ML20126K623

Notice of Violation from Insp on 850323-0510

ML20126K623
Person / Time
Site:	Perry
Issue date:	06/12/1985
From:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20126K615	List: IR 05000323/2005010 ML20126K612 ML20126K623
References
50-440-85-17, NUDOCS 8506190297
Download: ML20126K623 (2)

See also: IR 05000323/2005010

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Appendix

NOTICE OF VIOLATION

The Cleveland Electric Illuminating Docket No. 50-440

Company (CEI)

As a result of the inspection conducted on March 23 through May 10, 1985, and

in accordance with the General Policy and Procedures for NRC Enforcement

Actions, (10 CFR Part 2, Appendix C), the following violations were identified:

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1. 10 CFR 50, Appendix B, Criterion V, as implemented by CEI's Corporate

Nuclear Quality Assurance Program (CNQAP), Section 0500, Revision 6,

states that " activities affecting quality shall be prescribed by documented

instructions, procedures, or drawings, of a type appropriate to the

circumstances and shall be accomplished in accordance with these

instructions, procedures, or drawings".

Contrary to the above, sufficient administrative controls were not

prescribed in appropriate procedures to adequately govern conduct of

integrated run-in testing activities performed under control of Temporary

Operating Instructions prior to preoperational test release for

performance (440/85017-01(DRS)).

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

2. 10 CFR 50, Appendix B, Criterion V, as implemented by CEI's CNQAP,

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Section 0500, Revision 6, requires that activities affecting quality

shall be accomplished in accordance with procedures.

Contrary to above, the Low Pressure Core Spray System, a safety related

system required for safe shutdown was operated without utilizing (or in

accordance with) procedures (440/85017-07(DRS)).

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This is a severity Level IV violation (Supplement II).

3. 10 CFR 50, Appendix B, Criterion V and Regulatory Guide 1.68, Revision 2,

as implemented by CEI's CNQAP, Section 0500, Revision 6, requires that

activities affecting quality shall be prescribed by documented

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instructions of a type appropriate to the circumstances and that test

procedures shall include appropriate checklists and signature blocks to

control test performance and the sequence of testing.

l Contrary to the above, Perry Nuclear Fower Plant Test Program

Instruction, TPI-7 "Preoperational, Acceptance and Special Test Procedure

Preparation, Review and Approval" was not appropriate to control test

performance and the sequence of testing for test procedures as described

in Paragraph Sa (440/85017-08(DRS)).

This is c Severity Level V violation (Supplement II).

8506190297 850612

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Appendix 2

4. 10 CFR 50, Appendix B, Criterion V, as implemented by CEI's CNQAP,

Section 0500, Revision 6, states that " activities affecting quality shall

be prescribed by documented instructions, procedures, or drawings, of a

type appropriate to the circumstances and shall be accomplished in

accordance with these instructions, procedures, or drawings." Test

Program Instruction-27 Section 4.2 requires that pretest checklists be

completed as part of the release for test package.

Contrary to the above, actions pursuant to these checklist verifications

were inadequately accomplished in conjunction with test procedures

TP 1E12-P001, " Residual Heat Removal (RHR) System" and TP 1R43-P001,

" Division 1 Standby Diesel Generator." Checklist verifications conducted

to ensure that design changes are incorporated into the test procedure and

that the test procedure is written to the latest approved revision of

design documentation and to the as-built condition of the plant did not

identify the need to incorporate Engineering Change Notice NJ35313 into

the RHR test procedure. This design change had already been depicted on

plant drawings and in the as-built plant condition. In addition, checklist

verifications conducted to ensure that lifted leads and jumpers had been

reviewed for impact on standby diesel generator testing did not identify

a jumper installed which bypassed the diesel generator out-of-service

alarm (440/85017-05(DRS)).

This is Severity Level V violation (Supplement II).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to

this office within thirty days of the date of this Notice a written statement

or explanation in reply, including for each item of noncompliance: (1) cor-

rective action taken and the results achieved; (2) corrective action to be

taken to avoid further noncompliance; and (3) the date when full compliance

will be achieved. Consideration may be given to extending your response time

for good cause shown.

JUN 121985 h%hye ,

Dated R. L'. Spessard, Director,

Division of Reactor Safety

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