ML20207F595
| ML20207F595 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/05/1986 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-0IE-0255, PY-CEI-IE-255, NUDOCS 8701060146 | |
| Download: ML20207F595 (4) | |
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f THE CLEVELAND ELECTR P.O. Box 5000 - CLEVELAND. OHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLDG. - 55 PUBLICSoVARE Serving The Best Location in the Nation MURRAY R. EDELMAN SR VICE PRESOE4f NUCLEAR December 5, 1986 PY-CEI/0IE-0255 L Mr. R. F. Warnick, Chief Reactor Projects Branch 1 Division of Reactor Projects, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket No. 50-440 Response to Notice of Violation 50-440/86025-01
Dear Mr. Warnick:
This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/86025 dated November 6, 1986. Your report identified areas examined by Messrs. K. A. Connaughton, G. F. O'Dwyer, J. W. McCormick-Barger, B. H. Little, and C. H. Brown during their inspection conducted from September 11 through October 16, 1986 of activities at the Perry Nuclear Power Plant.
Our response to Notice of Violation 50-441/86025-01 is attached.
Please feel free to contact me should you have any additional questions.
Very truly yours, Y
L-qs e
Murray R. Edelman Senior Vice President Nuclear Group MRE:nje Attachment ec: Jay Silberg, Esq.
Paul Leech (2)
K. Connaughton Document Control Desk (USNRC) 8701060146 861205 PDR ADOCK 05000440 t l 0
e-Attachment PY-CEI/01E-0255 L 50-440/86025-01 Restatenant of the Violation 10 H3, Appendix B,' Criterion V as implemented by CEI's Quality Assurance Plan, section 5, requires that activities affecting quality shall be prescribed by and' accomplished in accordance with instructions and' procedures.
' Contrary to the above:
a.
On July 11,.1986, technicians performing maintenance to replace an electrical termination screw failed to follow precautions and-take necessary steps' identified in the work instruction to prevent residual heat removal system outboard containment isolation valve actuation.
(see'LER 86-034) b.-
.On July 12, 1986, technicians performing residual heat removal system isolation actuation instrumentation channel functional testing failed to perform test steps in the sequence prescribed in the surveillance test instruction resulting in an inadvertent isolation of shutdown cooling.
(see LER 86-032) c.- 'On July 14,.1986, a technician performing a leak detection system instrumentation channel functional test failed to perform test steps in the sequence prescribed in the surveillance test instruction resulting in an inadvertent reactor water cleanup system isolation.
(see LER 86-035) d.
On August 5, 1986, operating personnel failed to manipulate reactor water cleanup letdown isolation bypass and test switches in the sequence prescribed by applicable operating instructions resulting in an unplanned reactor water cleanup system isolation.
(see LER 86-043)
This is a Severity-Level IV violation.
Corrective Steps Which Have Been Taken and Results Achieved a.
While replacing a stripped screw on a relay socket lead termination, a technician overlooked steps in the procedure which required installing a temporary jumper, and thus allowed the circuit to open resulting in the Residual Heat Removal (RHR) System outboard containment isolation valves autoisatically isolating.
The RHR system was restored to the shutdown cooling mode. The technician involved has been individually counseled. Additionally, Instrumentation and Control technicians and work planners have been group counseled to include precautions in work orders to prevent unnecessary safety system actuations, and to review and follow these precautions while performing work.
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- Attachment PY-CEI/01E-0255 L b.
While performing the Reactor Vessel Steam Dome Pressure and Reactor Vessel Pressure (RHR Cut-in Permissive) channel functional test, poor
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communications between two plant technicians in separate' panel locations resulted in the instructions being performed out of-sequence. A jumper lead, installed to prevent an RHR system isolation was removed prior to reconnecting a lifted wire to the isolation relay resulting in an RHR (shutdown cooling) isolation.
Shutdown cooling flow was immediately re-established. Plant technicians directly' involved with the isolation have been counseled regarding proper communication while performing plant surveillances and maintaining strict ccepliance with instruction sequences.
Additionally, all I&C technicians have been retrained regarding proper instruction compliance and communication techniques while performing plant evolutions.-
c.
In restoring the switch lineup following satisfactory performance of the channel-functional surveillance test on the Main Steam Line Tunnel temperature instrument, the "RWCU LD ISOL BYPASS" switch was returned to " NORMAL" without first placing the "RWCU LD ISOL TEST" switch to'" NORMAL." This resulted in de-energization of the isolation relay causing an RWCU system isolation to occur.
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' Control room operators quickly determined the cause of the system isolation and returned the "RWCU LD ISOL TEST" switch to normal.'
The RWCU system was restored to normal operation within 10 minutes.
The technician involved in this event has been counseled with regard to the importance of carefully reading and following instructions.
I&C technicians have all been made aware of the circumstances and
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corrective actions described in the LER associated with this event.
d.
Prior to the performance of a Reactor Water Cleanup (RWCU) system surveillance, I&C technicians requested a Control Room operator to place the "RWCU LD ISOL BYPASS" switch in the " BYPASS" pocition and then to place the "RWCU LD ISOL TEST" switch in " TEST" to check the l
l operation of an annunciator that had previously malfunctioned and had been repaired. After the annunciator check'had been completed, the l.
operator returned the switches to normal in the wrong' sequence l
resulting in an RWCU system isolation.
f Control Room operators quickly restored the RWCU system to normal.
The Control Room operator involved in this event has been counseled to be more cautious and to utilize written instructions when appropriate. Additionally, all Control Room operators have been trained regarding the function and proper operation of the "RWCU LD l.
ISOL TEST" and " BYPASS" switches.
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Attschment PY-CEI/01E-0255 L Corrective Steps to Prevent Recurrence The first three events (those involving I&C personnel) occurred over a period
.of four consecutive days. As a result, the training associated with the.first event had not been conducted prior to the second and third events occurring.
. The counseling and training provided for all three events was sufficient,
- however,.to prevent recurrence of further events, as is evidenced by the lack
- of' recurrences of procedural violations leading to LER's by I&C personnel since
_ July, 1986. Additionally, we are undertaking a multiphase project to evaluate our current work practices and training as they relate to industry practices.
1 This project will allow us to draw upon the strong points of successful plants and to learn from the experiences of troubled sites.
In addition to being useful at Perry, the results of this project will be presented at the Nuclear Power Plant Instrument Engineer's Conference (NPPIEC) of the Instrument Society of America (ISA) in 1987, and should prove useful to other utilities.
With regard to the fourth event, involving Operations personnel, training was provided to all operators regarding the proper operation of the bypass switches. A similar event, occurring on September 25, 1986 (see LER 86064),
involved restoration of a bypass switch to the normal position and was specifically related to implementation of interim corrective actions for design deficiencies with the Riley temperature switch modules. The Division 2 Leak Detection System bypass switches for RWCU, RHR and RCIC were being placed in
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bypass during the once per-shift Channel Checks as part of the interim corrective action to prevent spurious system isolations until all the Riley temperature switch modules could be replaced. These modules have now all been-replaced, however, we intend to continue using this procedure until assured 4
that the replacement modules do not give spurious trips. A Standing Instruction has been issued which cautions personnel with respect to the proper
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operation of the Riley modules. Finally, the personnel involved with this 1 ster event have all been counseled.
5 Date of Full Compliance Full compliance has been achieved.
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