ML20134H841

Discusses Insp Rept 50-440/96-08 on 960826-0911 & Forwards NOV

ML20134H841
Person / Time
Site:	Perry
Issue date:	11/06/1996
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Myers L CENTERIOR ENERGY
Shared Package
ML20134H844	List: ML20134H841 ML20134J151
References
EA-96-367, NUDOCS 9611150017
Download: ML20134H841 (5)

See also: IR 05000440/1996008

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November 6, 1996

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EA 96-367

Mr. Lew W. Myers

Vice President - Nuclear

Centerior Service Company

P. O. Box 97, A200

Perry, OH 44081

SUBJECT: NOTICE OF VIOLATION

(NRC SPECIAL INSPECTION REPORT NO. 50-440/96008(DRS))

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Dear Mr. Myers:

This refers to the insped wn conducted on August 26 through September 11,

1996, at the Perry Nuclear Power Plant. The inspection included a review of

the circumstances surrounding the loss of both trains of the Emergency Closed

Cooling (ECC) system in 1993, and the loss of both trains of Control Room

Unergency Recirculation due to low ECC temperature in 1994. The report

documenting the inspection was sent by letter dated September 17, 1996, and a

predecisional enforcement conference was conducted on October 11, 1996. These

events were reported to the NRC in Licensee Event Reports dated January 24 and

October 28, 1994.

Based on the information developed during the inspection and the information l

that was provided during the conference, the NRC has determined that

violations of NRC requirements occurred. The violations are cited in the

enclosed Notice of Violation (Notice) and the circumstances surrounding the

violations are described in detail in the subject inspection report.

In July 1993, during performance of a heat exchanger performance test on ECC

Train A, the surge tank overflowed. Subsequent review determined that

ECC/ Nuclear Closed Cooling butterfly isolation motor-operated valve (MOV)

OP42-F295A was leaking in excess of 250 gallons per minute (gpm) because the

valve was stroking past its full closed position as a result of mispositioned

limit switches and mechanical stops. The limit switches and mechanical stops

were subsequently re-adjusted and the valve was satisfactorily tested.

The valve limit switches and mechanical stops had been previously adjusted on

March 19, 1993; therefore, the valve was unable to perform its isolation

function from March 19 to July 2,1993. ECC Train A was inoperable because in

the event of a loss of offsite power / loss of coolant accident (LOOP /LOCA) with

a single active failure of the Division 2 emergency diesel generator, it would

have lost inventory at a rate such that, within one minute of receipt of the

surge tank low level alarm, the Train A pump would begin to cavitate. The

plant was in Operational Conditions 1, 2, or 3 from June 2 to July 2,1993.

Additionally, during this period both trains of ECC were inoperable for

approximately 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> while the Division 2 emergency diesel generator was out

of service.

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9611150017 961106

PDR ADOCK 05000440

e PDR

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L. W. Myers 2 November 6, 1996

The root causes of the event were personnel error and weak procedural

direction for setting M0V limit switches and mechanical stops in 1993 and the

failure to classify valves OP42-F295A/B as ASME Section XI Category A valves

for which seat leakage is limited to a specific maximum amount.

The violations in Section I of the Notice represent a significant failure to

comply with the action statement for a Technical Specification Limiting

Condition for Operation and are classified in the aggregate in accordance with

the " General Statement of Policy and Procedure for NRC Enforcement Actions"

(Enforcement Policy), NUREG-1600, as a Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount

of $50,000 is considered for a Leverity Level III problem. Because your

facility has been the subject of escalated enforcement actions within the

previous two years' prior to your identification of the violations in

December 1993, the NRC consMered whether credit was warranted for

Identification and Corrective Action in accordance with the civil penalty

assessment process in Section VI.B.2 of the Enforcement Policy. Credit was

warranted for your architect / engineer's identification that both trains of ECC

had been inoperable in December 1993.

Credit was warranted for your corrective actions for the violations in

Section I of the Notice. These included re-adjusting the limit switches and

mechanical stops on valve OP42-F295A and conducting post-maintenance testing

to verify the valve would function as required; initiating an engineering

evaluation to determine if the potential for an incorrectly set butterfly

valve limit switch or mechanical stop on other systems could cause a similar

problem; revising the Limitorque Limit / Torque Switch adjustment procedure to

require a post-maintenance leakage test on butterfly MOVs which have an

established seat leakage limit and clarify instructions for setting limit

switches and checking mechanical stop nut settings; and providing training to

maintenance and system engineering personnel on this event and the necessity

of verifying proper butterfly valve closure. Although the NRC identified .

during the 1996 inspection that valves OP42-F295A/B and OP42-F325A/B were not I

properly classified as Category "A" in the in-service testing program, the 1

valves had been tested within the frequency specified for Category "A" valves

as a result of Generic Letter 89-10 and preventive maintenance activities. 1

This failure to classify the valves as Category "A" had been previously '

identified by your staff in January 1994 but no action was taken. The failure

to take corrective action for this isolated deficiency is cited in Section II

of the Notice. The in-service testing program was subsequently revised to

properly classify these valves.

Therefore, to encourage prompt identification and comprehensive correction of

violations, I have been authorized, after consultation with the Director,

Office of Enforcement, not to propose a civil penalty in this case. However,

significant violations in the future could result in a civil penalty.

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A Severity Level III violation for failure to take corrective action (identified in June 1993) was issued

on August 31,1993 (EA 93-176).

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L. W. Myers 3 Novmber 6,1996

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Section II of the Notice describes two violations involving failure to (1)

take adequate corrective actions to prevent ECC system temperature from

decreasing below 55' F, and to (2) classify certain valves as Category "A" in

the in-service testing program. Each of these violations has been catagorized

at Severity Level IV in accordance with the Enforcement Policy.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response. The NRC will

use your response, in part, to determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter, its enclosure, and your response will be placed in the NRC Public

Document Room (PDR). i

Sincerely,

/s/ W. L. Axelson (for) ,

A. Bill Beach

Regional Administrator

Docket No. 50-440

License No. NPF-58

Enclosure: Notice of Violation

cc w/ encl: J. P. Stetz, Senior Vice

President, Nuclear

L. W. Worley, Director, Nuclear

Services Department

J. D. Kloosterman, Manager,

Regulatory Affairs

W. R. Kanda, Director, Perry Nuclear

Assurance Department

N. L. Bonner, Director, Perry

Nuclear Engineering Dept.

H. Ray Caldwell, General

Superintendent Nuclear Operations

R. D. Brandt, General Manager Operations

Terry J. Lodge, Esq.

State Liaison Officer, State of Ohio

Robert E. Owen, Ohio

Department of Health

C. A. Glazer, State of Ohio, ({k

Public Utilities Commission g

DOCUMENT NAME: G:\EICS\ PERRY 2.PKG

SEE ATTACHED CONCURRENCES

\V

Ta receive a copy of his document, indimes in me box: 'C' = Copy w/o attachment / enclosure "E" = Copy with attachment / enclosure *N" = No copy

0FFICE RIII:EICS l RIII:RA0 l RIII:DRP l RIII:DRS l RIII:RA0 l

NAME Pelke/ Burgess /kjc Berson Caldwell Grant Beach

DATE 10/ /96 10/ /96 11/ /96 11/ /96 11/ /96

,

OFFICIAL RECORD COPY

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J. P. Stetz 3

Section II of the Notice describes two violations involving failure to (1)

take adequate corrective actions to prevent ECC system temperature from

decreasing below 55' F, and to (2) classify certain valves as Category "A" in

the in-service testing program. Each of these violations has been categorized

at Severity Level IV in accordance with the Enforcement Policy.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response. The NRC will .

use your response, in part, to determine whether further enforcement action is l

necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter, its enclosure, and your response will be placed in the NRC Public

Document Room (PDR).

Sincerely,

l

. A. Bill Beach

Regional Administrator

J Docket No. 50-440

License No. NPF-58

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Enclosure: Notice of Violation

J. P. Gk\y;,Genkr  % 0esihenh Le }eer&W

cc w/ encl: 1. W. F,..

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Y ke Pra iderit, L J

L. W. Worley, Director, Nuclear

Services Department

J. D. Kloosterman, Manager, l

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Regulatory Affairs

W. R. Kanda, Director, Perry Nuclear

Assurance Department

N. L. Bonner, Director, Perry

Nuclear Engineering Dept.

. H. Ray Caldwell, General

Superintendent Nuclear Operations

R. D. Brandt, General Manager Operations

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Terry J. Lodge, Esq. ,

State Liaison Officer, State of Ohio l

Robert E. Owen, Ohio

Department of Health

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C. A. Glazer, State of Ohio,

Public Utilities Commission

4

DOCUMENT NAME: G:\EICS\ PERRY 2.PKG

Ta roosive a copy of this document, indicato in the box: "C" = Copy w/o attachment / enclosure "E' = Copy with attachment / enclosure *N' = No copy

0FFICE Ril/iggICSh/l Rill:RA U )l Rill /HP l RIII:DR_S l RIII:RA9 l

NAME PelV5'Bu 3i %s/kjc Berson p u Calddlj/ Grantif @ Beach

DATE 10/h /9C 10/'] / /96 11/4 / /96 l11/ I( Y9$

"~

11/ /96

0FFICIAL RECORD COPY

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L. W. Myers 4 November 6, 1996

Distribution i

p'FUBLIC;IE-01 P

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JTaylor, EDO

JMilhoan, DEDR  ;

LChandler, OGC

, JGoldberg, 0GC

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l FMiraglia, NRR

RZimmerman, NRR ,

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l Enforcement Coordinators

i RI, RII, RIV

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JHopkins, NRR

OC/LFDCB

Resident Inspectors, Perry

JGilliland, OPA

HBell, 0IG '

GCaputo, 01

EJordan, AE0D

MSatorius, OE

OE:EA (2) (Also by E-Mail)

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Docket File

l DRP

State of Ohio '

RAO:RIII

SLO:RIII i

PAO:RIII

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