ML20199H272
| ML20199H272 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/24/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199H267 | List: |
| References | |
| 50-440-97-07, 50-440-97-7, NUDOCS 9711260068 | |
| Download: ML20199H272 (2) | |
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NOTICE OF VIOLATION Centerior Service Company Docket No. 50-440 Perry Nuclear Power Plant License No. NPF 58 During an NRC inspection conducted from May 3 through June 23,1997, a violation of NRC requirements was identified. _ In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600, the violation is set forth below:
Perry _ Nuclear Power Plant, Unit 1 Technical Specification (TS) 5.4.1.a. requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978.
a.
Regulatory Guide 1.33, Revision 2, Appendix A, ' Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," states, in part, that procedures should be established for combating loss of electrical power (Section 6.c.).
Combriting the loss of electrical power includes complying with the basis for Techn' cal Specification 3.3.1.2, " Source Range Monitor (SRM) instrumentation,"
Condition D, when electric power is lost to the SRM drive system with the SRMs not fully inserted. The basis states that the mode switch shall be locked.
Cont ary to the above, on June 5,1997, there was no procedure established to combat a loss of electric power to the SRM drive system, in that there was no procedure directing that the mode switch be locked in the shutdown position.
b.
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, " Typical Procedures for Pressurized Water Reactors and Bolling Water Reactors," states, in part, that procedures should be implemented for tagging (Section 1.c.) and for obtaining permission and clearance for personnel to work on plant equipment (Section 9.e.).
Plant Administrative Procedure (PAP) 1401, " Safety Tagging," had been established and met the requirements of RG 1.33. Step 6.7.3. of PAP 1401 requires that prior to performing the activity for which safety tags are placed, the Person-in-Charge, who is responsible for the associated activity, shall ensure that a walkdown is conducted of the wark area and of the appropriate red-tagged boundaries. Step 6.7.4. of PAP 1401 further requires verification that the tag-out has been properly signed on as part of the walkdown. Removing valve R44-F0528B from service on June 2,1997, was an activity for which placement of safety tags was required.
. Contrary to the above, removal of valve R44-F05288 from its in-line position was completed before a walkdown verified that the associated tag-out had been properly signed on.
c.
Regulatory Guide 1.33 Revision 2, Appendix A, February 1978, " Typical Procedures for Pressurized Water Reactors and Boiling. Water Reactors," stated in part that procedures should be established for performing maintenance (Section 9) that can 9711260068 971024 PDR ADOCK 05000440 0
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Notice of Violation safety-related emergency closed cooling valves, controlled by Work Orders (WO) 97-1787 and 97-1791 and conducted on June 10,1997, were maintenance activities.
Contrary to the above, Work Orders (WO) 97-1787 and 97-1791 were documented instructions that were not appropriate to the circumstances, in that the WOs did not include approp iate direction or guidance to ensure that the unusually low expected leakage rates would not be masked by test conditions.
This is a Severity Level IV victation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Centerior Service Company (Licensee) is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Documen' control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Regic M and a copy to the NRC Resident inspector at the facility that is the sabject of this Notice, ethin 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at Lisle, Illinois, this 24th day of October 1997