ML20212A837
| 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: |
| 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.
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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.
However, specific examples where inattention-to-detail, lack of documentation to support
engineering conclusions, and deficient technical depth were observed. Modification packages
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that contained risk and core damage assessment analyses demonstrated a sound safety focus.
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Safety evaluations performed in accordance with 10 CFR Part 50.59 were thorough and
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
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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
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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
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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.
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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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J. Wood
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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 _ /
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Distribution:
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RPC (E-Mail)
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B. Clayton, Rill w/ enc!
SRI Perry w/ encl
DRP w/enci
DRS w/enci
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PUBLIC IE-01 w/enci
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GREENS
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DOCDESK (E-Mail)
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