ML19332C404

Responds to NRC 891025 Ltr Re Violations Noted in Insp Rept 50-440/89-23.Corrective Actions:Work Stopped on Div III & Restoration Began to Return to Operation & All Actions Required by Tech Spec 3.0.3 Completed

ML19332C404
Person / Time
Site:	Perry
Issue date:	11/22/1989
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1098, NUDOCS 8911280081
Download: ML19332C404 (3)

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iTHE CLEVELAND ELECTRIC ILLUMINATING COMPANY

i. 5 P.O. BOX 97 - PERRY, OHIO 44001 3- TELEPHONE (216) 2594737 5 ADoRESS-10 CENTER ROAD FROM CLEVELAND: 241 1650 l Serving The Best Lccation in the Nation

' Al Kaplan PERRY NUCLEAR POWER PLANT wct mSOENT. l uuctsa ort.,un - 4

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t November 22, 1989 c PY-CEI/NRR-1098 L '

i U.S.. Nuclear Regulatory Commission ,.

i Document Control Desk' Washington, D..C. 20555 Perry-Nuclear Power Plant L.

Docket No. 50-440 Response to-Notice of Violation 50-440/89023-02 m :Centlement g This letter acknowledges receipt'oC the Notice of Violation contained within

' Inspect ion - Rep' ort 50-440/89023 dated October 25, 1989. The report' identified j areas examined by Messrs.:.P. L. Hiland and G. F. O'Dwyer'during their l

- inspection conducted from August-11 through October 11, 1989 of activities at' the Perry Nut: lear Power Plant, Unit 1.

Our reiponse to Notice of Violation 50-440/89023-02 is attached.- Please call 1

should'you have any additional questions.

-Very.truly yo 8,

~Al Kaplan Vice President ,

Nuclear Group AK/njc Attachment c'e -' T. Colburn P. Hiland R. C. Knop - USNRC, Region III 0s i 89112000e1 9911gy y

jDR ADOCK 05000440 PDC

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( PY-CEI/NRR-1098 L 50-440/99023-02 Restatement of Violation Technical Specification 6.8.1.a requires that written precedures be l established, implemented, and meintained for surveillance tests.

r Contrary to-the above, on September 25, 1939, while perfc>rming Surveillance

- Instruction SVI-G43-T1306i " Suppression Pool Hakeup Timer Channel-A ,

Functional / Calibration for'1G43-K1," plant personnel failed to correctly '

implement Steps 5.3.9 and 5.1.10. .The incorrect installation of test, leads -!

into the wrong control room panel resulted in failing a control power-transformer for.an Emergency Service Vater discharge valve and the subsequent need to declare affected Division 1 safety related equipment inoperable.

This is a. Severity Level IV violation (Supplement I)

Corrective Actions Taken and Results Achieved On Septpmber 25,1989 at 1846 a loss lof control power to the A Emergency Service Water-(ESV) system pump discharge valve rendered the ESV system and.

its dependent systems inoperable. During the-same time period the Division III'ECCS (High Pressure Core Spray) and DG vere out-of-service for maintenance 3

placing the-plant into Technical Specification (TS) 3.0.3 Vork was stopped-on Division III and' restoration began so as to return it' o operetion. .

Division III was declared operable at 2030 and the operators.txited from TS 3;0.3. All~ actions-required by Technical Specification 3.0.3 were completed ,

as reb,uired. Division I was declared operabli at 0430 on September 26 after replacement and retest of the ESV control power transformer. Thie' event was-s reported in LER 89-027 '

The cause of this event is personnel error. 7ta .i t the Instrument and Control Section (ICS) technicians were performing a o. .111ance Instruction, they-unknowingly placed a jumper on the terminals ebn the correct number but in . ,

the vrong panel. Independent verification by the second technician failed to.

identify the' error. When the connecting toggle switch was closed, a short t circuit damaged the coatrol power transformer to the ESV pump discharge' valve. .

Corrective Action to Prevent Recurrence i

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'The ICS ' technicians responsible for the failed indepen'ent verification vere counseled with respect to their respcnsibilities and attention to detail.

The technicians vere required to prepare and present a training class to all IC3 field persornel on the lessons learned f rom this event.

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Attachm:nt PY-CEI/NRR-1098 L 4

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Additionally,-although not a corrective action to this Notice of Violation, enhancements to the independent verification procedural requirements bsve been' L

implemented. This was a result of_ separate yet similar independent verification problems within the same time frame.- The changes-include the

! mandatory separation of personnel performing valve line up and tag-out verifications by time and distance as well as a requirement to complete all ,

documentation of independent verification at the job site. However, it should be noted that separation of personnel by time and distance when performing surveillance activities cannot be reasonably achieved without significantly increasing the length of time that a system is in the test mode while performing the surveillance. Therefore, personnel accountability for additional attention to detail must be emphasized in these activities. l

'Date of Full Compliance ,

Full compliance.vas achieved upon restoration of the ESV control transformer ,

and satisfactory performance of SVI-G53-T1306 on September 26, 1989.

, Completion of-the training of ICS personnel as described above ia in progress J

and- vill be completed by December 31, 1989.

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