ML20198A226
| ML20198A226 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/10/1998 |
| From: | Myers L CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-440-98-18, PY-CEI-NRR-2338, NUDOCS 9812160184 | |
| Download: ML20198A226 (4) | |
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e pan _ _ namn Pbrry Nuclear Power Plant 5N oc 4 Lew W Myern 440-280 59 t5 W C Prw dent Fax:440-2804029 December 10,1998 PY-CEI/NRR-2338L United States Nuclear Regulatory Commission
- Document Control Desk i
Washington, D.C. 20555 Perry Nuclear Power Pla.:t Docket No. 50-440
Subject:
Reply to a Notice of Violation (NRC Inspection Report No. 50-440/98018)
Ladies and Gentlemen:
Enclosed is the Perry Nuclear Power Plant (PNPP) response to a Notice of Violation documented in NRC Inspection Report 50-440/98018 (DRS), which was transmitted by letter dated November 10, 1998. One violation of NRC requirements was identified. In accordance with 10 CFR 2.201, the violation is being accepted as written.
In your cover letter transmitting the notice of violation, you requested a description of the corrective actions planned to ensure that our staff would generate transient combustible permits as required. Because these investigations are not yet complete, a supplement to this violation response will be submitted to discuss the results of these investigations and the applicable corrective actions identified.
' If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager-Regula'ory Affairs, at (440) 280-5606.
Very truly yours, JY i
Enclosure h.
cc: NRC Region ill Administrator
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NRC Resident Inspector NRR Project Manager 9812160184 981210 tI PDR ADOCK 05000440 f G
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PY CEI/NRR-2338L Enclosure Page1of3 REPLY TO A NOTICE OF VIOLATION RESTATEMENT OF THE VIOLATION During an NRC inspection conducted on September 8 through October 20,1998, one violation of NRC requirements was identified:
Perry Nuclear Power Plant Unit i Technical Specification 5.4.1.a., requires that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978.
Appendix A of RG 1.33, Revision 2, lists the Plant Fire Protection Program as an activity that should be covered by written procedures.
Part of the Plant Fire Protection Program is implemented by Plant Administrative Procedure PAP-1916," Duties of the Fire Watch," Revision 4 (April 28,1998). Step 6.3.5 specifies that prior to and during hot work activity, the fire watch person shall be responsible for verifying that the special instructions of the Burn Permit have been met, and that no fire hazards exist that would prohibit commencement of work.
Contrary to the above, on September 2,1998, the inspectors identified that a fire watch did not verify that the special instructions of Burn Permit No. B98-DG-83, which was used for the welding conducted on the diesel generator I room roof, were met. Specifically, combustible material that was within 35 feet of the hot work activity was not removed or J
covered prior to the commencement of the hot work activity as required by the special instructions of Burn Permit No. B98-DG-83.
This is a Severity Level IV violation (Supplement 1).
ACCEPTANCE OR DENI AL OF Tile VIOLATION The Violation is accepted as written.
REASON FOR THE VIOLATION The reason for the violation is procedural inadequacies. The fire protection program is governed by several procedures. For this work activity, three procedures were necessary to implement the activity: Plant Administrative Procedure (PAP)-1912, Burn Permits for Ignition Sources; PAP-1913, Control of Transient Combustibles; and PAP-1916, Duties of the Fire Watch. The outside location of the work and the tena " combustibles" are not clearly defined by the procedures and the requirements were not well understood by the personnel involved.
The work activity was classified as non-safety and was being performed outside on the roof of the Unit 1, Division 1 Diesel Generator Building. The work area was separated from the diesels and equipment by a concrete roof. The personnel involved did not recognize, nor were they informed, that the roofof the building was part of a safety-related structure.
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Enclosure Page 2 of 3
_ Als'o, the wood be'ag used that was uncovered was assumed not to be combustible due to being fire retardant treated or not being required by procedure to be fire retardant treated. These factors caused the failure to generate a Transient Combustible Permit as required by PAP-1913 and a failure to cover all combustibles as required by PAP-1912 and the burn permit.
I A contributing cause to this event was personnel error The supervisors and fire watches involved 1
in the hot work activity failed to ensure that the requirements of PAP-1912 and the burn permit had been met because they failed to ensure all combustibles within 35 feet were covered or 1
removed. The fire watch also failed to stop the hot work activity when the wood, that had been covered prior to activating the burn permit, became uncovered.
DATE WHEN FULL COMPLIANCE WAS ACIIIEVED
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Full compliance with PAP-1916, Duties of the Fire Watch, was achieved on September 2,1998 upon the completion of the hot work activity.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
.. The supervisors and fire watches involved in this event were coached and counseled on 1
complying with the requirements PAP-1912, Burn Permits for Ignition Sources, and PAP-1916, Duties of the Fire Watch.
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.1 CORRECTIVE STEPS TO AVOID FURTHER VIOL.ATIONS The following actions to be addressed under the Perry Nucl:ar Power Plant (PNPP) Corrective Action Program have been developed and are intended to reinforce the responsibilities of the fire
. watch and improve the control of transient combustibles:
The fire protection procedures are being reviewed by a high priority condition report investigation to identify areas where the procedure may not accurately reflect the intent of the requirement, to identify potential procedural conflicts, and to recommend changes to correct the areas that are determined to be potential weaknesses. The investigation is scheduled to be complete on January 9,1999.
' Additionally, a high priority condition report has been initiated to evaluate the collective significance of recent fire protection issues. The circumstances of this violation are included as I
part of the evaluation. The results of the evaluation will determine if changes to the fire protection program are necessary. The investigation of this condition report is currently scheduled to be complete on December 17,1998.
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PY-CEI/NRR-2338L '
i Enclosure Page 3 of 3 t
Thy following identifies those actions considered to be regulatory commitments. Any other actions
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' 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 Perry Nuclear Power Plant of any questions regarding this document or any associated
COMMITMENTS l
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When the investigations identified below are complete, a supplement to this violation response will be submitted to discuss the results of the investigations and the applicable corrective actions identified.
The fire protection procedures are being reviewed by a high priority condition report investigation to' identify areas where the procedure may not accurately reflect the intent of the requirement, to identify potential procedural conflicts, and to recommend changes to correct the areas that are determined to be potential weaknesses. The investigation is scheduled to be complete on January 9,1999.
Additionally, a high criority condition report has been initiated to evaluate the collective significance of recent fire protection issues. The circumstances of this violation are included as 1
part of the evaluation. The results of the evaluation will determine if changes to the fire protection program are necessary. The investigation of this condition report is currently scheduled to be complete on December 17,1998, 1
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