ML20210R268
| ML20210R268 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/22/1986 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0256, PY-CEI-OIE-256, NUDOCS 8702170366 | |
| Download: ML20210R268 (4) | |
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b f THE CLEVELAND ELECTR P.O. BOX $000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLIC SQUARE Serving The Best Location in the Nation MUFEAY R. EDELMAN SR. VICE PRE &lOENT December 22, 1986 Nucuan PY-CEI/01E-0256 L Mr. Charles E. Norelius, Director Division of Reactor Projects, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Perry Nuclear Power Plant Docket No.
50-440 Response to Observations Contained Within Inspection Report 50-440/86027
Dear Mr. Norelius:
This letter acknowledges receipt of Inspection Report 50-440/86027 dated November 18, 1986. Your report described the special team inspection conducted at Perry from November 5 through November 7, 1986 to assess our Licensee Event Report (LER) analysis and reporting programs. Team members included Messrs.
J. McCormick-Barger, S. Stern, J. Stefano, R. Scholl, R. Becker, P. Leech, E. Weiss and G. O'Dwyer.
As requested in your cover letter, our response to your observations identified in Section 7 of the Inspection Report is attached. Please feel free to contact me should you have any additional questions.
Very trul ou s, LN?
Murray R. Ed an Senior Vice President Nuclear Group MRE:nje Attachment cc: Jay Silberg, Esq.
Paul Leech (2)
K. Connaughton Document Control Desk (USNRC) 8702170366 861222 DR ADOCK 0500 O
ggg 2 S 1986 RoI
Attcchment PY-CEI/01E-0256 L Observation a)
The licensee should continue to work toward streamlining / simplifying the process for identifying, documenting, and tracking events from inception-to final resolution.
' Response Since your visit, our corrective action tracking program for Licensee Event Reports (LERs) has been streamlined by adopting the onsite Commitment Tracking
-System for this function. This change is reflected in Revision 3 to PAP-0603,
" Licensee Event Reports" dated November 5, 1986. Additionally, and as y
discussed during your visit, PAP.0606, " Condition Reports and Immediate Notifications" is undergoing revision. This new revision simplifies the instructions for processing Condition Reports, among other changes. This revision is nearing the final approval stage. ~We intend to continue our efforts toward streamlining / simplifying the LER and the Condition Report (CR) processes as we identify opportunities during our ongoing reviews.
1 Observation b)
The licensee should consider taking steps to expedite the action items identified by the Work Review Task Force.
Response
The Work Review Task Force was established to allow deliberate analysis of plant problems for long term, permanent corrective actions. It is necessarily a slow process and is not intended to provide short term, interim solutions.
The Task Force consists of management and technical personnel from several key areas who report to_the Vice President, Nuclear Operations. This provides the management overview and technical expertise necessary to effectively determine l
. root causes of plant problems and to provide permanent solutions to them within the framework of our plant organization without being disruptive to current plant operations. The Task Force is effectively accomplishing its mission and therefore, we intend to continue operating as presently structured.
We, of course, will continue to monitor progress and make changes if necessary.
t Observation c)
The licensee should assure that timely written responses to LER Trend Report recommendations are forthcoming from the applicable organizations.
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. Response Under the current program, although formal response is requested, trend report recommendation status may be verbally communicated or may be verified by Licensing and Compliance Section personnel. We are evaluating several opportunities for facilitating the implementation of LER Trend Report recommendations. Greater emphasis from a management standpoint has resulted i
in improved performance in this area already.
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.Attechnent PY-CEI/01E-0256 L Observation d)
The licenaee should develop a program that assures that operators and technicians are better informed of events that have occurred elsewhere, particularly events that are related.to personne1' error.and/or equipment problems that are similar to equipment or conditions found at Perry. Emphasis
'should also be.placed on assuring that operators are trained on what they should expect to see during the initial plant startup when considering events 7that have occurred at other recently licensed BWR plants during initial startup.
Response
Perry presently has a program which accomplishes'the goals mentioned above, as described to you during your visit. The. Perry Reliability and Design Assurance Section receives, screens and distributes, as appropriate, all-SERs, SOERs, IENs, IE Reports, Vendor Information and Advice Letters and INPO Nuclear.
Network items. Those personnel requiring timely notification of related industry events are kept well informed. The Perry Training Section performs reviews of similar documents for training significance. They determine whether the material should _be presented and how best to present it.
Once this review-is complete, the material may then be incorporated into the approp'rtate training programs, particularly the Requalification Program. -The operators may not be able to describe specific events at other plants by name or in great detail, but the lessons learned and concepts gleaned from these reports are
- either taught'to them, or have already been embodied in the procedures and programs.
Observation e) l The licensee should expand the scope of the I&C Task Force to. include identifying more'short term solutions to plant I&C-problems.
Response
The I&C Task Force was established for the particular purpose of determining how our operational I&C practices compare with other operating plants to allow us to make refinements to our programs. This is necessarily a longer term effort and, as such, is not conducive to the recommendation as stated. We have however,- taken several measures outside of this Task Force effort to improve
. day-to-dcy I&C practices and to immediately correct identified deficiencies as Lthey.have occurred. These measures have included counseling and training sessions as well as procedural and design changes to facilitate performance of I&C surveillances and other activities. We will continue to monitor our I&C
. performance and take short term corrective actions as problems are noted, while the Task Force effort progresses toward its longer range objective.
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I i -- CI Attachment PY-CEI/0IE-0256 L Observation f)
Management should review Perry _ corrective actions for reportable events to see l
'if the current lead time for implementing these corrective actions could be reduced or interim actions taken to reduce the likelihood of recurrence.
Response
Management does review the corrective actions for reportable events to assure timely and adequate interim actions to reduce the likelihood of recurrence.
Our Quality Assurance Department has also reviewed _the effectiveness of corrective actions and has focused on the same concern. We are beginning to see improvement in this area and believe that through continued efforts the likelihood of recurrence of unwanted events will decrease even more.
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