ML20215C640

Notice of Violation from Insp on 860623-0821

ML20215C640
Person / Time
Site:	Perry
Issue date:	10/03/1986
From:	Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215C617	List: IR 05000440/1986020 ML20215C613 ML20215C640
References
50-440-86-20, NUDOCS 8610100381
Download: ML20215C640 (2)

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. Appendix Notice of Violation The Cleveland Electric Illuminating Docket No. 50-440 Company License No. NPF-45 As a result of the inspection conducted on June 23 through August 21, 1986, in response to the charcoal adsorber bed combustion events and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985) the following violations were identified.

1. 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 0QA 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) identifics 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 l instructions or procedures used to control testing activities of the Off-Gas System components were inappropriate, inadequate or incorrect as follows:

a. Attachment 1 of the data sheet for Generic Procedure GEN-M-021 (which delineates the testing) did not adequately prescribe the heating of the charcoal adsorber 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 in violation of the vendor's installation instructions. (See sub paragraph 4.b)

b. This procedure (Attachment 1 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 subparagraph 4.e.(1))

This is a Severity Level IV violation (Supplement I).

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2. The Perry Nuclear Power Plant Facility Operating License No. NPF-45, Section 2.C.(b) states in summary a commitment to the provisions of 10 CFR 50, Appendix R, III.K. as documented in the Final Safety Analysis Report Section 9A.6 and as approved in Supplement No. I to the Safety Evaluation Report dated August 1982.

10 CFR 50, Appendix R, III.K. entitled " Administrative Controls" requires establishment of administrative controls to minimize fire hazards in areas containing structures, systems, and components important to 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 electrical space heaters to elevate system temperature during the test, the adsorber charcoal beds were ignited. (See paragraph 5.b.)

This is a Severity Level IV violation (Supplement I.D.2).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending your response time for good cause shown.,

Dated: /6 9 F b Carl J. aper ello, Director

/~' Division of Reactor Safety J

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