PY-CEI-NRR-2371, Provides Suppl Response to Violations Noted in Insp Rept 50-440/98-18.Corrective Actions:Two Condition Rept Investigations Were Performed to Evaluate Issues Re Fire Protection Program & Addl Training Was Conducted

Provides Suppl Response to Violations Noted in Insp Rept 50-440/98-18.Corrective Actions:Two Condition Rept Investigations Were Performed to Evaluate Issues Re Fire Protection Program & Addl Training Was Conducted

ML20206A828
Person / Time
Site:	Perry
Issue date:	04/21/1999
From:	Myers L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-440-98-18, PY-CEI-NRR-2371, NUDOCS 9904290041
Download: ML20206A828 (3)

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eb j. e ya hrry Nuclear Pbwer Plant l ~

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Lew W Myers 440-280-5915 Vias President Fax:440-280-8029 April 21,1999 PY-CEl/NRR-2371L United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 Supplemental Response to a Notice of Violation Ladies and Gentlemen:

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Enclosed is a supplemental response to the Notice of Violation contained in NRC Inspection Report 50-440/98018. The initial reply was transmitted by a letter dated December 10,1998 (PY-CEl/NRR-2338L). The Notice of Violation io. ntified combustible materials that were not covered in accordance with plant procedures. The NPC letter transmitting the inspection report also requested a description of the corrective actiont ,nanned to ensure that tran permits would be generated as required.

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At the time the initial reply was submitted, corrective action investigations had not been completed and certain corrective actions had not yet been identified. The enclosure provides a

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discussion of the results of these investigations, as committed to in the initial response.

AD If you have questions or require additional information, please contact Mr. Henry L. Hegrat, Manager - Regulatory AfTairs, at (440) 280-5606.

1 Very truly yours, Y

Enclosure cc: NRC Region til Administrator NRC Resident inspector NRR Project Manager

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9904290041 990421 PDR ADOCK 05000440 G PDR. _

0 PY-CEl/NRR-2371L Enclosure Page 1 of 2 Supplemental Response to Notice of Violation contained in Inspection Report 50/440-98018 Two condition report investigations were performed to look at issues involving the fire protection program. One investigation evaluated the issue identified in the Notice of Violation, and fire protection procedures were under review at the time of the initial response. The other investigation evaluated the collective significance of several recent fire protection issues, including the use of transient combustible permits. This supplemental response provides a 1 discussion of the results of those investigations and the corrective actions identified.

The condition report investigation J.c.t ;--it? 6 huis for the Notice of Violation response included a corrective action to review fire protection program pxedures. The main cause was determined to be a weakness in continuing training for the fire protsetion program and a contributing cause was that multiple procedures implement the program. These weaknesses are being addressed by the additional training and reinforcement of expectations as discussed below.

Both corrective action program investigations identified that a main cause of the fire protection issues was a lack of employee awareness of the program requirements due to inadequate supervisory involvement. The investigations determined that increased emphasis on the requirements of the fire protection program was necessary during continuing training and monitoring performance in the field. To correct this deficiency, personnel expected to be involved in the implementation of the fire protection program received training on the procedural requirements in ilic nre protection program. This training included a review of the requirements for control of transient combustibles, i.e., combustible free zones, burn permits for ignition sources, and fire impairments. The training also included a refresher of management expectations with respect to procedural compliance. This training was conducted in advance of the current refueling outage to ensure the requirements and expectations were reinforced and clearly understood before the heavy outage work period began. I The Fire Protection Coordinator has developed a series of short training modules addressing fire protection program procedures. This training is primarily focused towards maintenance personnel and is being provided at section/ crew meetings or other convenient forums.

Eventually, it is anticipated that this training may be incorporated into maintenance continuing training.

The Director, Perry Nuclear Maintenance Department, has established expectations for pre-job briefings that include fire protection requirements. The expectations for these briefings include special emphasis on control of transient combustibles. These expectations have been expressed to maintenance department management and supervision. Additionally, the maintenance department director briefed the rest of the Perry management team on the results of a self assessment conducted to review the effectiveness of pre-job briefs within the maintenance organization.

l l One of the corrective actions being taken in response to the overall issue is to benchmark other plants to assess their fire protection program strengths and good practices that could be applied at Perry. This benchmarking is planned following the completion of the current refueling outage. The objective of this effort is to ensure that clear ownership and controls are established to prevent combustible materials from entering the plant without authorization. This is intended to ensure specific accountability for combustible materials is assigned to the activity and/or the individual responsible.

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PY-CEl/NRR-2371L Enclosure Page 2 of 2 Additional procedure reviews, unrelated to the specifics of the violation, are planned following the current refueling outage. As part of a forward-looking effort to streamline and standardize appropriate processes at FirstEnergy Nuclear Operating Company (FENOC), these reviews are intended to identify where the tire protection program procedures can be clarified, simplified, and consolidated. It is the ultimate intention that the fire protection procedures at FENOC facilities be standardized.

Fire protection program requirements have also been incorporated into an error lab that has been developed at the Perry site. The error lab is a human performance initiative. The facility has been established to practice error prevention techniques and reinforces many program requirements, such as foreign material exclusion, scaffolding construction and clearance, and radiation protection practices, as well as the fire protection program requirements. The lab includes examples of chemical storage, fire impairments of doors, and combustible free zones.

This lab is part of the initial training program for outage contract personnel. Additionally, contractor personnel have been trained on fire protection procedures, including lessons learned from previous fire protection issues.

The fire protection program requiremer ts are being reinforced through pre-job briefings, job performance review, and continuing training. The error lab, which includes reinforcement of fire protection program requirements, is being evaluated for use by company employees in addition to the contractor employees. These actions are intended to improve performance with respect to the fire protection program.

COMMITMENTS I No regulatory commitments were identified in this response. Any actions discussed in this document represent intended or plaaned actions, are described for the NRC's information, and are not considered to be regu* y commitments. Please notify the Manager - Regulatory '

Affairs at the Perry Nuclear Power Plant of any questions regarding this document or any associated regulatory commitments.

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