ML20133D378
| ML20133D378 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/11/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8507220183 | |
| Download: ML20133D378 (8) | |
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- 55 PUBLICSoVARE Serving The Best L.ocation in the Nation MURRAY R. EDELMAN VICE PRESIDENT NUC LE AN July 11, 1985 PY-CEI/01E-0076 L Mr. R. L. Spessard, Director Division of Reactor Safety, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 50-440/85017 Noncompliance Responses
Dear Mr. Spessard:
This letter is to acknowledge receipt of Inspection Report 50-440/85017 attached to your letter dated June 12, 1985. This report identifies areas examined by Messrs. D. E. Hills, G. F. O'Dwyer, S. G. DuPont and R. D.
Lanksbury during their inspection conducted March 23 through May 10, 1985 at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated June 12, 1985. This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regula-tions.
Our response has been submitted to you within thirty days of the date of the Notice of Violation as you requested.
If there are additional questions, please do not hesitate to call.
Very truly yours, Murray R Edelman Vice President Nuclear Group MRE:nje Attachments 8507220183 050711 PDR ADOCK 05000440 PDR I k 0
V60/
r-Mr. R. L Spessard, Director July 11, 1985 PY-CEI/01E-0076'L cc:
Mr. J. A. Grobe USNRC Site, SBE30 Mr. D. E. Keating USNRC Site, SBB50 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Mr. R. F. Warnick, Chief Reactor Projects Branch 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 l
C=____-___________-__________-___
._____________________-________J
PY-CEI/01E-0076 L Page 2 of 2 Test Program Instruction (TPI)
-6, "IC&R Test Procedure, Temporary o
Operating Instruction and Alarm Response Instruction Preparation, Review and Approval", has been revised to require that cognizant control room personnel be made aware of abnormalities which affect proper implementation or completion of T01's.
These actions will greatly reduce the likelihood of unplanned events because the plant operations personnel, who work in the control room, have more extensive training and experience in integrated plant operations and system interrelationships. Daily Instructions were issued on April 8, 1985 and May 10, 1985 to ensure Control Room personnel understand their responsibilities and CEI management policy in this matter.
In accordance with TPI-6, TOL's are used for for operating systems / equipment under Nuclear Test Section jurisdiction when performed outside the controls of a preoperational, acceptance or IC&R test procedure. TOL's are not used for testing in that these procedures are not used to verify acceptance criteria or satisfy test commitments; however, in some instances, TOI's are used to determine the workability of portions of preoperational tests. TOI's are approved by the System Test Engineer, Lead System Test Engineer, and Shift Supervisor (Test Coordinator). These personnel are certified Test Engineers in accordance with ANSI N45.2.6 and 1.8 or, in the case of the Shift Supervisor, licensed as an Senior Reactor Operator. Generally, procedure steps are listed and perf ormed in a manner similar to routine plant operating procedures, however, at the discretion of personnel in the procedure preparation cycle, compicx activities are to be prescribed with signature /date attestation checklists.
To ensure the adequacy of the System Operating Instructions (SOL's) and provide a more uniform approach to the implementation of T01's, S01's are used with a TOI approval sheet whenever possible. To ensure this policy is implemented fully, all of the TOI's have been recalled and reviewed to determine if an SOI could be substituted. Unless justification for continued use of a special TOL could be established, an SOI with an approved TOI cover sheet is required to be used for any operation of the affected system. Training has been conducted with the STE's to ensure that this policy is understood and implemented.
TPI-27 (Section 4.1) has been revised to require that a list of significant events which occurred prior to a system release for test are included in the release for test package. This Itst is reviewed by the TPRC during the release for test process.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Attcchment 1 PY-CEI/01E-0076 L Page 1 of 2 RESPONSE TO NONCOMPLIANCE 440/85-17-01 Statement of Noncompliance 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 centrols 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 (440/85-17-01 (DRS)).
This is a Severity Level IV Violation (Supplement II).
Corrective Action Taken and Results Achieved Two events, pressurization of the Emergency Service Water Heat Exchanger (ESW-HX), and an inadvertent containment spray occurred while systems were being operated under Temporary Operating Instructions (TOI's). An evaluation has determined there was no damage to the ESW-HX as a result of being momentarily subjected to the shutof f head pressure of an ESW pump, and the ef fects of water spray inside the containment have been systematically evaluated and documented and the corrective actions are in the final states of completion. Although some pipe insulation was wetted no significant damage was identified. Additional corrective actions involving procedures and personnel have been implemented as described below.
Corrective Action Taken to Avoid Future Noncompliance As a result of these unplanned events, the policy and procedures governing the use of TOI's were reviewed. Both unplanned events occurred because Test Engineers failed to identify and compensate for system interrelationships and the effects of other testing and operating activities. To prevent similar occurrences, Plant Operations Personnel are now taking a more active role in directing and coordinating operations-related test activities. Specifically, the following actions have been taken:
The Shift Supervisor has assumed the duties of Test Coordinator.
o o
Performance of T01s is included in the Plan of the Day (POD) and coordinated through the Shift Supervisor.
o Authorization f rom the Control Room is required when a TOI is performed. Reauthorization is required if the performance ext 2nds beyond a 24-hour period.
1 Attachrent 2 PY-CEI/01E-0076 L Page 1 of 2 RESPONSE TO NONCOMPLIANCE 440/85-17-05 Statement of Noncompliance 10 CFR 50, Appendix B, Criterion V, as implemented by CEI's CNQAP, Section 0500, Revision 6, states that " activities af fecting 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 instruct-ions, 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-P-001,
" Residual Heat Removal System" and TP 1R43-P-001, " 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 NJ 35313 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)).
Corrective Action Taken and Results Achieved Although Engineering Change Notice (ECN) NJ 35313 had been incorporated into the design drawing and had been verified in the as-built drawing program, the change was not incorporated into the Preoperational Test procedure. The omission was detected and corrected during the performance of the test, since the test was developed to verify that the system functioned as designed. The project has conducted training on the need for attention to detati during test preparation and the preparation of release for test checklists.
A lif ted Icad, which was tagged and logged in accordance with TPI-18
" Temporary Alterations", resulted in an annunciator not responding as expected during Test Procedure IR43-P-001. The lifted lead was not identified by the STE as affecting the test because it was being tracked with the R61, Main Control Room Annunciator System, and was not identified with the system being tested, R43, Standby Diesel System. The lifted lead tag was cleared, the lead was reterminated, and the test was successfully completed.
Atteclunent 2 PY-CEI/01E-0076 L Page 2 of 2 Corrective Action to Avoid Future Noncompliance System Test Engineers are receiving additional training as part of Special Project Plan " Test Procedure Assurance Review." This training includes the importance of attention to detail in the development, review and release of Test Procedures. A Management Procedure Review Team has been established to conduct a line by line review of in process and completed test procedures for any indications of test procedure inadequacies.
The Checklists in TPI-27, " Release for Test:
Preoperational and Acceptance Tests," have been revised to require that the review of lif ted leads and jumpers include generic support systems such as C91 (Computer), C95 (Emergency Response Information) and R61 (Main Control room Annunciators). The Lifted Lead and Jumper Log has been reviewed by the Test Coordinator to ensure that lif ted leads and jumpers which have been in place more than 3 months are still required.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
1 PY-CEI/01E-0076 L Page 1 of 1 RESPONSE TO NONCOMPLIANCE 440/85-17-07 Statement of Noncompliance 10 CFR 50, Appendix B, Criterion V, as implemented by CEl's CNQAP, Section 0500, Revision 6, requires that activities af fecting 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)).
This is a severity Level IV violation (Supplement II).
Corrective Action Taken and Results Achieved In preparation for the Division 1 Standby Diesel Generator Load Test, a Low Pressure Core Spray Pump was started by an operator under verbal direction from the System Test Engineer. The operator's failure to review prerequisites and operating limits prior to operating the system was a violation of PAP-0201, Section 6.2,
" Conduct of Operations", however, it did not result in the violation of any prerequisite or operating limit, or any damage to the system.
The corrective actions described below have been taken to avoid future noncompliance.
Corrective Action Taken to Avoid Future Noncompliance To ensure operating personnel meet the requirements of PAP-0201, Section 6.2, daily instructions (PAP-0201, Section 6.7.5) were issued to direct plant personnel not to operate or permit operation of any system without an approved and current procedure. The General Supervising Engineer of Operations has directed that Shift Supervisors strictly enforce this policy.
In addition, operations personnel have been counselled to be aggressive in assuming responsiblity for the system operations aspect of the test program and to ensure their training and experience are utilized during plant testing activities.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
PY-CEI/0IE-0076 L Page 1 of 1 RESPONSE TO NONCOMPLIANCE 440/85-17-08 Statement of Noncompliance 10 CPR 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 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.
Contrary to the above, Perry Nuclear Power 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 5a (sic)
Paragraph 5b (440/85-17-08 (DRS)).
This is a Severity Level V violation (Supplement II).
Corrective Action Taken and Results Achieved Test Procedure IR43-P-001, " Division 1 Standby Diesel Generator", Revision 1, as approved by the Test Program Review Committee (TPRC), permitted the sequence of steps to be altered with the approval of the System Test Engineer (STE), who is certified in accordance with ANSI N45.2.6, and 18.1.
By maintaining a chronological test log and affixing a signature and date to each step, the TPRC could verify during the Test Results Review that the sequence actually used maintained the intent and technical requirements for the test. Although the sequence in which TP-1R43-P-001 was performed did not violate any technical requirements, af fording this latitude to the STE for determining test sequence has the potential for permitting test conditions or system configurations which do not meet the intent of the test procedure as approved by the TPRC. The corrective actions taken below have been taken to avoid future noncompliance.
Corrective Action Taken to Avoid Future Noncompliance To ensure that test conditions and system configurations during test perfor-mance meet the intent of the approved procedure, Test Engineers have been directed to perform steps in the exact sequence listed in the procedure.
Deviations from the sequence listed are permitted only when such deviations are specifically permitted and identified in the procedure and approved by the TPRC prior to testing. Test change forms were issued for tests in progress to delete permission for the STE to alter the test sequence.
Test Program Instruction (TPI-7), "Preoperational, Acceptance and Special Test Procedure Preparation, Review and Development", has been revised to require that limitations for performing steps out of sequence be specific and identify procedure steps by numbers. STE's received training in the requirement for performing Test Procedure steps in the listed sequence.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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