplicableprocedures Reviewed SE process Independent review of selected outage SEs 4
e Page 12
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' ECC System Surge Tank Emergency Make-up Capability SE (continued)
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Corrective Actions Taken (continuea)
Provided training to the preparer, the revievier, and the Plant Operational Review Committee (PORC) members Plant General Manager re-emphasizes management expectations to PORC members Discussions were held between management and Company Nuclear Review Board (CNRB)
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ECC System Surge Tank Emergency Make-up Capability SE (continued)
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.yy Corrective Actions Planned Continuing Training Provide feedback into 50.59 Safety Evaluation training Continue review of SEs
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Provide training to the Safety Evaluation Review Subcommittee (SERS) i members On-going periodic SE review effort ECC system modification to eliminate leakage concern Page14 l
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' ECC System Surge Tank Emergency Make-up Capability SE pnunued)
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Significance Violation of any regulation is significant
- Error was made when the NCC was ciispositioned as permanent "use-as-is" Actual impact on plant safety was minimal
- Low probability of occurrence
- Operability determination / compensatory measures were in place Questions?
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AdditionalInformation Requested
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AdditionalInformation Requested
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(continued)
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-ECC TCV modification SE Improperly documented SE for ECC TCV modification Reply to Notice of Violation in NRC Inspection Report 97002, dated June 26, 1997 Determined that a strong basis to support USQ determination did not exist Root Cause Preparer bounded the failure mode effects on complete loss of system
- SE preparer / reviewer failed to recognize appropriate failure mode effects
- Safety reviewers accepted bounding analysis Page 17
AdditionalInformation Requested (continued)
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ECC TCV modification SE Corrective Actions Taken Returned plant to previous configuration
- Disabled ECC TCV Bypass Line modification Provided training to engineers
- Contracted Failure Modes and Effects classes for Design and Plant Engineering Sections e
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AdditionalInformation Requested (continued) i
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Corrective Actions Planned Incorporate lessons learned into training program 50.59 Safety Evaluation Self-Assessment
- Considerindustry/regulatorychanges Restore ECC TCV inodification Questions?
Page 19 l
10 CFR 50.59 Program
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Management Ownership / Involvement Human Performance Collective Significance Page20
e 10 CFR 50.59 Progranbnued)
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Extent of condition Re-review of SEs Training program was adequate SE review committees are effective
- History of rejecting SEs is evident
- Maintains appropriate detail and safety focus Page 21
10 CFR 5C.59 Program (mnunued)
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Engineering staff past performance
- Recognition of dryweII shield door USQ
- Plant staff responded through appropriate licensing action Engineering staff recent performance f
- Recognition of the tornado missile design error USQ
- Timely identification that plant design was not in compliance with design /licensingbasis
. Plant staff responded through appropriate licensing action Committed to 50.59 self-assessment Page 22
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10 CFR 50.59 Programpnunued)
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Collective Significance Independent review performance has management's attention Overall management has confidence in safety review program
- Management reviewed the50.59 program
- Safety was maintained
- Sensitivity has been heightened Corrective actions taken for human performance have been diverse and complete Continued emphasis is now a training objective
- Future occurrences wi!I be prevented Page 23 u__ _
e 10 CFR 50.59 Programpnunued) l 2
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Conclusion Then - to - Now
- Reinforced expectations
- Emphasized licensing basis as well as technical information
- Ensured safety questions are clearly answered Conclusions
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Summary
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The differences and extent of condition do not indicate a programmatic breakdown Corrective actions taken for human performance have been diverse and complete Management has confidence in safety review process and that future occurrences will be prevented Perry Management Team is committed to safe reliable operation and full compliance with all regulations Page 25
Perry Xuclear Power Plant I
g Reactor Recirculation Flow Contro:L Valve Issue Corrective Actions October 7,1997 CENTERIOR ENERGY Page 26
Discussion Topics
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Introduction Lew Myers 1
Purpose / Desired Outcome Lew Myers l
Reactor Recirculation Flow Howard Bergendahl Control Valve Corrective Action Discussion 9
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Purpose
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t Follow up on our previous meeting to provide additional information on corrective actions taken to prevent l
unanticipated Reactor Recirculation Flow Control Valve i
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Desired Outcome I
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Assurance that Flow Control Valve corrective actions have been appropriate and comprehensive Establish an understanding that Management involvement in the corrective action program has significantly improved Page29
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Items to be Discussed
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A review of corrective actions from 1994 and the 1996 event Continuous improvement of the Perry Corrective Action Program e
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e Post-1994 Actions
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,m. _ m Previous corrective actions are described in the NRC inspection report (96018) as follows:
"The operator training of the impact of a blown fuse for an operate / isolate solenoid valve was ineffective" r
Corrective actions taken:
System engineer conducted classroom training on flow control valve events i
for operations and engineering Developed simulator training for operating crews to prepare for the possibility of unanticipated FCV movement Training added to requalification training program to ensure information j
would be periodically reinforced l
Page31
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"The corrective action of cycling the isolate / operate valves weekly was ineffective because of inadequate follow through" Corrective actions taken:
l Increased the frequency of solenoid valve replacements as a preventative measure i
Took action to cycle valves weekly, if available, to extend the life Discussed a similar problem with GE resulting from operating at higher voltage and checked our voltages to make sure we did not have that problem l
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Post-1994 Actions (continued) z.,
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During this period also investigated and resolved a hydraulic oil quality problem
- Breather filter (desiccant) changeou ts
- Fullers earth filterchangeouts
- System oil flushes
- Assistance from chemistry consultant i
In 1996 cycling was suspended to evaluate and correct a pump vibration problem Later determined that the vendor made changes to this type of solenoid valve such that newer valves had higher operating temperatures, which introduced additional problems 1
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Post-1994 Actions (continued)
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"The corrective action of changing the procedure was l
inadequate because it did not clearly state the purpose of the added action" l
i Corrective actions taken:
The procedure was changed to include a note about the potential for FCV movement The procedure was also changed to ensure the fuses were checked before operation to identify a stuck solenoid These changes also included a check of subloop pressures to determine if i
the solenoids were in the proper position Procedure changes did cause the previous crew to stop, and the crew involved to contact the system engineers for input
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e 1996 Event Corrective Actions Review of corrective action program implementation for the 1996 event Interdepartmental investigation team with a written charter Comprehensive investigation
- Used Human Performance Enhancement System (HPES) techniques
- Used Problem Solving and Decision Making (PSDM) evaluation techniques Concluded that root cause was loss of oversight by Shift Supervisor
- Level of involvement distracted from oversight
- Failed to meet management expectations for use of resources and application of training Contributing causes
- Procedurecompliance
- Solenoid valve materialcondition Page35
1996 Corrective Actions (continued)
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Operations Personnel Defined expectations regarding communications of corrective action plans and operational troubleshooting plans Developed a process for resolution of risk significant and risk contributor system / component problems Re-emphasized the independence of the STA in decision making and i
corrective action plan development i
Communicated details of the solenoid operate / isolate valve failure and the reactivity event, and lessons learned l
Communicated management expectations for Operations personnel who interface with senior reactor operators Conducted simulator scenarios on conservative decision making, teamwork, and resource management Evaluated non-operational SRO tasks Determined if any additional precautionary operator actions are necessary when manipulating components that could affect reactivity Page 36
g 1996 Corrective Actions (continued)
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Plant Personnel Clarified management expectations regarding communication between the Control Room and plant staff i
- Maintain a questioning attitude
- Request all relative information from the Control Room when participating in decision making and insure information provided is thoroughly understood
- Share the ownership of the results of the decision making process Communicated details of the solenoid opeate/ isolate valve failure and the reactivity event, and lessons learned Communication External to Plant INPO presentation i
Davis Besse presentation 9
Company Nuclear Review Board review i
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l 1996 Material Condition Actions l
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Identified root cause of solenoid valve sticking Thin oil film Localized high temperatures Low oil quali;y n
Replaced valves.with improved design Industry notified of findings through Nuclear Network Installed arnmeters in control room for monitoring coil currents Effectiveness review scheduled for 9 months after installation Remove installed valve for disassembly and inspecti
. to predict and prevent future failures r gas
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Comparison of1994 and 1996 Corrective Actions
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- 1994 actions addressed the individual issues identified at that time Valve failures Awareness of potential flow control valve drift 1996 investigation identified another issue involving the role of the Shift Supervisor and understanding of expectations 1996 evaluation included more management involvement, more in-depth review, and global corrective actions Page 39
Today's Program
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Good and getting better Moving from " FIND and FIX" to " PREDICT and PREVENT" All new issues are reviewed daily at morning Managers Meeting Weekly review of corrective action status by managers Interdisciplinary management review board to review investigations and trends i
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Today's Program (continued)
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Effectiveness reviews following completion of corrective actions for significant events (Category 1 and 2)
Senior management review of significant event investigations (Category 1 and 2)
Senior Management Collective Significance Review Board Questions?
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Overall Summary a=ggg_
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Discussed Emergency Closed Cooling system Safety Evaluation Good technicalevaluation Low safety significance Erred by focusing on Standard Review Plan Strong management involvement on this issue Basis' for USQ is a decrease in margin of safety ECC temperature control valve issue is approaching closu re Page 42
h Overal Summary (continued)
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Reactor Recirculation Flow Control Valve actions Post-1994 actions
- Valve changeouts were effective for issues at the time
- Manufacturer change increased failure rate
- Procedure actions sensitized operators
- Technical training to operators was appropriate 1996 Event actions
- Changed solenoid valve to eliminate root cause
- Found problem with shift supervisor responses to this and other problems
- Both achnical problems and human performance problems have been addressed All NRC questio.,s addressed or resolved Page 43 l
e Perry Nuclear Power Plant
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Management Meeting Presentation
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E.S. Xuclear Regulatory Commission 4
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l ENERGY 1
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Discussion topics
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- ; ; > r; -.;. ; t _g-p Desired Outcome Lew Myers Management Vision Lew Myers Discussion Directors Summary Lew Myers Page 2
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Desired Outcome
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_ 3 ;g Introduce the Perry Senior Management Team Strong, seasoned team with broad-based experience Provide an update on areas where we have good performance Key management focus areas after refueling outage Continued engineering improvements Continued reduction in maintenance backlog Process Improvements Automated Records Management System Corrective Action Program USAR Validation Plant cleanup / housekeeping Page3
Team Introduction
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3 Lew Myers Vice President. Nuclear-Perry Plant Manager-STP Unst 1 Plant Manager-Browns Ferry Tearn Manager-INPO Operations Manager-Waterford 3 MBA, Brenau University.1991 BS Mech. Eng., Purdue 1983 Associate. Nuclear Science.1970 SRO (St. Lucie) 1979 SRO (Waterford) 1983 30 vaars ewpenerve l
I BellKanda Bob Schrauder Tem Rausch Plant Manager Derector. Engw.eenng Director. Quatrty and Personnet Cc.c:@ e.!
Director-Ouality and Personnel Developrnent Director-Nuclear Services Manager-Trawvng Section Manager-Training Section Manager-Ocensmg (Daves-Besse)
Supv-Operations Procedures Unrt Mark itegrated Scheduling and Controls Ucensing Supv (CP&L)
Project Manager-Procedure Upgrade i
er-Electrical Design Section Radiation Prot Supv (Bechtel)
EOP Coordmator
.Vlanager-8&C Section Operations Trainmg (Oyster Creek)
Miager-Technical Section BSNE. Univ. of Cincmna'i.1978 SRO Cert (Perry) 1997 MBA. Cleveland State.1995 BSEE. Univ. of Detroit.1972 BSNE. Univ. of Cmcenati 1988 MA. Case-Westem Reserve,1976 20 years expenence SRO Cert (Perry)
SRO (Perry) 1987 SRO Cert (Oyster Creek) 25 y=ars expenence 13 years empenence Neal Bonner Howard Bergendaht D6 rector. Mantenance Derector. Nuclear Servoces Dwector-Nuclear Engmeering Manager-Techrwcal Serveces (STP)
Manager-Design Engineenng (D-B)
Rad Prot Manager (STP)
Manager-Maintenance (D-8)
Sr. Supv. Rad Prot (Salern)
Supt-Electrical Ma,nt (D-B)
Supt-!&C (Daves-Besse)
JD Delaware Law School.1988 MS, Urww. of Flonda.1982 BSEE. Mchigan Tech 197ti BS. SUNY' Oneonta.1980 SRO (Davis-Besse) 1990 SRO (South Texas) 1996 21 years experience 17 years expenence Page 4
Management Vision
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Demonstrate Standards of Excellence that set us apart as leaders Safety People Reliability Cost Planning for the future Strategic Business Pian Perry Plan for Excellence l
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Bill Kanda Plant Manager
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. Develop a strong safety culture Nuclear (reactivity control)
Radiological Industrial Risk-informed decisions Improvements in radiological control programs and storage of contaminated material Established accountability for plant material condition Page 6 l
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Bill Kanda Plant Manager (continued)
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Clear expectations and accountability Benchmark and evaluate top performing plants; proactive through self assessments Focus on human performance improvement initiatives Encourage employee involvement Employee personal development and training programs Page 7 l
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Robert Schrauder Director, Engineering
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Recent Successes RFO6 preparation / implementation ECCS Suction Strainer Service Water piping Self assessments / inspections Future Focus Configuration Management Design Basis Documentation USAR Validation Safety Evaluation program Activity Resource Management System (ARMS)
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Xeal Bonner Director, Maintenance l
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J PERRY NUCLEAR POWER PLANT On-line Corrective / General Maintenance Backlog Status <57 2,500 2,272 CfwGM Backlog l 2,000
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733 760 544 513 500-04-May '95 Sep '95 Dec '95 Mar '96 Jun 16 Sep '96 Dec '96 Mar 17 Jun 17 Sep '97 Page 9 L_--
Howard Bergendahl Director, Xuclear Services
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Outage Planning Benchmarked Outage Management Team Project Managers On track for 38 days INPO Assist Visit Corrective Action Program Benchmarked 1
Low threshold Increasing n.cramment involvement in all phases 1993-1997 - continuous improvement r
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Howard Bergendahl Director, Xuclear Services (continued)
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Administration Procedure quality Information accessibility Security Safety Emergency Planning 1
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Tim Rausch Director, Quality and Personnel Development
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' Aggressive Overview Organization QA Audits /Surveillances focusing on important issues Independent Safety Engineering Group (ISEG)
- Safety System FunctionalInspection activities
- Engineering oversight Training Management Training
- FundamentalsofLeadership
- Leadershipin Action Continuing Training program focusing on lessons learned and skill development Page12
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Recent Perry Progress sxm m n2:n : =:.tre __. C P'-
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Attribute 1990 1991 1992 1993 1994 1995 1996 1997 Outage (RFO2)
(RFO3)
(HFO4)
(RFO5)
(RFO6) (Proj)
RFO Duration (Days) 119 85 189 74
<40 I
Outage Scope Growth (%)
45 9.5 3.26 (To Date)
Availability Factor (%)
65.3 90.8 72.7 44 47.4 93.3 76 84.4 Forced Outage Rate (%, IEEE. No RFO) 1.2 8.4 7.4 37.8 1.3 6.7 4.6 6.1 Capacity Factor (Net MDC) 64.2 86.5 69 38.7 44.4 87.8 74 83.1 (YTlD Maintenance General Backlog
>2500 2272 760 446 Collective Radiatic,n Exposure (P-Rem) 639.495 147.305 571.048 278.406 691.187 64.805 308.5 255 SALP Rating (Rounded Average) 2 2
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Summary
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Perry has an experienced team in place Team taking ownership of processes Team reinforcing expectations
. Confident in our ability to move Perry forward Page 14 L"""--
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