IR 05000440/1996008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-440/96-08

ML20134M930
Person / Time
Site:	Perry
Issue date:	11/15/1996
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Myers L CENTERIOR ENERGY
References
NUDOCS 9611260093
Download: ML20134M930 (2)

Text

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Novauber 15, 1996

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Mr. Lew : Vice President - Nuclear

Centerior Service Com7any  !

P.O. Box 97, A200  !

Perry, OH 44081 j I

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SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO.

50-440/96008(DRS))

Dear Mr. Myers:

This will acknowledge receipt of your letter dated October 28,1996,in response to i

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, our letter dated September 27,1996, transmitting a Notice of Violation associated with.

Licensee Event Report 93-021," Loss of Safety Function For Emergency Closed Cooling System A," which failed to provide an adequate assessment of the safety consequences

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and implications of an event at your Perry Nuclear Power Plant. We have reviewed your I corrective actions and have no further questions at this time. These corrective actions will

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be examined during future inspections.

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Sincerely, Original signed by Geoffrey E. Grant Geoffrey E. Grant, Director

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Division of Reactor Safety Docket No. 50-440 i

See Attached Distribution DOCUMENT NAME: G:\DRS\PER111_6.DRS

' To receive a copy of thle document, Indicate in the bom "C* = Copy without attachment /endosure *E' = Copy with attachment / enclosure

"N* = No copy OFFICE - Rlli E Rlll E. Rlll gp C Rlli _ l NAME EDuncan:ntypq {g; MRiryndT4. JJacobT6iigM. HClaytch3 [$Qrant DATE 11/lf/96 11/1996 11/6796 11/17/9@)() g OFFICIAL RECORD COPY 260043 9611260093 961115 n d c W-O\

PDR ADOCK 05000440 0 PM h J

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L. 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 I Nuclear Engineering Department H. Ray Caldwell, General Superintendent Nuclear Operations R. D. Brandt, General Manager Operations cc w/Itr dtd 10/28/96: 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 Distribution w/ltr dtd 10/28/96:

Docket File DRS A. B. Beach, Rlli PUBLIC IE-01 Rlli PRR Enf. Coordinator, Rlll OC/LFDCB SRI, Perry CAA1 (E-mail)

DRP LPM, NRR W. L. Axelson, Rlil

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A:C NTEREOR y ENERGY IRW NUCLEAR POWER PLANT Mail Address:

10 CENTER ROAD P.O. BOX 97 PERRY, OHIO 44081 PERRY. OHIO 44081 (217) 259-3737 October 28, 1996

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PY-CEI/NRR-2101L

United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 l

Perry Nuclear Power Plant Docket No. 50-440 Reply to a Notice of Violation l

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l Ladies and Gentlemen: l Enclosed is the the reply to the Notice of Violation contained in NRC Inspection Report 50-440/96008, which was transmitted by letter dated September 27, 1996. The Notice of Violation involves submission of a Licensee Event Report 93-021, " Loss of Safety Function For Emergency closed cooling System A," which failed to provide an adequate assessment of the safety consequences and implications of the event. '

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

Very truly yours, l

M g Lew Vice President - Nuclear CRE sc Enclosure cc: NRC Region III NRC Resident Inspector NRC Project Manager qh f \

l Operoneg Compor',es Clevesond Electnc mam noteg N I 1 E, toieco Eo son

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1 PY-CEI/NRR-2101L

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Enclosure i Page 1 of.3 n

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REPLY TO A NOTICE OF VIOLATION

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. Violation 96008-01 j Restatement of the Violation

10 CFR 50.73 requires, in part, that the Licencee Event Report (LER) contain an assessment of the safety consequences and implications of the event.

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contrary to the above, on January 24, 1994, the licensee submitted Licensee

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Event Report 93-021, which failed to provide.an adequate assessment of the safety, consequences and implications of the event in that i

l The. cover letter and title of LER 93-021 indicated only a loss of safety

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function for Emergency Closed Cooling (ECC) system "A" although ECC

{ system "B" was also inoperable for about 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> during the event, and i

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The main body of the LER only explicitly discussed a loss of ECC "A".

Although the out-of-service condition of the Division 2 diesel generator .

on June 14 and 15 was discussed, neither the impact on the operability of .]

ECC "B" nor the consequences of a total loss of ECC was mentioned.

l This is a Severity Level IV violation (Supplement I) (50-440/96008-01). 1

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Reason for the Violation i

The cover letter, title, and body of the LER did not clearly reflect the safety consequences and impact of the event because the associated event evaluation process did not determine accurate nor comprehensive conclusions regarding j event safety consequences and impact. The cause.of the inadequate evaluation l is personnel error (i.e., oversight on the part of the Compliance. engineer who i prepared the LER) . A review of activities in progress at the time of LER l preparation, indicates that the preparer had just recently transferred to the j Regulatory Affairs Section (RAS) from-the System Engineering Section, and was j

. assigned other complex projects which required action during the period of the l LER investigation. Discussions with the preparer (who is no longer at the l

Perry Nuclear Power Plant (PNPP)) indicated that the assignment and preparation. )

of the LER was performed on an abbreviated schedule; however, the preparer indicated that the Technical Specification (TS) violations and the full consequences of the loss of'ECC safety function should have been recognized, addressed, and documented in the LER.

A contributing factor for this issue is that the level of supervisory involvement was inadequate to ensure successful performance of the task. This included overseeing work in progress, and control of work assignments. The RAS Compliance Unit supervisor at the time LER 93-021 was prepared, is no longer at PNPP. Review of the associated preparation documentation.did not indicate that any substantive comments on the draft LER were received from the Compliance Unit supervisor. Although the LER preparer was a skilled and experienced individual (i.e., former shift technical advisor), supervisory oversight should (

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PY-CEI/NRR-2101L Enclosure Page 2 of 3 have resulted in the content of the LER being challenged. Review comments from the RAS manager at the time questioned whether the issue resulted in a TS-violation. The LER preparer answered that the issue did not involve a TS violation; the issue was not appropriately resolved at that time in the review process.

As mentioned in the cause discussion above, the preparer was tasked with

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additional complex assignments, and was working to an abbreviated schedule.

Additionally, the associated corrective action program investigation was assigned to the LER preparer, which resulted in the LER preparer becoming the driving force for technical resolution of the issue (versus the engineering / operational experts) and also resulted in the LER preparer having to evaluate the issues not directly related to the LER. The aspects of additional work assignments, abbreviated LER development schedule, and investigation responsibilities were within the responsibility and control of the Compliance Unit supervisor, and these aspects contributed to the LER preparer not thoroughly evaluating and reporting the safety consequences and implications of the event.

Another contributing factor was undefined accountability. The responsibilities of personnel reviewing the LER were not well defined and personnel were not held accountable for the accuracy / completeness of the information within the LER. The LER was sent out for' site multi-disciplinary review; however, the LER review copies were not marked, as is the current practice, to delineate responsibility for verifying and concurring in the LER contents. This reduced

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C the effectiveness of the multi-disciplinary reviews by blurring responsibility and accountability of reviewers and contributed to the inadequate LER.

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Corrective Steos Taken and Results Achieved Since the time of LER 93-021 development (January 1994), improvements have been made to the corrective action program and to the program for controlling written communications with the NRC.

1) PAP-1608, " Corrective Action Program," has' superseded PAP-0606,

" Condition Reports," (which was in effect at the time of the LER 93-021 investigation) and the investigation associated with a reportable event is assigned to a person trained in root cause evaluation techniques, and no longer automatically assigned to the RAS Compliance Unit. The improved program requires the most appropriate section to investigate the reportable event and interface with the compliance engineer responsible for preparation of the associated LER. This process allows the assigned investigating section to focus on resolution of the technical issues and the Compliance engineer to focus on LER preparation in accordance with 10 CFR 50.73 requirements.

2) PAP-0611, "NRC Conatunications," effective July 25, 1995, now clearly delineates responsibilities and accountability in the review process for outgoing correspondence to the NRC, and draft copies of LERs are currently marked with the appropriate sections identified so that reviewers know what their specific verification / concurrence 4 k responsibilities are regarding LER content.

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PY-CEI/NRR-2101L Enclo2ure Page 3 of 3 I j Corrective Steos That Will Be Taken To Avoid Further Violati SD.E The compliance engineer, compliance' supervisor, and the RAS manager responsible for the preparation and submission of LER 93-021 are not presently assigned to any of those positions; however, the current. RAS manager, Compliance supervisor, and compliance engineers have discussed the significance of the

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Since the time LER 93-021 was written, the RAS Compliance Unit _and the RAS manager positions have been restaffed. Methods of developing LER responses-(e.g. , review' process enhancements in PAP-0611) and ownership of issues (e.g.,

investigation assignments in PAP-1608) have been addressed and have resulted in .

improved LER content. )

The issues addressed by LCR.93-021 were substantially j more complex than the technical and regulatory issues typically addressed in LERs. Based on the level of scrutiny that LERs now receive from both internal l and external sources on a continuing basis, and improvements in the method of developing LERs, the actions already taken are considered to be sufficient to preclude recurrence of this violation.

Date When Full'Comoliance Will be Achieved Full compliance will be achieved by December 20, 1996, upon submittal of a supplement to LER 93-021

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The following table identifies those actions which are considered to be regulatory commitments. Any other actions discussed in this document represent intended or planned actions, are, described for the NRC's information, and are not regulatory commitments.

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Commitments

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1. Full compliance will be achieved by December 20, 1996, upon submittal of a supplement to LER 93-021.

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