ML20006E321

Discusses Implementation of Facility Revised Inservice Testing Program,Per Generic Ltr 89-04.Improvements Listed, Including sign-off Matrix Deletion at End of Instruction & Movement of Comments Section

ML20006E321
Person / Time
Site:	Perry
Issue date:	02/09/1990
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-04, GL-89-4, PY-CEI-NRR-1132, NUDOCS 9002220646
Download: ML20006E321 (2)

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r I' .THE CLEVELAND ELECTRIC lLLUMINATING COMPANY-  ;

l, .r P.O. BOX 97 5' PERRY, OHIO 44001 5 - - TELEPHONE (216) 260-3737 E ADDRESS 10 CENTER ROAD

FROhl CLEVELAND: 479 1260 W TELEX: 241599

. ANSWERBACK: CEIPRYO

? ' Al Kaplanl Serving The Best Location in the Nation 1-PERRY NUCLEAR POWER PLANT l , VICE f*ESIDENT February 9, 1990 PY-CEI/NRR-1132 L ,

.U.S. Nuclear Regulatory Commission I Document Control Desk Washington, L. C. 20555 t

Perry Nuclear Power Plant Docket No. 50-440 Implementation of PNPP's Revised '

In-Service. Testing Program Puri.uant to GL 89-04 Gentlement The Cleveland' Electric Illuminating Company (CEI) has received and reviewed the NRC staff'o- letter _ dated January 2, -1990 granting interim approval'of the relief requests contained in CEI's In-Service Testing Program (ISTP) for. pumps and valves for the Perry Nuclear Power Plant (PNPP), Unit 1, submitted by letter PY-CEI/NRR-1063L dated October 3, 1989 in response to Generic Letter

.(GL)J89-04.

In our OctoberL3, 1989 response to GL 89-04, CEI confirmed.that PNPP's In-Service Testing Program (I.;TP) conforms to the positions-provided in GL '

89-04

aad that implementing. procedures (surveillance instructions),will be in place hy September-30, 1990. In follow-up telephone conversations with the  ;

NRC stattfzin December 1989, the NRC staff was again informed of our on going effortafto complete revision of the implementing. procedures of our updated -

g ISTP.; Consistent with the schedule provided by the NRC staff in its January 2,:1990 ISTP interim relief letter, CEI has implemented those portions of our ISTP.for which implementing procedures have currently been revised. By April .

-3, 1990 .CEl will have revised the remainder of all quarterly and the remainder l -of.all cold shutdown ISTP surveilla'nce instructions re dring revision to meet 4 the. recommendations of GL 89-04. The balance of PNPP's ISTP implementing procedur.ue requiring revision to meet the recommendatious of C, 89-04 relate to work scheduled for performance no earlier than PNFP's second refueling I ' outage. .Fevision of these procedures will be completed on or about September 3,1990, and in any event, prioc to the next scheduled performance of the work -

in. question.

Revision of PNPP's ISTP implementing procedures for incorporation of the GL 89-04 recommendations would'not alone have demanded a schedule of the duration provided above. He=ever, CEI's current revision of ISTP surveillance

.instructione in the majority of cases also entails a complete revision of the instruction to incorporate format and human factor changes which CEI committed

-to in response to the NRC's February 1989 Diagnostic Evaluation Team findings.

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LU$NRC. Fsbrutry 9, 1990 PY-CEI/NRR-1132 L n

l The' improvements being incorporated include * '

o Incorporation of sign-off steps within the instruction prerequisites and test'section - deletion of separate sign-off matrix at end of p instruction.

o Where minimum component manipulation is required, incorporation of independent verification steps within the instruction during actual restoration.

o Step sign-offh to signify completion of specific test requirements and identification of test results - SAT or UNSAT.

o Specific identification of method used for verification of acceptable valve disc movement, e.g. stem, disk . pressure, local 3 indicator, etc.

o Addition of requirements for identification of all remote indicating lights being verified with their panel numbers and location when e performing position indication testing (PIT).

o Movement of the." Comments" and " Performed By" sections behind the

" Acceptance Criteria" section. '

o Addition of sign-offs to Acceptance Criteria.

The CL 89-04 recommendations and the above format and human factors improvements are being incorporated into PNPP's ISTP implementing procedures during.one revision cycle in order to minimize the overall number of procedure revisions required and thereby to minimize the potential for errors, cost,'and length of time that procedures are in the review cycle. CEI anticipates a significant enhancement in the quality of PNPP's In-Service Test Program as a result ofLthis effort. CEI also anticipates the earliest possible implementation of PNPP's revised ISTP by this approach. ,

In its January.2. 1990 ISTP interim' relief letter, the NRC staff granted conditional interim relief with respect to pump relief requests PR-4 .PR-7, PR-8 and PR-ll with an added provision that by the end of the next refueling outage, the licensee is expected'to have taken the necessary actions to meet the code acceptance criteria. CEI is ctrrently reviewing available options

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including the implementation of. temporary test instrumentation that would permit.taking the required data with greater accuracy, if such instrumentation can be procured. Alternatively, CEI is not ruling out deleting water-leg pumps from the In-Service Test' Program, where feasible. A decision will.be made by: September 1990. At this time however, CEI does not plan to implement any permanent design changes in this area during PNPP's second refueling outage. Further correspondence:on this issue will need to address the post-second-refuel outage status of these relief requests.

If you have any questions, please feel free to call.

Ver trul ours, Al Kaplan Vice President Nuclear Croup AK/njc cc: T. Colburn P. Hiland NRC Region III