ML20134A583

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-440/96-08

ML20134A583
Person / Time
Site:	Perry
Issue date:	01/23/1997
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Myers L CENTERIOR ENERGY
References
NUDOCS 9701290004
Download: ML20134A583 (2)

See also: IR 05000440/1996008

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January 23, 1997

EA 96-367

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Mr. Lew W. Myers

Vice President - Nuclear

Centerior Service Ccmpany

P. O. Box 97, A200

Perry, OH 44081

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-440/96008(DRS))

Dear Mr. Myers:

This will acknowledge receipt of your letter dated December 6,1996, in response

to our lotter dated November 6,1996, transmitting a Notice of Violation associated with

the circumstances surrounding the loss of both trains of the Emergency Closed Cooling

(ECC) system in 1993, and the loss of both trains of Control Room Emergency

Recirculation due to low ECC temperature in 1994 at your Perry facility. We have

reviewed your corrective actions and have no further questions at this time. These

corrective actions will be examined during future inspections.

Sincerely,

/s/ M. Icach (for)

Geoffrey E. Grant. Director

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Division of Reactor Safety

Docket No. 50-440

Enclosure:

Ltr 12/06/96 L. W. Myers,

Centerior Energy, to US NRC w/ encl

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Distribution:

9701290004 970123

See attached list

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January 23, 1997

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J. P. Stetz, Senior Vice

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President, Nuclear

L. W.- Worley, Director, Nuclear

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Services Department

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J. D. Kloosterman, Manager,

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Regulatory Affairs

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W. R. Kanda, Director, Perry Nuclear

Assurance Department

N. L. Bonner, Director, Perry

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Nuclear Engineering Department

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H. Ray Caldwell, General Superintendent ,

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Nuclear Operations.

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R. D. Brandt, General Manager Operations

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Terry J. Lodge, Esq.

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State Liaison Officer, State of Ohio

Robert E. Owen, Ohio Department of Health

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C. A. Glazer, State of Ohio,

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Public Utilities Commission

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CENTERDOR

ENERGY

PERRY NUCLEAR POWER PLANT

Mail Address:

10 CENTER ROAD

P.O. BOX 97

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PERRY, OHIO 44081

PERRY, OHIO 44081

(216) 259-3737

December 6,1996

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PY-CEI/NRR-2118L

United States Nuclear Regulatory Commission

Document Control Desk

Washington, D.C. 20555

Perry Nucl:ar Power Plant

Docket No. 50-440

Reply to a Notice of Violation

Ladies and Gentlemen:

Enclosed is the reply to the Notice of Violation contained in NRC Inspection Report 50-

440/96-08, which was transmitted by letter dated November 6,1996. The Notice of Violation

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describes three violations involving: a failure to comply with the actions of Emergency

Closed Cooling (ECC) system Technical Specification Limiting Conditions for Operation; the

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failure to take adequate corrective actions to prevent ECC system temperature from

decreasing below 55' F; and, the failure to appropriately classify an ECC system valve as an

American Society of Mechanical Engineers Code,Section XI, Category "A" valve in a timely

manner.

If you have questions or require additional information, please contact

Mr. James D. Kloosterman, Manager - Regulatory Affairs, at (216) 280-5833.

Very truly yours,

W

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Lew W. Myers

Vice President - Nuclear

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Attachment

Enclosure

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NRC Region III Administrator

NRC Resident Inspector

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NRC Project Manager

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Attachment i

I, Lew W. Myers, being duly sworn state that (1)I am Vice President, Nuclear of the

Centerior Service Company, (2)I am duly authorized to execute and file this certification on

behalf of the Cleveland Electric Illuminating Company and Toledo Edison Company, and as

the duly authorized agent for Duquesne Light Company, Ohio Edison Company, and

Pennsylvania Power Company, and (3) the statements set forth herein are true and correct to

the best of my knowledge, information and belief.

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Lew W. Myers

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Sworn to and subscribed before me, the [p

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Enclosure

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REPLY TO A NOTICE OF VIOLATION

Violation 96008-I

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Restatement of Violation

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Technical specification 3.7.1.2 requires, for Operational Conditions 1,2,3,4, and 5, the emergency closed

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cooling (ECC) loop (s) shall be operable which are associated with systems or components which are

required to be operable. With an ECC loop (s) inoperable which is associated with system (s) or

component (s) required to be operable, declare the associated system (s) or component (s) inoperable and

take the action required by the applicable specification (s).

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A.

Contrary to the above, from March 19 to July 2,1993, while the plant was in Operational

Conditions 1,2,3,4, or 5, ECC Train A was inoperable and its associated systems or components

were not declared inoperable, and action was not taken for its associated systems or components

as required by the applicable specifications. (01013)

B.

Contrary to the above, from 3:13 a.m. on June 14,1993, until 11:05 p.m. on June 15,1993,a

period of about 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />, while the plant was in Operational Conditions 1,2, or 3, both trains of

ECC were inoperable and their associated systems or components were not declared inoperable,

and action was not taken for their associated systems or components as required by the applicable

specificctions. (01023)

This is a Severity Level III problem (Supplement 1).

Reason for the Violation

The ECC train / system inoperability discussed in the Notice of Violation resulted from excessive leakage

through valve OP42-F295A. This leakage was caused by a combination of personnel error and inadequate

procedural direction for setting motor-operated valve (MOV) limit switches and mechanical stops. The

valve was improperly set during maintenance performed on March 19,1993, resulting in the excessive

leakage. A post-maintenance leakage test was not programmatically required nor performed at that time

since the valve was classified as an American Society of Mechanical Engineers (ASME) Code,Section XI,

Category "B" valve, and as such, did not have specific leakage criteria assigned. The valve leakage was

not identified until July 1,1993, when a routine operational evolution identified concerns with the isolation

capability of the ECC system.

Corrective Steos Taken and Results Achieved

The limit switches and mechanical stops for valve OP42-F295A were readjusted on July 2,1993. An

allowable leakage criteria was determined for the valve and a post-maintenance leak test was performed on

the same day. The valve successfully met its leakage acceptance criteria and passed the post-maintenance

test.

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Corrective Steos that Will Be Taken to Avoid Further Violation

The procedure on adjusting Limitorque limit / torque switches, General Electrical Instruction (GEI)-0014,

"Limitorque Limit / Torque Switch Adjustment," was revised to provide the requisite level of direction for

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PY-CEI/NRR-2118L

Enclosure

Page 2 of 6

setting limit and torque switches, and adjusting mechanical stops. The procedure revision also added a

post-maintenance test requirement for butterfly valves that have an established seat leakage limit. Training

was conducted for appropriate Maintenance and Engineering personnel on this issue and on the necessity

of verifying proper butterfly valve closure.

An engineering evaluation was perfonned to determine if other motor operated butterfly valves were

affected by the causes that resulted in the inoperability of 0P42-F295A; other than the other valves in the

ECC system which perform a similar isolation function (0P42-F295B, OP42-F325A, and OP42-F325B,

which were not leaking but had no leakage criteria established), no other concerns were identified. These

valves were re-categorized as an ASME Code ,Section XI, Category "A" valves on October 8,1996. As

such, they will be periodically leak tested as part of the In-service Testing program (ISTP) against specific

leakage acceptance criteria. Additionally, the Engineering Department conducted a review of other ASME

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Code,Section XI, Category "B" valves in the ISTP to determine if their respective categorization needed to

be changed: no additional valves requiring re-categorization were identified.

Date When Full Compliance Will Be Achieved

Full compliance has been achieved.

Additional Information

Both examples in this violation state that the actions required by Technical Specification (TS) 3.7.1.2. were

not taken as required. With respect to example B, although the actions required by TS 3.7.1.2. were not

taken, this specification would not have been the most limiting TS. TS 3.8.1.1.e. required that with a -

Diesel Generator (DG) (e.g., Division 2 DG) inoperable, a " cross-train check" be performed. Given that

ECC train "A" was inoperable, the associated TS 3.8.1.1.e. shutdown statement would have been entered

had the inoperability of ECC train "A" been recognized.

Violation 96008-II

Restatement of Violation

10 CFR Past 50, Appendix B Criterion XVI, " Corrective Action," requires, in part, that measures be

established to assure that conditions adverse to quality are promptly identified and corrected. In the case of

significant conditions adverse to quality, the measures shall assure that the cause of the condition is

determined and corrective action taken to preclude repetition.

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Contrary to the above, as of September 11,1996, the licensee had failed to promptly correct a significant

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condition adverse to quality as demonstrated by the following:

1.

In February 1986, a control complex chiller tripped on low refrigerant temperature due to

low lake water temperatures (Emergency Closed Cooling water to the chiller must be

greater than 55* F to meet chiller design requirements). As corrective action for this

condition the licensee initiated Design Change Package (DCP) 86-0224 to alleviate the

problem; however, the design change only considered ECC accident heat loads and did

not consider minimum loads when Emergency Service Water was less than 55" F.

2.

In February 1994, with ESW "A" and ECC "A" running and supplying a minimal heat

load, ECC "A" temperature was observed to be below 55* F.

3.

DCP 94-0027 was implemented in Spring 1996 to maintain ECC temperature above 55

F with low lake water temperature and low heat load conditions and the post.

modification test did not confirm the adequacy of the design. Subsequently, on March 7,

1996, ESW "A" and ECC "A" were in operation with no heat load, and ECC "A"

temperature decreased from 64* F to 56* F before ESW "A" was secured to prevent ECC

"A" from decreasing below 55* F. (02014)

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

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B.

Contrary to the above, as of August 26,1996, the licensee had not corrected a significant

condition adverse to quality. Specifically, the licensee had previously identified on January 20,

1994, that valves OP42-F295A/B and OP42-F325A/B were not classified as Category "A" in

accordance with American Society ofMechanical Engineers (ASME),Section XI,1983, Article

IWV-2000, and no corrective action was taken until this condition was identified by the NRC

during a 1996 inspection. (02024)

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

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Violations A. and B. are addressed individually below.

Background (Violation A3

As stated in the Inspection Report, Control Complex chiller unit operability has been challenged in the past

due to low refrigerant temperatures resulting from ECC supply temperatures being less than 55* F,

particularly with little or no heat loading on the ECC system. This scenario occurs as a result oflow ESW

system temperatures; the ESW system is supplied from Lake Erie and provides the source ofcooling for

the ECC system via the ECC system heat exchangers. The issue was initially identified in February 1986,

when the Control Complex chiller units tripped while operating with ECC supply (i.e., ESW system) water

temperatures at 34* F. The corrective actions resulting from this event primarily involved restricting ESW

flow to the ECC heat exchanger via installation of a bypass line at the ESW discharge of the heat

exchanger, effectively reducing the discharge line from a 14 inch diameter to a 3 inch diameter, thus

minimizing heat exchanger heat transfer. Throttling instructions were provided to Operations personnel

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regarding control of ECC system temperatures to assure adequate heat removal capability during accident

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conditions. These actions were believed to have resolved ECC system temperature control concerns.

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Enclosure

Page 4 of 6

In Febreary 1994, the ECC system was observed to be drifting below 55' F during RHR heat exchanger

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performance testing, again challenging the operability of the Control Complex chillers. The event was

evaluated via the corrective action process, with notification provided to the NRC under LER 94-005. The

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results of the investigation indicated that the 3 inch diameter ESW by-pass line was sized without

considering minimum heat loads potentially generated during testing operations. Plant operators were

locally stationed to continuously monitor and control ECC system temperatures when the Lake Erie water

temperatures fell below 55 F. An additional modification was pursued to relieve the operator burden by

installation of automatic temperature control.

After extensive evaluation of options and conceptual designs for resolution of the effects oflow lake water

temperatures, DCP 94-027 was developed to install a three-way, electro-hydraulic, temperature control

valve capable of divening and bypassing 100% of ECC system flows around the ECC heat exchanger,

effectively eliminating heat transfer capability between the ESW and ECC systems. Following installation

of the modification during the fifth refueling outage, temperatures were again recognized as decaying

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toward 55 F. The failure of the modification to control temperature without heat loading on the ECC

system was investigated in accordance with the corrective action process.

Reason for the Violation (Violation A3

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This violation was caused by the failure to adequately recognize the full range of ECC system design and

operating requirements, including those present during testing configurations until 1994. In developing

DCP 94-027, system design and operating requirements were fully recognized and established in the

respective design report. However, a heat transfer mechanism associated with the resultant modified

configuration was not fully recognized during modification development and implementation; therefore,

this heat transfer mechanism was not accounted for in the design nor the post-modification test.

Corrective Steos Taken and Results Achieved (Violation A3

Procedural controls were implemented via precautions in the system operating instructions and guidance in

the alarm response instructions, to avoid challenging the temperature limitations of the ECC system and

Control Complex chillers given the gradual rate of decay of ECC while bypassing 100 percent of ECC heat

exchanger flow.

Corrective Steos that Will Be Taken to Avoid Further Violation (Violation A3

To address the issue associated with not fully recognizing system design and operating requirements,

fuither occurrence should be precluded through changes that have been implemented in the design change

processes. These changes include: development of formalized design reports which contain system

functional and operational requirements, as well as, a complete modification design bases; a multi-

disciplinary modification development and review team; and, integrated Operations involvement

throughout the modification process, including testing.

Revised procedural controls (e.g., revision to Plant Administrative Procedure (PAP) - 0309, " Processing

Plant Modifications," and Nuclear Engineering Instruction (NEI) - 0373, " Initiating, Developing, and

Processing Design Modifications") are being developed to enhance post-modification testing guidelines,

particularly with respect to demonstrating the functionality ofinstalled modifications.

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Enclosure

Page 5 of 6

In addition, the bases for lowering the alarm setpoint for ECC water supply temperature to resolve system

response to low lake water temperatures and to eliminate the need for administrative measures for

operating the system over the complete range oflake temperatures, are being evaluated. The program

involves establishing the design bases for chiller refrigerant temperature and developing test parameters

and executing testing to demonstrate system operability at ECC supply temperature lower than the current

55* F limitation.

Date When Full Comnliance Will Be Achieved (Violation A3

Full compliance will be achieved with the implementation of the additional post-modification testing

guidelines. This action will be completed by March 31,1997.

Reason for the Violation (Violation B3

As discussed in the reply to the first violation, valve OP42-295A was initially classified as an ASME Code,

Section XI, Category "B" valve, which does not require leakage testing to a specific acceptance criteria.

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When this issue was being evaluated in late 1993, it was identified that due to limitations that valve

leakage had on ECC system operability, the valve's Code categorization needed to be re-evaluated and

revised. This was documented in Condition Report 93-0508 as Condition Report Corrective Action

(CRCA) 93-0508-01. However, when this corrective action was evaluated and subsequently closed, the

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corrective action focused on determining a specific leakage acceptance criteria; the issue of Code

categorization was inappropriately not addressed. The reason that this action was not addressed was due to

an oversight on the part of the individual that was responsible for evaluating and closing the respective

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CRCA. Since the valve was already categorized as a Category "B" valve as part of e e approved ISTP,

coupled with the failure to re-categorize the valve when it was identified during issue resolution, the valve

remained improperly categorized until questioned by the NRC during their inspection.

Corrective Steos Taken and Results Achieved (Violation B3

Valves OP42-F295A, OP42-F295B, OP42-F325A, and OP42-F325B were re-categorized as ASME Code,

Section XI, Category"A" valves on October 8,1996. As such, they will be periodically leak tested as part

of the ISTP progren against specific leakage acceptance criteria.

Corrective Stens that Will Be Taken to Avoid Further Violation (Violation B3

As discussed in the response to Violation 96008-1, the Engineering Department conducted a review of

other ASME Code,Section XI, Category "B" valves in the ISTP to detennine if their respective

categorization needed to be changed; no additional valves requiring re-categorization were identified.

Date When Full Comnliance Will Be Achieved (Violation B3

Full compliance has been achieved. To facilitate additional confidene that valves have been appropriately

categorized / tested, an additional evaluation is in progress for non-safety to safety related system interfaces

within the Primary Coolant Leakage Reduction for Systems Outside Containment program.

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Enclosure

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The following table identifies those actions which are considered to be regulatory commitments. Any

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other actions discussed in this document represent intended or planned actions, are described for the NRC's

information, and are not regulatory commitments. Please notify the Manager - Regulatory Affairs at the

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Perry Nuclear Power Plant of any questions regarding this doeurnent or any associated regulatory

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commitments.

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Commitments

Date When Full Comoliance Will Be Achieved (Violation A3

Full compliance will be achieved with the implementation of the additional post-modification testing

guidelines. This action will be completed by March 31,1997.

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