ML20138N596
| ML20138N596 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/24/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0118, PY-CEI-OIE-118, NUDOCS 8511050247 | |
| Download: ML20138N596 (4) | |
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f THE CLEVELAND ELECTR P.O. BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622 9800 - lLLUMINATING BLDG - 55 PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT NUC LE A R September 24, 1985 PY-CEI/01E-0118 L Mr. R. F. Warnick, Chief Project Branch 1 Division of Reactor Projects U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 50-440/85046 Noncompliance Response
Dear Mr. Warnick:
This letter is to acknowledge receipt of Inspection Report 50-440/85046 transmitted by letter dated August 26, 1985. This report identifLed areas examined by Messrs. J. A. Grobe and F. R. Dunaway during their inspection conducted July 8 through August 5, 1985 at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated August 26, 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 requested.
If there are additional questions, please do not hesitate to call.
Very trul yours, M
L J
Murray R. Edelman Vice President Nuclear Group MRE:nje Attachment 8511050247 850924 PDR ADOCK 05000440 PDR gg{p 3 Q jg 0
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Mr.
R. F. Warnick, Chief September 24, 1985 1
PY-CSI/0IE-0118 L Mr. J. A. Grobe USNRC Site, SBB50 Mr. K. A. Connaughton USNRC Site, SBB50 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
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Attachrent PY-CEI/01E-0118 L Page 1 of 2 Response to Violation 440/85046-02 (DRP)
A.
Statemtat of Violation 10 CFR 50, Appendix B, Criterion 6, " Document Control," as implemented by the applicant's Quality Assurance Plan, Secticn 6 Revision 1, dated May 6, 1985, requires that the issoance of instructions shall be controlled including approval for release and distribution to and use at the location where the activity is accomplished.
Contrary to the above, Temporary Change Noticas (TCN)-005 for Plant Administrative Procedure (PAP)-1402, Revisior. 2, " Control of Lifted Leads, Jampers, Temporary Electrical Devices and Mechanical Foreign Items," which modified the procedure for controlling temporary alterations affecting equipment under test jurisdiction and temporary alterations af fecting control room annunciators, was assigned an effective date the same as the signature approval date and no special provisions were made for expedited distribution or training to the new program requirements. Additionally, the procedure change was not :ntered into the operations manual in the control room until seven days after the effective date of the procedure.
This is a Severity Level V violation (Supplement II).
B.
Response
1.
Corrective Action Taken and Results Achieved:
As the plant makes the transition from construction to a.' oparating plant, Revision 2 of PAP-1402, " Control of Lifted Leads, Jumpers, Temporary Electrical Devices and Mechanical Foreign Items," was issued on July 3, 1985, to provide more stringent controls for the use of temporary alterations.
Immediately prior to the date that Revision 2 became effective, it was identified that the procedure could be improved by adding requirements to obtain Test Engineer concurrence for Temporary Alterations and by more explicit identification of annuciators affected by lifted leads.
These requirements were added to the procedure using a Temporary Change to avoid delaying the use of the new procedure (Revision 2 to PAP-1402). The procedure governing temporary changes did not require delaying the effective date of a temporary change to permit full distribution m:d did not require training prior to the implementation of the change.
Project personcel have reviewed the implementation of PAP-1402 between the effective date on July 3, 1985, and distribution of the change on July 10, 1985. Although several temporary alterations were installed and removed without STE signatures during this period, previously approved methods for obtaining STE concurrence were applied. Additionally, no alterations which required marking an annunciator were installed during this period.
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Attachment PY-CEI/0IE-Oll8 L Page 2 of 2 2.
Corrective Action to Avoid Further Noncompliance:
a.
PAP-0502, " Preparation, Review, Approval, Revision and Cancellation o Adminstrative Procedures" has been changed to require t'.at the date when a procedure or temporary change becomes effective shall permit sufficient time for training and controlled distribution.
b.
PAP-0211, " Procedure and Instruction Training" has been changed to require training of appropriate personnel when a temporary change to a Plant Administrative Procedure is issued.
c.
Administrative personnel involved in the processing of pro-cedures and any subsequent temporary changes were reinstructed in the requirements for expeditious processing of these documents to controlled copy holders within required time limits.
3 Date When Full Compliance Will be Achieved:
Full compliance has been achieved except for completion of training to the change to FAP-0211, which is scheduled for October 4, 1985.
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