IR 05000440/2013007

Revised Non-Cited Violation 05000440/2013007-01 in NRC PI&R Inspection Report 05000440/2013007

ML14246A151
Person / Time
Site:	Perry
Issue date:	09/03/2014
From:	Boland A T Division Reactor Projects III
To:	Harkness E FirstEnergy Nuclear Operating Co
References
EA-14-143 IR-13-007
Download: ML14246A151 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 September 3, 2014

EA-14-143

Mr. Ernest Harkness Site Vice-President FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant P. O. Box 97, 10 Center Road, A-PY-290 Perry, OH 44081-0097

SUBJECT: PERRY NUCLEAR POWER PLANT - REVISED NON-CITED VIOLATION 05000440/2013007-01 IN NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000440/2013007

Dear Mr. Harkness:

On January 3, 2014, the U.S. Nuclear Regulatory Commission (NRC) issued the subject inspection report following completion of a baseline problem identification and resolution (PI&R) team inspection. In this report, the NRC inspectors documented a finding of very low safety significance (Green) and associated non-cited violation (NCV) of Technical Specification (TS) 3.4.11, "RCS Pressure and Temperature (P/T) Limits," for the failure to comply with reactor vessel pressure/minimum temperature limits (NCV 05000440/2013007-01). Specifically, from June 2011 through July 2013, reactor operators operated the plant with a vacuum in the reactor vessel during 5 cold startups and 1 cooldown. Vessel pressures at a vacuum, i.e., less than 0 pounds per square inch gauge, are not indicated on the graphs (the pressure/temperature limit curves) associated with TS 3.4.11. The purposes of specifying the minimum temperatures at a bounding range of vessel pressures are to prevent brittle fracture (nonductile) failure of the vessel and to maintain adequate shutdown margin to criticality. As discussed in the inspection report, the NRC concluded, at the time, that the operation of the reactor in those 6 instances represented a violation of the TS. However, after further review, the NRC has concluded that a violation of TS 3.4.11 did not occur. The intent of the curves was to show the minimum temperatures which must be maintained at the pressures shown on the curves. These pressures range from 0 to 1400 pounds per square inch gauge. Because pressures less than 0 pounds per square inch gauge, i.e., a vacuum, are not shown, operation of the reactor in a vacuum on the 6 instances discussed in the inspection report did not represent a violation of the TS. However, those instances did represent operation outside of the parameters used in the analysis by your vendor (General Electric) to generate the pressure/temperature limit curves. This analysis is incorporated into the Facility Operating License No. NPF-58 by Amendment 127 issued by the NRC to Perry on April 29, 2003, and the curves are incorporated into TS 3.4.11. The analysis assumed reactor pressure of 0 pounds per square inch gauge or greater for startups, cooldowns, and power operation. Although we have now concluded that a violation of TS 3.4.11 did not occur during the 5 reactor cold startups and 1 cooldown discussed in the inspection report, we have concluded that the operation of the reactor outside of the parameters of the analysis involved a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings." Criterion V requires, in part, that activities affecting quality be prescribed by procedures appropriate to the circumstances. Startup and cooldown of the reactor are activities affecting quality and the instructions and procedures used by the operators for these activities, IOI-1, "Cold Startup"; IOI-4, "Shutdown"; and Surveillance Instruction (SVI-)B21-T1176, "RCS Heatup and Cooldown Surveillance," were not appropriate to the circumstances. Specifically, they allowed reactor vessel pressure during the 5 cold startups and 1 cooldown from June 2011 through July 2013 to be less than 0 pounds per square inch gauge, outside of the pressure parameter inputs to the analysis that is the basis for the pressure/temperature limit curves of TS 3.4.11.

As part of the corrective action for the original TS NCV (in your corrective action program as

Condition Report 2013-18689), you submitted a license amendment request, dated June 23, 2014, to revise the pressure/temperature curves to show pressures less than 0 pounds

per square inch gauge and the associated minimum temperatures. The NRC is treating the Criterion V violation as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. The cross-cutting aspect identified in NRC Inspection Report 05000440/2013007 for the previously documented NCV of TS 3.4.11 is appropriate to the Criterion V violation, as is our previous determination of very low safety significance (Green). In our letter dated August 5, 2014, we notified you that we have accepted your License Amendment Request for review. Further correspondence on this request will be through the established process for licensee amendment requests.

If you contest the violation or significance of this revised NCV, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident

Inspector Office at Perry Nuclear Power Plant.

If you disagree with the cross-cutting aspect assigned to this finding, you should provide a response within 30 days of the date of this letter, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at Perry Nuclear Power Plant.

In accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding," of the NRC's "Rules of Practice," a copy of this letter and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Anne T. Boland, Director Division of Reactor Projects

Docket No. 50-440 License No. NPF-58

cc w/encl: Distribution via LISTSERV Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Anne T. Boland, Director Division of Reactor Projects

Docket No. 50-440 License No. NPF-58

cc w/encl: Distribution via LISTSERV DISTRIBUTION w/encl

John Jandovitz RidsNrrPMPerry Resource

RidsNrrDorlLpl3-2 Resource RidsNrrDirsIrib Resource Cynthia Pederson

Darrell Roberts Steven Orth

Allan Barker Carole Ariano Linda Linn DRPIII DRSIII Patricia Buckley

Carmen Olteanu ROPassessment.Resource@nrc.gov

DOCUMENT NAME: Perry IR 2013007 Letter Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII RIII RIII NRR OE NAME MKunowski:rj SOrth ABoland DDorman 1 PHolahan 2 DATE 08/19/14 08/19/14 08/19/14 08/26/14 08/27/14 OFFICIAL RECORD COPY

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1 NRR concurrene provided via email from L. Casey on August 26, 2014 2 OE concurrence provided via email from K. Hanley on August 27, 2014