PY-CEI-NRR-1713, Responds to NRC Re Violations Noted in Insp Rept 50-440/93-17.C/As:licensee Will Perform Evaluation to Analyze Historical Data for Both Annulus Exhaust Gas Treatment & CR Emergency Recirculation Sys

Responds to NRC Re Violations Noted in Insp Rept 50-440/93-17.C/As:licensee Will Perform Evaluation to Analyze Historical Data for Both Annulus Exhaust Gas Treatment & CR Emergency Recirculation Sys

ML20059B870
Person / Time
Site:	Perry
Issue date:	10/25/1993
From:	Stratman R CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1713, NUDOCS 9310290125
Download: ML20059B870 (3)

Text

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CENTERDOR.

. ENERGY >

PERRY NUCLEAR POWER PLANT Mail Address:- Robert A.Stratman PO. BOX 97 -#

VICE PRESIDENT' NUCLEAR

- 10 CENTER ROAD PEMY, OHIO 44081 PERRY, OHIO 44081 (216) 259-3737 1

October 25, 1993 PY-CEI/NRR-1713 L U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Perry Nuclear Power Plant-  !

Docket No. 50-440 Reply to Notice of Violation l

Gentlemen:

This letter provides Cleveland Electric Illuminating's response to the Notice.

of Violation contained in Inspection Report 50-440/93017 dated September 24, 1993. The report documented the results of a routine radiation program inspection conducted by Mr. M. Kunovski and Mr. R.' Paul on August 23-27, 1993.

Attachment 1 provides the specific response to Notice of Violation-50-440/93017-01 (DRSS).

If you have any questions or require. additional information, please contact 1 Kevin Donovan, Matager - Regulatory Affairs at (216) 259-3737 extension.5606.

Sincerely, f J/ f/

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Robert . Stratman .,

RAS:DVC ,

Attachment cci NRC Project Manager NRC Resident Inspector Office NRC Region III 5

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4~ PY-CEI/NRR-1713 L Attachmsnt 1 Page 1 of 2 Response to Notice of Violation 50-440/93017-01 Restatement of the Violation Technical Specification 3.7.7.1 states that at least three FHB ventilation' exhaust subsystems shall be operable when irradiated fuel is being handled in the FHB.

Technical Specification 4.7.7.1.c, in part, requires that each of the three required Fuel Handling Building (FHB) ventilation exhaust subsystems be demonstrated operable after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying that a laboratory analysis of a representative carbon sample meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

Contrary to the above, on August 9, 1993, when irradiated fuel was being handled in the FHB, two of the three required FHB ventilation exhaust subsystems were not demonstrated operable after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying that a laboratory analysis of a represe tative carbon sample met the laboratory testing criteria of Regulatory Position C.6.a of-Regulatory Guide 1.52, Revision 2, March 1978.

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

Reason for the Violation Fuel Handling Building (FHB) ventilation system exhaust trains B and A reached 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation on July 7 and July 30, 1993, respectively. In accordance with Operations Administrative Procedure (OAP-1701) " Tracking of LCOs", Potential Limiting Condition for Operation (PLCO) tracking sheets were initiated to remind personnel that fuel handling activities could not be performed prior to charcoal' samples being taken in accordance with Technical Specification 4.7.7.1.c requirements. At this time, vork orders were also initiated to extract the charcoal samples. I Personnel established FHB Integrity on August 7, 1993, not recognizing that the surveillance requirements for the FHB ventilation exhaust system had not been satisfied. Therefore, Technical Specification requirements for FHB Integrity were not satisfied on August 9, 1993 when fuel handling activities (fuel sipping) vere performed. This violated the FHB ventilation exhaust I system operability requirements of Technical Specifications 3.7.7.1 and 1 3.7.7.2.

This event was attributed to personnel error, inattention to detail. 0AP-1701 requires that PLC0 tracking sheets be maintained by the Unit Supervisor until they are cleared. Moreover, both 0AP-1701 and 0AP-0103, " Shift Relief and Turnover", require all Active and Potential LCO tracking sheets to be reviewed by the Unit and Shift Supervisors prior to shift turnover. In this event, PLC0 tracking sheets had been properly initiated, and should have prevented i

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, " f,' . PY-CEI/NRR-1713 L Attschmznt'l-Page 2 of 2 l

1 any attempt to establish FHB Integrity and to handle fuel prior to the l charcoal sample being taken. However, these tracking sheets were inadequately reviewed while attempting to establish FHB integrity on August 7, 1993.

A contributing factor to this event was that the work order to extract the charcoal sample was not performed in a timely manner. Although vork orders had been initiated in a timely manner, they had not been completed on August 7, 1993, when FHB Integrity was being established.

Corrective Action Taken and Results Achieved Following identification of this event, representative charcoal samples were >

taken for B and A trains on August 24 and August 27, 1993, respectively, and-analyzed with satisfactory results. In addition, personnel involved in this event have been counseled with respect to the importance of following procedural requirements. Further, a Daily Instruction was written requiring a higher priority work order be written following 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation to ensure prompt charcoal sample extraction.

While investigating this event, it was discovered that both the Annulus Exhaust Gas Treatment and Control Room Emergency Recirculation Systems contain identical Technical Specification Surveillance requirements. In the past, lover priority vork orders (as in this event) were also written when 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation had occurred for these systems. Accordingly, an evaluation vill be performed to analyze historical data for both the Annulus Exhaust Gas Treatment and Control Room Emergency Recirculation Systems to determine if representative charcoal samples were taken within the required Technical Specification interval.

Because this event was a technical specification violation, Licensee Event Report 93016 vas prepared and forwarded to the NRC on September 24, 1993.

Actions to Avoid Further Violations This event vill be reviewed by licensed personnel during requalification training.

Date Vhen Full Compliance Vill Be Achieved Full compliance with Technical Specifications 3.7.7.1 and 3.7.7.2 was achieved on August 10, 1993, when fuel sipping equipment was removed from the FHB area, and FHB integrity was no longer required.

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