ML20137M625
| ML20137M625 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/04/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0107, PY-CEI-OIE-107, NUDOCS 8509130287 | |
| Download: ML20137M625 (4) | |
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f I!)b IlI E V E b!;M D E L ECT RIC I L L U M IN ATlH G C O M P A N Y P.o. Box 5000 - CLEVELAND OHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSQUARE Sening The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT NUC LE AR September 4, 1985 PY-CEI/01E-0107 L Mr. R. R. Warnick, Chief Projects Branch 1 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 50-440/85033 Noncompliance Response
Dear Mr. Warnick:
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This letter is to acknowledge receipt of Inspection Report 50-440/85033 attached to your letter dated August 5, 1,85.
This report identifies areas examined by Messrs. J. A. Grobe and J. P. Brown, Jr. during their inspection conducted June 3 through July 8,1985 at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated August 5, 1985 This response is in accordanca 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 beer. submitted to you within thirty days of the date of the Notice of Violation as you requested. If there are additional questior.s, please do not hesitate to call.
Very truly yours, 5
Murray R. Edelman Vice President Nuclear Group MRE:nje Attachment 8509130287 850904 PDR ADOCK 05000440 I
S&
SEP 6 1985
Mr. R. F. Warnick Septeinber 4, 1985 PY-CEI/01E-0107 L cc:
Mr.-J. A. Grobe USNRC Site, SBB50 Mr. D. E. Keating USNRC Site, SBB50 Mr. K. A. Connaughton USNRC Site, SBB50 U.S. Nuclear. Regulatory Commission Document Control Desk Washington, D.C.
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4 RESPCMSE TO NONCOMPLIANCE 50-440/85033 i
10 CFR 50, Appendix B, Criterion V as implemented by the applicant's Corporate Nuclear Quality Assurance Program, Section 0500, Revision 6, requires that activities affecting quality be prescribed by and accomplished in accordance with documented proadures. Administrative procedure PA-0206, Revision 5,
" Housekeeping", requires that floor plans be developed designating house-keeping zones for plant areas. hose floor plans designate that the reactor i
vessel and B pool were Zone III areas which require material accountability.
1 Contrary to the above, no procedures were written to control materials in the j
reactor vessel and B pool. Material accountability activities were specified in a memorandum. In addition, the specified material control measures were not implemented on June 22, 1985 when the inspector observed materials (e.g.,
reactor vessel stud protectors) had not been logged out of the reactor vessel area prior to flood-up and full flow low pressure coolant injection testing.
This is a Severity Level V violation (Supplement III).
Corrective Action Taken and Results Achieved During the period of inspection discussed in the notice of violation, the reactor vessel head was removed to perform preoperational tests 1B13-P-001, 1F14-P-001,_and 1F15-P-001.
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In an effort for plant personnel to gain experience in the implementation of area housekeeping and accesr controls, the responsibility for controlling the Unit 1 refueling floor was transferred from Nuclear Construction Department l
(NCD) to Perry Plant Technical Department (PPTD) through generation of Work Authorization NFS 85-7434. Work order 85-02239 was generated to provide l-Temporary Work Instructions for access control and material accountability for j
the reactor vessel and B pool areas.
I On June 22, 1985, the NRC Resident Inspector expressed concern with the implementation of material accountability in the area of the B pool and reactor vessel. In response to this concern, the following actions were implemented:
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Increase the field of view for the security officers in the area and increase the number of security officers on duty at all times.
o Inform all levels of Project Management of the need for increased-i j
awareness and proper implementation of controls, including disciplin-ary action as necessary to insure compliance.
he B pool was inspected for cleanliness on 6/19/85 prior to filling the upper pools, and documented on a Precleaning Data Sheet. On 6/28/85,' the next time j
the pools were drained, an examination for material and items in the area of the B pool and refueling / auxiliary platforms was performed by NCD and Security.
The items present were re-inventoried, providing a new baseline for the itesMasterial log sheets.
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Once these actions were completed, material accountability and personnel access controls were satisfactorily accomplished for the RPV, B pool and platform areas. NFL NIS 85-7434 and No 85-02239 were closed after the vessel head was re-installed to support SIT. All materials, tools and other ite:ns were retrieved and accounted for in the log.
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Corrective Action Taken to Avoid Future Noncompliance Prior to reopening the refueling flocr after SIT /ILRT, the entire refueling i
floor was designated as a zone III. %e cleanliness requirements for the refueling floor are specified by procedure PA-0206 " Housekeeping", Revision 5.
Procedure NEDP 3-0801 " Reactor Pressure Vessel / Restricted Area Access Control" Revision 3 was utilized to control material and personnel access. PA-0111
" Unit 1 Refueling Floor Access Control" was written which incorporates the requirements from NEDP 3-0801 and the portions of PA-0206 concerning zone i
designation and personnel-material accountability. PA-0111 provides the necessary control measures to iglement the PA-0206 requirements and is now used on the Unit 1 refueling floor.
Procedure PA-Olli offers a number of improvements to control personnel access and material accountability. %ese improvements include the following:
o Personnel taking material onto the refueling floor now must assume the responsibility for removing the material by the end of his/her shift or 4
have the material entered on the Long Term Tool-Material Inventory Log.
o The procedure clearly defines the authority and responsibility of the security officers to deny access to anyone who willfully or repeatedly l
fails to follow procedural requirements, o
Procedure PA-0111 provides access control to the entire refueling floor where the previous procedures only controlled the B pool area.
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o his procedure assigns the responsiblilty for procedural compliance to l
the individual.
I Training in the requirements of PA-0111 b.as been provided to the appropriate Engineers, Security Personnel and Job Supervisors. In addition, continuous OQS i
surveillance of the implementation of these requirements on the refueling floor was instituted. B is surveillance continued until CEI management had adequate assurance that the requirements are being consistently implemented.
The collective actions described herein will reduce the chances of additional i
problems through the more definite control established and the clearer lines of i
responsibility afforded through a Project Administration level procedure.
Date Full Compliance Will Be Achieved-Full compliance has been achieved, i
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