IR 05000440/1996004

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-440/96-04

ML20129F863
Person / Time
Site:	Perry
Issue date:	10/01/1996
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Myers L CENTERIOR ENERGY
References
NUDOCS 9610070055
Download: ML20129F863 (2)

Text

October 1, 1996

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-440/96004(DRS))

Dear Mr. Myers:

This will acknowledge receipt of your letter dated September 19, 1996, in response to our letter dated August 19, 1996, transmitting a Notice of Violation associated with Inspection Report No. 50-440/96004. This report summarized the results of the plant under drain system inspection at your Perry Nuclear Power Plant. We have reviewed your corrective actions and have no further questions at this time. The implementation of these corrective actions will be examined during future inspections.

Sincerely, Original Signed by Geoffrey E. Grant Geoffrey E. Grant, Director Division of Reactor Safety Docket No. 50-440 See Attached Distribution DOCUM g 7.ENT NAME:

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L. October 1, 1996 cc:

J. P. Stetz, Senior Vice President - Nuclear L. W. Worley, Director, Nuclear Services Department J. D. Kloosterman, Manager, Regulatory Affairs W. R. Kanda, Director, Perry Nuclear Assurance Department N. L. Bonner, Director, Perry Nuclear Engineering Department H. Ray Caldwell, General Superintendent Nuclear Operations R. D. Brandt, General Manager Operations cc w/ltr dtd 09/19/96:. Terry L. Lodge, Esq.

State Liaison Officer, State of Ohio Robert E. Owen, Ohio Department of Health C. A. Glazer, State of Ohio Public Utilities Commission Distrib.ution:

Docket File w/ encl DRS w/ encl A. B. Beach, RIII w/ encl PUBLIC IE-01 w/ encl RIII PRR w/ encl Enf. Coordinator, RIII w/ encl OC/LFDCB w/ encl SRI, Perry w/ encl CAA1 (E-mail) w/ enc 1 DRP w/ encl LPM, NRR w/ encl W. L. Axelson, RIII w/ encl i

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PERRY NUCLEAR POWER PLANT Mait Address:

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September 19,1996 PY-CEI/NRR-2092L

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United States Nuclear Regulatory Commission i

Document Control Desk Washington, DC.20555

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Perry Nuclear Power Plant Docket No. 50-440 Reply to a Notice of Violation In Accordance With 10 CFR 2.201 ~

Gentlemen:

Enclosed is the Perry Nuclear Power Plant reply to the Notice of Violation contained in NRC Inspection Report 50-440/96-04, which was transmitted by letter dated August 21,1996. The Notice of Violation involves inadequate corrective actions which resulted in a failure to perform testing of the Plant Underdrain system.

If you have questions or require additional information, please contact Mr. James D. Kloosterman, Manager - Regulatory Affairs at (216) 280-5833.

Very truly yours, w /. A)./d e%

w W. My r~ s Vice President - Nuclear DTG:sc Enclosure cc:

NRC Region HI Administrator NRC Resident Inspector NRC Project Manager Operating Componees Clevelond Dectne muminating a.

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i PY-CEI/NRR-2092L Enclosure Page1of3 REPLY TO A NOTICE OF VIOLATION Violation 96004-03 Restatement of the Viointion 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action" requires that measures be established to assure that conditions adverse to quality such as deficiencies, deviations and nonconformances, are promptly identified and corrected.

Contrary to the above, a condition adverse to quality involving failure to perform Perry unded-iJs system testing at the frequency required by plant procedures, was not promptly conected. The deficiency was didevmmi on June 18,1992, but, as ofMay 1, 1996, the testing still was not being performed at the required frequency.

Raaeon for the Viointion On June 18,1992, the System Engina~ing Section (SES) identified, via Corrective

Action program Condition Report (CR)92-182, that Periodic Test Instruction (PTI)-P72-

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P0001, "PI mt Underdrain Continuity Test," and PH-P72-P0002, " Plant Underdrain

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Groundwater Inflow Test" were not being performed as required by plant procedures.

Performance of these PTIs is delineated in the Updated Safety Analysis Report (USAR),

q Hydrologic Engineering Section 2.4.13.5.4,"Maintanance and Testing." SES is responsible for coordinating the performance of the PTIs; however, these PTIs have been routinely deferred in the past. Evaluation of the CR determined that the routine deferral of these PTIs was caused by recurring equipment problems associated with the Plant Underdrain system and improper interpretation of Plant Administrative Procedure (PAP)-

1105, " Surveillance Test Control," when deferring and rescheduling the PTIs.

After the corrective actions delineated in the above CR were closed, the PTIs continued to be defened; SES did not apply the appropriate level of attention toward solving the

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equipment problems, nor were the necessary actions taken to meet the required testing.

Additionally, the CR did not discuss or evaluate the apparent lack of management oversight / involvement. A review was conducted ofoutstanding/ delinquent PTIs; no other PTIs were found to be routinely defrned. Specifically, the cause for routine deferral of Plant Underdrain system testing is a lack of management

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oversight /involvernent regarding Plant Underdrain system testing.

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Enclosure Page 2 of 3 A contributing factor to the inadequate management oversight /m' volvement was the level

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of management review required by PAP-1105 for defened tests remained at the same

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level of management each time the tests were not performed; therefore, higher levels of

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management were not notified of the deferrals.

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A contributing factor toward not performing the PTIs within the required test intervals continues to be poor availability of the Plant Underdrain pumping system. De pumping system is located in a corrosive environment (i.e., calcium carbonate buildup) which causes recurring component failures on pumps, float switches, electrical disconnects,

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pump control circuitry, etc. The past corrective actions have not been effective in managing the required system maintenance to ensure test performance.

Corrective Stens Taken and Results Achieved

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SES has reised the priority for repairing the Plant Underdrain pumping system.

Maintenance is now perfonning system inspections and repairs on a regular basis; system

reliability has improved as a result.

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The Plant Underdrain Continuity Test (PTI-P72-P0001) was performed in late July 1996 and early August 1996 with satisfactory results. The Plant Underdrain doundwater Inflow Test (PTI-P72-P0002) was initiated on August 26.1996, and will be complete on i

September 27,1996. If equipment problems occur during performance of the PTI, efforts I

will continue until the test is completed with satisfactory results.

Corrective Stens That Will Be Taken To Avoid Further Viointions

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ne Plant General Manager has verbally communicated to site section managers a

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management expect.4 ion regarding periodic testing and maintenance; testing required by commitments in the USAR, or other licensing bases documents will not be routinely postponed. In addition, the expectation includes a philosophy that postponement of testing is not acceptable without the proper level of attention / emphasis placed on perfonning tests in a timely manner.

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These management expectations and provisions for higher levels of management oversight / involvement will be documented via a revision to PAP-1105. His revision

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will establish a hierarchy of review / approval levels that includes escalated approval for

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cach successive / excessive PTI postponements, such that the appropriate level of management attention is achieved.

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PY-CEI/NRR-2092L

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Enclosure

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Page 3 of 3 i

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On-going engineering evaluation of the Plant Undenfrain system to increase pump l

reliability will continue. 'Ihe Plant Underdrain system design will be evaluated for practical design changes that will minimize the number of components impacted by the

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calcium carbonate buildup effect.

Improvements to system performance will be achieved by evaluating the system's maintenance history to deannina whether the correct and appropriate preventative maintenance is being performed, and to revise it as nwy. Additionally, performance monitoring parameters will be identified and monitored for predicting degradation and required maintenance prior to failure.

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Date When Full Comnlinnea Will Be Achieved Full compliance will be achieved with a revision to PAP-1105 and performance of the engineering evaluation by December 12,1996.

The following table identifies those actions which are considered to be regulatory

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commitments. Any other actions discuscad in this document represent intended or l

planned actions, are described for the NRC's information, and are not regulatory commitments. Please notify the Manager-Regulatory Affairs at the Perry Nuclear Power i

Plant of any questions regarding this document or any associated regulatory commitments.

Commitment Commitment Date i

PAP-1105 will be revised to establish a hierarchy of review / approval December 12,1996 levels that includes escalated approval for each successive / excessive PTI postponements, such that the appropriate level of management attention is achieved.

l The Plant Underdrain system design will be evaluated for practical December 12,1996

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design changes that will minimize the number of components impacted by the calcium carbonate buildup effect.

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