ML20086S703
| ML20086S703 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/28/1995 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0427, PY-CEI-OIE-427, NUDOCS 9508020090 | |
| Download: ML20086S703 (6) | |
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We CENTERDOR ENERGY Donald C. SheltOn PERRY NUCLEAR POWER PLANT Mail Address:
SENIOR VICE PRESIDENT PO BOX 97 10 CENTER ROAD PERRY, OHIO 44081 NUCLEAR PERRY, OHIO 44081 (216) 259-3737 July 28,1995 PY-CEI/0IE-0427L Regional Administrator United States Nuclear Regulatory Commission Region III 801 Varrensville Road Lisle, IL 60532 Perry Nuclear Power Plant Docket No. 50-440 Details for E&TS Self-Assessment Gentlemen:
Perry Nuclear Power Plant has developed a detailed plan for the scheduled Engineering and Technical Support (E&TS) self-assessment. Attachment 1 outlines the schedule, scope, level of effort, team qualifications to perform the self-assessment, and additional details. Based on discussion between Mr. James D. Kloosterman, Manager - Regulatory Affairs Section, and Mr. Roger Lanksbury of your staff, we understand that the NRC concurs in the request to perform this self-assessment in lieu of a full scope NRC Inspection.
In order to discuss the details of the self-assessment, a meeting has been scheduled for August 15, 1995, at the NRC Region III offices. This meeting vill provide an opportunity for us to describe our plan for acca plishing a thorough and effective self-assessment, and to answer any questions you may have.
If you have any questions or require additional information, please contact Mr. James D. Kloosterman at (216) 280-5833.
Very tr
- yours,
/W CRE:sc Attachment cc:
Document Control Desk NRC Project Manager NRC Resident Inspector Office G.E. Grant - Region III 010050 goo /
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PY-CEI/0IE-0427L Page l'of 5 PNPP Engineering and Technical Support (E&TS) Self-Assessment Schedule The Engineering and Technical Support (E&TS) self-assessment will commence with an entrance meeting at the Perry Nuclear Power Plant (PNPP) on September 11, 1995.
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The self-assessment will consist of three consecutive weeks of evaluation concluding on September 29, 1995, with an exit meeting currently scheduled for i'
October 6, 1995. The final report is scheduled for issuance by October 30, 1995, under QA Audit Report No. PA 95-25.
Scope The E&TS self-assessment at PNPP will be conducted in accordance with NRC Inspection Procedure 37550, " Engineering." This assessment may be concurrently
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and/or subsequently evaluated by the NRC in accordance with NRC Inspection i
Procedure 40501, " Licensee Self-Assessments Related to Team Inspections."
j The self-assessment will evaluate PNPP's engineering activities, particularly the effectiveness of the engineering organization to perform routine and reactive site activities, including the identification and resolution of technical issues. This objective will be accomplished by providing a detailed. review of engineering activities following the general intent of each specified inspection requirement in Section 37550-02.
Specific' areas will be evaluated utilizing unique checklists. Credit will be taken for recent internal evaluations (e.g., Design Engineering Assessment and Review) of engineering performance for certain areas of the inspection l
requirements. These areas will be clearly identified and documented in the assessment report. The basis for any conclusions deduced from previous self-assessments will be fully developed and documented.
The Inspection Procedure 37550 requires that several safety-significant design changes be evaluated for proper program implementation. The primary selection criteria is based on content related'in the NRC E&TS inspection notification letter which requested that emphasis be placed on engineering completed design changes planned for implementation in Refueling Outage 5 or the current operating cycle. Other criteria considered in the selection process included:
plant safety significance (including shutdown risk i
considerations);
complexity and in-depth evaluation required; effect on the design basis; j
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PY-CEI/0IE-0427L l
Page 2 of 5 inter-discipline mix; and, outsourced or licensee generated.
The following fifth cycle design changes have been initially selected for review:
1.
- 87-0725 - This design change replaces analogue temperature modules associated with the Leak Detection system with digital leak detection monitors made part of the General Electric Nuclear Heasurement Analysis & Control system.
2.
- 91-0085 - Change-out of Automatic Switch Company solenoid valves to Valcor valves on the inboard main steam isolation valves.
3.
- 94-0027 - Installation of a by-pass line and 3-vay diverting temperature control valve around each Emergency Closed Cooling system heat exchanger.
4.
- 94-0139 - Installation of piping, pipe supports, and valve for a new Emergency Service Water (ESV) keepfill system.
5.
- 95-0017 - Installation of a different type of check valve on the Reactor Core Isolation Cooling (RCIC) system turbine exhaust piping riser.
A new section of piping vill be installed and the test connection vill be modified to include a second isolation valve.
The above design changes contain a representative mix of the aforementioned desired selection criteria. This review will provide for an in-depth and rigorous evaluation of PNPP's design change program, including an assessment of the effectiveness of recent program improvement initiatives.
Additional design documents may be selected for review, if appropriate, to confirm assessment conclusions.
NRC Inspection Procedure 37550 also requires that several temporary modifications be evaluated to verify conformance with the applicable requirements. The following temporary modifications have been initially selected for review:
1.
- 1-90-0039/1-90-0043 - This temporary modification is being made permanent by Design Change Notice #4987 which documents the use of a measuring and test equipment pressure gage at a vent valve. In addition, the placement of the vent valve in a throttle position and use of a hose to direct leak-off to the floor drains is made permanent.
2.
- 1-92-015 - This temporary modification is being made permanent by DCN #4985 l
vhich is written to clear the Residual Heat Removal (RHR) "A"
& "B" l
Out-of-Service annunciator alarms caused by removing electrical power from two RHR motor operated valves.
3.
- 1-92-0061 - RHR Motor Operated Valve leaks-by and a hose is temporarily connected to the flush line vent to reroute leakage.
s PY-CEI/0IE-0427L Page 3 of 5 4.
- 1-95-0016 - Lifted leads and jumpers are implemented to make the Unit 2, Division 3 DC electrical system inoperable while a design change is being pursued.
5.
Simple Modification Request Form #95-05032 - Injection of a leak sealant on a Reactor Vater Clean-Up system motor operated valve stuffing box to stop a packing leak.
The temporary modifications selected are based on their safety significance, age, end discipline mix. This review along with other reactive activities, vill provide a solid indication of the effectiveness of PNPP's engineering response to emergent plant conditions.
Other key attributes of the engineering organization's performance which vill be specifically considered for evaluation or review during the self-assessment include:
engineering involvement in site activities, including an evaluation of interdepartmental and intradepartmental communications and work item backlogs; self-assessment programs and effectiveness of these programs, including a review of audits performed on engineering activities:
engineering involvement in corrective action systems, including root cause analysis and corrective action timeliness; l
effectiveness of the ISEG organization; design changes and modification activities such as those associated with ATVS mitigation and the SB0 rule; and adequacy of post-modification testing.
Level of Effort i
The self-assessment team vill conduct the assessment on a full time basis for three weeks (i.e., 18 man-veeks). Additional team member effort will be dedicated for pre / post self-assessment activities. The Perry Nuclear Engineering Department is cognizant of the schedule and vill provide the necessary interface and corrective action investigation support to ensure the effectiveness of the E&TS 1
self-assessment.
PY-CEI/01E-0427L Page 4 of 5 Team Qualifications to Perform the Self-Assessment The self-assessment team vil) consist of six members divided into two groups.
One group vill place emphasis on engineering technical content while the other vill focus on engineering administration, interface, and self-assessment effectiveness.
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Each member of the group vill employ' unique checklists to ensure consistency and completeness in meeting the required objectives. Additional qualified personnel are available and may be requested to assist on specific topics, as required.
The Technical Group will be led by Mr. Roger Parker of the Independent Safety Engineering Group (ISEG).
Mr. Parker is a degreed Electrical Engineer with 20 years of diversified engineering experience at both Davis-Besse and Perry Nuclear Power Plants. He has participated on a Safety System Functional Inspection (SSFI) and other self-assessments.
Mr. Parker vill also serve as the Team Manager for the overall assessment.
The Administrative Group vill be led by Mr. Jeffrey Lausberg who is a certified lead auditor from the Quality Assurance Section, a degreed Nuclear Engineer, and a Senior Member of the American Society for Quality control.
Mr. Lausberg has over 15 years of experience in managing and conducting assessments. Among the assessments Mr. Lausberg has supervised is the System Based Instrumentation and Control Inspection self-assessment of the Perry Plant conducted earlier this year.
Mr. Curt Angstadt is a degreed Civil Engineer in the Perry Nuclear Engineering Department with over 20 years experience in nuclear power plant design and supervision of design activities. Thirteen of these years were with Gilbert / Commonwealth, Inc.
He is a registered Professional Engineer and has specific expertise in structural and piping / pipe support design areas, as well as the overall design process.
Mr. Thomas Hiss is a degreed Mechanical Engineer in the Plant Engineering Section at Davis-Besse.
He has over 20 years of experience with nuclear power plant design requirements and design related issues and functions as a lead in the Mechanical Design Unit.
His primary responsibilities include those activities necessary to assure compliance with American Society of Mechanical EngineersSection XI requirements as they relate to repair, replacement, and modification of plant systems and components.
The remaining two members of the team are two highly experienced technical consultants from Stone & Webster (S&V) and ENERCON Services.
Mr. William Chamberlain of S&W has a BS degree in Mechanical Engineering, Professional Engineer Registration and 34 years of engineering experience. He has been the Senior engineering representative responsible for completing five nuclear power plant station designs.
Engineering assessments he has previously performed include assignments at Davis-Besse, Savannah River, and Comanche Peak.
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PY-CEI/01E-0427L Page 5 of 5 Mr. Carter Nolan of ENERCON has a BS degree in Electrical Engineering, Professional Engineer registration, and over 20 years of technical and management experience.
Mr. Nolan has most recently participated in an E&TS pre-inspection self-assessment at the South Texas Project where he helped develop the final report and the presentation to management.
Additional Details Issues arising as a result of the self-assessment activities will be documented, prioritized, and resolved within the PNPP Corrective Action Program. The self-assessment team has full authority to conduct this self-assessment and has direct access to senior PNPP management through the Directors of the Nuclear Assurance and Nuclear Engineering Departments.
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