ML20245C188
| ML20245C188 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/22/1987 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-0IE-0264, PY-CEI-IE-264, NUDOCS 8707020037 | |
| Download: ML20245C188 (3) | |
Text
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CLEVELANo, oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDo. - $5 PUBLICSQUARE P.o. Box 5000 1
Serving The Best location in the Nation MURRAY R. EDELMAN SR. VICE PRES 10ENT NUCLEAR January 22, 1987 PY-CEI/01E-0264 L Mr. R. F. Warnick, Chief Reactor Projects Branch 1 Division of Reactor Projects, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket No. 50-440 Response to Notice of Violation 50-440/86028-02
Dear Mr. Warnick:
This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/86028 dated December 23, 1986. Your report identified areas examined by Messrs. K. A. Connaughton, G. F. O'Dwyer, and M. J. Oestmann during their inspection conducted from October 17 through December 2, 1986 of activities at the Perry Nuclear Power Plant.
Our response to Notice of Violation 50-440/86028-02 is attached. Please feel free to contact me should you have any additional questions.
Very truly yours, Murray R. Edel Senior Vice President Nuclear Group MRE:nje Attachment ec: Jay Silberg, Esq.
Paul Leech (2)
K. Connaughton Document Control Desk (USNRC) 8707020037 B70122 PDR ADOCK.05000440:
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r Attachment PY-CBI/0IE-0264 L Page 1 of 2 Response to 50-440/86028-02 Restatement of the Violation "10 CFR 50, Appendix B, Criterion V as implemented by the PNPP Quality Assurance Plan, Section 5, requires that activities that affect quality shall be prescribed by clear and complete documented procedures, instructions, and/or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these documents.
Contrary to the above, instructions provided for the installation of temporary heat tracing on safety-related leak detection system flow instrument sensing lines were inadequate in that they failed to specify the number and placement of temperature sensors required to allow control of sensing line temperature.
As a result, the instrument sensing lines were subjected to excessive i
temperatures between November 1st and November 2nd,1986." [ sic, October]
This is a Severity Level V Violation Corrective Action Taken and Results Achieved The Reactor Core Isolation Cooling (RCIC) Leak Detection System steam flow transmitter sensing line was observed exceeding the recommended temperature band during the interval from October 1 through October 9, 1986 and was de-energized for troubleshooting. A Nonconformance Report and a Condition Report were initiated on October 2, 1986, and a second Condition Report was initiated on October 10, 1986 to provide for investigation and resolution. The evaluations concluded that the controlling temperature sensors were improperly installed in that they did not provide accurate temperature indications to the controller. Metallurgical specialists determined that the affected portion of the leak detection sensing lines were acceptable "as is" for the completion of
'j the RCIC system testing. A suitable configuration for the arrangements and locations of the monitoring thermocouples was developed, including input from vendor personnel. Additionally, the electricians monitoring the heat trace were instructed to take hourly local temperature readings with a hand-held thermometer at various recommended points. No further excessive temperature problems were experienced after October 9, 1986.
1 Appropriate craft personnel received additional training on temporary heat treat installation including the proper number and placement of the temperature sensing thermocouples. Following completion of RCIC testing, the entire sensing loop was replaced during the scheduled maintenance outage of November 1986.
I I
Attachment PY-CEI/01E-0264 L Page 2 of 2 Corrective Steps to Prevent Recurrence As interim corrective action, a temporary change has been made to GWI-0005, Revision 1, " General Postweld Heat Treatment Requirements", which expands the I
" purpose" of the instruction to include all heating applications. It clarifies thermocouple installation and requires that a sketch detailing the arrangement of the heating elements and the thermocouples be developed for the use and application of this equipment. This procedural improvement is sufficient to prevent recurrence of this event in the future.
The postweld heat treating equipment supplied by Cooperheat has been used for heat treatment without incidents for many years at Perry.
Normal " heat-treat" applications require surf ace temperatures up to 1300 degrees F for which the existing postweld heat treating equipment is adequate. However, for this particular lower temperature application on the sensing lines, improper thermocouple placement and arrangement contributed to an inadequate temperature control situation. To further prevent this type of temperature control problem in the future, new heat trace / treat equipment has been procured.
For heating below 400 degrees F, new Cooperheat VT20 " heat-tracing" systems are now available onsite which have a maximum temperature rating of 400 degrees F and include solid state, full temperature range, thermostatic controllers.
For heating above 400 degrees F, a new programmable controller has been acquired to greatly improve temperature control. Also, new Type K thermocouples, which are capacitor discharge welded directly to the heated surface, have been acquired for use in temporary heating to provide more reliable and accurate temperature indications to the controller. Appropriate work planners have been made aware of the availability and appropriate applications of the new " heat-tracing" equipment. A formalized training program for the application and installation-of the VT20 heat-tracing system is presently under development.
It will be provided for the applicable planners, craft, system engineers, QC inspectors, and supervisors. To more fully address all types of heat treating / tracing at Perry, Revision 2 to GWI-0005 is in progress. The acquisition of the improved equipment, along with the associated training, will further prevent recurrence of this event.
Date of Full Compliance The temporary change to GW1-0005 is presently effective.
Full compliance has been achieved. Additionally, formal training in the use of the newly purchased Cooperheat VT20 equipment will be completed by March 31, 1987.
Information from the training program will be incorporated into Revision 2 of GWI-0005, titled " General Heat Treatment Requirements", by May 31, 1987.