ML20203B764

Responds to NRC 971231 & s Re Violations Noted in Insp Repts 50-440/97-16 & 50-440/97-22.Corrective Actions: Leakage Pathway Was Isolated & Appropriate Tagout Boundary Established

ML20203B764
Person / Time
Site:	Perry
Issue date:	02/19/1998
From:	Myers L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-440-97-16, NUDOCS 9802240415
Download: ML20203B764 (5)

Text

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -

Perry Nuclear Power Plant E*__

LE=

10 Center Road gWyY PO Bcx 97 m

Perry One 44081 Lew W Myers 440-28659:S

%:e Presscent Fax 44326%B029 Februa.y 19,1998 PY-CEl/NRR 2254L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 Reply to Notices of Violation Ladies an ' Gentlemen:

Enclosed are the Perry Nuclear Power Plant (PNPP) replies to two Notices of Violation contained in NRC Inspection Reports 50 440/97016 and 50-440/97022, transmitted by letters dated January 2,1998 and December 31,1997, respectively. The requir:d 30-day response due dates were extended by the NRC to February 19,1998 during a telephone discussion that was held between Mr. Thomas J. Kozak, Branch Chief-DRP, Region 111, and Mr. llenry L. Hegrat from the PNPP on January 26,1998, if you have questions or require additional infonnation, please contact Mr. Henry L. Hegrat, Manager Regulatory Affairs, at (216) 280-5606.

Very truly yours,

.A eQ Lew W. Myers Vice President-Nuclear Enclosure cc:

NRC Region III Administrator i

NRC Resident inspector

- ~

NRC Project Manager I

J jJ 9802240415 980219j l

,l.<.ll DR ADOCK 050004 0

1 PY-CEI/NRR 2254L Enclosure Pageiof4 REPLY TO NOTICE OF VIOLATION 50-440/97016-03 Restatement of the Violation Perry Nuclear Power Plant Unit 1 Technical Specification (TS) 5.4.1.a specifies, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Appendix A of NRC Regulatory Guide 1.33. Revision 2, specifies activities that should be controlled by written procedures. Safety tagging is a specified activity.

Perry Administrative Procedure 1401," Safety Tagging," Revision 8 (January 1995), requires, in part, that tag-outs be prepared and verified to adequately isclate potential hazards to personnel and equipment prior to commencement of work.

Contrary to the above, on October 6,1997, personnel began work on a reactor recirculation system flo v control valve actuator without verifying that the tag-out adequately isolated the work area from the reactor coolant system. As a result, the potential hazard associated with low pressure reactor coolant was not isolated from personnel, and consequently, equipment and personnel were sprayed with reactor coolant.

This is a Severity Level IV violation (Supplement 1)

Background

The safety tag-out for recirculation system flow control valve (FCV) actuator work did not isolate the FC /

from the reactor coolant system and a failure of the FCV packing occurred during the actuator work. This resulted in leakage from the reactor coolant system through the FCV nacking which was then icolated by closing an additional valve.

Reph This violation is accepted as written.

Reason for the Violation The reason for failure to meet the Plant Administrative Procedure (PAP)-1401 requiremems is less than adequate workmanship in the generation and implementation of a tagout for the associated work to be accomplished. Our investigation identified shortcomings in some work practices as well as written and verbal communications.

Corrective Stens Taken and Results Achieved The leakage pathway was isolated and appropriate tagout boundary established. A work stand down was initiated for both snifts (12-hour shifts) to emphasize safety tagging.

Guidance for tagout preparation / review has been enhanced and communicated to ensure that a tagout prepared in advance of the associated work document is reviewed for adequacy against the fully completed

PY-CElHRR-2254L Enclosure Page 2 of 4 work document. On November 25,1997, process enhancements were put into place to ensure that refueling outage work orders receive a detailed operational review, which includes an enhanced review for equipment removal adequacy, similar to that presenth performed for "on line" work orders.

The work planning group and tagout group have worked together to develop and communicate expectations regarding the completeness and level of detail used in prepaiation of tagout requests associated with work

)

documents. Roles and responsibilities to ensure safe working conditions have been re-emphasized to maintenance supuvisors and coordinators. The repetitive tasks utilized for the valve actuator replacements (the activity in progress when the violation occurred) have been revised to clearly establish the requirement to have the reactor recirculation system isolated, drained, and tagged to prevent packing leakage during the work.

Corrective Sleps That Will be Taken to Avoid Further Violations Activities are in progress to benchmark industry practices and implement improvements based on that benchmarking, in Se area: of overall tagout program, tagout preparation techniques, and contractor in-processing training for the tagout process and general responsibility for assuring a safe working environment. Additional steps are discussed in the " ADDITIONAL DISCUSSION OF SAFETY TAGGING ISSUES" section of this enclosure.

Date When Full Comnliance.Will be Achieved Full compliance was achieved " October 6,1997, when the appropriate tagout boundaries were established.

REPLY TO NOTICE OF VIOLATION 50-440/97022-01 Restatement of the Violation Perry Nuclear Power Plant, Unit 1 Technical Speci6 cation (TS) 5.4.1.a requites that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision 2, Appendix A, February 1978," Typical Procedures for Pressurized Water Reactor and Boiling Water Reactors." Regulatory Guide 1.33 states, in part, that procedures should be implemented for tagging (Section 1.c). Perry Administrative Procedure (PAP) 1401. " Safety Tagging,"

had been established and met the requirements of RG 1.33.

Perry Administrative Procedure 1401, Steps 6.4.9,6.4.11, and 6.5.4, respectively, required: tag-out preparers to note any significant tag-out effects on system and plant operability in the " Preparer / Reviewer's Notes" section of the tag-out sheet; tag-out reviewers to note any significant tag-out effects on system and plant operability in tae " Preparer / Reviewer's Notes" section of the tag-out sheet; and tag-out authorizers to evaluate the tag-out's effect on co rent plant status prior to authorization.

Contrary to the above, or October i 1,1997, the preparer and reviewer of tag-out 29491 did not note a significant tag-out effect on system and plant operability in the " Preparer / Reviewer's Notes" section cf the tag-out sheet and the authorizer did not adequately esaluate the effects of the tag-out on plant status prior to authorization. Specifically, the preparer, reviewer and authorize of tag-out 29491 failed to adequately

PY-CEl/NRR-2254L Enclosure Page 3 of 4 evaluate the tag-out and determine that a water flowpath from the reactor vessel to the suppression pool would be created during the slow depressurization of the scram air header.

i This is a Severity Level IV violation (Supplement 1).

lhckeround Personnel involved with a tag-out generated for scram air (SA) header valve work incorrectly believed that the scram discharge volume (SDV) vent and drain valves would close before the scram inlet and outlet valves started opening as the SA header slowly depressurized. Ilowever, the scram inlet and outlet valves started opening before the SDV vent and drain valves closed w hich created a water flowpath from the reactor nressure vessel (RPV) to the suppression pool.

The actual safety significance of this event was low. Shutdown cooling was nevc: significantly jeopardized.

This event, however, is of concere due to the failures of barriers designed speaideally to ensure evolutions are conducted in a safe and centrolled manner and the potential for similar events to continue to challenge plant operators. This et ent was reported in LER 97-013. " Control Rod Drive flydraulic System Ma;ntenance Activities Result in Reactor Protection System Actuations"(PY-CEl/NRR-2227L).

ILcply This violation is accepted as,vritten.

Reason for the Violation The cause of the event associated with the violation was attribut d to inadequate operator actions to place the plant and equipment in the condition necessary for the tagout. Neither the tagout nor planning documents specified that the SDV was to be isolated before the scram valves were opened. Weaknesses were identified in the areas of coordinating document usage, including the appropriate level of expertise in the Control Rod Drive flydraulic (CRDH) system removal process, questioning attitude in tagout development and review, and expectations concerning the assessment of risk significance during outage situations.

Corrective Steos Taken and Results Achieved The RPV drain path was isolated by the actuation of the Reactor Protection system, and the appropriate tagout boundaries were established. Personnel reonsible for the development, review, and authorization of tagouts have been counseled on the importance of producing tagouts based on verifiable, factual information and on the requirements with regard to providing positive actions to ensure components are placed in required positions during tagout activities. Information regarding the importance of segrencing of tags for tne CRDil system was added to the tagout database.

Appropriate manager ent personnel were coached to re-emphasize to them their responsibility to make expectations clear regarding conduct of ri:k reviews for emerging outage activities. On November 25,1997, process enhancements were put into place to ensure that refueling outage work orders receive a detailed operational review, which includes an enhanced review for equipraent removal adequacy, similar to that presently per ormed for "on-line" work orders.

f

PY-CEl/NRR 2254L Enclosure Page 4 of 4 Corrective Steps That Will be Taken to Avoid Further Viointions Development of numerou, procedural and policy enhancements is under way to capture the lessons learned and management expectations idertified by this event. Additional steps are discussed in the " ADDITIONAL DISCUSSION OF SAFETY TAGGING ISSUES" section of 4is enclosure.

Date When Full Comoliance Will be Achieved Full compliance was achieved on October i I,1997, when the event was terminated and appropriate tagout boundaries were established.

ADDITIONAL DISCUSSION OF SAFETY TAGGING ISSUES l

As part of the investigation of the event documented by LER 97-013, an additional corrective action document was initiated to address broader concerns about tae effectiveness of the Safety Tagging program and past atterrm to improve it on an event by-event basis. This bread based multi-disciplined investigation has resulted ii....e development of additional long term corrective actions. These actions include the following:

1) Revise PAP-1401 to more appropriately assign tagout process responsibilities, and add requirements to more effectively identify and respond to high risk conditions associated with tagouts.

2) Develop and implement enhanced training, which includes training matrices andjob task analyses, for the responsibilities associated with the tagout process.

3) Revise procedures for the work' order process and preventive maintenance program to accommodate -

i.

the revision to PAP-1401,

4) Site management is developing initiati.:s to more effectively communicate management expectations for enforcement of an effective safety tagging program.

No regulatory commitments were identified in this response. Any actions discussed in this document represent intended or planned actions, are described for the NRC's information, and are not considered to be regulatory commitments. Please notify the Manager - Regulatory Affairs at the Perry Nuclear Power Plant of any questions regardirg this document or any associated regula'ory commitments.

V W

p

.)