ML20197H559
| ML20197H559 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/23/1997 |
| From: | Myers L CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-440-97-09, 50-440-97-9, NUDOCS 9712310312 | |
| Download: ML20197H559 (6) | |
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- uO 44 ua w uye torso sess w e pres.aant rac we80am December 23,1997 PY-CEl/NRR 2240L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear 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 50-440/97009 for the Perry Nuclear Power Plant (PNPP), which was transmitted by letter dated November 26,1997. The Notice of Violation included three violations, if you have questions or require additional information, please contact Mr. llenry L. llegrat.
Manager - Regulatory AITairs, at (440) 280-5606.
Very truly yours,
!' knit for Lew W. Myers Enclosure ec:
NRC Region til Administrator NRC Resident inspector NRC Project Manager g+
9712310312 971223 7
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PY-CEl/NRR 2240L 3-y Enclosure 7
Page 1 of $
REPLY TO A NOTICE OF VIOLATION yiolation (50 4401.97049 01(DRPM g-Restatementaf the Violatin,n 10 CFN 1 art 80.73(a)(2)(iv) requires that the licensee shall submit a licenzee event report (1).sR) within 30 days e the discovery of any event or condition that resulted in a manual or automatic actuat.on of any engineered safety fmae (ESF).
Autor.A rw. ion of the electronic logic that is intended to switch se hip pressure core spray (liPCS) rwo
. ute condensate storage tank to the suppression pool is an actuation of an ESF,
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Contrary to tne above, the licensee has to date not submitted an LER describing the circumstances surrounding an unexpected automatic actuation of the llPCS s ction logic on July 15,1997.
Reply This violation is accepted as written.
Reason for titt hhtien A LER was not s'.abmitted because the Perry Nuclear Power Plant (
,aaWheheves that the acttation resulted inun and was pan of a pre-planned sequence during testing or reactor operation. The PNPP staff har.
reviewrd the violation closelv and assessed the decision to retree! the original noti 6 cation (nade pursuant to 10 CFR $0.72. Ahhough we do not fully agice with the violation, we accept the NRC interpretation oithe regulatory guidance, bec.mse the evolution was not properly documented in accordance with Operations
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Fiction Standing Instructions.
me PNPP Regulatory Affaits Section staff understands the requirements of 10 CFR 50 73; in tut. the w
function in qantion (llPCS pump suction whill due to high suppression pool level) was determ'ned te be reportable as an ESF actuation when not properly anticipated on May 27,1997, and such an event was reported in LER 97 004 " Invalid liigh Supp ession Pool Level Signal Results in Engineered Safety Feature Actuation." As pari vf the corrective actions for that event, standing instructions, vere developed to 1) noti?
all operating crews of the potential reportability of the HPCS suction shift as an ESF,2) leave the HPCS suctica aligned to the supprest'ca poci, and 3) ensure that any pre-planned suppression pool related evolutions that could cause a 'ngh suppression pool level were recorded in the Unit Log as pie-planned events to ensure a reportability issue did not arise.
When the direction to log potential events waa given it was not the intention to have operators make lncremental quantitativejudgments about system interactions (i.e., containment pressure and suppression pool level). Rather, it vas to document recognit:on that the activity had the potential to increase suppression pool level which in tum could result in the well understood and expected interaction with suppression pool level ESF instrumentation, even though the suppression pool water level was being maintained within the reauirements of Technical Specification (TS) Limiting Condition for Operation (LCO) 3.6.2.2.
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PY-CEl/NRR 2240L Erclosure Page 2 of 5 On July 15,1997, the operators made a quantitative judgment about the magnitude of system interactior.
between the containment pressure and suppression pool water level and, in contrast with management expectatiens, did not record the activity as having the potential for causing an ESF actuation. When the annunciator was reccised in the control room, indicating the ESF actuation, the alarm was veriGed to have beca a re'. ult of the containment ventilation operatica, and it was then realized that the evolution was not previoudy documented in the Unit Log as a pre-planned evolution with a potential to actuate the ESF on L
high suppression pool level. Due to the lack of documentation and initial questions concerning the condition of the instrumentation that caused the actuation, the event was conservatively reported under 10 CFR 50.72.
j lt should be noted that the system had already been aligned to the suppression pool, and that the ESF actuation was limited to logic operation only.
p Alt iough, the instruction to log the evolution was not complied with, the noncompliance did not result in l
operation of tN plant in a different manner inan if there had been full compliance with the instruction. The plant was being operated in a conservative manner and this event was considered to be a pre-planned es olution.
Correctire Steps Talcp and Resuhs Achiesed As part of the corrective actions for the July 15,1997, event, the llPCS system operating instruction was revised to clarify that during normal plant operations which affect suppression pool les el or cause turbulence, the llPCS suppassion pool transfer logic may actuate, and that such actuation is considered part of the pre-planned evolution. This clarification alleviates the requiremen' for operators to log the I
expectation for normal plint operations. Since that time, no reportrJ -
- t actuations associated with
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suppression pool level and the llPCS suction shill have occurred.
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COIrrttiEC SlepJi_lf'_Mnid1prther Violations No further corrective actions are planned for this violation.
DateEhenlulLComtliance Will be Achigicd Full compliance will be achieveo on January 22,199E, with the submittal of a licensee ever report in accordance with 10 CFR 50.73(a)(2)(iv).
Yiolation (50-440/97009-02(DRP))
licitatemenLDLthe iiolation 10 CFR Part 50, Appendix 11, Criterion V," Instructions, Procedures and Drawings," requires that activities affecting quality be prescribed by procedures appropiiate to the circumstances.
Contrary to the above, on July 29,1997, the inspectors identiGed that licensee procedure PAP-1105,
" Surveillance Test Control." Revision 8 (dated July 18,1995), which prescribed activities affecting suality,
..as not appropriate Specifically, the procedure did not include guidance to operations on how to evaluate systr m operability determinations for situation 3 where test ecceptance criteria changed after performance of the test.
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PY-CEl/NRR-2240L Enclosure
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This violation is accepted as written.
Reason for the Violation The reason for this violation S procedural weakness. When Plant Administrative Procedure (PAP)-1105 was developed, guidance was provided for incorporating Technical SpeciGeations (TS) changes (which have implementation dates)into surveillance instructions, as well as guidance on what to do if parameters are found to be outside acceptance criteria while performing a test; however, consideration was not given to incorporating guidance on implementing changes in TS surveillance acceptance criteria not specifically listed in the TS.
Corrective Step,s Taken and Results Achieved interim guidance to operators to assist in implementing changes to TS suiveillance acceptance criteria not resulting from TS amendments has been developed in the form of a s:anding instruction until PAP-1105 can be revised.
Corrective Stggs to Avoid Further Violations PAP-1105 will be revised to provide guidance to operators to assist them in implementing changes to TS surveillance acceptance criteria not resulting from TS amendments. PAP-1105 is scheduled to be revised by March 6,19?8.
Datv_\\Yhsn Full Comnliance Will be Achieved Full compliance was achieved on Decembe. 4,1997, when the interim guidance to operators to assist in implementing changes to TS surveillance acceptance criteria not resulting from TS amendments was implememed in the standing instruction.
Violation (50-440/97009-04(DRP))
Restatement of the Violation Perry Nuclear Power Plant Unit 1 Technical Specification (TS) 5.4.1.a. requires that written procedures shall be implemented covering the applicable p aceduies recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A. " Typical Procedures for Pressurized Water Reactors and Boiling Water.teactors," states in part, that maintenance that can affect the performance of safety-related equipment (Section 9.a) should be properly performed in accordance with wri, ten procedures appropriate to the ci-cumstances.
Work Order (WO) Number 97-0873 controlled maintenance that could have affected the performance of Control Complex Clull Water safety-related Valve OP47-F085A. Section 130 of the WO directed that the
PY CEl/NRR-2240L l
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Page 4 of 5 valve be repacked in accordance with Generrl Maintenance Instruction (GMI)-0061," Valve Packing Instruction " Revision 2 (January 26,1996).
Contrary to the above, on July 8,1997, the inspectors identined that safety-related Valve OP47-F085 A was not repacked in accordance with WO No. 97-0873.
lisply This violation is accepted as written.
Reaso1Lfor.the Violation The reason for the violation is personnel error, failure to follow procedure. Maintenance personnel responsible for repacking the valve had reviewed GMI 0061 numerous times prior to performing the work but did not reference the instruction and document activities as prescribed by the instruction. Although working conditions were not condue:ve to having the instruction in close proximity while performing some of the steps, the individual performing the work should has e utilized the instruction on location at appropriate intervals and documcated tnat the necessary steps had been performed.
COIIcclitc Sicps Tak. n and Results Achiegd Alter the work was accomplished, the maintenance worker, the vendor, a maintenance supervisor and a maintenance engineer reconciled the instructional steps and work order with the packing work completed.
They detennined that the work met the instructional requirements and completed the appropriate documentation. A corrective action document was initiated to address the procedural compliance issue. As part of the investigation, GMI.0061 was reviewed to ensure that it provided appropriate guidance for the type of packing used in WO 97-0873. The guidance was deemed to be adequaw and no discrepancies were noted.
Corrsetive Steps to Avoid Further Violations
'the maintenance supervisor and worker were counseled concerning the event and meeting procedural requirements. Additionally, GMI-0061 was revised an August 25,1997, which made the instruction casier to implement.
Date When Full Compliance Willhc_Achiered Full compliance was achieved on July 8,1997, when the GMI-0061 instructional steps and WO 97 0873 v.as reconciled with the work performed and the documentation was completed.
The following identines those actions which are considered to be regulatory commitments. Any other actions discussed in this document reprer.ent intended or planned actions, are described for the NRC's information, and are not regulatory commitn.ents. Please notify the Manager - Regulatory Affairs at the Perry Nuclear Power Plant of any questions reg'trding this document or any associated regulatory commitments.
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PY-CEl/NRP. 2140L l
Enclos ;e
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P:ge $ of 5 Commitments
- 1. Full compliance will be achieved on January 22,1998, with the submittal of a licensee event report in accordance with to CFR 50.73(a)(2)(iv) for the July 15,1997, event.
- 2. PAP 1105 will be revised to pros ide guidance to operators to assist them in implementing changes to TS surveillance acceptance criteria not resulting from TS amendments. PAP-1105 is scheduled to be revised by March 6,1998.
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