IR 05000440/1987025
| ML20247M165 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/23/1989 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8906020381 | |
| Download: ML20247M165 (1) | |
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MAY 2 31989 a
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Docket No. 50-440
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The Cleveland Electric Illuminating Company l
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ATTN: Mr. Alvin Kaplan
Vice President I
Nuclear Group i
- 10 Center Road l
Perry, OH 44081 l
I Reference:
CEI. Letter PY-CEI/NRR-1008L of May 5, 1989, Commitment Extension Request to Notice of Violation 50-440/87025-03
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Gentlemen:
This letter is in response to your request for a six month extension to October 31, 1989, for fully computerizing your Reliability Information Tracking System (RITS). We have reviewad your reasons for the request and understand them. Further, it is our. understanding that in the interim, as stated in your letter'PY-CEI/NRR-0873 dated June 20, 1988, a database of component
~-failures is being manually maintained on a stand alone computer which can
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provide trends of maintenance related problems.
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Based on our review, your request is granted.
Sincerely,
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, pat;WA, S!GNED BY HUBERI 3 hELU Hubert J. Miller, Director Division of Reactor Safety cc:
F. R.. Stead, Director, Nuclear Support Department M. D. Lyster, General Manager, Perry Plant Operations Department R. A. Newkirk, Manager, Licensing and Compliance Section S. S. Kensicki, Director, Perry
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Plant Technical Department I
cc w/1tr dtd 05/05/89:
DCD/DCB (RIDS)
' Licensing Fee Management Branch T. Colburn, NRR Resident Inspector, RIII g 60 M h $905235%y0 Harold W. Kohn, Ohio EPA
- Terry J. Lodge, Esq.
James W. Harris, State of Ohio o
Roger Suppes, Ohio Department of Health State of Ohio, Public Utilities Commissicn
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g g Jabl nski/jk Ring Cooper 1 ler 05/ /89 05/ @ '89 05/s3/89 05@/89 SW E
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THE. CLEVELAND ELECTRIC ILLUMINATING COMPANY
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P.O. sox 97
PERRY, oHlo 44001 5 TELEPHONE (216) 259 3737
ADoRESS 10 CENTER ROAD -
FROM CLEVELAND: 241 1650 Serving The Best Location in the Nation PERRY NUCLEAR POWER PLANT Al Kaplan WCE PRE $aDDet NUOLEAA GAOUP
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May 5, 1989
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PY-CEI/NR,R-1008 L fl.S. Nuclear Regulatory Commission
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Document Control Desk Washington, D.C.
20555
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Perry Nuclear Power Plant Docket No. 50-440
Commitment Extension Request l
to Notice of Violation i
50-440/87025-03 l
Gentlemen:
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This letter requests a six month extension to the original commitment date of April 30, 1989 stated in'our initial response to Notice of Violation 50/440/
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87025-03 submitted April 29, 1988 (PY-CEI/NRR-0845 L).
Supplemental
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information to our original response letter was submitted June 20, 1988 (PY-CEI/NRR-0873 L) for completeness.
Presently the Reliability Information Tracking System (RITS) is being implemented manually and will be fully computerized by October 31, 1989. The objective of this program is to analyze component failures and cased on the results, recommend corrective action to pravt:nt recurrence.
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Installation of the newly developed P.ITS program will be delayed to avoid any interruption of on-line computer systems needed to support the first refueling outage and minimize the risk of possible interfacing problems not previously j
identified. The RITS program interfaces with three major existing programs:
l Perry Plant Maintenance Information System (PPMIS), Perry Equipment Masterfile System (PEMS) and Perry Materials Management System (PMMS). Maintaining functional operability of these comput1r systems is important to the refueling outage tracking activities. We therefore, respectfully request en extension
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l from April 29, 1989 to October 31, 1989 to allow time for post-outage activity update completion, production installation and training time for the new computerized RITS program.
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Document: Control Desk'.
-2-May 5, 1989 PY-CEI/NRR-1008 L
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'We have included copies of the original response (Attachment 1) and
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If there are any further questions, please feel' free to call.
-Very truly,yours, Al Kaplan Vice President-
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Nuclear Group-
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AK:nje Attachments cc:
-T. Colburn Senior Resident Inspector H. Miller, USNRC Region III J
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ATTACHMENT I
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Fl:.E CCP7 IN RED
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BOX 97 a PERRY. CHIO 44081 a TELEPHONE (216) 2$9 3737 a ADDRESS 1o CENTER ROAD
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Serving The Best Location in the Nation
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PERRY NUCLEAR POWER PLANT
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Al Kaplan
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- wcs passent uvea u aaov, April 29,1983 PY-CEI/NRR-0045 L
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U.S. Nuclear Regulatory Commission Document Control Desk
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Washington, D. C.
20555
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Perry Nuclear Power Plant Docket No. 50-440 Response to Notice of Violation 50-440/37325-03
Dear Gentlemen:
This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/87025 dated March 31, 1988. The report identified areas examined. by Mr. W. Kropp and others during their inspection conducted f rom January 11, 1988 through February 9,1988 of activities at the Perry Nuclear Power Plant, Uni t 1.
Our response to Notice f Violation 50-440/87025-03 is attached. Please call should you have any additional questions.
Very truly yours,
'N Al Kaplan Vice President U
Nuclear Group AK cab Atcachment c c:
T. Colburn K. Connaughton H. Miller - USNRC, Region III
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PY-CEI/NRR-0845 L
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V0 87-9361'vas performed.to troubleshoot and repair a leak from a d
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snubber located abov'e an RER pressure transmitter lE12-N00!'.-
The WO Closing and: Summary Sheet initially stated-in..the i w fiate
failure cause summary,'" steam. leak at snubber". This was deemed-insufficient and was revised to;" Instrumentation tubing connection q
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leaking., Loose: connec tion * since ' the. problem was. identified as a
. loose' tubing. connection.. This change'has been incorporated into.
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the PPMIS history.' file for'this V0.
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VO 87 94981was performed to. troubleshoot.a Division II Diesel e.:
Generator failure.to start during'the performance of iSVI-R43-T1318. The VO Closing and Summary sheet initially stated-
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in the immediate failure cause summary, " Diesel Div. II did not-
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see pneumatic start". This was deemed insufficient and was
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- i revised to "Not identified.- Suspect solenoid start valves 1R43-F0037B and F0030B" since the'troublesho'oting failed.to'
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pinpoint the.:ause.' This change has been incorporated'into the,
PPMIS history file for this WO.
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f.. VO 87-9677 was performed to troubleshoot't and repair incorrect-level indication for a RHR heat exchanger. The VO Closing and Summary Sheet initially stated in the immediate failure cause summary, "RHR HK A level indication.is low".
This vas deemed insufficient and vas revised to " Level transmitter lE12-N0008A out-of calibration" since the calibration problem is the cause which would be utilized in. Failure Analysis trending. This change has been incorporated into the PPMIS history file for this V0.
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g. - VO 87-l'0'213 was performed to repair bad connectors for two LPRMs reading downscale. The VO Closing and Summary Sheet states in the immediate failure cause summary, " Bad connectors". This was deemed adequate since the problem was downscale LPRMs and the immediate cause was bad connectors. Identification of the cause of bad connectors would be part of the root cause evaluation'as part of th' Failure Analysis program and is thus outside the scope e
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or requirements of PAP-0905.
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V0 87-2249, 87-8746, 87-9361, 87-9677, 87-10390: Incorrect or y
incomplete V0 closing codes.
The ineffectiveness of VO closing codes was identified by CEI during the INPO Maintenance Self Assessment which was completed in November of 1987. These codes were initially designed to aid in failure analysis. However, due to recommendations provided from the Failure Analysis committee and the ongoing development of the Reliability Information Tracking System (RITS), the decision was made to eliminate many of these PPMIS closing codes from the PAP-0905 work order process. The failure analysis program needs vill be better supplied through a centralized evaluation of the existing VO closing summaries.
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Attcchrant PY-CEI/NRR-0845 L Page 7 of 9
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VO 87-4825, 87-8298, 87-8597, 87-9677: Incorrect or incomplete Master
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Part List (HPL) numbers.
The concern over MPL numbers chosen during VO initia' ion was identified by CEI during a OA audit report PIO 87-12, " Effectiveness of Corrective Action", issued July 29, 1987. PAP-0905 states that Vos should, when practical, address only one MPL number, and that single MPL numbers need not be addressed on Vos written to fill and vent instrumentation, for troubleshooting, or on standing V0s.
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VO 87-4825 was written to determine the cause of a Reuter-Stokes indexer failure. The MPL number utilized to open this VO was
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"N/A" since the indexer was not installed in the plant and thus
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had no MPL number. This indexer was removed from the field and
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replaced with a new indexer on March 26, 1987 in accordance with VO 87-2620. The MPL number used for VO 87-2620 was 1C51-J0002C'
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and the failure cause was identified as " unknown, VO 87-4825 vritten to troubleshoot failed indexer". VO 87 4825 could not have had a MPL number assigned to a salvaged component no longer instrlled in the field. However, to ensure identification of this VO during future trending or failure analysis, the work summary specified the MPL number of the component when it was installed in I
the field and also referenced UO 87-2620 as the VO vhich originally removed the component from the field. Therefore, we believe that this VO was written properly and is not an example of a violation, b.
VO 87-8298 vas written to troubleshoot a contact failure to open on relay lE12-K42. The MPL number utilized to open this VO was the system MPL lE12. The Plant Equipment Master-file System (PEMS) which ties into PPMIS to provide equipment data based on the MPL number input, does not contain MPL numbers for relays.
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Therefore, the identification number for this relay could not have been used as the VO initiating MPL number. Bovever, to ensure
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identification of this VO during future trending or failure analysis, the work summary specified the problem as a relay
3 1E12-K42 failure to open. Therefore, we believe that this VO vas Written properly and is ict an example of a violation.
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VO 87-8597 vas written to troubleshoot a lov temperature indication for the Division I Diesel Generator lube oil. Since the problem had not yet been identified, the MPL number utilized to open this VO vas the DG lube oil system MPL 1R47.
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specific component were to be identified as the problem, the only
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vay to change the MPL number would be to void the VO and then open a new VO vith that UPL number. Nonetheless, troubleshooting failed to identify any problems. Ior future trending or failure analycis the suspected trouble components are vell documented throughout this V0.
Therefore, we believe that this VO vas written properly and is not an example of a violation.
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Attech=nt PY-CEI/NRR-0845 L Pago 8 of 9 R
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VO 87-9677 vas written to troubleshoot and repair incorrect level
indication for a RER heat exchanger. Since the problem was suspected to be the controller 1E12-R0604A, this MPL number was utilized to open this V0.
Troubleshooting identified the level'
transmitter 1E12-N0008A as being out of calibration. Again, the
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only way to change a VO initiation MPL number is to void the VO and then open a new VO vith the new MPL number. Since this is not I
required and extremely inefficient, this vill not be done.
However, to ensure identification of the VO during Nture trending or failure analysis, the corrective action ident' Aied in the Closing and Summary Sheet specifies the required recalibration of level transmitter 1E12-N0008A. Therefore, we believe that this VO vas written properly and i:: not an example of a violation.
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VO 87-9361: Inadequate closing summary on the VO Closing and Summary.
Sheet.
This VO vas performed to troubleshoot and repair a leak from e f.nubber located above an RER pressure transmitter 1E12-N0050B. The VG Closing and Summary Sheet initially stated in the closing summary, "No leakage anymore". This was deemed insufficient and was revised to "Revorked tubing fitting with reactor seal #5" since this was the actual work required to correct the problem. This change has been incorporated
into the PPMIS history file for this V0.
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The concerns identified in Audit PIO 87-12 were listed as observations because they were subjecti te and related to ef festiveness of implementation of the corrective action programs as opposed to compliarce with the procedures. The Quality Assurance procedure, NOADI-1840, requires that each deficiency be documented on an Action Request (AR).
As indicated in your report, our audit program has become more
" performance related". The audit found compliance with the program to be adequate but the deficiency noted was " performance related". The line which separates deficiencies from improved performance is not well defined and is open to interpretation Jesulting in this deficiency being l.,
documented as a recommendation rather than an AR.
As for your identified i
example, the audit organization has re-evaluated the effectiveness of the Condition Report program and no.ed an improvement in both number open and
sean time for closure of Condition Reports. This improvement was l'
partially due to actions taken as a result of the recommendations in Audit
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PIO 87-12.
Corret.p /e Action To Avoid Further Violytions l
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Tne Preventive Maintenance Deferral Evaluation / Justification Sheet as I
discussed previously vill be formally incorporated into IAP-0501 and l
PAP-0906, for Instrumentation and Control Section and Maintenance Section l
respectively, by June 30, 1988. The guidelines for performing a proper technical evaluation for rescheduling repetitive tasks vill be provided to the appropriate engineers by May 30, 1988.
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Attachment
PY-CEI/NRR-0845 L 4,
Page 9 of 9 a
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Ll. 'As discussed previously, procedure changes relative to the valve
.q lubrications were completed January.29, 1988. Training.for
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. appropriate maintenance personnel to these procedure changes has also
.been completed.
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The previously discussed revision to PMI-0030 to provide'for
' documentation of retest completion vill be complete by May 20, 1988.
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To ensure:that the intent of the requirements of PAP-0905:is adequately met, the following corrective actions'have been or vill be. implemented.-
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Training is being.provided to work supervisors and planners
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emphasizing'their VO review responsibilities and the importance of
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providing adequate ' summaries on the VO Closing' and Summary Sheet.
This effort vill be complete by May 31, 1988.
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A Reliability Information Tracking System (RITS) is being implemented
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objective of this program is to analyze component failures, and based
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on the results, recommend corrective actions to prevent recurrence.
As a result of this program, changes are being made to PAP-0905, Vork Order' Process.
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a.: A Program Change Request (PCR) has been initiated to provide a section on the VO Closing and Summary Sheet for MPL numbero 1f all affected equipment. This will ensure a greater capture yw centage
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When trending for failure analysis or planning a V0;on a
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particular component.- This PCR will be complete by
. November 30, 1988.
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PAP-0905 was revised (effective March 1, 1988) to eliminate the-need for the work groups to determine "Failu.e Category" and (;
"Cause of Failure" closing codes.- The RITS program vill utilize the summaries within the VO package to consistently determine V0
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closing codes for trending purposes when deemed necessary.
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To ensure that the interpretation between deficiency and improved b$
performance is made conservat)vely, QA' guidelines have been revised to (?'
clarify the threshold for isn.Ing ARs to include not only programmatic deficiencies or' noncompliance, but also significant deficiencies which
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affect the effective implementation of processes. Appropriate GA i
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personnel were trained to this change April 29, 1988.
Date of Full Compliance Pull. compliance vill be achieved upon full implementation of RITS by April 30, 1989.
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ATTACHMENT 2
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pO BOX 97 e PEARY. CH:0 44081 e TELEPHONE (2161 259 3737 m
Aco A E SS.10 CENTER ROAD Serving The Best Location in the Nation PERRY NUCLEAR POWER PLANT
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Al Kaplan am June 20, 1983 saucutAaonoue PY-CEI/NRA-0873 L
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U.S. thciear Regulatory Commission Document Control Desk Washington, D.C.
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Perry bciear Power Plant Docket No. 5 0-440 Followup Response to btice Of Violation 50-440/07025-03 Ge ntleme n:
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this. letter provides a followup to our response to Notice Of Violation
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50-440/07025-03 contained within our letter PY-CZI/NRR-0845L dated f
April 29,1988.
Inspection Report 50-440/37025 dated March 31, 1988 identified areas examinen by W. Kropp and others during their inspection conducted from l
January 11 through February 9,1938 at the Perry Nuclear Power Plant.
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additional information is provided as a result of discussions with Mr. S.
l Reynolds of your stail and the letter from you dated May 20, 1988 requesting l
additional inf ormation.
I We have included the original response letter for completeness as, Attachment 2 wnich addressed the identified violations of NRC requirements and provided our corrective actions to preve.c: recurrence.
While we had evaluated the ef fects of these violations and concluded that no plant safety, operability, or reliability concerns existed, the content of these evaluatiess were not i~
discussed in detail in the original response. As a result 4 ' the request for c,f.
additional inf ormation, details of these evaluations are provided within the l
supplemental information, Attachment 1.
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If there are any further questions, please feel free to call.
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Al Kaplan
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Vice President Nuclear Groap
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AL eab At tachme nts cc:
K. Connaugt ton T. Colburn H. Miller - US!RC Region III pgru n Cr n ' "
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Attachment 1 PY-CEI/NRR-0873 L Page 4 of 8
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C.
As a result of your request, a detailed review was performed within the last two veeks on a random selection of recently completed corrective
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maintenance Vos. It showed that the corrective actions to improve VO documents discussed in our original response are both appropriate and effective.
In all cases, it was determined that the VO adequately described the work which was performed, the immediate failure cause, the corrective actions taken, and identified all affected components. Thus, actions already taken ensure the recording and availability of accurate maintenance history data for effective' trending.
The many actions taken or being taken to improve the quality of maintenance history data as discussed during the maintenance inspection
are reproduced below.
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Expanded Vork Request form to prompt initiator to provide
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additional information useful in planning of the work order and in
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reproduction of plant conditions at the time of the concern. For example, the Vork Request form now requires a written summary response for the vork problem description, events / testing in
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progress, how the problem was identified, and system
status / configuration. (Effective 1/18/88)
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Computer sof tvare changes to allow the "Vork Summary" section of
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the PPMIS screen to be updated af ter work completion. This change was made because of an identified concern with the quality of i
information in the computer, based on pre-VO assumpticas of the necessary.vork. Along with the sof tvare change, PAP-0905 has been
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changed so that the work planner or vork supervisor has a " work
summary" field to fill out during package closeout cycle.
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i Training of maintenance planners on the importance of entering
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accuratt. information into PPMIS vork summaries. This was held
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since the Vos being trended continued to identify problems with the
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quality of work suararies versus actual work performed in the V0.
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A " Failure Cause" section was added to the "Vork Order Closing and
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Summary Sheet" in order to obtain improved failure descriptions.
This used to be just a 2-letter failure code which was not utilized vell.
(Effective 6/30/87)
The Vork Order Process (l'AP-0905) has also been changed to add a
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new "Vork in Progress Description Log".
This is a form used to document "as-found" conditions and to record the work performed and problems encountered. This form provides substantisily more information to the reviewer of the package, and results in better closing summaries, better information to utilize in root cause determination and better ability to identify the scope of work that was actually performed.
(Effective 12/17/87)
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Attachment 1
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PY-CEI/NRR-0873 L Page 5 of 8-I
Changes were made to the usage of the Troubleshooting Log so that
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I&C technicians.now create a new log sheet for each shif t, and
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better document.the work performed during their shift. Continuing training has emphasized the need to provide documentation of-
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actions performed to investigate and correct problems.
Recent plant systems training has been held with selected
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maintenance and I&C supervisors and planners. This is a " Systems and Integrated Operations" course, which is a substantial plant systems overview, to improve t6e planners ability to plan and reviev V0s.
Maintenan'e and I&C Training Programs continue to be implemented c
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s and improved as we work toward INPO Accreditation of this program.
Continued emphasis on the quality of information provided on the
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work order closing and summary sheet, including vork summaries. ',
This is accomplished through feedback to the work groups as the information is input into RITS.
The RITS program as briefly discussed previously is the system at Perry which utilizes the maintenance history data and provides effective trending. The following additional information regarding the function and logistics of the RITS program is provided to resolve remaining questions on maintenance trending at Perry.
The PNPP Reliability Information Tracking System (RITS) is intended to
' improve overall plant reliability and reduce maintenance costs through identification of specific and generic equipment failure trends. The system extracts information from Corrective Maintenance V0s as they are completed. Each corrective action VO is independently reviewed by a Reliability Engineer to provide reasonable assurance that failure causes have been adequately evaluated.
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Where appropriate, additional failure analysis or testing vill be y
prescribed. Then, component identification and failure analysis data is
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transferred into the RITS data base. Using the Master Parts List (MPL)
Y Numbers entered for the Vork Order, equipment data is retrieved from the Per y Equipment Masterfile System creating a unique twcord in the RITS system for each corrective maintenance action. The record contains the
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manufacturer code, model number, serial number, and in service date. It also includes a description of the failure, corrective action to repair or replace and a space for entering the root cause. Failures, corrective
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actions and root causes are coded for sorting and trending purposes. The system provides failure data by generic failures on all safety and non safety related plant components. Examples of data to be trended would include gross failures by generic component, by manufacturer, MPL number, failure mechanism, corrective action and root causes. Each record includes appropriate dates so the failure statistics such as mean time between failure and rate of failure can be computed. Periodic reports are
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analyzed to determine if their are trends or patterns of common failure characteristics which could be eliminated or corrected.
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Page 6 of 8
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.The RITS program has been utilizing maintenance history data back to k.
June 1, 1986, and has performed engineering reviews and accuracy
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verification of maintenance history data back to June 1,1987. It should l
be noted that Perry did not become_ a commercial operating plant until
November, 1987. In fact, participation in the Nuclear Plant Reliability Data System (NPRDS).vas not required until. commercial operation.
Maintenance history data before this point would tend to skew equipment failure trending due to the many early life design and installation error type equipment' failures that vould not be a problem af ter the extensive
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"preoperational and startup testing phases are complete.
Implementation of,the RITS program has already proven to be a valuable and
effective maintenance trending tool.
Several trends have been identified that resulted in the performance of failure investigations. The system is
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.being automated and expanded (approximately 50 percent complete) and is scheduled to be fully implemented by April 1989. In the interim a
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database of failures is being manually maintained on a stand alone
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computer.
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Attachment 1 l
PY-CEI/NRR-0873 L
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D.
We agree that certain observations made in audit reports should have been
'l documented as deficiencies on Action Requests (AR). To ensure that the interpretation between deficiency and improved performance is made conservatively, QA guidelines have been revised to clarify the threshold for issuing ARs to include not only programmatic deficiencies or noncompliance, but also significant deficiencies which affect the ef fective implementation of processes. Appropriate OA personnel were trained to this change.
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The objective of our audit process is to assess the effectiveness of the processes controlled by our QA Program which are Performance related.
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As noted in your. inspection report, our audit program has been in this S
mode for some time. The corrective action identified in our original
response vill preclude r,ecurrence of this deficiency and ensure our established corrective action process meets' the same guidelines as our performance based audit process. Additionally, a presentation was given to the maintenance inspection team during their visit in January discussing the numerous improvement initiatives taken as a result of the effectiveness of corrective action concerns. The project responsiveness to this concern exemplified ' that an AR is not necessary to ensure appropriate project atternon to QA identified observations or deficiencies.
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-Attachment 1
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PY-CEI/NRR-0873 L
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Page 8 of 8
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Overall Conclusion t
In your letter requesting a follovup vritten response you concluded that,
"overall, your response did not address the salient points that impact plant system performance; instead you emphasized corrective actions that pertained to correction of instructions and documentation." Ve are concerned with this conclusion as it vas not our intention to imply that we had not performed an assessment on plant system performacne..The identified violations of NRC requirements involved insufficient-instructions and/or documentation and similarly, our response focused on
corrective action to prevent recurrence through permanent procedure changes and retraining. Our evaluations during and following the i
inspection assessed the impact on plant system performance and in no case did the violations have deleterious effects on plant safety,. operability,
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or reliability. However,' ve recognize the need to document these impact
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assessments in future responses to identified concerns.
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