PY-CEI-NRR-0742, Responds to NRC Re Violations & Deviations Noted in Insp Rept 50-440/87-19.Corrective Actions:Sys Engineer Input Will Be Utilized to Evaluate Possibility of Rescheduling Certain Outstanding Tasks

Responds to NRC Re Violations & Deviations Noted in Insp Rept 50-440/87-19.Corrective Actions:Sys Engineer Input Will Be Utilized to Evaluate Possibility of Rescheduling Certain Outstanding Tasks

ML20236N541
Person / Time
Site:	Perry
Issue date:	11/06/1987
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
PY-CEI-NRR-0742, PY-CEI-NRR-742, NUDOCS 8711160219
Download: ML20236N541 (6)

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e THE CLEVELAND ELECTRIC iLLUMIN ATING COMPANY  !

P.O. BOX 97 a PERRv. OHIO 440s1. a. TELEPHONE (216) 250-3737 a ADORESS-1o CENTER ROAD Serving The Best Location in the Nation Murray R. Edelman PERRY NUCLEAR POWER PLANT

. sa. vns entsioEnt , j NUG. EAR November 6,1987 PY-CE1/NRR-0742 L {

Document Control Desk U.S. . Nuclear. Regulatory Commission Washington, D. C. '20555 Perry Nuclear Power Plant Docket No. 50-440 i Response to Notice of Violation 50-440/87019-01 and Notice of De viation 50-440/87019-03 Gentlemen'

.h This letter acknowledges receipt of the Notices of Violation and Deviation {

contained within Inspection Report 50-440/87019 dated October 7, 1987. The 1 report identified areas examined by Mr. Z. Falevita during his inspection i conducted from August 31 through September 4,1987 of activities at the Perry j Nuclear Power Plant, !! nit 1.

j Our 'respense to these items is attached. Please feel free to contact me should -i l

you have any additional questions.

l Very truly yours, I l

Murray R. E 1 man Senior Vice President Nuclear Group MRE: cab At tachment cc: T. Colburn K. Connaughton USNRC, Region 111 8711160219Ohh40 PDR ADOCK O PDR a

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Attachm nt 1 l

!< PY-CEI/NRR-0742 L Page 1 of 3 l I j 50-440/87019-01 (1/2)

' Restatement of the Violation 10 CFR 50, Appendix B, Criterion V, as implemented by Perry Nuclear Power Plant

' Operational quality Assurance Manual requires, in part, that activities affecting quality be accomplished in accordance with approved procedures. '

Contrary to the above:

1. The licensee's responsible system engineer failed to review the following-outstanding and late safety-related Repetitive Tasks (preventive maintenance) for safety significance and/or rescheduling of the tasks as  !

required by Operations Manual Procedure PAP-0906, Revision 1:

No. 485003699 [ sic) (General Maintenance checks on safety-related MCC), 1 No, R86004208 (Maintenance on 4.16KV ESF breaker),

No. R85000145 (Maintenance on safety-related limitorque valve). (

2. The licensee failed to ensure that a monthly review of Lifted Leads, 1 Jumpers and Electrical Devices (LLJED) Tag Order No.15-923, dated  !

November 2, 1985.vas performed in the months of April, June and November,  :

1986 and in the month of May 1987, as required by Operations Manual l Procedure PAP-1402, Revision 4. .

I This is a Severity Level IV violation (Supplement I).  !

Response to 50-440/87019-01-(1)

Corrective Actionc Taken and Results Achieved The Cleveland Electric Illuminating Company acknowledges the underlying' concern behind issuance of the Notice of Violation and believes that actions already underway vill address that concern.

PAP-0906 requires that the System Engineer review and provide concurrence for  ;

safety-related Repetitive Tasks if the work is to be rescheduled to a later j date. This is the preferred action to be taken if a Repetitive Task is abcut 1 to exceed its " late" date. However, the program'for Repetitive Tasks does j allow for work to not be rescheduled, so that it may be performed at the next i practical opportunity. In this case, it is classified as " outstanding", and is I closely tracked. Veekly and monthly reports are distributed to project i personnel to make them aware of these outstanding tasks. The Repetitive Tasks identified in the Notice of Violation remained with the work groups avalting an opportunity for performance, as allowed by the program. The desired goal, however, is to perform preventive maintenance on schedule, or to perform the i engineering review so that the tasks may be rescheduled. In'kecping with this j desired goal, a comprehensive initiative is being implemented at the Perry l Nuclear Power Plant. Tnis initiative is designed to reduce the number of open i_ _ _

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' . Attachment 1 PY-CEI/NRR-0742 L Page 2 of 3 i

vork orders and outstanding preventive maintenance Repetitive Tasks. One of

- the thrusts of this initiative is increased System Engineer input for scheduling of Repetitive Tasks.- This input includes reviews of outstanding tasks for capability of performance during various Operational Conditions.

' Reviews of outstanding Repetitive Tasks have shown that the single most significant factor impacting the ability to perform preventive maintenance '

tasks is.the plants Operational Condition. The System Engineer input vill be.

combined with other available information in_the implementation of an

" Operations Quarterly Schedule". This schedule vill make plant equipment available for preventive maintenance work on a scheduled three-month basis.

Utilization of this schedule should dramatically reduce the number of-  ;

outstanding Repetitive Tasks, and increase the number of future tasks completed on's-hedule. In order to provide for review of Repetitive Tasks which'may be addra to-the outstanding list, a periodic engineering reviev vill be

- imriement v rhis reviev vill determine the appropriate disposition for each Task '> outstanding list.

8.*'.tiona ./, System Engineer input-will be utilized to evaluate the possibility of rescheduling certain tasks which are presently being tracked as outstanding. Vith the establishment of refueling outage dates and the implementation of the Operations Quarterly schedule, engineering consideration can be given to rescheduling selected tasks to coincide with these events.

Implementation of the Operations Quarterly Schedule vill be achieved through a phase-in process. The initial phase vas. begun in late October, 1987. Full development and implementation is expected to take one year.

Corrective Action To Be Taken To Prevent Recurrence Please see the above discussion.

Date of Full Compliance Upon full implementation of the initiatives related to the preventive maintenance program, the concern expressed in the violation should be resolved, i

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Response to 50-440/87019-01 (2)

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- During the course of this inspection, docunientation was provided-to the inspector to show that inconsistency of morthly reviews was a licensee identified issue as.carly as March of 1986. Continued. attention to this subject.through October of 1986 led to drafting of a nev.LLJED Tag Order Form including a special section to document the performance of the monthly review, and improved tracking of review performance by the respcusible section

. . 1 The new LLJED Forms were first draf ted in October 1986, and became effective in

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January of 1987 when Revision 4 of PAP-1402 vas approved. These new forms

. provided a special'section for the monthly review of newly created LLJED tags.

It vas decided that tags hung prior to creation of the nev form would not be backfit.

The improved tracking included creation of a computerized Repetitive Task which required a responsible individual to ensure all the monthly reviews had been performed, beginning in October 1986. The paperwork associated with this

. Repetitive Task was provided to the inspector to prove that th; review of LLJED

Tag 15-923 was indeed performed for the months of November 1986 and May 1987.

.The fact that the ceview for these months had been performed vas. acknowledged by the inspector during the exit meeting at the close of the inspection.

I No further corrective actions are planned in response to this example of the Notice of Violation, due to the effectiveness of licensee actions since October of 1986, and due to the lack of safety significance of this item.

Additional Notes Related to 50-440/87019-01 ,

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. It should be noted that the inspection report states in Section 2.b.(1) that "The NRC inspector informed the licensee that failure to con 61ct a review of late tasks as required by Procedure PAP-0906 is an example of a violation to the requirements of 10 CFR 50, Appendix B, Criterion V". At the exit meeting however, the inspector noted that a number of repetitive tasks were overdue without Engineering approval for rescheduling, and recommended that better )

planning or periodic Engineering review of overdue tasks be performed. It was identified that this recommendation vould be tracked as an Open Item.

It should also be noted that the inspection report states in Section 4.a.(2) that " Based on the above, the inspector informed the licensee that failure to 3 conduct the required technical reviews on a monthly basis as required by the {

procedure is another example of a violation to the requirements of 10 CFR 50, j Appendix B, Criteria V". At the exit meeting however, the inspector explained that his only concern was that the new form had not been backfit to the older tags, thereby resulting in a he.d-to-read form. This item was not identified to the licensee as an Open Item, or Violation-Level IV.

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PY-CEI/NRR-0742 L Page 1 of 2 L 50-440/87019-03 Restatement of the Deviation

.As a result of the inspection conducted August 31 through September 4, 1987, the following deviation.to NRC commitment contained in your letter dated June 20,;1987 was identified.

Commitment "CEI will provide improved permanent barrier separation in the RPS' relay cabincts.(H13-P691, H13-P692, H13-P693 and H13-P694) prior to startup following the July 12, 1987 outage."

Contrary to theLabove, numerous separation violations were identified by the NRC: inspector in the above RPS panels during a follovup inspection conducted to

' determine the effectiveness of'the licensee's corrective action taken to resolve this concern.

Corrective Actions Taken and Results Achieved On June 20, 1987, the Augmented Investigation Team expressed a separation concern when " intruder" divisional. wiring in the RPS panels was found physically touching the predominant panel divisional wiring. Although analysis had shown that the separation was adequate, (i.e. no postulated fault within a single panel vould cause a malfunction of the system associated with the circuits of the redundant train), CEI agreed in our June 20, 1987' letter to provide improved separation for-these wires. This improved separation was provided by installation of a high-temperature-resistant sleeving material over the intruder viring of concern. The Work Order which installed the sleeving.in accordance with the design change package was closed on July 28, 1987.

However, the design change package which directed the work established a more stringent criteria for separation than the " physically,touching" criteria. The-criteria utilized was that intruder viring within six inches of predominant panel viring was to be identified and sleeve'd. When the inspector reviewed the RPS panels in early September, he did not identify any instances where unsleeved intruder viring was touching the panels predominant viring, nor were any instances found where unsleeved intruder viring could have been pushed into close proximity with predominant panel wires. Following identification of instances by the NRC inspector where intruder viring was closer than six inches i to predominant panel vires, a new design change package was initiated, the remaining wires were sleeved, and the responsible engineer conducted follovup reviews of the panels to verify that all the viring requiring sleeves had been worked. This Votk Order was closed on October 9, 1987.

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PY-CEI/NRR-0742.L'

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, '50-440/870192 3 -.(continued) .

' < Thedesighchangehackagesalso. provide.foritheadditionofaNOTEto-the.

%- drawings.,hich addresses the' sleeving material. . This provides;information to  !

' future us'ers:onTthe purpose r of the-sleeving, s'o that future' work'insideLthe ,'3

,s cpanels vill not. unknowingly remove.this material.

It.should'be noted that Report Section 4.a.(1).(a)'and-(b) discussed 1

',6 observations unrelated to the June 20,~-1987 commitment.o.The' subjects of-these

. observations'have since been addressed.

iDate-When Corrective' Action Vill Be Accomplished-L ICorrective actionsThave been completed.-

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