IR 05000440/1997006
| ML20149E604 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/11/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Myers L CENTERIOR ENERGY |
| References | |
| 50-440-97-06, 50-440-97-6, NUDOCS 9707180244 | |
| Download: ML20149E604 (2) | |
Text
July 11, 1997
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-440/97006(DRS))
Dear Mr. Myers:
This will acknowledge receipt of your July 2,1997 letter in response to our June 3, 1997 letter transmitting a Notice of Violation associated with the above mentioned inspection report. This report summarized the results of the routine safety inspection at your Perry Plant. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
Sincerely, j
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/s/ J. M. Jacobson (for)
l John A. Grobe, Acting Director Division of Reactor Safety Docket No. 50-440 Enclosure:
Ltr 07/02/97, L. W. Myers, Centerior Energy, to USNRC w/ encl (
See Attached Distribution l
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G PDR DOCUMENT NAME: G:\\DRS\\PER071 7.DRS To receive a copy of this document, Indicate in the box "C" = Copy w/o attach /enci
"E" a Copy w/ attach /enci " = No copy j
OFFICE Rill:DRS lC Rill:DRS l,N Rlll:DRP l ;>
Rlll:DP \\\\ /
NAME Butler /kjc %3 W Westberg W Miller a4 JacoQsdg/Q6je DATE 07/l) /97 07/)) /97 07/n /97 07/)\\ )R7 A/
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l L. July 11, 1997 cc w/o encl: H. L. Hegrat, Manager, Regulatory Affairs j
W. R. Kanda, Director, Quality and l
Personnel Development l
J. J. Powers, Director, Perry Nuclear Engineering Department R. D. Brandt, General Manager, Nuclear Power Plant Department cc w/ encl:
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:
Docketfile wlencl_
Rlli PRR w/enci Rlll Enf. Coordinator w/ encl s
RPL)BLIC IE-011w/encil)
- dC/LFDCB w/enci LPM, NRR w/ encl l
DRP w/enci A. B. Beach, Rlli w/ enc!
DRS w/enci J. L. Caldwell, Rlll w/enci j
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CENTERDOR ENERGY Power Generation Group Perry Nuclear Power Plant Mad AMress'
216-2804915 Lew Cenlar Road P.O. Box 97 FAX:218-280-8029 Vee President Pony. Ohc 4061 Peny. OH 4081
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July 2,1997 PY-CEI/NRR-2186L
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United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 Reply to a Notice of Violation
Ladies and Gentlemen:
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f aclosed is the reply to the Notice of Violation contained in NRC Inspection Report 50-440/97006 for the Perry Nuclear Power Plant (PNPP), which was transmitted by letter dated June 3,1997. The Notice of Violation addressed two surveillanceinstructions that were performed prior to correcting erroneous information in the instructions.
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Non-intent conditional procedure / instruction changes were initiated to correct the erroneous
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information, but were not reviewed and approved prior to performance of the surveillance instructions.
PNPP persorinel determined the intent of the procedure was being met and incorrectly concluded that the procedure could be performed as written since the erroneous information was only used as a reference value to confirm a relay contact position.
If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory Affairs, at (216) 280-5606.
Very truly yours, A40 Enclosure cc:
NRC Region III Administrator NRC Resident inspector NRC Project Manager Jb '
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PY-CEI/NRR-2186L
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Enclosure Page1 of3 REPLY TO A NOTICE OF VIOLATION
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VIOLATION 97006-01
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Restatement of the Violation During an NRC inspection conducted on April 21 through 24,1997, a violation of NRC requirements was
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identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement l
Actions"(Enforcement Policy), NUREG-1600, the violation is listed below:
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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, I
procedures, or drawings.
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. Perry Administrative Procedure (PAP)-0522, Revision 7, " Instruction Changes," states, in part, that non-intent conditional changes receive approval from two members of plant management staff knowledgeable in the affected area, at least one of whom is either the Shift Supervisor (SS) or the Unit Supervisor (US); and that the change is assigned an effective date and is implemented in the respective instruction.
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Contrary to the above, on December 8,1995, the licensee performed surveillance instructions
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SVI-E32-T5400-E, "MSIV Leakage Control System - Steamline B Bleedoff Flow Channel Calibration for IE32-N053E," and SVI-E32-T5400-J, "MSIV Leakage Control System - Steamline C
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Bleedoff Flow Channel Calibration for IE32-N053J," before issuing non-intent conditional t
procedure / instruction changes (PICS) that changed the expected relay contact reference voltage from 0 Vac to 120 Vac. The PICS were subsequently approved on January 9,1996.
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This is a Severity Level IV violation (Supplement 1).
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Issue e
i In NRC Inspection Report No. 50-440/9 /006, it was identified that Perry Nuclear Power Plant (PNPP)
personnel performed two surveillance instructions (SVis) with erroneous information in the procedure. Non-intent conditional procedure / instruction changes (PICS) were initiated to correct the erroneous information, L
but were not reviewed and approved prior to performance of the SVIs. The NRC expressed concern that the instrumentation and control (I&C) supervisor and the Unit Supervisor (US) did not follow the PIC procedure
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(Plant Administrative Procedure (PAP)-0522, " Changes to Procedures and Instructions") prior to performing the two SVis.
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The NRC concluded that the performance of the two SVIs before completing the PICS had minimal safety
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been discussed with the US. However, the NRC was concerned that the I&C supervisor used a " window of opportunity" to accomplish safety-related testing and time was spent trying to find a way to perform the SVis before completing the PIC process. In addition, the US had the opportunity to implement the PICS
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before performing the SVis.. In accordance with PAP-0522, the US's signature and date would have
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documented approval of the PICS for use with the instructions.
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PY-CEUNRR-2186L
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Enclosure
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Background On December 7,1995, an I&C technician stopped the performance of an SVI at an insvuction ste that relay contacts were closed. The expected voltage as parenthetically referenced in tbc instructio was 0 Vac. Ilowever, the I&C technician obtained a voltage of approximately 124 Vac a,d terminated the performance of the SVI assuming the procedure was in error. The I&C supervisor independently reviewed the electrical schematic and concluded that the expected voltage was 120 Vac. A review of three similar instructions found the reference to be identical. The I&C technician initiated an I&C Temporary Change
l Request for the four SVis on December 7,1995, to change the expected reference voltage to 120 Vac.
Additionally, a Potential Issue Form (PIF) was written to document these conditions.
On December 8,1995, the I&C supervisor determined that an opportunity existed to complete SVis before issuing the PIC, Since the expected voltage was referenced in parenthesis (parenthetical expected values
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found in SVis provide reference points and are not intended to be actual data values) and the intent of the step was to verify the contact was closed, the I&C supervisor concluded the SVIs could be completed as
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written. The l&C supervisor determined that PAP-1105, " Surveillance Test Control," provided sufficient latitude to complete the SVis before issuing the PIC. The procedure stated, in part, that test instructions are followed in a step-by-step sequence unless deviation is speciHcally allowed, such as working with inadequate instructions. The l&C supervisor described to the US that the procedure step could be met
although the expected voltage was ditTerent from indicated. The US agreed that the two SVIs could be
performed before PIC ariproval. The two SVIs were subsequently completed. The PICS were later approved on January 9,1996.
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s During a recent NRC inspection, PNPP personnel recognized that a potential con 0ict existed between i
PAP-0522 and PAP-1105. On April 24,1997, a PIF was initiated to investigate Technical Speci6 cations (TS) and Updated Safety Analysis Report (USAR) requirements associated with the PIC processi.
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Reason for the Violation The I&C supervisor and US did not follow the PIC procedure before performing two SVIs. A " window of opportunity" was used to complete safety-related testing before completing the PIC process. The cause of
the violation was that the l&C supervisor and US exercised poorjudgment by interpreting PAP-1105 to allow procedure deviation with US approval without first completing a PIC per PAP-0522. This decision conDieted with management expectations.
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Perry Unit 1 TS 6.8.3 " Temporary Changes," which was in effect at the time 2, was implemented by procedure pal 0522, Revision 7. The procedure stated, in part, that non-intent conditional changes receive
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approval from u members of plant management staff knowledgeable in the affected area, at least one of whom is either the Shift Supervisor (SS) or US; and that the change is assigned aa effective date and is implemented in the respective instruction. Although I&C management and the US agreed that the 120 Vac
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' The focus of the PlF was whether existing procedures, specifically PAP-1105, conflict with the intent of USAR Section 17.2.5 and PAP-0522. The statements in PAP-1105 regarding unexpected results based on inadequate instructions, and the implied acceptability to use inadequate instructions after discussion with the US, conflict with PAP-0522.
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- Previous TS 6.8.3 has been relocated to USAR Section 17.2.5 as a result of the implementation ofimproved TS.
procedure for temporary changes remains PAP-0522, which describes in detail the requirements for conditional instruction changes.
These requirements are a direct interpretation of USAR Section 17.2.5. PAP-0522 Section 5.4 describes mechanisms to implement
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conditional non-intent changes which are equivalent to " Temporary Changes" as described in USAR Section 17.2.5.
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PY-CEUNRR-2186L
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Enclosure
Page 3 of 3 reference value would confirm that the relay contact was closed, their decision to perform the two SVIs before PIC approval bypassed specific temporary change procedure and TS requirements.
Corrective Steps Taken and Results Achieved The current PNPP work culture and management expectations do not allow work to proceed using inadequate instructions. Additionally, the circumstances of this event were reviewed and discussed with the I&C supervisors and technicians to reinforce management's expectations.
PNPP management reemphasizes their expectation that no inadequate procedure or instruction will be used in a month!y newsletter, Procedure Adherence: The Foundation ofour Success. Strict compllance with correct procedures and instructions is the standard at the PNPP. Incorrect procedures or instructions must be modified through the PIC process before continuing. Furthermore, a site wide communication from the Senior Management Team was issued in parallel with this violation response.
Corrective Steps that Will be Taken to Avoid Further Violations PAP-1105 will be revised to reference PAP-0522 to correct inadequate procedures or instructions prior to proceeding with any surveillance or periodic test instruction. The procedure change will be completed prior to the next refueling outage, which is currently scheduled to begin on September 12,1997.
Date When Full Compliance Will Be Achieved
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Full compliance was achieved when the PICS were approved on January 9,1996.
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 descri'. ec for the NRC's information, and are not regulatory commitments. Please notify the Manager-R, alatory Affairs it the Perry Nuclear Power Plant of any questions regarding this document or any associated regulatory commitments.
COMMrrMENTS PAP-1105 will be revised to reference PAP-0522 to correct inadequate procedures or instructions prior to proceeding with surveillance or periodic test instruction performance. The procedure change will be completed prior to the next refueling outage, which is currently scheduled to begin on September 12,1997.