ML20196K846

Forwards Insp Rept 50-440/99-05 on 990301-05.No Violations Noted.Informs That Licensee Use of 10-Minute Rule & 4-Hour Rule Remains Under NRC Review.Expresses Re Practice Revising Unavailability Criteria on Recurrent Basis

ML20196K846
Person / Time
Site:	Perry
Issue date:	04/02/1999
From:	Gardner R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Myers L AFFILIATION NOT ASSIGNED
Shared Package
ML20196K849	List: IR 05000440/1999005 ML20196K846
References
50-440-99-05, 50-440-99-5, NUDOCS 9904070273
Download: ML20196K846 (3)

See also: IR 05000440/1999005

Text

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April 2, 1999

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. Mr. Lew W. Myers

Vice President - Nuclear

FirstEnergy Nuclear Operating Company

P.0, Box 97, A200

Perry, OH 44081

SUBJECT: NRC MAINTENANCE RULE INSPECTION REPORT 50-440/99005(DRS)

Dear Mr. Myers:

On March 5,1999, the NRC completed a special inspection of your implementation of 10 CFR

50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power

Plants," (the maintenance rule) at the Perry Nuc!sar Power Plant. The enclosed report presents

the results of that inspection.

Our inspection was a risk-informed, performance-based examination of your staff's use and

control of performance criteria. The inspection focused on your method of monitoring structure,

system, and component (SSC) unavailability times and practice of making recurrent adjustments

to performance criteria when SSC performance approached these limits.

Although no violations of NRC regulations were identified, your use of the "10-Minute Rule" and

the "4-Hour Rule" (a concept called " managed restoration") remains under NRC review. The

inspectors were concerned that greater rigor in implementing the practice was necessary to

ensure that its use was carefully controlled.

' While your practice of revising unavailability criteria on a recurrent basis and revision of -

reliability criteria as the number of functional failures approached limits appeared to be based on \

adequate technical considerations, this practice had the potential to mask degrading equipment \

performance. .

'

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and the

enclosure w;ti be placed in the NRC Public Document Room.

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L. Myers -2-

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

Original /s/ Ronald N. Gardner

Ronald N. Gardner, Chief

Electrical Engineering Branch

Docket No.: 50-440

License No.: NPF-58

Enclosure: Inspection Report 50-440/99005(DRS) i

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cc w/ encl: H. Hegrat, Manager, Regulatory Affairs l

R. Schrauder, Director, Nuclear i

Engineering Department l

W. Kanda, General Manager

Nuclear Power Plant Department

N. Bonner, Director, Nuclear

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Maintenance Department

H. Bergendahl, Director

Nuclear Services Department

State Liaison Officer State of Ohio

R. Owen, Ohio Department of Health l

C. Glazer, State of Ohio Public 1

Utilities Commission

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Distribution:

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RPC (E-Mail)

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B. Clayton, Rlll w/ encl

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PUBLIC 1E-01 w/enct

Docket File w/enct

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DOCDESK (E-Mail)

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