ML20214F775
| ML20214F775 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/10/1986 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20214F732 | List: |
| References | |
| PY-CEI-OIE-0253, PY-CEI-OIE-253, NUDOCS 8611250429 | |
| Download: ML20214F775 (5) | |
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e t THE CLEVELAND ELECTR P.O. BOX 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLDG.
- 55 PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN SR VCE PRESIDENT November 10, 1986 NUCMAR PY-CEI/01E-0253 L Mr. C. J. Paperiello Division of Reactor Safety, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket No. 50-440 Response to Notices of Violation 50-440/86020-01 and -02
Dear Mr. Paperiello:
This letter acknowledges receipt of the Notices of Violation contained within Inspection Report 50-440/86020 dated October 3, 1986. Your report identified areas examined by Messrs. G. F. O'Dwyer, J. A. Holmes, J. A. Grobe and C. F. Gill during their inspection conducted from June 23 through August 21, 1986, at the Perry Nuclear Power Plant.
Our response to Notices of Violation 50-440/86020-01 and -02 and the information requested in the cover letter is attached. We expended considerable time and effort discussing closcout of several of the issues identified in this inspection report with the inspection team prior to and following the telephone exit meeting. The attachments reflect the information previously discussed. This response is being submitted beyond the requested 30 days from date of the report pursuant to discussions with Mr. C. Williams of your office the week of November 3, 1986.
Please feel free to contact me should you have any additional questions.
Very truly yours,
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Murray R. Edelm P
Senior Vice President G
Nuclear Group Attachment MRE:njc cc: Jay Silberg, Esq.
P. Leech (2)
NOV13 N K. Connaughton Document Control Desk (USNRC)
Attachesnt PY-CEI/01E-0253 L 50-440/86020-01 Restatement of the Violation 10 CFR 50, Appendix B, Criterion V as implemented by the Perry Nuclear Power Plant (PNPP) Operations Quality Assurance (0QA) Plan, Section 5, Revision 3, states that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." Appendix M of the OQA plan states that Criterion V applies to the components of the Off-Gas System designated as Augmented Quality on the Perry Quality Items Classification List (Q-List). The Q-List is defined as the controlled list of all permanent plant equipment and items which provides the safety and seismic classifications assigned to each piece of equipment or item. Perry Power Plant Nuclear Design Procedure 91-0355, Revision 3, effective May 5, 1986, defines Augmented Quality as Safety Code 4.
The Perry Quality Items _ Classification List (Q-List) identifies the charcoal adsorber vessels and the thermocouples within the vessels as Safety Code 4.
Contrary to the above, the inspector identified on June 24, 1986 that the instructipns or procedures used to control testing activities of the Off-Gas System components were inappropriate, inadequate or incorrect as follows:
- a. of the data sheet for Generic Procedure GEN-M-021 (which delineates the testing) did not adequately prescribe the heating of the charcoal adscrber beds and incompletely considered the parameters being tested in that there were no documented instructions for placement of the radiant heaters and there were no precautions against placing the heaters too close to the charcoal adsorber beds
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in violation of the vendor's installation instructions.
(See sub paragraph 4 b).
b.
This procedure (Attachment I to the data sheet of GEN-M-021) was also inappropriate for the testing activity in that it did not require review and approval by the organizational element (Test Program Review Committee) that reviews normal activities in this area.
(See sub paragraph 4.e.(2)).
c.
Work Order (WO) 86-7034 which controlled the testing activity was incorrectly designated Safety Code 5 whereas the charcoal beds and the thermocouples within the bed are designated Safety Code 4 by the Q-List.
Consequently, the level of administrative review of these work instructions was not commensurate with requirements.
(See sub paragraph 4.e(l)).
This is a Severity Level IV violation.
Attachment PY-CEI/0IE-0253 L Response to Violation 86020-01 Several separate meetings and discussions were held to resolve concerns with regard to the GEN-M-021 process. The following is a summary of the activities and information discussed since the event:
a)
GEN-M-021, GEN-M-021 Data Sheet, and Attachment I to the Data Sheet were being utilized in this instance to gather data concerning the cool down capability of the off-gas vault refrigeration system. Acceptance test data collected in 1985 led our engineering personnel to question the capability of the off-gas vault refrigeration system to meet its commercial guarantee.
This data gathering effort was not part of the preoperational testing of the off-gas system. All work necessary to support data gathering was performed in accordance with PNPP Operations Manual procedures which are intended to control such activities. Thus, as is pointed out in Notice of Violation 50-440/86020-02, the lack of Operations Manual procedures (administrative controls) for space heaters was the cause of this incident.
b)
The GEN-M-021 data sheet and attachments were reviewed and approved in accordance with the requirements of GEN-M-021, Rev. 2, paragraph 4.6.
The subject paragraph specifies review and approval of non-safety related data sheets by the responsible lead test engineer, which did occur.
c)
Work Order (WO) 86-7034 was initiated to allow testing of the off-gas vault refrigeration system which is a non-safety related system designated Safety Class 5 in accordance with the PNPP Q-List.
Designating the WO as Safety Class 5 for data gathering on this system was appropriate and consistent with the PNPP Q-List. Although used as additional data sources, the charcoal beds and thermocouples within the beds were not being tested.
In addition to this work order, we reviewed all GEN-M-021 related work orders from November, 1985 to August, 1986 to verify that the correct safety class designation was specified. In all 16 cases, the correct designation was used.
Four additional work orders associated with current work in progress were reviewed and found to be correct also. Following this review, an on line terminal for direct access into the work order data base was used to verify safety classifications of many current work orders. All were found to be classified correctly. Finally a review of all work orders written from July 8, 1986 to July 28, 1986 was conducted. No safety class discrepancies were discovered. These reviews included in excess of 1000 work orders. The safety classifications on all work orders reviewed were correct.
Corrective Steps to Prevent Recurrence Results of all the reviews indicate that no further corrective action is
.necessary. Please see our response to Notice of Violation 50-440/86020-02 for actions we have taken concerning the control of space heaters at Perry.
Date of Full Compliance The actions above have been completed. This response also addresses Open Items 86020-04 and 86020-05.
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PY-CEf/01E-0253 L.
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Restatement of the Violation w,
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The Perry Nuclear Power Plant Facility Operating Li'c,ense No. IfPF-45, Section 9'
2.C.(b) states in summary a commitment to the provief.ons.of 10 CFt: 50, Appendix R,III.K.asdocumentedintheFinalSafetyAnalysis)RepErtSection9A.6andas approved in Supplement No. I to the Safety Evaluath,n, R6 port dated August 1962.
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10 CFR 50, Appendix R, III.K. entitled " Administrative Controls" requires establishment of administrative controls to sinimize fire hazards in areas
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containing structures, systems, and componentk important ti safety.
Contrary to the above, during; systems testing of the Off-Gas Subsystems, there was no administrative procedure to adequately control the use of space heaters in these areas. As a result of the improperly controlled use of electr_ical space heaters to elevste system temperature during the test, the adsorberf charcoal beds were ighited.
(See paragraph 5.b.)
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This is a Severity Level IV violation.
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,e Corrective Steps Which Have Been Taken and Results Achiev'ed 9%
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The space heaters were deenergized immediately upon determination that _
s overheating was occurring and were subsequently remo dd from the vault. We l
agree that the first combustion event could have been prevented if pr6pifr d
1 administrative controls for the space heaters had been in place prior to this evolution. Therefore, w( have modified the of[ gas + system operating /~~R -
instruction (S01-N64) to risquire an engineering e0aluation prior to usion
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external heat sotirces (space heaters) in the of f ' gas system.f Additioneily, PAP-0508 "PNPP Operating Rules and Practices" hai.bcei revised to require that both Site Safety and Fire Protection be contacted betare placing temporary p' ' j heaters (space heaters) in facilities other than offices, eie. These procedure e
changes were approved on, August 8 and August 15, 1986 respectively and were both telecopied to the NRC inspectors ort August 22 and August 25, 1986. Other -
administrative procedures have been reviewed to define changes as appspriate to prevent recurrence of this type of event.
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,o Corrective Steps to Prevent Recurrence The procedural changes described above have been made'inl order to prevent the recurrence of an uncontrolled use of space heaters on site.
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Date of Full Complia.ce
?e The actions described above have been completed.
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Cover Letter Comments Your cover letter expressed concern over our apparent " absence of an aggressive, timely and effective response to the off-normal indications c
of fire in the charcoal adsorber beds." We believe our actions were timely in that I&C personnel were dispatched quickly to investigate the initial high readings on the thermocouples and the Fire Protection Coordinator was called in on the back shift to investigate the situation. Based upon reports from the I&C technicians that the high reading thermocouples had failed due to the externally applied heat, f rom the Fire Protection Coordinator that the burning paint and tape fumes were probably the result of the space heaters in the vaults, and by the fact that the vaults began cooling down following deenergization of the space heaters, Operations personnel concluded that the situation was under control and no combustion was taking place.
An,indepth review of the thermocouple data would have revealed that other thermocouples were beginning to register higher temperatures following our
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initial 1,nvestigation. We therefore agree with you that our actions could have been more aggressive in this area and, therefore, more effective.
All operators are being trained to the lessons learned from the combined
-events.
The operators _ learned from the first event as is evidenced by our response to the second event. We believe the training conducted on the combined events satisfies the concern expressed in your cover letter
< f pertaining to the first event.
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