ML20081F332
| ML20081F332 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/21/1983 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20081F302 | List: |
| References | |
| NUDOCS 8311020432 | |
| Download: ML20081F332 (3) | |
Text
.
P.O. BOX 5000 - CLEVELAND, OHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLOG - 55 PUBLIC SOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN October 21, 1983 VICE PRESIDENT NUCLE A R Mr. R. C. Knop, Chief Projects Branch 1 Division of Project and Resident Programs U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441
Dear Mr. Knop:
This letter is to acknowledge receipt of Inspection Report Number 50-440/
83-27; 50-441/83-26 attached to your letter dated September 28, 1983. This report identifies areas examined by Mr. M. Gildner during his inspection conducted July 1 through August 31, 1983, at the Perry Nuclear Power Plant.
Attached to this letter is our response to the one (1) Severity Level V Violation described in the Notice of Violation dated September 28, 1983. This response is in accordance with the provisions of Section 2.201 of the NRC's
" Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Our response has been submitted to you within thirty days of the date of the Notice of Violation as you required.
If there are additional questions, please do not hesitate to call.
Very truly yours, M. R. Edelman Vice President Nuclear Group MRE:pab Attachment cc:
Mr. M. L. Gildner UShTC Site Mr. R. L. Spessard, Director Division of Engineering U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C.
20555 8311020432 831027 gDRADOCK 0500044o OCT 2 41983 PDR
O O
RESPONSE TO ENFORCEMENT ITEM Below is our response to the Notice of Violation appended to United States Nuclear Regulatory Commission I.E. Report 50-440/83-27; 50-441/83-26.
I.
Noncompliance 440/83-27-01; 441/83-26-01 A.
Severity Level V Violation 10CFR50, Appendix B, Criterion V (Instructions, Procedures, and Drawings) and PNPP PSAR Chapter 17, Section 17.1.5, requires that activities affecting quality...shall be accomplished in accordance with instructions, procedures, and drawings.
CEI Corporate Project Administration Procedure 1501, Revision 3 Paragraph 1.2.1, states in part, " CONTRACTOR and VENDOR inquiries or notifications on reportable deficiencies are to be documented and evaluated for reportability pursuant to 10CFR50.55(e) and/or 10CFR21 by the PNPP Project Organization in accordance with this procedure."
CEI Corporate Project Administration Procedure 1501, Revision 3, Paragraph 1.2.3, states in part, "If more than seven (7) calendar days f rom date of receipt are required to complete the Engineering Evaluation, the condition will be identified as reportable."
Contrary to the above, CEI received notification from Gilbert Associates, Inc. (GAI) dated April 11, 1983, that three problems associated with the Emergency Diesel Generator Control System were identified and should be evaluated for reportability as substantial safety hazards.
CEI responded to GAI by letter dated August 4,1983, that the concerns were being addressed to the manuf acturers. No reportability evaluation had been initiated at that time.
Subsequently, as a result of an NRC audit of GAI, an evaluation was initiated by the licensee resulting in the reporting of two of the three problems as a potential 50.55(e) concern on August 16, 1983.
B.
Response
1.
Admission or D6nial of Alleged Violation We concur with the inspector's observation that the evaluation performed on the notification initially received from CAI was not documented in a timely manner; however, we wish to indicate that the seven calendar day time requirement is cpplicable only af ter a Deviation Analysis Report has been initiated.
2.
Reason for Admitted Violation As a result of requirements imposed by NUREG 0588 and the revised PNPP equipment qualification environments, a second review of the previously approved Diesel Engine Controls qualification plans was conducted by CAI. The comments from this second review were compiled and documented in a letter to CEI dated September 10, 1982. These comments were transmitted to the vendor for resolution on September 30, 1982.
Included in this list were the Emergency Diesel Generator Control System concerns.
l
' RESPONSE TO ENFORCEMENT ITEM
. PAGE 2 In a letter dated April 11, 1983, GAI suggested that CEI contact the vendor to obtain evaluation of three of these concerns as substantial safety hazards reportable under 10CFR21 since the design did not appear to comply with either specification or licensing requirements. CEI recognized these items as having been communicated to the vendor in September 1982 for technical review.
As the vendor had not provided the technical details requested, a documented evaluation for reportability was not initiated at that t ime.
3.
Corrective Action Taken and Results Achieved As cooperation in resolving technical issues was not forthcoming, we initiated Deviation Analysis Report's (DAR's) 138 and 139 on August 12, 1983, which resulted in two of the three problems being identified as potentially reportable pursuant to 10CFR50.55(e).
Both of these problems, identified on DAR 139, require further evaluation. An interim report reflecting this was submitted on September 15, 1983, and the final report is scheduled to be submitted by December 30, 1983.
4.
Corrective Steps to Avoid Further Violation Two courses of action have been pursued. The first is a revision to the GAI Perry Procedures Manual (PPM) which cicarly delineates the lines of communication and notification from GAI to CEI.
Appropriate management from both the CEI Engineering and Quality Assurance organizations are notified of any GAI determinations regarding possibly reportable events involving the PNPP Project.
This was included in Section 3.24, Revision 20, of the PPM, effective September 30, 1983.
Secondly, a PNPP procedure has been developed to provide for preliminary engineering review of identified design discrepancies when clarification is necessary to determine whether a possibly reportable deficiency has been discovered.
This then feede into our Deviation Analysis Report system if further action is required.
5.
Date When Full Compliance Will Be Achieved Full compliance, including training of appropriate personnel, will be achieved by November 30, 1983.
a