ML20212A837

Forwards Insp Rept 50-440/99-13 on 990712-30 & Notice of Violation.Insp Included Evaluation of Engineering Support, Design Change & Modification Activities,Internal Assessment Activities & Corrective Actions

ML20212A837
Person / Time
Site:	Perry
Issue date:	09/13/1999
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jeffery Wood CENTERIOR ENERGY
Shared Package
ML20212A842	List: IR 05000440/1999013 ML20212A837 ML20212A853
References
50-440-99-13, EA-99-222, NUDOCS 9909170142
Download: ML20212A837 (4)

See also: IR 05000440/1999013

Text

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September 13,1999

EA 99-222

Mr. John K. Wood

Vice President - Nuclear

FirstEnergy Nuclear Operating Company

P. O. Box 97, A200

Perry, OH 44081

SUBJECT: PERRY ENGINEERING AND CORRECTIVE ACTIONS INSPECTION

REPORT 50-440/99013(DRS) AND NOTICE OF VIOLATION

Dear Mr. Wood:

On July 30,1999, the NRC completed an engineering and corrective actions team inspection at

your Perry Nuclear Power Plant facility. The enclosed report presents the results of that

inspection.

The inspection included an evaluation of engineering support, design change and modification

activities (including 10 CFR Part 50.59 safety evaluations and applicability reviews), internal

assessment activities, and corrective actions. Within these areas, we selectively observed

activities in progress, reviewed procedures and representative records, observed plant

conditions, and discussed activities and concerns with members of your staff. 3

Your engineering organization was effectively performing routine and reactive site activities,

including the identification and resolution of technicalissues. Design change and modification

packages, for the most part, were well-planned, comprehensive, and technically correct. i

However, specific examples where inattention-to-detail, lack of documentation to support I'

engineering conclusions, and deficient technical depth were observed. Modification packages

that contained risk and core damage assessment analyses demonstrated a sound safety focus. ,

Safety evaluations performed in accordance with 10 CFR Part 50.59 were thorough and I

showed improvement from previous assessments periods. Operability determinations were

usually detailed and well documented, except for a few examples where inattention-to-detail

and deficient technical depth were observed.

The corrective action program (CAP) was effective in identifying, resolving, and preventing the

recurrence of issues that could degrade the quality of plant operations or safety. The CAP was

implemented with a low threshold for problem identification, the CR backlog was appropriately

prioritized, and the use of CR trending to detect repetitive problems was well established.

However, the use of non-CAP tracking databases (e.g., ACTON) to manage organization work

activities resulted in some conditions adverse to quality being entered into these databases

without proper and timely corrective action resolution. Operating experience program material

was appropriately incorporated into plant activities. Inter-departmental cornmunications were

successfulin promoting active staff participation in the CAP. Quality assurance audits and

9909170142 990913

PDR ADOCK 05000440

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. engineering self-assessment activities were thorough and identified performance based

concerns.-

Based on the results of this inspection, the NRC has determined that a violation of NRC

requirements occurred. The violation is cited in the enclosed Notice of Violation (Notice) and

the circumstances surrounding it are described in detail in the subject inspection report. The

violation is of concem because the technical specification (TS) surveillance requirements for

Emergency Core Cooling System (ECCS) pump performance are significantly non-conservative

with respect to the Updated Safety Analysis Report (USAR). The deficient TS surveillance

requirements were initially identified by your staff in a March 1998 CR. In January 1999, the l

corrective actions were documented as complete based on preparation of a TS change request

and supporting calculations, but the corrective actions did not include informing the NRC or

your Operations staff that the TS surveillance requirements were inadequate. After 17 months

from initial identification, you still have not submitted the required TS change request to the

NRC. This violation is being cited in accordance with Appendix C'of the Enforcement Policy

because you failed to restore compliance by correcting the deficient TS surveillance j

requirements within a reasonable time frame after the deficient condition was identified.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements. .

The NRC also determined that three additional violations of NRC requirements occurred.

These violations are being treated as Non-Cited Violations (NCVs), consistent with Appendix C

of the Enforcement Policy. These NCVs are described in the subject inspection report. If you

contest the violation or severity level of these NCVs, you should provide a responee within

30 days of the date of this inspection report, with the basis for your denial, to the Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with a

copy to the Regional Administrator, Region Ill, and the Director, Office of Enforcement, United

States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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in accordance with 10 CFR Part 2.790 of the NRC's " Rules of Practice," a copy of this letter, its

enclosure, and your response will be placed in the NRC Public Doct: ment Room.

Sincerely,

Original /s/ Jc:n A. Grobe

John A. Grobe, Director

Division of Reactor Safety

Docket No. 50-440

License No. NPF-58

Enclosure: Inspection Report 50-440/99013(DRS)

cc w/ encl: H. Hegrat, Manager, Regulatory Affairs

R. Schrauder, Director, Nuclear

Engineering Department

W. Kanda, General Manager

Nuclear Power Plant Department

N. Bonner, Director, Nuclear

Maintenance Department

H. Bergendahl, Director

Nuclear Services Department

' State Liaison Officer, State of Ohio

R. Owen, Ohio Department of Health

C. Glazer, State of Ohio Public

utilities Commission

See Attached Distribution

DOCUMENT NAME: G:\DRS\PER99013.WPD

To receive a copy of this document, indicate in the box:"C" = Copy without enclosure *E"= Copy with enclosure"N"= No cog _ /

OFFICE RilM E RlilAA tv Rlli M p 6 g

NAME GHYudan/sd RGardner TKozak-/RSReynolde BClaytonge JGrptie

DATE 09/9 /99 09/p/99 09/f/99- 09/11/99 09/df/99 g/ /99

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OFFICIAL RECORD COPY

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Distribution:

R. Borchardt, OE w/enci

D. Dambly, OGC w/ encl' l

V. Ordaz, NRR w/enci I

RPC (E-Mail)

Project Mgr., NRR w/enci ,

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J. Caldwell, Rlli w/enci

B. Clayton, Rill w/ enc!

SRI Perry w/ encl

DRP w/enci

DRS w/enci

Rlll PRR w/ encl

PUBLIC IE-01 w/enci

. Docket File w/enci

OE:EA File w/enci

GREENS

LEO (E-Mail) 1

DOCDESK (E-Mail)

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