Text

Petition for Immediate Enforcement Action to Ensure That Util Complies W/Provisions & Requirements of OL
	ML20043C010
Person / Time
Site:	Perry
Issue date:	04/06/1990
From:	Hiatt S; OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML20043B998	List: ML20043B997; ML20043C000; ML20043C002; ML20043C010;
References
	2.206, NUDOCS 9006010180
	Download: ML20043C010 (28)
	v • d • e

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> k Aym i 1919 UNITED STATES OF AMERICA gg g f/

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NUCLEAR HEGULATOAY COMMISSICN j

Before the Directo', Office of Nuclebr Reactor Regulation

.in In the Matter of I

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c' THE CLEVELAND ELECTRIC ILLUM7NATING

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COMPANY, ET AI..

) Docket No. 50-440

)

2.206 Petition (Perry Nuclear Power Plar.t, Unit 1)

)

ngsegh" PETITION FOR IMMEDIATE ENPORCEMENT ACTION 1.

INTRODUCTION Pursuant to 10 CPh 2.206, the Ohio Citizens for Responsible Energy, Inc. ( OC RE " ) hereby petitions thu Directot, Otfice of Nuclear heactor Regulation to take s

irnmediate enf orcernent action to ensure that the Cleveland Electric Illuminating Company coroplies with the provisions and requirements of the operating license for the Perry Nuclear l

Power Plant.

II.

DESCRIPTION OF PETITIONER Petitione OCRE in a private, nonprofit corporation organized under the InA vf the Stato of Ohio.

OCRE apecializes in research and advocacy on issues of nuclear reactor saf ety and has as its goal the prorr.otion and

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i 9006010180 900529 ADOCK 0500g O

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application of the highest standards of safety to such facilities. OCRE was an intervenor in the operating license l

proceeding for the Perry Nuclear Power Plant.

Members of OCRE l

live and own property within 15 miles of Perry.

III.

GROUNDS FOR RELIEP

[

l At 2:37 AM on April 3, 1990, the Cleveland Electric Illuminating Co, Licensee for the Perry Nuclear Power Plant,-

declared an' Alert in accordanco with its emergency plan because both Division 1 and Division 2 of the PNPP Emergency Service-l Water System were declared inoperable'.

Division 1 of ESWS was

[

i declared inoperable because a failure of a gasket seal allowed a stream of water to impinge upon a motor' control panel, which t

resulted jn failure of the Division 1 ESWS bacswash pump.

The Division 2 CSWS backwash pump has been out of service since on or about November 15, 1989, due to lack of replacement parts.:

The Division 1 ESWS was repaired and returned to service by 6:01 AM on April 3, and the Alert was lifted.

Apparently the l

Division 2 ESWS is sti.11 out of service.

The Perry plant i

l continued to operate throughouE the Alert.

(See attached news-l l

k articles.)

l By allowing the Division 2 ESWS to be inoperable since t

November 1989, the Licensee has violated the terms and conditions of the PNPP. operating license, as defined.by the i

2 6

9 t

plant Technical Specifications.

PNPP Technical Specification 3.7.1.1 requires the ESWS

j loops to be operable when the systems or equipment' associated with them are required to be operable.

The Technical F

Specifications define OPERABLE - OPERABILITY as follows:

i i

1.29 A system, subsystem, train, component or device l

shall bc OPERABLE or heve OPERABILITY when it is-capable of performing its specified function (s) and when all necessary attendant instrume,qtation, controls, electric power, cooling or seal water,~ lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its i

function (s) are also capable of performing their related support function (s).

Determining which such auxiliary functions and components are necessary requires an examination of the' plant licensing-basis, the Final Safety Analysis Report.

FSAR Section 9.2.1.3 states that the ESWS "(t) raveling screens, P49-001A and B,_

7 and their associated screen wash' pumps, are automatica1'ly started f

electrically by a LOCA signal and will run continuously until the signal is cleared."

Thus, the backwash pumps are,-

according to the PSAR licensing basis, necessary'for the'ESWS j

to perform its function.

When the backwash pump for Division i

2 ESWS became inoperable in November 1989, the Division 2.ESWS 1

loop should have been declared inoperable, and the appropriate Technical Specification action statement entered.

The action j

statement for Technical' Specification 3.7.1.1 states:

J With an emergency service water loop (s) inoperable which j

is associated with system (s) or component (s) required to 6

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be OPERABLE, declare _the associated system (s) or component (s) inoperable and take the ACTION required by the applicable Specification (s).

To determine which systems are associated with the Division 2 ESWS requires an examination of the plant licensing basis, the FSAR.

FSAR Section 9.2.1.2 indicates that the Division 2 ESWS supplies the Division 2 RHR heat exchangers, the Division 2 standby diesel generator, the Division 2 Emergency Closed Cooling Heat Exchanger, and the Division 2 ruel Pool Cooling Heat Exchanger.

For the Einergency Closed Cooling -System, Technical Specification 3.7.1.2 requires the=ECC loops to be operable when the associated systems are required to be operable.

The_

action statement requires that, with an ECC loop inoperable, the associated systems or components are to be declared inoperable and the action required by the applicable Technical Specifications taken.

For the Emergency Closed Cooling System, PSAR Table 9.2-14 indicates that the Division 2 Emergency Closed Cooling Cooling System supplies the RHT B pump seals, the RHR B room cooler, the RHR C pump seals, and the RHR C room Cooler.

Thus, with the Division 2 ESWS inoperable, the following systems and components are to be declared inoperable: Division 2 RHR heat exchangers, Division 2 standby diesel generator, RHR B pump seals and room cooler, RHR C pump seals'and. room cooler, and Division 2 Fuel Pool Cooling System.

With the plant in 4-l

9

.i Operational Condition 1, the action statements-for the following Technical Specifications are invoked:

Tech'nical Specification 3.5.1, ECCS - Operating:-for Division 2, with=both LPCI subsystems B and C inoperable,: restore at least one subsystem to operable status'within:72 hours,-

otherwise be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Technical Specification 3.6.3.2, Containment Spray: with oneL containment spray loop inoperable, restore it to operable-status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown.within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Technical Specification 3.6.3.3, Suppression Pool' Cooling: with one suppression pool cooling loop inoperable,, restore.it-to-operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in.at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown'within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Technical Specification 3.8.1.1, A.C. Sources -. Operating: with either diesel generator Division l'or Division 2 inoperable, restore it to operable status within-72 hours or be in at least

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hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown I

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within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

k Thus,..in November 1989,, the Licensee had,72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .to.

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restore.the Division 2,ESWS-backwash pump toiservice,twand e

. failing to do so, the perry plant should have been placed in s

hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown

. within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Perry Nuclear Power Plant has operated in violation of its Technical. Specifications since November 1989.

IV.

RELIEP REQUESTED i;

10 CPR 50.36 (c) (2) defines Limiting Conditions for Operation as "the lowest functional capability or performance levels of equipment required for. safe operation of the s

facility."

When a Limiting Condition for Operation is not met, "the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

The Licensee failed to comply with these provisions.

Because this lack of compliance.with the PNPP Technical Specifications rdiscs substantial 1 health and safety issues (see Consolidated Edison Co. of New York (Indian l

Point, Units 1, 2, and 3), CLI-75-8, 2 NRC 173, 175 (1975);

_ Northern Indiana Public Service Co. (Bailly Generating Station, Nuclear-1), CLI-78-7, 7 NRC 428, 433 (1978), aff'd sub nom, t

l 6

1 3

6 I

a Porter County Chapter v. NRC, 606 F.2d 1363 (D.C. Cir. 1979),

the granting of relief is appropriate.

OCRE requests that:

1.,the NRC. order CEI to place Perry Unit 1 in cold shutdown unless and until the Division 2 ESWS-is made operable, as defined by the plant Technical Specifications and the plant licensing basis as defined in the PNPP FSAR; 2.qthe NRC issue a Notice of Violation.with regard to this matter and impose the appropriate civil-penalty; and I

3. the NRC take any other action which is just and proper, l

I Respectfully submitted, M

Susan L.

Hiatt OCRE Representative l

8275 Munson Road Mentor, OH 44060 (216) 255-3158

/W/Lki /770 DATED:

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r Faultyfilter touches off pm,%m Perry alert By TOa4 BRECMENRIDGE panel that powers a back-wash By declaring the-alert at 2.37 a.m CEI committed itself to a 730 sw wenn

h. -

pump.

The Perry nuclear power plant 3

The pump cleans debris from one s.m. shutdown of the plant if the went on alert status for 3% hours of two 40-foot-high screens that fil-back-wash pump circuitry could not etrly yesterday after water spray FRORE/1.A ter lake water entering the emer.

be repaired. But the work was done from a leaky filter touched off gency cooling water system.

by 6 01 a.m o.Tecials said.

events that forced plant operators iems. said NRC spokesman Russ Without the pump. the screen is Power was reduced to 954 by to declare an emergency water-Marabito "By the same token,when considered inoperabic.

4.50 a.m.but was restored.said CEI coolingsystem inoperable.,

a (back-up) system that is needed to Unfortunately for CEI. the back.

spokesman Michael Lumpe.

No one was mjured and public provide cooling water to other wash pump on the other screen had The leak occurred because of a s.fety was neser threatened, sa safety systems is declared inoper-been down since November while loose tw>lt on a rubber gasket. Kap-federal regulators and ofTicials abic,we look at it quite closely."

the utility waited for new part?,

Ian said. Corrective action could in-E1dec n a nd The event began about 1130 a m.

said Alvin Kaplan.sice presidentin ciude additional bolts and more lowest of four emergency classifica.

during testing of safety equipment, charge of CEI s nuclearoperations.

frequent inspections,he said.

tions, at 2.35 a.m. It was lifted at -

that. included components in the With both screens moperable.

Anti Perry actisists said the acci-6'01 a' alert is called when an acci-

-ei4si pump house a concrete the emergency water systemhad to dent was further proof that the be declared inoperable under plant is a hazard. The event "shows m

building north of the plant's reactor terms of the plant's license. said that this is a risky industry. Forts-An dent poses a pcnential threat to

emplex, Patrick Hiland.NRC on site inspec-nately we weren't in any imminent P ant operations.

The building houses pumps for a tor.

danger, but the risk is still there."

l

,gy,,

back-up system that would de! aver Realistically, the submerged fil.

said Susan Hiatt of Ohio Citizens cials, as well aa Lake. Geauga and..

cooling water.to reactor-safety sys. ters probably could have done thetr for Responsible Energy.

Ashtabula county commissioners, tems if' primary cooling. systems job for several months without the The plant has declared n'ine.

e' were notified immediately after the - ;

'y dert was declared and - were back-wash pumps. Hiland said.

less-serio.as " unusual events" since I3il'd-briefed later in the morning.

A seal on a small screen that fil-The plant's primary cooling wa-testing began.

~

It was the second alent at the lers incoming lake, water failed, ter system continued withoid prob-Twelve " alerts

were declared at y

.t plant. The first occurred March 16.

officials said. Water sprayed about. Iems during the event officiais nuclear power plants ' nationwide if 1967. when power was lost Ihr five 10 feet and, shorted:out a control said.

last year.

.i minutes to alarms in the plant's

_,.. - 93 s.

g control room, officials said. r

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The US Nuclear Regulatory,

Commissiort expects a. thorough 3

investipion of the event within 30 d

days.

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The most importantissue is that there was no health or safety prob-!g t

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LOCAL REPORT y-vne Broken seal at Perry plant investigated ferent situations. In this case, Perry work-tric filuminating Co., has dual emergency reauwao start wnm service water systems. But one of the ers had six hours to return the system to By John C. Kuehner systems has been out of operation since service, which they did.

Perry Nuclear Power Plant operators November because of a problem in find-Lumpe said plant operators are trying are investigating why a gasket seat broke ing replacement parts, Perry spokesman to learn why the gasket seal broke. The yesterday morning unleashing a chain of Michael Lumpe said.

NRC will take no action against plant op-events that forced plant operators to re-Perry operators must call an alert when crators.

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duce power and declare an alert.

two emergency core cooling systems are Count) and state emergency officials in

' The public fxed no danger from the declared inoperable.

. Lake, Geauga and Ashtabula counties alert, Nuclear Regulatory Commission At 2:37 a.m. yesterday, operators de-were monitoring the event on a moment-spokesman Russ Marabito said. The alert clared an alert, the second lowest of four by-moment basis, said Robert H. Retzler, was called only because the seal failure emergency classifications. The alert lasted director of the Lake County Emergency was a problem from a regulatory and pro-uatil 6:01 a.m. Reactor power was re-Management Agency. Emergency opera-cedural standpoint, he said.

duced from 100 percent to 95 percent for tion centers in-the three counties and at When the gasket seat broke, Marabito about an hour while the cooling system the state level were partially activated, he said.

said, water sprayed a nearby motor-con-was repaired.

The emergency officials stayed in con-trol panel. The water caused several emer-Even though the emergency service wa-tact by a five-way phone link. They also gency service water system components.

ter system remained operable, NRC tech-had a direct line into Perry's Technical such as pumps, to fail.

nical specifications require that if any por-Support Center, a communications pipe-The emergency service pumps provide tion of the emergency cooling system fails.,

line to handle their questions.

water to backup safety systems that de-the whole system must be declared inoper--

Yesterday marked the second time

~ " ' l liver water to the plant during emergen-able.

cies. Water is needed in emergencies to Depending on the system; the_NRC al-plant operators have declared an alert at remove heat from the nuclear core and to lows'a specified amount of time to repaie Perry. The first one occurred March 16, problems or shut 'down the plantm, t a 1987, during the plant's start-up and test act as a coolanit for plant systems.

The plant, operated by Cleveland Elec-Different time allotments exist.for dir ~ phase.

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Y [] 90 UNITED STATES OP-AMERICA NUCt. EAR REGULATORY COMM18820W 4efore the Director, Office of Nuclear Reactor Regulation' In the Matter of

)

Tile CLEVELAND ELECTRIC II.I.Utt!NATING

)

s r.*0MPANY, ET A1,.

I Docket Wo.10-440 1

2 206 Petition (Perry Nuclear Power Plant, Unit 1)

)

PETIT!CN FOR IMMEDIATE ENFORCE:43MT ACT!04 K444/

1.

INTRODUCTION

=

Pursuant to 10 CFR 2.206, the Chao Citizens for Responsible Energy, Inc. ("OCRE") hereby Petitions the Director, office of Nuclear Reactor Regulation, to take immediate enforcement action to ensure that the Cleveland Electric Illuminating Company complies with the provisions and requireinants of the operating license for the Ferry Wuclear Power Plant.

C DESCRIPTION OF PETITIONER Petitioner CCRE is a private, nonprofit corporation organizea unoer sne aaws or tne atace of vnio.

ocka, specializes in research and advocacy on issues of'auclear reactor safety and~has as its geal the promotion and IDO --- 005427 N"

Of70L A-CI

a

^

application of the highest standards of safety to such

{

facilities. OCRE was an intervenor in the operating license l

proceeding for the perry Nuclear Power Plant.

i Members of OCRE i

live and own property within 15 miles of terry.

i i

l GROUNDS FOR RELitt At 2:37 AM on April 3, 1990, the cleveland tiectric illuminating Co, 1.icensee f:r the Perry Nuclear Power Plant, declared an Alert in accordance with its emergancy plan because-moth Division 1 and Division 2 of the PNPP taergency Service Water System were declared inoperable.

Division 1 of E8WS was I

declared innpernwh weeaues a failure ** a easkes seal allewed

?

a stream of water to impinge upon~a motor control panel, whien resulted in fmilure of the Division i ESWs backwash pump.

i The Division 2 ESWS backwash pump has been out of service'since on or about November 15, 1949, due to lack of replacement parts.

1 The Division i ESWS was repaired and returned to service by 6:01 AM on April 3, and the Alert was lif ted.

Apparently the Division 2 ESWS is still out of service.

The party plant continued to operate throughout the Alert.

1see attached news articles ) %

. ' b,.

By allowing the Df. vision 2 ESWS to be inoperable since November 1989, the Licensee has violated the-terms and' conditions of the PNPP operating license, as defined by the i'

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j plant Technical Specifications, i

L FNPP Technical Specification 3.7.1.1 requires the ESWS Aoops to be operable when the systems er equipment associetad I'

with them are required to be operable.

The Technical f

Specifications define OPERABLE - CPERASILITY as follows:

l 1.29 A syst'em, subsystem, train, component' or device shall be optRAsts or have OPERASILITY when it ir capable i

of. performing its specified function (s)T and when A11 necessary attendant instrumentation, controls, electric power, cooling or seal water, lubrication, or' other auxiliary equipment that are required _for the system, subsystem, - trair., component orEdevice to perform its:

function (s) are also capaole of perf orr.ing tneir reldted support function (s).

t Determining which such auxiliary functions and components I

.are necessary requires an examination of the plant licensing' basis, the Final Safety Analysis Report.

FSAR Section 9.2.1.3 l

I l

states tnat the ESWS "(t) raveling screens,-P49-001A and B, and their associated screen wash pumps, are automatically started electrically by a LOCA signal and will run continuously until l

i the signal is cleared."

Thus, the backwash pumps are, i

f according to the LFSAA licensing basis, necessary for the ESWS to perform its function.

When the backwash pump-for Division 2 ESWS becase inoperable in-November'1989, the Division 2 ESWS i

loop should have been declared' Inoperable, and the' appropriate Technical.0pecification action statement entered.

The action.

t statementdfor ' Technical Specification 3.7.1.1 states: -

4 With an emergency-service water loop (s) inoperable which p

i is associated with systea(s) or component (s) required to h

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-?e be OPERA 8LE, declare the associated system (s) or.

component (s) inoperable and take-the ACTION-required by-

.the applicable Specification (s).

~

To determine which-systems are associated with the Division 2 ESWS requires an examination of the plant licensing-basis, the FSAR.

FSAR Section:9.2.1.2 indicates,that~the Division 2:ESWS supplies the Division 2 RHR heat eechangers, J

the Division 2 standby diesel generator, the Division!2' Emergency Closed Cooling 1:an: Exc$ anger, and: the Divi; ion 2 a

Fuel Pocl Cooling; Heat Exchanger.

For the Emergency Closed Cooling System, Technical

]

Specification 3.7.1.2 requires. the ECC' loops to be operable i

wnen the associated systems are required to be operable. 'The-action statement requires'that,'with an ECC: loop inoperable,:

the associated systems,or components are to-be-declared 1

inoperable and the action required by.the applicable Technical-specifications taken.

For the Emergency closed Cooling-$ystem, q

t FSAR' Table 9.2-14 indicates that the' Division 2 Emergency Closed Cooling Cooling System supplies the RNR B pump seals, the RHR 5. room cooler, the RHR C pump ; seals, and> the RRR C room cooler.

l Thus, with the Division 2 ESWS inoperable, the following systems and components are to be-declared inoperable: Divisic'n V

2 RHR he tt exchangers, Division 2 standby diesel generator, RHR V

R pump seals and room cooler, RHR C pump seals atul room cooler, l

.1 and Division 2 Fuel pool Cooling System.,,With the plant in.

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following Technieal specifications are invoked:

l Technical Specification 3.5.1, ECCS - Operating: for Division 2, with both LpC1 subsystems 8 and C inoperable, restero at least one subsystem to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , otherwise be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 1

and in cold shutdown within the dollowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

l l

Technical Specification 3.6.3.2, Containment Spray: with one containment spray *. cop inoperable, restore it to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

j-Technical Specification 3.6.3.3, suppression Pool Cooling with one suppression pool cooling loop inoperable, restore it to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least het shutdown within the ner.t 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown within the fallowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Technical Specification 3.8 1 1, A.C. Sources - Operating: with either diesel generator Division i or Division 2 inoperable, l,

restore it to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least het shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdowt l

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within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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9 Th s November 19_19, the Licensee had 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the ' Division 2 ESWS backwash pump to service, and

- f ailine to do so, the Perry alant. sht uld have been placed in-het snu,cdwen within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown 1

within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Perry Nuclear Power Plant 1

has operated in violation of its Technical-Specifications since I

a Novemcer 1989.

IV.

RELIEF REQUESTED -

10 CPR 50.36 (c) (21 ~ defines Limiting Conditions for Operation as the lowest functional capacility. ort performance.

l 1evels of equipment required for. safe operation of the..

facility."

When a Limiting Condition.'for Operation-is not met, "the licensee shall shut down the reactor-or follow any.

l remedial action permitted by the-technical specifications.until '

.t i

the condition can be met."

The Licensee-failed to comply with these provisions.

Because this lack of compliance with the PNPP Technicai Specifications raiset substantial health and.

satety issue.s (see Consolidated Edison-Co. of' New York (Indian l

~

Point, Unigsgij 2, and 3), CLI-75-8,. 2 NRC 173,.175 (1975).

. w.

Northern Indiana Public Service Co. (Sailly Generating Station, Nuclear,-1),. CL1-78-7, 7-NRC 428, 433 (1978), gj,[,'j g ng.

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't Porter County Chapter V.____WRC,-606 T.2d 1363 (D.C. Cir. '1979),

the granting of telief is appropriate.

OCRE requests thatt 1.- the. NRC order CEI to place ~ Perry Unit l'in cold shutdown l

unless-and until the Division.2 RsWs is made operable, as defined by the-' plant Technical Specifications-and'the plant licensing basis as defined in the PNPP F5 art-1 l-i.

l-

2. the NRC issue a Notice of Violation with regard to'this.

matter an,d' impose.the appropriate civil penalty.and

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3. the N

-(tgke any other action which is just and proper.

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...p a 4 Respectfully submitted, t

S 1

Susan L. Hiatt

{

CCRE: Representative-j 8275 Munson Road i

Mentor, OK.44060

. i (216) 255-3158

i.

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LOCAL REPORT q w

c Broken seal at Perry plant investigated snent situeeseos se ads cou. Pavy wesh.

evic fueminating ro, has deel emergency

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wrwice water systems. See one of the ees lead sis $ssers ete steere die syssem es By Jotn C. Kuehner service, wenc9t they did.

systesses has been oeet of operassee tiece 4.eaupe said esesne speeseoes ese Perry Noelear Power Plant aperatoes Noveneber becente of a pectileen in fiend- ~ se tenne why see gasket seat heshe.

ave investigassop why a gastret seal brotte ing es.*_- e. c ; parts. Perry spehessese MRC wig sete son action sosiast pleut ep.

yesserday suserseeng. esdeashing a chain of Mechaet f ware said erseers.

8D events that forced plant operators era re-Perry operators meest call an siert whese Ceemer see sense emessency asimiets in doce peser med deetme== seert.

two emeenency eme cooling syseems see - Latte. Gesege sed Asleesbels escuties the pubese Inced so danger from the declared isiepersMe.

alert. Nuclear Regulatory Cosesnission At 2:)T a.m. yestesday. operators de.

wese amenigering the event e a seament-

potresseease Ross Marabies said. ifee sleet claeed an aleet 18ec second emeest of four by-seessmene basis. said Retnest H. Reenter.

was esiled only becsene Ilse seat faisuee ensevnency efassdications. Ylee aters lassed director of she 8.ste casenty Esmessemey Managensent Agesecy. Emergeney speca-was a problern frene a regelseery and pro-eentil 6188 a.sse. Reacter power was re.-

tien centess in she three cemeties and at

,j ceduval standpoint. he said.'

disced Frase top percent se 95 percent for" eene sense Gewel weve posseeWy eteisesed, he When ttie gedet sesi beelte. Marabito stemet an heer while ese ceeteeg syseene

'said.

said. water sysse3ed a t eseby neuter.cnn-was repaired Time essessency eKicie$ sosped se eso.

trol penei. The mater caened several emer.,,

f-:ven t%oesah'she esseergency service ws.

eact by a five.way phase liegt.

also gency service waeer system conoponents,. 7. ter syseeses renseined operable. NRC sech.

had a disert line imee. Pevey's T-~ pipe such as poenps, se fail. r... w 'J nicatspecifications eeguire sense if any par.

ow' sensi,of the enseegency cooling syseem faits, Suppers Ceaser. a =

lisse to temme their geessions.

i

",;The' emerpseey service'poenys

'. backup safet se(

%wlielelyseene eneest toe deetared inaper.

Yesterdayisosittee.the,. seteed eine

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shfeL deelesed se alert at se she ingemee

. ose the system. else NRC al.

pleet, _. -l

iit needed sse y I

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eeemesed 9derde 84.

Persy. The %*sIWgleet*p'-up ased test..

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ispicci avnesnet of tiene se reparr

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NUCLEAR REGULATORY COMMISSION-

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EDO Principal-Correspondence Control-h-

FRON:

DUE: 05/25/90

.EDO CONTROL: 0005427 DOC DT: 04/06/90 FINAL REPLY:

Susan L. Hiatt Ohio-Citi:: ens for-Responsible Energy. Inc. (OCRE) n TO:

u-gj NRR

~ FOR SIONATURE OF:

- GRN: **-

' CRC NO:

p.

DESC:

ROUTING:'

^

2.~206 PETITION RE PERRY' NUCLEAR POWER PLANT-(Murlev. JRR Davis, RIII

= DATE: 05/04/90 Lieberman, OE ASSIGNED TO:

CONTACT:

OGC Scinto SPECIAL INSTRUCTIONS OR REMARKS:

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tf 'i.7l 9> n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Director, office.of Nuclear. Reactor' Regulation' in the Matter ~of

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Tile CLEVELAND ELECTRIC ILLU?!!NA!!NG

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-COMPANY, ET AL.

> Docket No. $0-440

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2.206 Petition (Perry Nuclear Power Plant, Unit 1)

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')l PETITION FOR IMMEDIATC NPORCEMENT ACT10'4 l

INTRODUCTION O

Pursuant to 10 0FR 2.206, the Chao Citizens for I

Responsible Energy,-Inc. ("0CRE") hereby-Petitions the Director, Office of Nuclear Reactor Regulation, to take 1

immediate enforcement action to ensure that the Cleveland i

)j Electric illuminating Company complies with-the provisions 1 and i

requirements of the operating license for the Perry Nuclear Power Plant.

.- )

11.

DESCRIPTION OF PETITIONER

_l Petitioner CCRE is a private, nonprofit corporation r

- organisea unoer tne laws or tne state of vaio.

ocka specializes in research and advocacy aan issues of nuclear

.I reactor safety and has as its goal the promotion and

' ' i'.

1 EDO --- 005427

'{

097 d L. A -c (

1 application of the highest standards of safety to such f acilities. OCRE was an intervenor in the operating license 4

proceeding for the perry Nuclear Power plant.

f Members of OCRE live and own property within 16 miles of Perry.

111.

GROUNDS FOR RELIEF At 2:37 AM on April 3, 1990, the Cleveland Electric illuminating Co, *_teensee fer the Perry Nuclear Power Plant, declared an Alert in accordance with its emergency plan because moth Division i and Division 2 of the PNPP Emergency Service Water System were declared inoperable.

Division 1 of EsWS was i

declared innperania heeause a failure es a emer<as seal allewed a stream of water to impinge upon a motor control panel, whica resulted in failure of the Division i Esws backwash pump.

The Division 2 ESWS backwash pump has been out of service since on or about November 15, 1989, due to lack of replacement parts.

The Division i ESWS was repaired and returned to service by 6:01 AM on April 3, and the Alert was lifted.

Apparently the Division 2 ESWS is still out of service.

The Perry plant continued to operate throughout 'the Alert.

(see attached news i

articles,) c3 By a'11 wing the Division 2 ESWS to be inoperable since November 1989, the Licenses has violated the teras and' conditions of the PNPP operating license, as defined by the N

e I

plant technical Specifications.

PNpp Technical Specification 3.7.1.1 requires t' he ESWS i

Aeops to be operable when the systems er equipsmat associet.ad j

with them are required to be operable.,

The. Technical specifications-define CPERABLE - OPERABILITY as followes

);i 1.29 A syst'em, subsystem, train, component-or device shall be CPERAsLE or have OPERA 81LITY when it. is ' capable of performing its spect.fied function (sliand when all l

J necessary attendant instrumentation, controls,. electric.

power, cooling or seal' water,. lubrication,. or other auxiliary. equipment that are required f or tho' system, j

subsystem, train, component or device to perform its.

-i function (s) are also capaole of performang tneir related j

support function (s)..

j Determining which such auxiliary _ f unctions and components are necessary requires an examination of the plant licensing:

basis, the Final-Safety Analysis Report.. FSAR Section 9.2.1.3 states that the tsWS " ttiraveling screens, P49 001A and s, and their associated screen wash pumps, are automatically started-electrically oy a LOCA signal and -will run continuously until the signal is cleared.* Thus,.the backwash pumps are, according to the FSAA licensing basis, necessary for the 58Ws ~

to perform its f unction. When the backwash pump for Division 2 ESWS became inoperable in November 1999, the Division 2 ESWS loop should have been declared' inoperable, and tne appropriate-Technica1. specification action statement entered.

The action statementdfkr

Technical specification 3.7.1.1 states:

With an emergency service water loop (s) inoperable which is associated with system (s) or component (al required'to...... **.

I

c be OPERABLE, declare the associated system (s) or component (s) inoperable and take the ACTION required by the applicable Specification (s).

To determine which systems are associates with the i

Division 2 ESWS requires an examination of the plant licensing basis, the FSAR.

r$AR Section 9.2.1.2 indicates that the Division 2 ESWS supplies the Division 2 RNR heat exchangers, the Division 2 standby diesel generator, the Division 2 Emergency Closed Ocolang lient Exc.$ anger, and the Division 2 l

Fuel Pccl Cooling Heat Exchanger.

For the Emergency Closed Cooling System, Technical Specification 3.7.1.2 requires the ECC loops to be operable wnen the associated systems are required to be operable.

The action statement requires that, with an ECC ioop inoperable, the associated systems or components are to be declared inoperable and the action required by the applicable Technical specifications taken.

For the Emergency Closed Cooling System, f

FSAR Table 9.2-14 indicates that the Division 1 Emergency closed Cooling Cooling System supplies the RHR 8 pump seals, I

the RHR S room cooler, the RHR C pump seals, and the RRR C room cooler.

Thus, with the Division 2 ESWS it. operable, the following systems and components are to be declared inoperable Divisich V

2 RHR heat exchangers, Division 2 standby diesei generator, RHR V

B pump seals and room cooler, RHR C pump seals and room cooler,,

and Division 2 Fuel pool cooling System.,,Mith the plant in

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following Technical Specifications' are' invoked:

l Technical Specification 3.5.1, EccS - Operating: for Division-2, with both Lpc! subsystems B and C inoperable', restore at least one subsystem to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , otherwise be in at least het shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months I

and in cold shutdown within the fo11owing24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

- j Technical Specification 3.6.3.2, containment spray: with one-i containment spray '. cop' inoperable, restore it to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least hot shutdown within U

the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown within the following 24:

hours.

i Technical Specification 3.6.3.3, suppression pool Coolings with one suppression pool cooling loop inoperable,. restore it to -

operable -status within 72 houtst or be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .and in cold shutdown within the fallowing'24' hours.

Technical Specification 3.8.i.1, A.C. Sources - Operating: with either diesel generator Division i or Division 2 inoperable,-

restore it to operable status within 72 ' hours or be in at least het shutdown within the next' 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in cold shutdown 4.

b

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2 m

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s within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

1

'A Thde. a ". November 1989, the Licensee had 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the Division 2 ESWS backwash-pump to service, and failing to do so, the. perry plant should have been placed in hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and;in cold ishutdown -

within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The Perry Nuclear Power plant

\\

has operated in violation of its Technical specifications since a

i Novemner.1989.

-l 1

IV.

RELIEr AtoussTED j

a

.0 CPR 50.36 (c) (2) defines Limiting' Conditions for L

Cperation as."the icwest funct:.onal capacility or. performance

(

invels of equipment required for safe operation of the i

facility."

When a Limiting Condition for operation is not met,

]

"the licensee.shall shut down the-reactor or' follow'any 1

remedial. action permitted by the technical. specifications until '

'j the condition can be met."

The Licensee' failed to comply with-

- these provisions.

Because this lack of compliance with the PNPP Technical Specifications raiseg substantial: health and safety issues (see Consolidated Edison Co. of New York (Indian 1

Point, Unigspj2,and3),CLI-75-8,2NRC173,175.(1975);

Northern Indiana Public Service Co. (Bailly Generating Station, e

Nuclear,-1),. CLI-78-7, 7 NRC 428, 433 (1978), AM'dgg,ng.

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Porter County Chapter v. MRC, 606 F.2d 1363 (D.C.-Cir. 1979),

the granting of relief is appropriate.

OCAR requests that

1. the NRC order CEI to place Perry Unit i in cold shutdown untoss and.until the Division 2 28W8 is made operable, as defined by the plant Technical Specifications and: the plant' q

licensing basis as defined in the PNPP-FSARt' i

kl

2. the NRC issue a Notice of Violation-with regard to this-matter an,d impose the appropriate' civil penalty: and-e]{-

..My!?s % *

3. the N

{tgke any other action which is just and proper.

<... t b; ' 5tti

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..y. u-Respectfully submitted,-

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Susan L. Hiatt i

'OCRE. Representative-l 8275 Munssa Road I

Mentor, OH 44060 (216) 255-3154 1

'i. ;

$4/c. (, Of d DATED:_

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LOCAL REPORT q w i t.

Broken seal at Perry plant investigated

_..e y

er_nasi.e..e.. -.se., eneer._,

,,,.,e,e, _

wevice weser sy,eems. Ses one el asse ~ ers had see hears se seeseen she syseman es I

serveer, wedete they d6d.

syssesas has been one of operasene giace 8==r= said sneene speesese, ase Gegieg

,,,,,%3,,,,,,,,,,

-^ a se fied-Perry Meeteer Power Plant apermenes F... _!:: becesene er a EEe_r_y g !___

se seers why tese gasket seat beesie. IDe ing es_" xa: peres, NRC e4R tesie sie aceies assinet gAsset ep-see invesesgaeemp why a sesiret Seal bralie

. sed Mw.hael E.maape said yeseerday enerneag. meleashieg a chseet of

. Perry operases meest esil me o ert w nen Ceessy and sense einessency emeials in -

d 0

erseers.

events eBist forced plane opersoors err re-e eineesency cowe coeging syneeses are 1,alte. Gesege med Asleeste0s essasies doce power and dectave se apert.

the potese faced se danger femen the deceased insperabee.

weee % the eveet om a ansaprNI.

As. 2:)F a.ne. yeseesday, operseers de.

afers. N ac8est Regoletery Commenission clared an alert. tese secosed gamest of four branesanees bases. said Rebeet 99. Reesler.-

direcese of she e. ate Conne; Esmoogemey syngressman Ross Marabien said.' the slees emeeseeney classTecations. The steet lassed Managessear Agency. Esseergeni:y opera.

was called only because time seat faiieser easit 6DI a.ne. Reacter power mes re.

ties eeeeers is else elete commeies and at was a problese feesa a seguissory and pro-deced fases 100 giercent se 93 peveemt $se eine sense Sevel wese possie8y seeissese, he

,j cederal standpoiet. lee said.'

abase an asser while.e8ee escases sysseem when stie gastet send tecke. Maratisse said.

said, water sprayed a nearby nester-rne-was seposeed The essesgency e81Ecials sessed in eso.

Even e%eessh she eneergency service wa.

eact by a dive-war ytose 3iegt They adse trol pseet. The waere caused several eenct... _ 3 s,. '. eer syseesse eenemined operable. NRC serb.

feed a dieece line inee. Perry's TecW gency service' weser syssess s- -

resces, specifications eequire stese if any par.. Seposee Gemeer a coessmenicesiees pipe such as peasps, se fait. :... g ;.

seen,ef;ehe casessency coolies syneene faits,. Iine se handte their geeseisee.

i

" Jibe essergemey service'em,deo,,

ths,weeleisyseeni,rnest be declased ineqper.

veseerdayiseeihee.rhe seeend tiene W

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6ectop safeMy*b.:.{eme.'

sheei,-y--i en some syseems, she NRc et.

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. e ena operaserthoog,d, erlesed an efeat at se she.-

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- __ 98eed 86,.

spiecified ameest of timme se sepair Perry. The %*ste:gsesesy a-_.

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seeded,i's. ~

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8987. darias seaseg and eest..

phase.

rp,*,M, *.,.*j'. p'.

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v hsit thenmelen er'ssust do e seie s ens.

e l,a..eisse aggaenneens esist for dif:.

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