ML20136H888

Suppls Comments Expressed During 850926 Meeting Re NRC SALP Rept of Jan 1984 - June 1985.Activities to Ensure Implementation of Test & QA Program Requirements Listed. Addl Action to Enhance Plant Readiness Also Being Taken

ML20136H888
Person / Time
Site:	Perry
Issue date:	10/25/1985
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20136H863	List: ML20136H858 ML20136H869 ML20136H888
References
PY-CEI-OIE-0133, PY-CEI-OIE-133, NUDOCS 8511250221
Download: ML20136H888 (3)

Text

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to i E 3 h . , } }h t i 11 " i if Y! bl E. L. L L' b ]. Rt a i P.o. Box 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESloENT October 25, 1985 NUCMAR PY-CEI/01E-0133 L Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, illinois 60137 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 SALP Response

Dear Mr. Keppler:

This letter is The Cleveland Electric Illuminating Company's response to the staff's report on the Systematic Assessment of Licensee Performance (SALP) for the Perry Nuclear Power Plant for the period January 1, 1984 through June 30, 1985. This response summarizes and supplements our comments on the SALP evaluation expressed during our meeting with the staff on September 26, 1985.

The Illuminating Company was encouraged to have received a Category I rating, the highest, in four of the functional areas versus only one functional area during the previous assessment period. We are also pleased that your staff has recognized the improving trend in four other functional areas which were rated Category II. This indicates to us that NRC management recognizes the strong commitment to quality on the part of The Cleveland Electric Illuminating Company.

We also recognize the value of assessment programs in the early identification and resolution of problems. In response to the earliest indications that an adverse trend existed in the Preoperational Test Program, CEI has taken aggressive action to alleviate concerns regarding the Test Program. Beginning on April 3, 1985, a task force was established to evaluate the Test Program and recommend actions necessary to improve performance. As a result of this task force evaluation and input from your staff, a Special Project Plan was developed. This Special Project Plan was implemented to provide positive assurance of the adequacy of the Test Program by implementing the actions outlined during our meeting on June 3, 1985. This meeting was documented in Inspection Report 85036. Our goal of positive assurance of the adequacy of the test program was achieved by augmenting the existing test program with the following:

1. Extensive evaluations and refinements were made to the Test Program Manual. The evaluations were based on the results of QA surveillance and management observation, and the refinements improved field compliance with regulatory requirements. Specific changes 0511250221 851121 PDR ADOCK 05000440 0 PDR L j

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EMr. James G. Keppler October 25, 1985 PY-CEI/01E-0133 L t ~ included': Increased use of. operating phase-procedures for system operation, housekeeping,-alarm response and temporary alterations; assignment;of,a plant shift-supervisor as test coordinator; and, increased (controls of' administrative requirements for test changes, test prerequisites and. measurement and test instruments.

2. - An independent. verification program was initiated to assure that test

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commitments-were' identified and satisfied..rThis program included

' ' searches of the 'FSAR, SER, Emergency -and Fire Protection Plans, and.

.Licensingfcorrespondence. Experienced personnel verified that the commitments in'these documents were; satisfied in the test program.

This action-assures that tes't commitments, which may have been missed, were properly. implemented.,

~ 3. A line by line review of:allLPreoperational and Acceptance Test Procedures' described in Chapter 14 of the FSAR was conducted by'

'a special Management . Procedure Revieu Team consisting of senior.

jpersonnel;with extensive, design and test-experience. ,This review C evaluated and. directed improvements .to the' technical adequacy,~ scope andilevel'of detail in Test Procedures.'

4. A review and evaluation of Initial Check-out and Ruc-in Procedures was performed to-ensure;the adequacy ofc component. testing. 'Although originally the Special Project Plan was focused on. system testing,

,this~ pro'g ram also ensured that the evaluation of.the Test Program was

-comprehensive in' scope.

5. Improved training and supervision was provided.for personnel involved Lin writing and reviewing test procedures.E This program included training in'both test program requirements and refinements to the. '

program, and emphasized more frequent' contact between management personnel and test engineers.. In addition, both the. Test and Quality Sections. assigned _a supervisor to each shift _to direct and monitor

, test activities.-

A Performance Evaluation Team was-established by the Test Section

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iSupervisor to evaluate the conduct of testing.and. provide guidance to test engineers regarding. test performance and program requirements.

.We believe that these actions, along with extensive efforts'to improve-

!' -attention to detail, communication and responsiveness.to the NRC,.were

= comprehensive 1Ln scope and effective in assuring the adequacy.of the Test Program.

<Because CEI is proud-of the aggressiveness and effectiveness of its quality.

assurance program, we are'very concerned about the conclusion regarding our

. effectiveness in preventing recurring problems in the Preoperational Test g

Program. Our experience has shown that the ef fectiveness of the QA program is

l dependent on project wide awareness of the importance of QA program

j. Limplementation. Therefore,'our response to this concern concentrated on ensuring that the entire test organization ~is fully aware of the importance of

_ implementing Test and QA program requirements. Specific activities include:

Comprehensive training / awareness sessions were conducted by the

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Nuclear Test Section and Operational Quality Section General

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'Mr.EJames G. Keppler October 25, 1985

. PY-CEI/0IE-0133 L h! . . .

_ -Supervising

Engineers for all test.and quality personnel., These sessions alerted; personnel to problem areas and. stressed the importance of; complete program adherence.and responsiveness to

. problems identified.-

2.' The QA Surveillance Program was strengthened: to focus on the known

. problem areas and' emphasize verification of corrective action adequacy and-implementation.

3. A' periodic' review of concerns with respect'to quality was emphasized

. at both- Test Procedure Review Committee and Plant: Operations _ Review Committee meetings.

The: actions described'above demonstrate our' increased management attention to the areas o,f concern identified in the SALP report. With respect to Licensing, our independent verification of-commitment implementation in the preoperational

. test area is an example of: enhanced l controls to ensure quality in; addressing.

t licensing issues. 4 s

As recognized.b'y the staff in your. report, The Cleveland Electric Illuminating Company is taking additional action to enhance plant. readiness for operations..

This includes steps to' incorporate' lessons learned'from'the preoperational test phase'into.the plans for startup testing andt operations. ;Also, personnel reassignments are.in process which will better utilize project personnel with

_ previous commercial' nuclear experience. This will' assure that sufficient.

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personnel with previous commercial nuclear _ experience'are available to support plant operation.

We believe that the' actions described in this response address each of the-potential problem. areas identified in the SALP. .We will continue to aggressively implement _our management controls and quality assurance program and we.are confident that this course of action will result in continuing

-improvements in our performance. If you have any. questions, please call.

Very truly yours, h W

Mu Edelman Vice President Nuclear Group MRE

.nje l' __ 'ce: J. Silberg, Esq.

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J. Stefano (2)

J. Grobe

~K. Connaughton

' Document Control Desk