ML20205A957
| ML20205A957 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/11/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8504260204 | |
| Download: ML20205A957 (3) | |
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i P.O. BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLIC SOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN April ll, 1985 VICE PRESIDENT NUCMAR Mr. R. F. Warnick, Chief Reactor Project Branch 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry.N3 clear Power Plant Docket Nos. 50-440; 50-441
Dear Mr. Warnick:
This letter is to acknowledge receipt of Inspection Report 50-440/85-002; 50-441/85-002 attached to your letter dated March 12, 1985.
This report identifies areas examined by Messrs. J. A. Grobe, D. E.
Keating and G. F. O'Dwyer during their inspection conducted January 7 through Fcbruary ll, 1985, at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated March 12, 1985.
This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Our response has been submitted to you within thirty days of the date of the Notice of Violation as you required.
If there are additional questions, please do not hesitate to call.
Very truly yours,
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Murray R. Edelman Vice President Nuclear Group MRE: gin Attachment cc:
Mr. J. A. Grobe USNRC Site, SBB50 Mr. D.
E. Keating USNRC Site, SBB50 U.S. Nuclear Regulatory Commission Document Control Desk Wachington, D.C. 20555 190j j
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RESPONSE TO ENFORCEMENT ITEM Below is_ouriresponse to the Notice of Violation appended to
.l United States Nuclear Regulatory _ Commission I.E.nReport No.
50-440/85-002;-50-441/85-002.
I..Noncomoliance A.
. Severity Level IV Violation 10 CFR 50, Appendix-B, Criterion XI, as implemented through the applicant's Corporate Nuclear ~ Quality Assurance Program, Section 1100, Revision 4, requires that a testing program shall be established to assure-that.alli testing required-to demonstrate that structures, systeme'and components will perform' satisfactorily in service'is_ identified and performed in'accordance with-written test' procedures which incorporate the require-mentsfand acceptance limits contained in applicable design documents.
Certain design; requirements and acceptance limits for the safety-related instrument-air system and automatic depressurization. system are' prescribed in the following design documents:
Final Safety Analysis Report (FSAR) Section 6.8.1, Safety Evaluation Report (SER), Supplement No. 2, Section 6.3.1.3, and the Licensing Review Group-II (LRG-II) position paper, Section 8-RSB,-adopted by the applicant in'a letter to.the NRC dated September-16, 1982, document a design requirement that_the safety-related instrument air system provide sufficient capacity in air receiver tanks to insure that seven days of system leakage can be accomodated without compromising automatic depressurization system operability.
SER, Supplement-No. 2, Section 6.3.1.3, and LRG-II position paper, Section 8-RSB, document a design requirement that_the automatic depressurization' system provide sufficient capacity _in.the accumulator for each valve to support two valve actuations-at seventy percent of design _drywell pressure which is equivalent to five valve actuations at atmospheric drywell' pressure.
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.R:sponse to Enforcement Item April 11, 1985 Page 2 Contrary to the above, approved. test procedures No.
1P57-P-001, " Safety-Related Instrument Air System", and 1B21B-P-001, " ADS /SRV Preoperational Test", did not demonstrate by test.the design capacities of the air receiver tanks or valve accumulators.
Safety-related instrument air system leakage was not required to be determined and automatic depressurization system valves were only. cycled two times at atmospheric drywell pressure.
B.
Response
l 1..
Corrective Action Taken and Results Achieved Concerning the finding that safety-related instrument air leakage testing did not adequately demonstrate design requirements, Test Procedure 1P57-P-001, " Safety-related Instrument Air System" will be revised to address testing to I
assure the system provides sufficient capacity in air-receiver tanks such that seven days of system leakage can be accommodated without compromising automatic depressurization system operability.
This revision is anticipated to be completed May 15, 1985.
.(Item No. 440/85-002-01).
Concerning the finding that Test Procedure 1B21B-P-001 l
" ADS /SRV Preoperational Test" did not test the design capacities of the valve accumulators, the procedure will be revised to provide demonstration of the accumulator ability to support five valve actuations at atmospheric drywell pressure.
This revision is anticipated to.be completed by i
(
April 30, 1985.
(Item No. 440/85-002-04).
l-This additional testing will assure that the safety-related i
instrument air and the automatic depressurization systems function'as designed.
I 2.
Corrective-Action Taken to Avoid Further Noncomoliance E
A Management Procedure Review Team has been formed to assure maximum confidence in procedure adequacy.
The scope of the team assignment will be to fully evaluate concerns, review those procedures for adequacy in which near term testing is about to commence, evaluate recently performed preops comparingLprocedure reviews with impact on results and help develop any required corrective action.
3.
Date When Full Compliance Will Be Achieved Full compliance is expected to be achieved by May 31, 1985.
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