Similar Documents at Perry |
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Category:Letter
MONTHYEARIR 05000440/20230042024-01-30030 January 2024 Integrated Inspection Report 05000440/2023004 L-23-207, License Amendment Request (LAR) for Adoption of TSTF-264-A Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2024-01-24024 January 2024 License Amendment Request (LAR) for Adoption of TSTF-264-A Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs L-24-017, 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative2024-01-24024 January 2024 30-Day Voluntary Report in Accordance with Industry Groundwater Protection Initiative IR 05000440/20234022024-01-10010 January 2024 Cyber Security Inspection Report 05000440/2023402 ML24003A8032024-01-0303 January 2024 Notification of NRC Fire Protection Team Inspection Request for Information ML23321A0472023-12-20020 December 2023 Letter to Rod L. Penfield - Perry Nuclear Power Plant, Unit 1 - License Renewal Regulatory Audit Regarding the Environmental Review of the License Renewal Application L-23-171, CFR 50.55a Request Number VR-9. Revision 0, Feedwater Check Valve Exercising Test Frequency2023-12-0808 December 2023 CFR 50.55a Request Number VR-9. Revision 0, Feedwater Check Valve Exercising Test Frequency L-23-244, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000440/20230112023-11-28028 November 2023 Biennial Problem Identification and Resolution Inspection Report 05000440/2023011 IR 05000440/20234032023-11-27027 November 2023 Security Baseline Inspection Report 05000440/2023403 ML23292A2972023-11-17017 November 2023 Table of Contents LAR (L-2023-LLA-0111) L-23-238, Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 202023-11-10010 November 2023 Mid-Cycle Revision to the Core Operating Limits Report for Operating Cycle 20 L-23-052, Submittal of the Updated Safety Analysis Report, Revision 232023-10-27027 October 2023 Submittal of the Updated Safety Analysis Report, Revision 23 ML23292A2482023-10-19019 October 2023 Fws to NRC, Federal Agency Coordination Under ESA Section 7 for Perry Nuclear Plant, Unit 1, License Renewal, and Concurrence with Not Likely to Adversely Affect Determination for Northern Long-eared Bat ML23292A2472023-10-19019 October 2023 Fws to NRC, Perry Nuclear Plant, Unit 1, License Renewal List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected IR 05000440/20230032023-10-11011 October 2023 Integrated Inspection Report 05000440/2023003 ML23249A1032023-10-0303 October 2023 Letter to Rod L. Penfield, Site Vice President-Perry Nuclear Power Plant, Unit 1-Notice of Intent to Conduct Scoping Process and Prepare an Environmental Impact Statement ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure ML23261C3642023-09-25025 September 2023 License Renewal Application Online Reference Portal ML23261B0192023-09-25025 September 2023 Aging Management Audit Plan Regarding the License Renewal Application Review ML23256A3592023-09-22022 September 2023 Determination of Acceptability and Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding the Energy Harbor Nuclear Corp. 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AC Sources-Operating. to Clarify the Power Factor Requirements When Performing Diesel Gener2023-06-0505 June 2023 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A Revision 2, Change TS 3.8.1. AC Sources-Operating. to Clarify the Power Factor Requirements When Performing Diesel Gener ML23144A3562023-05-25025 May 2023 Information Meeting with a Question and Answer Session to Discuss NRC 2022 End of Cycle Plant Performance Assessment of Perry Nuclear Power Plant, Unit 1 L-23-134, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-23023 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) IR 05000440/20230012023-05-0404 May 2023 Integrated Inspection Report (05000440/2023001) L-23-122, Annual Radiological Environmental Operating Report2023-04-26026 April 2023 Annual Radiological Environmental Operating Report L-23-121, Annual Radiological Effluent Release Report2023-04-26026 April 2023 Annual Radiological Effluent Release Report 2024-01-30
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARL-16-055, Response to Request for Additional Information Regarding VIO 05000440/2015010-012016-02-24024 February 2016 Response to Request for Additional Information Regarding VIO 05000440/2015010-01 L-15-375, Reply to a Notice of Violation2016-01-15015 January 2016 Reply to a Notice of Violation L-10-242, Reply to a Notice of Violation: EA-10-0352010-08-30030 August 2010 Reply to a Notice of Violation: EA-10-035 L-09-159, Response to Annual Assessment Letter2009-06-0202 June 2009 Response to Annual Assessment Letter ML0631001932006-10-26026 October 2006 Response to Issues Identified in NRC Inspection Report 05000440-06-014 ML0615204912006-05-24024 May 2006 Response to Us NRC Inspection Report 05000440-06-08 - Perry Nuclear Power Plant Confirmatory Action Letter Followup Inspection Corrective Action Item Implementation Inspection ML0613602182006-05-0909 May 2006 Response to Nuclear Regulatory Commission Inspection Report 05000440/2006007 - NRC Follow Up Inspection of IP 95002 Action Items ML0522105152005-08-0808 August 2005 Denial of Non-cited Violations Contained in NRC Inspection Report 05000400/2005003 ML0522105122005-08-0808 August 2005 Response to NRC Inspection Procedure 95003 Supplemental Inspection, Inspection Report 05000440/2005003 ML0512503422005-04-28028 April 2005 Reply to a Notice of Violation, EA-04-214 ML0513003072005-03-28028 March 2005 Reply to a Notice of Violation and Notice of Payment of Civil Penalty; EA-01-083 ML0510301682005-03-25025 March 2005 Reply to a Notice of Violation; (EA-01-082; EA-04-172) ML0412704862004-04-30030 April 2004 Response to Enforcement Action EA-03-208 from, Perry Nuclear Power Plant, Notice of Violation ML0410606092004-04-0808 April 2004 Reply to a Notice of Violation; EA-04-020 ML0406503632004-02-27027 February 2004 Reply to Notice of Violation; EA-03-197 ML0330404082003-10-24024 October 2003 Revised Response to a Notice of Violation, EA-03-007 ML0310002362003-04-0303 April 2003 Reply to a Notice of Violation; EA-03-007 2016-02-24
[Table view] |
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Perry Nuclear Power Plant 10 Center Road FirstEnergy Nuclear Operating Company Perry, Ohio 44081 William R. Kanda Fax. 440-280-5579 440-280-8029 Vice President - Nuclear April 08, 2004 PY-CEI/NRR-2786L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket Number 50-440 License Number NPF-58
Subject:
Reply to a Notice of Violation; EA-04-020 Ladies and Gentlemen:
Enclosed is the response to Notice of Violation, EA-04-020, issued to the Perry Nuclear Power Plant (PNPP) by the Nuclear Regulatory Commission on March 12, 2004. The details of the violation were documented in NRC Inspection Report Number 05000440/2003-010 issued on January 30, 2004. The violation was issued for failure to establish adequate written procedures to periodically vent the highest point on the discharge of the common low pressure core spray and residual heat removal 'A' water leg pump, in violation of Technical Specification 5.4. The violation is associated with a white significance determination process finding.
There are no regulatory commitments contained in this submittal. Any actions discussed in this document that represent intended or planned actions, are described for the NRC's information, and are not regulatory commitments.
If you have any questions or require additional information, please contact Mr. Vernon Higaki, Manager-Regulatory Affairs, at (440) 280-5294.
Very truly yours, g ;
Enclosure /
cc: NRC Region IlIl Administrator NRC Senior Resident Inspector - PNPP NRR Project Manager- PNPP
.l:...:.
PY-CEI/NRR-2786L Enclosure Page 1 of 3 REPLY TO A NOTICE OF VIOLATION; EA-04-020 RESTATEMENT OF THE VIOLATION Technical Specification 5.4 requires, in part, that procedures shall be established, implemented and maintained as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 4, "Procedure for Startup, Operation, and Shutdown of Safety Related BWR Systems," recommends the establishment of written procedures for venting of emergency core cooling systems.
Contrary to the above, as of August 14, 2003, the licensee had not established adequate written procedures to periodically vent the high point on the discharge of the common Low Pressure Core Spray (LPCS) and Residual Heat Removal (RHR) train 'A' water leg pump. Specifically, the licensee did not include Valve N27F786 in Procedures SVI-E21-T1181, "LPCS Venting and Valve Lineup Verification," Revision 4 or SVI-E12-T1 182A, "RHR A LPCI Valve Lineup Verification and System Venting,"
Revision 2. As a result, gas accumulated in the vertical section of piping on the discharge of the water leg pump and, following a loss of offsite power on August 14, 2003, the accumulated gas expanded, air bound the water leg pump and rendered LPCS and RHR 'A' inoperable.
REASON FOR THE VIOLATION A procedure content deficiency contributed to the failure of the common LPCS and RHR "A" water-leg pump due to air binding. Another effect of the water-leg pump air binding was the division I feedwater leakage control system (FWLCS) and the suppression pool cooling mode of RHR 'A" were considered unavailable for a loss of offsite power event. The air binding of the water-leg pump is discussed in the root cause analysis report approved on October 8, 2003 for Condition Report (CR) 03-04764. The CR stated that inadequate venting procedures failed to remove entrapped air from two high point locations in the division 1 LPCS system and LPCS/RHR "A" water-leg pump piping including the FWLCS high point vent valve, 1N27-F786 and the LPCS/RHR "A" crossover piping, 1E21-F511. A review of historical system operating instructions for LPCS showed the FWLCS high point vent valve and the LPCS/RHR "A" crossover piping vent valve had not been included in the past filling and venting instructions.
Additional investigation of the cause of the air binding of the water-leg pump is in progress. Further correspondence will be submitted if there are substantive changes to the information provided to date.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED At 2145 hours0.0248 days <br />0.596 hours <br />0.00355 weeks <br />8.161725e-4 months <br /> on August 14, 2003, plant operators completed venting the LPCS/RHR "A" water-leg pump by opening the pump casing vent valve. Following venting, the LPCS/RHR "A" water-leg pump was started and developed normal discharge pressure. The LPCS and RHR "A" systems were then filled and vented.
Since the low pressure alarms cleared and the venting was completed, the RHR "A" system was declared operable at 2002 hours0.0232 days <br />0.556 hours <br />0.00331 weeks <br />7.61761e-4 months <br /> on August 15, 2003. LPCS was subsequently declared operable at 0318 hours0.00368 days <br />0.0883 hours <br />5.257936e-4 weeks <br />1.20999e-4 months <br /> on August 16, 2003. It was not detected
PY-CEI/NRR-2786L Enclosure Page 2 of 3 at this time that air was still contained in FWLCS and that it would prevent the operation of the division 1 FWLCS and the suppression pool cooling mode of RHR "A" following loss of offsite power events.
Additional venting was performed on September 11, 2003, as part of the investigation of the air binding event. Following venting of the division 1 feedwater leakage control system piping and the LPCS/RHR "A" crossover piping, it was recognized that the FWLCS piping and the crossover piping had contained a significant volume of air. At the completion of these venting evolutions, the previously unidentified loss of function of the FWLCS and the suppression pool cooling mode of the RHR "A" train was restored.
The LPCS system operating instruction, SOI-E21, was revised (revision 11 effective September 12, 2003) to include 1N27-F786, 1E12-F511 and two additional valves to vent air from the suction of the LPCS/RHR "A" water-leg pump piping, the LPCS pump piping and the division 1 feedwater leakage control system piping.
Surveillance procedure, SVI-E21-T1181, "LPCS Venting and Valve Lineup Verification" was revised (revision 5 effective September 12, 2003) to provide instructions to vent any collected air from valve 1N27-F786 and valve 1E21 -F51 1.
The LPCS system operating instruction was subsequently revised (revision 12 effective October 23, 2003) to provide explicit instructions for venting that included a required venting time of three to five minutes.
The LPCS surveillance was subsequently revised (revision 6 effective November 7, 2003) to provide explicit instructions for venting that included a required venting time of three to five minutes.
Periodic venting (weekly at first) was established to determine air accumulation rates in this piping. The period of time between venting was gradually increased based on identified air accumulation rates. Although air has been noted during venting evolutions, an air volume sufficient to impact operability has not been observed. The venting is now performed monthly in accordance with the surveillance interval.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No prior site corrective actions exist for similar issues, but industry wide operational
-experience indicates air binding of pumps in general is an issue. To that end, an extent of condition evaluation was performed that included pumps at the Perry Nuclear Power Plant, which perform a keep fill function and utilize a minimum flow restriction orifice to maintain a required backpressure. The review determined this issue (generation of air in LPCS/RHR "A" water-leg pump) is not present in the other emergency core cooling and reactor core isolation cooling water-leg pumps or the fire jockey pump. This is based on evaluations of the piping configuration differences, flow calculations through the associated minimum flow orifices and venting to determine that the piping is water solid.
Additionally, ultrasonic measurement testing was performed utilizing a Shear Wave instrument to verify accessible portions of the division 1 and 2 FWLCS piping were filled with water. Although this review determined that venting instructions on these systems were adequate, the system operating instruction for RHR, SOI-E12, was revised (revision 15 effective October 23, 2003) to include 1E12-F616B, the RHR BIC water-leg pump suction orifice instrument valve, in the RHR B/C venting instructions.
PY-CEI/NRR-2786L Enclosure Page 3 of 3 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The RHR "A" system, with the exception of the suppression pool cooling mode, was restored at 2002 hours0.0232 days <br />0.556 hours <br />0.00331 weeks <br />7.61761e-4 months <br /> on August 15, 2003. LPCS was operable at 0318 hours0.00368 days <br />0.0883 hours <br />5.257936e-4 weeks <br />1.20999e-4 months <br /> on August 16, 2003. FWLCS and RHR "A" suppression pool cooling mode were restored September 11, 2003, following venting of the division 1 feedwater leakage control system piping and the LPCS/RHR "A" crossover piping. The revised procedures, SOl-E21 and SVI-E21-T1181, were made effective September 12, 2003. A subsequent revision, SOI-E21 revision 12 and SVI-E21-T1181 revision 6, provided instructions to vent for 3 to 5 minutes. The system operating instruction for RHR, SOI-E12, was revised (revision 15 effective October 23, 2003).
All required procedure changes are complete and current venting procedures are considered adequate.