ML20045D479
| ML20045D479 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/23/1993 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Stratman R CENTERIOR ENERGY, CLEVELAND ELECTRIC ILLUMINATING CO. |
| Shared Package | |
| ML20045D480 | List: |
| References | |
| NUDOCS 9306290053 | |
| Download: ML20045D479 (3) | |
See also: IR 05000440/1993007
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JUN 2 3 833
Docket No. 50-440
Centerior Energy
ATTH: Mr. R. A. Stratman
Vice President-Nuclear
Perry Nuclear Power Plant
c/o The Cleveland Electric
'
Illuminating Company
10 Center Road
Perry, OH 41081-9514
Dear Mr. Stratman:
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SUBJECT:
EMERGENCY OPERATING PROCEDURES FOLLOWUP INSPECTION
(NRC INSPECTION REPORT NO. 50-440/93007(DRS))
This refers to the inspection conducted by Messrs. R. A. Langstaff, R. Mendez,
and A. Vegel of this office and Ms. V. E. Barnes of Performance, Safety and
Health Associates on May 10 through 21, 1993. The inspection included a
review of activities authorized for your Perry Nuclear. Power Plant. At the.
conclusion of the inspection, the findings were discussed with those members.
of your staff identified in the enclosed report. A followup teleconference
was held with Mr. K. P. Donovan and others of your staff on June 2,1993.
Areas examined during the inspection are identified in the report. The
inspection focused on your emergency operating procedures (EOPs)-and your
program for developing and maintaining your E0Ps. During the inspection,
improvements were noted in your flowchart E0Ps and in plant labeling to
support performance of E0P related tasks. However, we cannot conclude that
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your E0P program was sufficient to maintain the overall quality of the E0Ps.
This conclusion was based on the continuation of problems from the 1991 E0P
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team inspection regarding apparent deviations from the Emergency Procedure
Guidelines (EPGs), the lack of understanding of human factors principles, and
weak audits of the E0P program.
In addition, three items from the 1991 E0P Team Inspection (Report No.
50-440/91013(DRS)) remain open. The first item concerned your commitment to
review existing plant procedures and determine whether they met the BWR Owners
Group EPGs guidance for secondary containment control. Our inspection
concluded that your procedural reviews were not sufficiently thorough to
justify the deviations. We request that you provide us with a detailed
evaluation of how existing plant procedures meet the intent of the EPGs
secondary containment control guideline. Specifically your evaluation should
document how plant procedures, facility design, and licensing positions are
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used to meet or exceed the intent of the EPGs.
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The second item concerns an unresolved item regarding the lack of a procedure
for an alternate method of boron injection. We understand you have a
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technical justification for not having such a procedure and that you will
provide your justification to us.
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JUN N 1333
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Centerior Energy
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The third item involved human factors weaknesses in the E0Ps and the E0P
program.
In your response to the first item, we request that you address your
human factors approach with respect to the quality of E0P support procedures,
E0P writer's guides, and E0P verification and validation program.
,
Finally, we are concerned that ECP audits performed by Quality Assurance did
not technically challenge EPG deviation justifications and did not identify.
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continuing program weaknesses.
Please include in your response any planned.
corrective actions to this concern.
Based on the results of this inspection, certain of your activities appeared'
to be in violation of NRC requirements, as specified in the enclosed Notice of-
Violation (Notice). The violations are of concern because the corrective '
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actions you performed in response to a violation and deficiencies identified
by a previous NRC inspection were not completely effective. The human factors
concerns raised previously were not sufficiently addressed by the improvements
you made to your E0Ps and your E0P program. As a result, confusion among
licensed operators concerning the performance of some E0P steps was apparent
during this inspection.
You are required to respond to this letter and should follow the instruction
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
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actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, its enclosures, and your response to this letter will be placed
in the NRC Public Document Room.
The responses directed by this letter and the accompanying Notice are not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
Original signed by David J. Lange (for)
T. O. Martin, Acting Director
,
Division of Reactor Safety
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Enclosures:
1.
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2.
Inspection Report
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No. 50-440/93007(DRS)
)
3.
Slide Presentation of May 19, 1993
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See Attached Distribution
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Distribution
cc w/ enclosures:
F. R. Stead, Director, Nuclear
Support Department
D. P. Igyarto, Plant Manager,
,
Perry Nuclear Power Plant
K. P. Donovan, Manager,
,
licensing & Compliance Section
S. F. Kensicki, Director, Perry
Nuclear Engineering Dept.
H. Ray Caldwell, . General
Superintendent, Nuclear
Operations
DC/LFDCB
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R. J. Stransky Jr., LPM, NRR
J. Arildsen, NRR
V. Barnes, PSHA
Resident Inspector, RIII
Terry J. Lodge, Esq.
James R. Williams, State of Ohio
Robert E. Owen, Ohio
Department of Health
A. Grandjean, State of Ohio,
Public utilities Divisio
bec w/ enclosures:
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