ML20066G403
| ML20066G403 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/14/1990 |
| From: | Lyster M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20066G381 | List: |
| References | |
| NUDOCS 9101280036 | |
| Download: ML20066G403 (19) | |
Text
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CENTERIOR ENERGY PERRY NUCLEAR POWER PLANT Mail A00<ess 10 CENTER ROAD P.O. BOX 97 Michael D, Lyster PERRY. OHIO 44081 PERRY, OHIO 44081 Vce Fre90ent Ncw (216)259 3737 December 1.4, 1990 PY-CEI/NRR-1280 L U.S. Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Perry Nuclear Power Plant Docket No. 50 440 Response to Notices of Violation 50-440/90012-01, 02. and 03 Gentlemen:
This letter acknowledges receipt of the Notices of Violation contained within Inspection Report 50-440/90012 dated November 14, 1990. The report identified areas examined by the Region III
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special maintenance team led by H. Valker during the inspection conducted en September 17 through 21, and October 1 through 5, 1990.
Our response to the Notices of Violation, and to the three additional areas which we vere requested to address in our response, are provided in Attachments 1 through 4.
If you have any questions, please feel free to call.
Sincerely,
/
Michael D. Lyster MDL:DVC Attachment cc: NRR Project Manager NRC Resident Inspector office USNRC Region III i
operanno UNs DEC 171990 i
ciewond oecinc murnineng I0 led 0 f d $on 9101280036 910110 PDR ADOCK 05000440 0
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PY-CEI/NRR-1280 L Page 1 of 4 Violation I - Failure to Provide And Implement Appropriate-Instructions For Activities Affecting Quality Restatement of Violation 10 CFR 50, Appendix B, Criterion V, as implemented by Section 5 of the Quality Assurance plan and Section 17.2.5 of the Updated Safety Analysis Report, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and tN 't these activities be accomplished per these instructions, procedures, or dravings.
Contrary to_the above:
a.
On September 18, 1990 the-air pack for MSIV 1B21F022C_vas removed from the valve by a jenior maintenance man utilizing a vork package that did not contain detailed instructions appropriate to the circumstance for_ removal by_anoindividual with this.. skill level. As a result, hold down bolts on_the.
Norgren valves vere-partially removed resulting.in partial as found" condition of the disassembly of the air pack.
The d air pack vas lost even-though the licensee had made previous commitments to maintain the "as found"' condition so NRC inspectors could vitness the testing and disassembly of the air pack (440/90012-01A).
b.
Section 6.4 of Perry Administrative. Procedure PAP-1912, Revision 3.." Burn Permits.for Ignition Sources,"1 required that the-responsible supervisor verify all required inspections, signatures, notificationsLand' compensating actions were-complete prior to signing th'e. burn permit. On: October 2, 1990, the responsible supervisor' signed a burn permit for burning, velding, and grinding on elevation 620 of the Off-Gas Building prior.-to. verifying that all required inspections and: signatures vere complete (440/90012-01B).
-This is a Severity Level IV violation (Supplement. I).
-Viola _ tion Background With regards;to the second example cited (440/90012-01B) in support of Violation (440/90012-01), the-following factors should be
. considered.
1.
Results of the event evaluation-indicated that the responsible supervisor had signed and dated the spaces provided, but left the~ space for the time of verification blank. The work l
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PY-CEI/NPS-1280 L Page 2 of 4
,,j supervisor and the lire vatch person in the field had indicated that the supervisor had signed the way he did as he vas intending to_ return before the job actually started to perform the verification and annotate the actual time of the verification. When the improperly signed permit was discovered, the' burn permit had not been activated, and the hot vork had not commenced.
Since the work had_not reached the point where the supervisor's verification was required, he did not believe that a procedural violation had occurred since.the verification-could have been performed-as required.- However, this method of verification-is not-an acceptable method of procedure compliance at Perry.
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-2.
The work group had a burn permit for the activity to be performed. Additionally, the area was being set up in accordance with the burn per:ait, a trained firevatch person was present, and activation and deactivation steps of the hot work activity-to be-performed vere progressing in accordance with procedure.
It should also be noted that the Fire and Security. Inspection Unit had performed regular field inspections on plant hot work < activities prior to this occurrence, and hsd not identified any procedural violations. During the month of. September, 1990, fifty-five Burn Permit inspections had been performed. _ These inspections.are part
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of the-regular fire / life. safety inspections that the Inspection. Unit personnel perform'each month._ The resultsJof these inspections'and inspections. performed subsequent to-this event (see belov) support-3 the conclusion that this vas an isolated case.
Corrective Actions-That Have Been Taken and-Results Achhved -
i Vith regard to Violation-(440/90012-01A),'the crews involved in the MSIV maintenance work received instruction concerning the proper removal of ' air packs f rom-the HSIVs prior-to -any further vork~ on the other-MSIV's. As a result of this instruction to-the maintenance-vork crevs,cno other_ solenoid valve hold'dovn. bolts on air. packs t
- vere loosened when the air packs wereLremoved from the other MSIVs y
cduring this outage.
With regard to Violation (440/90012-01B),.the following activities vere 1 performed..
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- 1.~
Immediately following the discovery ~in the. field of the Burn Permit being improperly signed, various members of'the Fire'and
' Security Inspection. Unit staff met with all parties involved in the improper. signing of the permit.
Included in this meeting vere the hot work. supervisor's general superintendent and-the CEI contract administrator. The improper method of signing the Burn Permit was explained to all parties at the meeting, and-they indicated that they understood what had been performed vrong, and what the correct procedural method vas.
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- i-AttachmentI1-PY-CEI/NRR-1280 1, l
Page 3 of 4
-2.
On October 3, 1990, a memorandum delineating this event was hand delivered to-the two managers who have overa!!
responsibility for all-hot vork activity'on site. Both-managers informed their respective vork supervisors of'this event, and reviewed with them the proper method for performing the hot vork activity.
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3.
On October 3.-1990, the Fire and Security Inspection Unit d
personnel performed an unannounced field inspection on the
- j particular vork group, including the work supervisor,-involved in - the-incidenti on October 2 1990. The~ inspection shoved that the work group'vas folloving all portions of tha hot work
-activity procedure correctly.
i 4.
The; Fire'and Security Inspection ~ Unit personnel increased the number.ofEffeld inspections of plant hot work activities durirg the months of October and November, when the majority of hot j
vork_ activity vas. performed-during the outage. During these-two months,.901 inspections vere performed. No major'
_ procedural or programmatic problems vere: discovered.
1 5.-
Contractor-Services Section personnel 1 completed retraining of-11 their-vork supervisors and planners, regarding the proper method-Li
.of-performing hot vork activity including. procedural:
-1 compliance.
This training vas conducted over four days in; October, 1990.-
6.
-Quality Assurance Section. issued an Action Request to
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Contractor Services,Section for failure-to follow Burn Permit-j Procedures,-.and conducted an ongoing iield surveillance of L 1
- plantEhot work activities _ during; theioutage. - JThis Quality Assurance < surveillance vas' independent'of5the field inspections
- performed :by Fire and Security-Inspection ~ Unit personnel.. A total of-forty-nine' field inspections = vere performed.frem -
October 31ithrough. November 12,11990.; All observed hot-vork _
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- activity vas.. performed in'accordance with approved procedures..
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- As a: result of_ thesefinspections',10uality Assurance: Section :has -
cecommended that the Action Request be_ closed..
4 Corrective Actions-That-Vill be' Taken to Avoid Further Violations j
Vith regard ~ to Violation =(440/90012-OlA), GHI-0096, 'HSIV
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" Disassembly,-Repair, and Reassembly Instructions, vill. be revised.to d
add more' detail regarding -the' removal of ' the HSIV air packs. This-
' activity'v111 be.-accomplished by March 1 1991.-
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Vith regard to Violation (440/90012-01B), no additional actions:are considered necessary to preclude recurrence.
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4 A t ta chrt.en t 1 PY-CEI/NRR-1280 L Page 4 of 4 Date Vhen Ful' Compliance Vill be Achieved Vith regard to Violation (440/90012-01A), full compliance was achieved on September 19, 1990, when trained personnel correctly removed the second MSIV air pack.
Vith regard to Violation (440/90012-1B), full compliance was achieved on October 12, 1990, as work vas stopped prior *o implementation of the Burn Permit.
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/ttachment 2 J Y-CEI/NRR-1280 L
" age 1 of 2 Violation II - Nonconforming and Acceptable Fuses Located in the
-Same Storage Draver Restatement of Violation 10 CFR_50, Appendix B, Criterion XV, as implemented by Section 15.3.1 of the Quality Assurance Plan and Section 17.2.15.2.e of the Updated-Safety Analysis Report, required that nonconforming material be segregated, vhere practical, to prevent inadvertent installation or use.
Contrary to the above, ten boxes of nonconforming fuses vere located in the same storage draver of a fuse cabinet in the main varehouse with several boxes of acceptable fuses of thc same type (440/90012-02).
This is r. Severity Level IV violation (Supplement I).
Reasons for the Violation Previously, the implementation of segregated storage of
' nonconforming material consisted-of the use of a combination of physical segregation and tagging. - In reviewing this event it 'has 4
been decided that Perry vill continue to utilize a combination.of physical segregation and. tagging, but vill put a greater emphasis on segregation than in the past. _This approach vill also reduce the potential for issuing nonconforming material.
-Corrective Actions That-Have Been Taken and Results Achieved The fuses in question vere physically segregated upon discovery'of i
this situation. : ~ Additionally,- all non-conforming' fuses vere removed -
from the normal storage' locations and:placed in the' Procurement-Quality Hold Area.
As'a result of this action all non-conforming
-fuses are nov' physically segregated.
i corrective Actions That Vill be Taken to ' Avoid Further Violations Following the.NRC_ inspection, all_open-nonconformance reports vere re-evaluated:and.planssare currently ^ underway te remove-r nonconforming items from the normal-varehouse storage locations to
. physically segregated areas, when it is ' practical to do so. Note --
these nonconforming items are currently 1 tagged.
A second hold area-n
-has beer.-established for-items which.must be placed on a pallet rack because they are too large to fit into a storage cabinet. When items -are too large tan be physically segregated in either of the designated storage areas, they vill be' identified with nonconformance tags..This activity vill be accomplished by February 1, 1991.
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PY-CEI/NRR-1280 L Page 2 of 2 l
Date Vhen Full Compliance Vill be Achieved Full compliance vill be achieved on February 1, 1990, when all nonconforming items are physically segregated, where practical.
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-l PY-CEI/NRR-1280 L Page 1 of 5; Violation III - Inadequate Testing of the Electric and Diesel Driven Fire Pumps
, Restatement of Violation-Facility Operating License NPF-58, Section 2.C(6) required ' that the licensee comply with all provisions of the approved fire protection program as described in the Final Safety Analysis Report and approved in the Safety Evaluation Report dated May 1982 and Supplements:Nos. 1 through:10 thereto. Final Safety Analysis Report, Section E.2(c) stated that the fire pump conformed to National Fire Protection Association (NFPA) Standard Number 20.
NFPA Standard Number 20 Section 11-3.1 required an annual test of the fire pump to determine the ability of the fire pump assembly (pump, driver and controller) to perform satisfactorily at peak.
loads. Section 11-3.3 ' required that any significant reduction in the. operating characteristics of the fire pump assembly be report.o to the-ovners and-that repairs be made immediately.
Final Safety Analysic Roport, Section E.2(e) indicated that the largest flow demand for a single pump vas 3750 gallons.per minute at 85 psi.
Contrary to the abovel
-a.-
The electric-driven fire pump and the diesel driven fire pump vere-not adequately tested in that the fire pumps vere not.
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tested at shutof f pressure during.. tests on' September. 2,1987 March.12, 1989; and September 9, 1990-(440/90012-03A),
b.
-Corrective actions were not initiated after:the electric driven fire pump tests : dated September 2,1987: March 12, 1989: and September 9,fl9900 indicated significant pressure reduction-j
-(30%, 33% and 35% respectively) inithe operating,
characteristics of theLfire pump assembly., : In addition, the-diesel-driven fire pump test results dated September 2, 1987:
7 and Septemberi, 1990, did not record the 9'
March 12, 1989 engine speed or the pun.p speed at.over capacity to determine the operating characteristics of the fire puep (440/90012-03B).
The electric' fire pump test results dated Septemter 2, 1987, c.
March 12,1989,. and -September 96 1990_, and:the diesel fire-pump.
test results dated March 12,-1989, did'not' demon 4trate that each fire ptmp could meat the demand of 3750 gallons per minute at 85.psin(4A0/90012-03c).
This is a Severity lesel IV violation (Supplement I).
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b PY-CEI/NRR-1280 L Page 2 of $
Violation Background Vith regards to the first example cited (440/90012-03A) in support of Violation (440/90012-03), the following factors should be considered.
The referenced commitment in the USAR, Appendix 9A.5 to Chapter 9, Section E.2(c) had alvays been interpreted at Perry as referencing to design and installation requirements for the Fire Protection Vater Supply Systems.
Specifically, E.2(c) of NRC Branch Technical Position APCSB 9.5-1 establishes the NRC position that " Details of the fire pump installation should as a minimum conform to NFPA 20,
" Standard for the Installation of Centrifugal Fire Pumps." The Perry response was that "The fire pump installation conforms to NFPA 20." (emphasis added)
Commitments to testing see addressed in 9A.5 section CS and 9.5.1.4.
These commitments vere not intend.d to mean verbatim /100% compliance vith the most current NFPA testing requirements; however, we f ailed to clearly state this qualification. Ve vill do this.
We also did not address in our program description in the USAR hov ve vould reviev and implement program changes when codes are revised. Ve vill review the need for such program changes in conjunction with procedure revisions and revise the USAR accordingly.
k Testing was performed in 1987,1989, a:id 1990 to Revision 2 of Periodic Test Instruction (PTI) P54-P0036 which vas prepared in 1985. The NFPA 20 code in effect at that time was the 1983 edition.
Although Section 11-2.6.2 of that edition which addresses acceptance testing states that flows be performed at minimum (no flow or churn - shutoff pressure testing), rated (=2500 gpm for PNPP pumps).,
and peak (150% of rated =3750 for PNPP pumps) loads, Section 11-3.1 for annual testing requires only a flov to determine performance at peak loads be performed. Therefore, the PTI at the time it was prepared was in compliance with the provisions of NFPA 20 in effect at the time of test preparation.
Plant Administrative Procedure (PAP-0507), Preparation. Review and Approval of Instructions, requires instructions to be reviewed every two years in.the periodic review process.
Periodic Test Instruction l
P54-P0036 vcs reviewed in accordance with this process.
As a result of this proc (ss and prior to the NRC Inspector's arrival on site, a revision was l'titiated to this PTI which includes testing at shutof f pressure.
It sSould be noted that Fire Protection Engineering personnel had pteviously (prior to mid-1990) determined not to 1
a PY-CE1/h'RR-1280 L page 3 of 5 include this testing at no flow conditions (shuto:- pressure) because it is necessary to shut off the relief valve, then reset it after the test. This was not considered advisable at the time due to :avitatic7 ptrS' ems with the relief valve.
Since there are no fi.e protection system demands that require the pump to perform at this end of the curve, it vas not considered advisable at that time to subject the relief valve to unnecessary oper tion. These problems vere corrected in July of 1990 vith the installation of orifice plates. Revision 3 of PTI P54-P0036 vas then processed to include this testing change along vith other changes that vere considered enhanceuents to this instruction.
Vith regards to thi second example cited (440/90012-03B) in support of Violation (440/90012-03), the following factors should be considered when determining vhether no corrective actions vere taken following the September 9, 1990 test.
On September 13, 1990, the Responsible System E.gineer (RSE) reviewed the test rescits. The RSE plotted the data against the pump shop curve and noticed that the results indicated poor pump performance. The RSE then contacted the on-duty Control Room Unit Supervisor to discuss the results of the test. Vith the known difference between the data obtained from previous tests using the flov meters and the data from previous tests usiSg hydrant flevs, operability of the pump vas not suspected. This decision vas based on known background information that the data obtained indicated that the flov meters were again not functioning properly and vere providing erroneous data.
Since the PTI late date vas not until January 21, 1991, it was decided that credit for completion of the PTI would not be granted, and that the PTI would be re-perf ormed utilizing the new revision (Revision 3) prior to its late date.
Note - this PTI did pass all acceptance criteria delineated in the instruction.
In hindsight, a more appropriate action at this time vould have been to declare the pump degraded, prepare a vork order or temporary test instruction, and immediately test the pump using hydrant flows.
Hovever, the combination of strong background information on the unreliability of the flov meters, the availability of P54-C007 to act as a full back-up pump, and the heavy vork load due to the start of the refueling outage two days earlier vere major f actors in the aforementioned decision.
Corrective Actions That Have Been Taken and Results Achieved Vith regards to the second and third examples cited (440/90012-03B, 440/00012-03C) in support of Violation (440/90012-03), the following corrective actions vere performed.
1.
Since the full performance of the electric fire pump vas questionable, an impairment permit was issued on October 4, 1990 and compensatory measures were established until an accurate test could be performed. An evaluation was conducted
PY-CE1/tmR-1280 L Pagt 4 of 5 to determine if either of the fire pumps could have been in a degraded or inoperable condition not recognized by the past testing.
Past vork history was revieved for both P54-C0001 (diesel driven pump) hnd OP54-C0002 (electric fire pump) and any equipment associated with these pumps vhich could have affected the performance vere evaluated. This was done to determine if a pump problem could have existed, and been unknovingly corrected.
This vould have meant that the fire pumps vere in an inoperable state for sore period of time vithout adequate compensatory measures in place. The only repairs or modifications which could have improved the pump performance involved the relief valves.
Since the flov meter te>< results performed before and after this vork shoved no improvement, the work did not upgrade the fire pumps from an inoperable condition.
The test results on October 5, 1990, and October 17, 1990 vhich shov satisfactory performance using the pitot reading method are indicative of the past condition of these pumps.
2.
All past performances of fire pump tests (PTI-P54-P0036 and
.PTI.P54-P003) have been plotted against the pumps' acceptance test curves.
For all test results, all fire protection system demands for systems protecting safe-shutdovn capability vere able to be met by the data generated. The largest of these systems is the Unit 1 Cable Spreading system vith a demand requirement of 2338 gpm (including 500 gpm for hoses) with a i
pump discharge pressure of 116 psi. Therefore, the operability of the fire pumps to provide protec' ion of safe shutdovn equipment vas demonstrated within the 18-month period as required by Perry commitments and applicable regulations.
3.
Condition Report 90-347 vas initiated to document and evaluate this event.
4.
Revision 3 to PTI P54-P0036 vas issued, and perforced satisf actorily to demonstrate the operability of the fire pumps. This revision includes a test at no flow (shutoff pressure) performed by closing the relief valve.
5.
Results of this event evaluation indicate that some of the testing performed on the fire protection systems does not have a simple acceptance criteria for operability. The PTIs in which acceptable performance is based on an analysis of the test data rather than a single pass / fail criteria include PTI P54-P0003 Fire Main Flov Test, and P54-P0036. Therefore, both of these tests vill nov require review and verification by the Fire Protection Engineer for
.erability. This vill also allov for an evaluation of tL extent of system problem, degree of system operability, and appropriate compensatory measures.
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4 PY-CEI/NRR-1200 L Page 5 of 5 Corrective Actions That Vill be Taken to Avoid Further Violations Perry vill modify the USAR to clarify hov end when future Code 1
changes vill be incorporated into the Fire Protection Program.
Date when full compliance vill be achieved Full comp 12ance vas achieved upon successful performance of PTI P54-P0036 on October 17, 1990 vhich verified operability of the fire pumps to provide protection of safe shutdovn equipment within the 18-month period as required by Perry commitments and applicable regulations.
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PY-CEI/NRR-1280 L Page 1 of 7 Response to request to address three additional areas Use of emergtncy vork author 1 rations to allov maintenance work to begin prior to issuance of an approved maintenance work order NRC Inspection Report 50 440/90012 identifies the practice of beginning non-emergency maintenance prior to issue of the Vork Order as a veakness of Perry's Vork Control Program. Tvo specific concerns are mentioned in Section 3.4.2.3, Past Instrumentation and Control Maintenance. The concerns specifically identified are (1) troubleshooting vithout a Vork Order and (2) improper troubleshooting methods. This response addresses the first concern more appropriately referred to as Immediate Troubleshooting using tFe Troubleshooting Log, which is further broken dovn into tvo items; (1) the intent of PAP-0905, Vork Order Process, when using the Troubleshooting Log and (2) the use of a Troubleshooting Log instead of a Vork Order.
The first item to be addresset is a statement vritten in the inspection report which concludes that the intent of PAP-0905 is apparently not being met because troubleshooting began on Vork Orders which vere assigned a priority that was not consistent with the need to immediately repair the component.
The criteria for :he initiation and use of the Troubleshooting Log
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is administrative 1y addressed and controlled under PAP-0905, Vork Order Process, Sections 2.4 and 6.11.
Section 2.4 of PAP-0905 states, "A Vork Order is not required to initiate troubleshooting on a failed component or system.
A verbal request from the Control Room Unit Supervisor is sufficient to initiate troubleshooting in ar.cordance with Section 6.11."
Section 6.11, Troubleshooting Log, provides the details for initiating the Troubleshooting Log and control of the work in the field. This Section of PAP-0905 starts vith paragraph 6.11.1, and states, "when immediate corrective action is required, the Control Room Unit Supervisor may initiate use of the Troubleshooting Log performing the f ollowings..."
The intent of PAP-0905 is very clearly stated in both the above reference sections. The Control Room Unit Supervisor may initiate use of the Troubleshooting Log when he deems immediate corrective action is required. There are no conditional restrictions which require the Vork Order to be assigned a specific priority. To interpret the priority codes of PAP-0902, Vork Request System, as somehov restricting the use of the Troubleshooting Log is not consistent with Perry's administrative controls for the Vork Order i
Process.
The second and more important item is the practice of using the Troubleshooting Log prior to issuance of a vork order for J
non-emergency maintenence work.
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4 PY-CEl/NPJt-1200 L Page 2 of 7 As previously stated, PAP-0905 provides a means for the control Room Unit Supervisor to direct I&C and Maintenance personnel to begin troubleshooting a problem prior to the planning and reviev of a Vork order. The means is called the Troubleshooting Log and can be applied when emergency or non-emergency actions are required. The only criteria is that the Control Room Unit Supervisor believes immediate action is varranted.
The Troubleshooting Log is a very valuable tool when used correctly.
It allovs the work groups a means of ascertaining a problem and/or stabilizing an unvanted conlition while a Vork Order is i
simultaneously being processed.
In almost all cases, the Vork Order is issued to the field prior to corrective action taking place.
In many cases, once the problem is identified, vork is actually stopped until a Vork Order is written to specifically address the problem identified through the use of the Troubleshooting Log.
The use of the Troubleshooting Log does not differ greatly from the use of a Vork Order written to perform troubleshooting.
In accordance with Section 6.11 of PAP-0905, while working with the Troubleshooting Log the work organization is required to assemble vendor manuals, instructions, instrument file folders or dravings.
Each of these documents are revieved and approved for use at the
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Perry Plant and have a procedure which details how it is to be used when performing maintenance activities.
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As with a Vork order, the control Room Unit Supervisor must authorize:vork to begin via his signature and may restrict the amount of work performed.- Also like the Vork Order, the Control Room Unit Supervisor is required to review the work performed and sign acceptance of the Troubleshooting Log. This acceptance signature, however, seldem needs to be obtained since in most cases the Vork Order is issued to the field prior to any repairs taking place.-
Although the Troubleshooting Log does not go through the same review as a Vork Order.-the Quality control Section is notified prior to stsrting'a job vhen using the Troubleshooting Log under those circumstances which would normally require their review of a Vork Order. The work groups recognize that the use of the Troubleshooting-Log requires.more stringent controls anel communications vith the control Room Unit Supervisor than does a-Vork Order..These additional controls are addressed in Section 6.11.3 of PAP-0905.
i In conclusion,'the control Room Unit Supervisor uses his 'udgment to-j determine if immediate action is varranted, and' directs plant-personnel to begin troubleshooting a problem prior to the planning and reviev of a vork order.
Additionally, the Control Room Unit 5i
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a PY-CE1/NRR-1280 L Page 3 of 7 Supervisor is required to review the work performed and sign acceptance of the Troubleshooting Log, as he vould a Vork Order.
Ve, therefore, beliseve that the use of the Troubleshooting Log in non-emergency conditions (instead of a vork order) is adequately controlled and provides much the same assurance of quality control as a vork order.
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s A:ta:hment 4 PY-CI!/NRP-1200 L Page 4 of 7 Use of temporary changes such as lifted leads and jumpers rather than using the modit'ication process Ve agree that the total number of tempotary modifications (i.e.
lifted leads, jumpers, electrical devices, and mechanical foreign items) installed at Perry needs to be reduced, and that the majority of these modifications have been in effect for over six months.
Although this number requires reduction, the specific Category I Temporary System Alteration (TSAs), which by definition affects system operability (total of 20), falls within the allovable range as establed by management.
On August 29, 1990, the Plant General Manager, and the Director of Perry Nuclear Engineering Department issued a memorandum to Perry Managers acknovledging this unacceptable condition, and provided guidance for immediate actions to strengthen our modification program, and reduce and maintain a minimal level of temporary modifications. Specific provisions of the memorandum include:
1.
Temporary modifications vill not be permitted as interim alternatives to permanent design changes, unless absolutely needed to support continued plant operation. Established Design Change Packege (DCP) and Vork Order (VO) priorities vill be used to expedite modifications as required.
2.
Temporary modifications vill be used only for items which are truly temporary.
3.
The Hanager of Systems Engineering Section vill be responsible for approval of each temporary modification prior to implementation.
4.
A management review of outstanding temporary modifications vill be conducted to establish appropriate priority and scheduling codes for associated Design Change Notices, DCPs, and V0s.
Emphasis vill be placed on modifications installed for greater than six months, with the goal of permitting no temporary modifications to remain outstanding longer than one operating cycle.
A Senior Engineer, Electrical Design Section, vas assigned the responsibility for coordination of this effort.
The renewed emphases and management recognition of the veaknesses associated with the LLJED/MFI Temporary Alteration Program provided the support necessary to acthely pursue and initiate corrective actions.
Issuing the interim policy statement directly addressed and focused attention to these problems.
Under the coordination of Electrical Design Section personnel, the active Type I & II temporary alterations have been revieved and
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PY-CEI/NRR-1280 L Page 5 of 7 prioritized for field implementation based on scheduling constraints and system configurations. The major thrust was to reviev the older temporary alterations and attempt to have these completed, along with all Type I alterations.
Efforts as of December 12, 1990, indicate that the backlog (154) has been reduced to 95.
The following items vill be incorporated in a revision of PAP-1402, Control of Lifted Leads, Jumpers, Temporary Electrical Devices and Mechanical Foreign Items. This procedure revision and associated instructions are scheduled for implementation by January 31, 1991.
1.
Up-f ront engineering involvement for all LLJED/MF1 teaporary alterations.
2.
An adequate sulti-discipline engineering reviev and follov-up vhen a LLJED/MFI temporary alteration must be installed.
3.
A limit to the time period of installed LLJED/HFI temporary alterations to one operating cycle.
4.
Establishment of a plan to prioritize and schedule the issuance of Design Change Packages to make the LLJED/HFI temporary alterations permanent where warranted.
5.
Define when and how the LLJED/MFI temporary alteration may be use.
6.
Re-enf orcement of the LLJED/MF1 Technical Evaluation Form.
Finally, LLJED/MFI temporary alternations have in the past and in the future vill be tracked monthly via the Monthly Performance Report.
The report is reviewed monthly by all site managers.
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Attochment 4 PY-CEI/NRR-1280 L PaEe 6 of 7 Use of temporary change requests to revise procedures rather than ge, normal procedure revision process The Maintenance Team inspectors vere concerned over the " unusually high number of TCNs" vritten against I6C Surveillance Instructions.
Their main concerns appeared to be (1) a TCN results in a limited scope of instruction reviev due to the number of pages affected, (2) a TCN is not subject to the multi-discipline revision roviev process, and (3) in addition to the high number of TCNs. many of the TCNs have been in place for several years.
The first item't, scope could be limited to the instruction review that occurs when a TCN is vritten in lieu of a revision. Temporary Changes to Technical Instructions (PAP-0522, Section 6.5.2 and 6.5.3) list specific criteria for the discipline and in-depth reviewers to verify when given a TCN for reviev. These criteria are identical to those listed in PAP-0507 (Preparation, Reviev and Approval of Instructions), Section 6.3.7 for an instruction revision reviev.
There is no statement that limits a TCH review to only the specific pages changed by that TCN. The reviewer has access to all instruction materials and the 16C "Yellov-Line Draving" Program, therefore, the reviev of a TCH should in no vay be of a lesser overall quality than a revision reviev.
The second item to be addressed is the TCN review process versus the multi-discipline revision review process.
As delineated above, the processes are the same. All I6C TCNs, Intent and Non-intent, are distributed for reviev per the Responsibility / Approval / Discipline Reviev Matrix, Attachment 2 to PAP-0507, Preparation, Reulev and Approval of Instructions. This is the same matrix that is used to distribute revisions for ths reviev process. Therefore, TCNs receive the same multi-discipline review as any I6C Surveillance Instruction revision.
The third item to be addressed is the high number of TCNs to some instructions, and the fact that many of them have been in place for several years. This is a problem that I6C management has identified for some time and they have been addressing the issue. Note -
Perry's Administrative Procedures do not limit the amount of Temporary Changes to their procedures. At the time of the Maintenance Team inspection, 46 of 1400 instructions vere identified as having 10 or more TCNs issued since the last revision.
This represents about 3% of the overall number.
The previous I&C philosophy has been to revise instructions only when time allowed complete update to the current format.
However, a new approach has already been implemented that vill help reduce the numbers of TCNs and promote more revisions instead. I&C personnel have re-evaluated and re-prioritized all backlogged TCN requests, to try and consolidate them and reduce the numbers of new TCNs generated.
I6C management has directed their personnel to
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PY-CEI/NRR-1280 L Page 7 of 7 factor those SVIs with 10 or more TCNs written against them into the revision priority schedule.
Since that time, 15 Revisions /TC revisions have been completed on those "high numb 0r TCN" SVIs and another 21 are in process and are scheduled to be completed by the I
end of 1991. The overall process of reducing TCN numbers and revising all instructions to current format is being given much greater attention.
Positive resulta have already and vill continue to be realized.
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