ML20214W811

Forwards Response to Violation Noted in Insp Rept 50-440/86-23.Corrective Actions:Personnel Counseled Re Operation of Instrument Valves & Procedure IAP-0503 Revised

ML20214W811
Person / Time
Site:	Perry
Issue date:	11/14/1986
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
PY-CEI-OIE-0254, PY-CEI-OIE-254, NUDOCS 8612100406
Download: ML20214W811 (4)

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. ' /h /0 THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P.O Box 5000 - CLEVELAND. OHIO 44101 - TELEPHONE ;216) 622-9800 - lLLUMINATING BLDG - 55 PUBLIC SoUARE Serving The Best Location in the Nation MURRAY R. EDELMAN uc November 14, 1986 PY-CEI/01E-0254 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 Nos. 50-440 Response to Notice of Violation 50-440/86023-01

Dear Mr. Warnick:

This letter acknawledges receipt of the Notice of Violation contained within Inspection Report 50-440/86023 dated October 16, 1986. Your report identified areas examined by Messrs. K. A. Connaughton, P. D. Kaufman, S. Guthrie, C. H.

Brown, D. C. Koalof f and G. F. O'Dwyer during their inspection conducted f rom August 5 through September 10, 1986, at the Perry Nuclear Power Plant.

Our response to Notice of Violation 50-440/86023-01 is attached. Please feel free to contact me should you have any additional questions.

Ver truly.>fou s, F[=/ J Murray R. Ede'iman Senior Vice President Nuclear Group MRE:nje Attachment cc: Jay Silberg, Esq.

Paul Leech (2)

K. Connaughton 8612100406 861114 PDR ADOCK 05000440 0 PDR W 17 y 5 i TV,ol

s Attachcant PY-CEI/01E-0254 L 50-440/86023-01 Restatement of the Violation 10 CFR-50, Appendix B, Criterion XIV, as implemented by Section 14 of the Perry Nuclear Power Plant Quality Assurance Plan required, in part, that control of equipment be provided to maintain personnel and reactor safety and to avoid unauthorized operation of equipment and that equipment and systems in a controlled status be clearly identified, at a minimum, at all locations where the equipment may be operated.

Contrary to the above,

s. On May 22, 1986, first stage turbine pressure transmitter instrument isolation valves were placed in a controlled status without being l identified as such, and were subsequently operated in an unauthorized manner on May 29, 1986. (See LER 86-017)

b. Between June 26 and 27, 1986, differential pressure switch M15-N0061A instrument isolation valves were placed in a controlled status but were not identified as such. (See LER 86-029)

c. Turbine Bypass System pressure transmitter isolation valves were closed sometime between August 19, and September 2,1986, without authorization, and were, therefore, neither placed nor identified as being in a controlled status. (See LER 86-055)

This is a Severity Level IV violation.

Corrective Steps Which Have Been Taken and Results Achieved a) Instrumentation and Control (I&C) personnel isolated 2 of the 4 RPS turbine first stage pressure transmitters in preparation for a pressure test of the instruments' sensing line. While preparing to perform the pressure test, electrical maintenance workers, without proper drawings or authorization, incorrectly opened the instrument isolation valves to the pressure transmitters. Raising and lowering test pressure in the sensing line, caused the pressure transmitters to reach their trip setpoints resulting in RPS actuations. Investigation by control room personnel revealed that the maintenance workers performing the pressure test caused the RPS actuations.

The test was stopped, and the pressure transmitters were properly isolated by I&C personnel. Additionally, the electrical maintenance workers were trained regarding their responsibility to contact I&C personnel for instrument valve manipulations and the electrical maintenance planners were trained regarding their responsibility to ensure sufficient detail is included in work order packages.

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Attrchment PY-CEI/01E-0254 L b) The Annulus Exhaust Gas Treatment System "A" d/p switch and the "B" exhaust fan were taken out of service for routine calibration of the "A" d/p switch. During restoration of the switch to service, a defective electrical termination was found on the switch. Restoration efforts were suspended and repair of the termination proceeded over the following three shifts. When the system was restored to the " Standby" condition, the "B" exhaust fan automatically started. Investigation of the cause of the fan actuation revealed that the d/p switch isolation valves were closed, isolating the switch from the process stream. This caused the switch to sense low differential pressure, indicating low "A" system flow.

The instrument valves were returned to the "Open" position and the fan restored to the " Standby" condition. The technicians involved were counseled on the necessity of performing complete valve and electrical verifications when restoring equipment to service following completion of maintenance.

Additionally, following both this and the event discussed in Item (a),

IAP-0503 was revised to require instrument restorations to be re performed in their entirety and documented on a new Instrument Restoration Checklist when restorations are suspended for more than one shift, and to reemphasize that tags are to be hung on instrument isolation valves in accordance with existing equipment tagging procedures.

c) A reactor scram occurred due to an upscale trip on the Intermediate Range Neutron Monitors. The plant was in Operational Condition 2 (Startup),

performing initial nuclear heatup testing. A sudden increase in sensed steam pressure caused the steam bypass valves to fully open resulting in a reactor pressure decrease. Subsequent operator action to shut the valves, combined with an isolated pressure transmitter, caused the steam bypass valves to shut more rapidly than expected, resulting in a void collapse and neutron flux spike.

Following this event, the pressure transmitter isolation valves were opened and verified open. Extensive investigation of this event failed to reveal the specific activities that led to the sudden increase in sensed steam pressure. Valve lineups for 150 additional instruments were conducted to determine whether or not this was an isolated occurrence.

Only one valve, a test connection valve, was found out of its normal position. A second valve in series with this valve was found properly shut and the line was capped. No other discrepancies were identified.

Additionally, following this event, a memorandum from the Plant Manager to all project personnel was issued, which clearly specified the rules for operating instrument valves and also stated that unauthorized manipulation of instrument valves would be cause for disciplinary action.

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• *- Attachment PY-CEI/01E-0254 L Corrective Steps to Prevent Recurrence Following the first and second events described above, individuals and individual groups were counseled and/or trained, and procedure IAP-0503 was modified to help prevent recurrence of these types of events. However,

'following the third event, it was decided that a further emphasis was necessary to ensure that all personnel on site were aware of the requirement that only I&C personnel are authorized to operate instrument-related valves. A memorandum was issued by the Plant Manager to all project personnel re-emphasizing that only PPOD Instrument and Control Section personnel are authorized to operate instrument-related valves and also notifying them of the potential disciplinary action associated with failure to follow these directions. Additionally, Plant Administrative Procedure (PAP)-0205

" Operability of Plant Systems" and PAP-0905 " Work Order Process" were revised to include a note that operation of instrument-related valves be performed by I&C personnel only. All procedural changes and training / counseling sessions described above have been completed.

Date of Full Compliance Full compliance has been achieved.

In our continuing ef forts to ensure the proper positioning of instrument valves, we have performed a number of Quality Assurance surveillances of i our ongoing Special Project Plan (SPP)-1401, " Instrument Valve Line-up Verification." The results to date have been very positive, with no deficiencies in valve lineup or position identified that would affect instrument availability. In addition to these QA activities, I&C personnel have embarked upon a two-team, independent reverification of all instrument valve drawings (B-803 Series). All Technical Specification instruments have already been walked down and independently reverified. This effort will continue until all instrument loops under the scope of SPP-1401 are completed.

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