ML20127D189
| ML20127D189 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/17/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8506240148 | |
| Download: ML20127D189 (8) | |
Text
s f THE CLEVELAND ELECTR P.O. BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG - 55 PUBLIC SOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VtCE MSIDENT May 17, 1985 NUCLE AR PY-CEI/OIE-0048 LQ Mr. R. L. Spessard, Director Division of Reactor Safety, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket No. 50-440
Dear Mr. Spessard:
This letter is to acknowledge receipt of Inspection Report 50-440/85013 attached to your letter dated April 19, 1985.
This report identifies areas examined by Messrs.
R. D. Lanksbury, D. E. Hills and Ms. C. D. Anderson during their inspection con-ducted February 14 through March 22, 1985, at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Viola-tion dated April 19, 1985.
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,
/%4 Murray R. Edelman Vice President Nuclear Group MRE:sab Attachment gg 2 0 W 8506240148 8505 40 PDR ADOCK 0500PDR
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Mr..R. L. Speasard PY-CEI/OIE-0048 LQ May 17, 1985 L
.Page 2 cc:. Mr. J. A. Grobe USNRC Site, SBB50 Mr. D. E. Keating USNRC~ Site, SBB50 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Mr. R. F. Warnick, Chief Reactor Projects Branch 1 Division'of Reactor Projects U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 1
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RESPONSE TO ENFORCEMENT ITEM Below is the response to the Notice of Violation appended to United States Nuclear Regulatory Commission I.E. Report No.
50-440/85013(DRS).
I.
Noncomoliance A.
Severity Level IV Violation 10CFR50, Appendix B, Criterion XI, as implemented by CEI's Corporate Nuclear Quality Assurance Program
'(CNQAP) Section 1100, Revision 4, requires that a testing program be established to assure that all testing required to demonstrate that structures, sys-F tems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the require-4 ments and acceptance limits contained in applicable design documents.
Contrary to the above, preoperational test procedures TP OM25/26-P-001 and TP 1M98-P-001, and general procedure GEN-M-016 contained numerous examples (as detailed in paragraphs 3.a, 3.b.,
and.3.d. of Inspec-tion Report 50-440/85013(DRS) of a failure to implement requirements for testing contained in Regulatory Guide 1.68, Revision 2 and ANSI N510-1975 which the licensee committed to in Table 1.8-1 of the Final Safety Analysis Report [440/85013-01(DRS)].
l B.
Rerponse s
1.
Corrective Action Taken and Results Achieved The Cleveland Electric Illuminating Company (CEI) has reviewed the items identified as discrepancies during the NRC review of test procedures GEN M-16, TP OM25/26-P-001 and TP 1M98-P-001.
As appropriate, the inspector's concerns were resolved by_ verifying that the test requirements were satisfied in other test procedures or by incorporating the requirements into the appropriate procedures.
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. RESPONSE TO ENFORCEMENT ITEMS MAY 17, 1985 PAGE 2 4
- 2.
Corrective Action to Avoid Further Noncompliance The Cleveland Electric Illuminating Company has taken action to assure that the Perry Nuclear Power Plant testing procedures meet regulatory requirements and CEI testing commitments.
This effort includes review and upgrading of the Test Specifications and addi-tional training on the. identification and incorpora-tion into Test Procedures of the requirements and commitments contained in the FSAR, applicable guides and stan-dards, the Safety Evaluation Report and Supplements, and applicable docketed correspondence.
To improve CEI's ability to oversee and direct the review and upgrading of Test-Specifications, per-sonnel involved in the development of test speci-fications were relocated from Gilbert / Commonwealth Inc.'s corporate office to the PNPP site.
In addition, CEI has assumed direct responsibility for the quality assurance review of Test Specification revisions.
A Management Procedure Review Team (MPRT) has been formed to evaluate and provide recommendations to improve the test procedure development and review process.. The team is composed of senior level personnel with extensive nuclear test.and design experience.
Included in the scope of this evaluation is the determination of the actions necessary to assure th'at tests'which have'already been completed meet the necessary requirements.
The MPRT has been screening the System Test Engineers whose procedures were being released for test during the evaluation period to provide assurance to CEI management of the adequacy of the program being implemented.
4 Based on the preliminary findings of the MPRT, training was given to personnel involved in devel-oping, reviewing, and implementing Test Procedures.
This training emphasized the identification of testing requirements.
In our response to I.E. Report 50-440/85002; 50-441/85002, CEI initially committed to complete the MPRT. evaluation by May 31, 1985.
The MPRT is now in the final stages of its evaluation.
The conclusions and recommendations of the MPRT will be presented to CEI management'in a report on May 24, 1985.
Based on management review of the recommendations included in.
I this report, CEI will implement any additional corrective action needed to assure that test commit-3 i
ments are. satisfied.
RESPONSE TO ENFORCEMENT ITEMS MAY 17, 1985 PAGE 3 3.
.nate when Full Compliance Will Be Achieved PNPP management will review the recommendations of
.the MPRT and-by June 7, 1985, will initiate any additional actions necessary to achieve full compliance.
Specific details and a schedule for completion ~will be available at that time.
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II.
Noncompliance A.
Severity' Level'V Violation I
- 10CFR50',' Appendix B,' Criterion XIV, as implemented by CEI's CNQAP,'Section 1400, Revision 5, requires that measures be established to indicate by the use of markings such as stamps, tags, labels, routing cards, e
or other suitable means, the status of inspections and tests performed upon individual items of.the nuclear power plant:and for indicating the operating-status of components.. Test Program Instruction-9, Section 4.1.7, requires that any and all parties desiring to perform tmrk on equipment under Nuclear Test Section (NTS) l-control-shall.do so.only with the knowledge and express consent of the shift test engineer.
Contrary to the above, a blue Nuclear Test Section jurisdictional tag was not affixed to breaker EFlD12 L
for the hydrogen recombiner system.as required by Test l
Program Instruction-9 and breaker EFID04 for the emer-
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r gency closed cooling water' system was not tagged with a i
white Out-Of-Service Tag as required by Project Admin-l l
1stration Procedure 1104.
In addition, controls instituted-to accomplish the above requirements were inadequate to prevent construction personnel from dis-connecting the cable for the velocity feedback. signal i
from-the actuator on Recirculation Flow Control Valve IB33-F060A_without the knowledge or express consent of NTS.which had jurisdictionalacontrol. (440/85013-07(DRS)].
B.
Response
1.
' Corrective Action Taken and Results Achieved The Cleveland Electric Illuminating Company-investigated each of these discrepancies and i
provided the appropriate tags as required.
The cable for the velocity feedback signal from the actuator on.the Recirculation Control Valve s
IB33-F060A was~ reconnected and verified functional during preoperational: test 1B33-P-002.. The cable connector appears to have_become-. disconnected j
.during the erection of scaffolding in the area.
'2.1 Corrective Actio'n Taken to Avoid Further 4
Moncompliance
. Nuclear Construction Administration Section, Nu-clear: Test Section and Operational Quality Section
' conducted and documented. additional training of -
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RESPONSE'TO ENFORCEMENT ITEMS MAY 17, 1985 PAGE 5 craft supervisors and foremen on March 22, 1985.
i Also, appropriate NTS personnel were trained on March 27, 1985 by NTS management.
This training covered procedures about jurisdictional control and equipment operation.
An operational surveillance completed on April 29, 1985 showed the effectiveness of the training by l
showing a significant-improvement in jurisdictional l
tagging since the surveillance completed March 14,
)
1985.
CEI will conduct periodic surveillances of jurisdictional tagging to ensure continuing compliance with project requirements.
3.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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RESPONSE TO ENFORCEMENT ITEMS MAY 17, 1985 PAGE 6 III.
Noncomoliance A.
Severity Level V Violation 10CFR50, Appendix B, Criterion V, as implemented by CEI's CNQAP Section 0500, Revision 6, requires that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance 4
with these procedures.
Test Program Instruction-6, Section 4.3.3.2, requires that Alarm Response Instructions (ARIs) be generated for the preoperational test program and be made available to the control room operators.
Contrary to the above, ARIs for the preoperational test program were not being generated and made available to the control room operators.
[440/85013-09(DRS)]
B.
Response
1.
Corrective Action Taken and Results Achieved The actions required in response to alarms in the control room are defined by Perry Plant Operations Department (PPOD) ARIs.
Test Program Instruction (TPI)-6 provides a mechanism for System Test Engineers (STEs) to alert control room operators of any unique alarm response actions required during testing activities.
The purpose of TPI-6, to modif.y the PPOD ARIs when necessary to support testing activities, was not clearly stated in the inst ruction, and therefore, TPI-6 was being imple-mented inconsistently.
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2.
C21 rective Action to Avoid Further N;qsompliaggg TPI-6 is being. revised to clearly state that the pcrpose of the instruction is to provide a mechanism for STEs to initiate temporary changes to PIOD ARIs to support test activities.
- However, changes to the PPOD ARIs initiated by an STE will be reviewed, approved and issued in accordance with PPCD administrative procedures.
3.
QAle When Full Compliance Will Be Achieved Fui.1 compliance will be achieved upon completion of tha revision to TPI-6 to clarify the intent of the procedure.
This action will be completed by May 30, 1985.