ML20134H841
| ML20134H841 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/06/1996 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Myers L CENTERIOR ENERGY |
| Shared Package | |
| ML20134H844 | List: |
| References | |
| EA-96-367, NUDOCS 9611150017 | |
| Download: ML20134H841 (5) | |
See also: IR 05000440/1996008
Text
.-
?
'
.
1
November 6, 1996
.
EA 96-367
Mr. Lew W. Myers
Vice President - Nuclear
Centerior Service Company
P. O. Box 97, A200
Perry, OH 44081
SUBJECT:
(NRC SPECIAL INSPECTION REPORT NO. 50-440/96008(DRS))
Dear Mr. Myers:
'
This refers to the insped wn conducted on August 26 through September 11,
1996, at the Perry Nuclear Power Plant. The inspection included a review of
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
Unergency Recirculation due to low ECC temperature in 1994. The report
documenting the inspection was sent by letter dated September 17, 1996, and a
predecisional enforcement conference was conducted on October 11, 1996. These
events were reported to the NRC in Licensee Event Reports dated January 24 and
October 28, 1994.
Based on the information developed during the inspection and the information
that was provided during the conference, the NRC has determined that
violations of NRC requirements occurred. The violations are cited in the
enclosed Notice of Violation (Notice) and the circumstances surrounding the
violations are described in detail in the subject inspection report.
In July 1993, during performance of a heat exchanger performance test on ECC
Train A, the surge tank overflowed. Subsequent review determined that
ECC/ Nuclear Closed Cooling butterfly isolation motor-operated valve (MOV)
OP42-F295A was leaking in excess of 250 gallons per minute (gpm) because the
valve was stroking past its full closed position as a result of mispositioned
limit switches and mechanical stops. The limit switches and mechanical stops
were subsequently re-adjusted and the valve was satisfactorily tested.
The valve limit switches and mechanical stops had been previously adjusted on
March 19, 1993; therefore, the valve was unable to perform its isolation
function from March 19 to July 2,1993.
ECC Train A was inoperable because in
the event of a loss of offsite power / loss of coolant accident (LOOP /LOCA) with
a single active failure of the Division 2 emergency diesel generator, it would
have lost inventory at a rate such that, within one minute of receipt of the
surge tank low level alarm, the Train A pump would begin to cavitate. The
plant was in Operational Conditions 1, 2, or 3 from June 2 to July 2,1993.
Additionally, during this period both trains of ECC were inoperable for
approximately 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> while the Division 2 emergency diesel generator was out
of service.
.
9611150017 961106
ADOCK 05000440
e
.
4
L. W. Myers
2
November 6, 1996
The root causes of the event were personnel error and weak procedural
direction for setting M0V limit switches and mechanical stops in 1993 and the
failure to classify valves OP42-F295A/B as ASME Section XI Category A valves
for which seat leakage is limited to a specific maximum amount.
The violations in Section I of the Notice represent a significant failure to
comply with the action statement for a Technical Specification Limiting
Condition for Operation and are classified in the aggregate in accordance with
the " General Statement of Policy and Procedure for NRC Enforcement Actions"
(Enforcement Policy), NUREG-1600, as a Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount
of $50,000 is considered for a Leverity Level III problem.
Because your
facility has been the subject of escalated enforcement actions within the
previous two years' prior to your identification of the violations in
December 1993, the NRC consMered whether credit was warranted for
Identification and Corrective Action in accordance with the civil penalty
assessment process in Section VI.B.2 of the Enforcement Policy.
Credit was
warranted for your architect / engineer's identification that both trains of ECC
had been inoperable in December 1993.
Credit was warranted for your corrective actions for the violations in
Section I of the Notice. These included re-adjusting the limit switches and
mechanical stops on valve OP42-F295A and conducting post-maintenance testing
to verify the valve would function as required; initiating an engineering
evaluation to determine if the potential for an incorrectly set butterfly
valve limit switch or mechanical stop on other systems could cause a similar
problem; revising the Limitorque Limit / Torque Switch adjustment procedure to
require a post-maintenance leakage test on butterfly MOVs which have an
established seat leakage limit and clarify instructions for setting limit
switches and checking mechanical stop nut settings; and providing training to
maintenance and system engineering personnel on this event and the necessity
of verifying proper butterfly valve closure. Although the NRC identified
.
during the 1996 inspection that valves OP42-F295A/B and OP42-F325A/B were not
properly classified as Category "A" in the in-service testing program, the
valves had been tested within the frequency specified for Category "A" valves
as a result of Generic Letter 89-10 and preventive maintenance activities.
This failure to classify the valves as Category "A" had been previously
'
identified by your staff in January 1994 but no action was taken. The failure
to take corrective action for this isolated deficiency is cited in Section II
of the Notice.
The in-service testing program was subsequently revised to
properly classify these valves.
Therefore, to encourage prompt identification and comprehensive correction of
violations, I have been authorized, after consultation with the Director,
Office of Enforcement, not to propose a civil penalty in this case.
However,
significant violations in the future could result in a civil penalty.
1 A Severity Level III violation for failure to take corrective action (identified in June 1993) was issued
on August 31,1993 (EA 93-176).
--.
-
.
_.
.
.
-
.
.
!
L. W. Myers
3
Novmber 6,1996
Section II of the Notice describes two violations involving failure to (1)
take adequate corrective actions to prevent ECC system temperature from
decreasing below 55' F, and to (2) classify certain valves as Category "A" in
the in-service testing program.
Each of these violations has been catagorized
at Severity Level IV in accordance with the Enforcement Policy.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. The NRC will
use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter, its enclosure, and your response will be placed in the NRC Public
Document Room (PDR).
i
Sincerely,
/s/ W. L. Axelson (for)
,
A. Bill Beach
Regional Administrator
Docket No. 50-440
License No. NPF-58
Enclosure: Notice of Violation
cc w/ encl:
J. P. Stetz, Senior Vice
President, Nuclear
L. W. Worley, Director, Nuclear
Services Department
J. D. Kloosterman, Manager,
Regulatory Affairs
W. R. Kanda, Director, Perry Nuclear
Assurance Department
N. L. Bonner, Director, Perry
Nuclear Engineering Dept.
H. Ray Caldwell, General
Superintendent Nuclear Operations
R. D. Brandt, General Manager Operations
Terry J. Lodge, Esq.
State Liaison Officer, State of Ohio
Robert E. Owen, Ohio
Department of Health
C. A. Glazer, State of Ohio,
({k
Public Utilities Commission
g
\\
SEE ATTACHED CONCURRENCES
V
DOCUMENT NAME: G:\\EICS\\ PERRY 2.PKG
Ta receive a copy of his document, indimes in me box: 'C' = Copy w/o attachment / enclosure "E" = Copy with attachment / enclosure *N" = No copy
0FFICE
RIII:EICS
l
RIII:RA0
l
RIII:DRP
l
RIII:DRS
l
RIII:RA0
l
NAME
Pelke/ Burgess /kjc
Berson
Caldwell
Grant
Beach
DATE
10/
/96
10/
/96
11/
/96
11/
/96
11/
/96
OFFICIAL RECORD COPY
,
.
-
. _ .
...
.
. _ - .
'
.
J. P. Stetz
3
Section II of the Notice describes two violations involving failure to (1)
take adequate corrective actions to prevent ECC system temperature from
decreasing below 55' F, and to (2) classify certain valves as Category "A" in
the in-service testing program.
Each of these violations has been categorized
at Severity Level IV in accordance with the Enforcement Policy.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. The NRC will
.
use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter, its enclosure, and your response will be placed in the NRC Public
Document Room (PDR).
Sincerely,
l
A. Bill Beach
.
Regional Administrator
J
Docket No. 50-440
License No. NPF-58
Enclosure: Notice of Violation
'
1
J. P. Gk\\y;,Genkr % 0esihenh }eer&W
Le
'
cc w/ encl:
1. W.
F,..
Y ke Pra iderit, L J
.
L. W. Worley, Director, Nuclear
Services Department
J. D. Kloosterman, Manager,
l
Regulatory Affairs
'
W. R. Kanda, Director, Perry Nuclear
Assurance Department
N. L. Bonner, Director, Perry
Nuclear Engineering Dept.
H. Ray Caldwell, General
.
Superintendent Nuclear Operations
R. D. Brandt, General Manager Operations
Terry J. Lodge, Esq.
,
'
State Liaison Officer, State of Ohio
l
Robert E. Owen, Ohio
Department of Health
C. A. Glazer, State of Ohio,
,
Public Utilities Commission
DOCUMENT NAME:
G:\\EICS\\ PERRY 2.PKG
4
Ta roosive a copy of this document, indicato in the box: "C" = Copy w/o attachment / enclosure "E' = Copy with attachment / enclosure *N' = No copy
0FFICE
Ril/iggICSh/l
Rill:RA U )l
Rill /HP
l
RIII:DR_S
l
RIII:RA9
l
NAME
PelV5'Bu 3i %s/kjc
Berson p u
Calddlj/
Grantif @
Beach
DATE
10/h /9C
10/'] / /96
11/4 / /96
l11/ I( Y9$
11/
/96
"~
0FFICIAL RECORD COPY
i
..
.
.
.
-
--
_ ~ . .
.
. . - .
_
-
--
.. --
-
'
1
L. W. Myers
4
November 6, 1996
Distribution
i
p'FUBLIC;IE-01 P
SECY
CA
'
JTaylor, EDO
JMilhoan, DEDR
LChandler, OGC
JGoldberg, 0GC
l
,
l
FMiraglia, NRR
RZimmerman, NRR
,
l
l
Enforcement Coordinators
i
RI, RII, RIV
JHopkins, NRR
'
OC/LFDCB
Resident Inspectors, Perry
JGilliland, OPA
HBell, 0IG
'
GCaputo, 01
EJordan, AE0D
MSatorius, OE
OE:EA (2) (Also by E-Mail)
,
Docket File
l
State of Ohio
'
RAO:RIII
SLO:RIII
i
PAO:RIII
f
3
i
l
L
/
'
i
,
l
150017
.
I