ML20076A963

Responds to NRC Re Violations Noted in IE Insp Repts 50-440/83-13 & 50-441/83-12.Corrective Actions:Charter of QA Advisory Committee Revised to Require Quarterly Meetings

ML20076A963
Person / Time
Site:	Perry
Issue date:	08/08/1983
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076A961	List: ML20076A963
References
NUDOCS 8308180397
Download: ML20076A963 (3)

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P o Box 5000 - CLEVELAND. OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING DLOG - 55 PUBLIC SQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN vict PRE 5lof NT August 8, 1983 NUC LE A R Mr. J. F. Streeter, Chief Engineering Branch I Division of Engineering U.S. Nuclear Regula tory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441

Dear Mr. Streeter:

This letter is to acknowledge receipt of Inspection Report Number 50-440/

83-13; 50-441/83-12 attached to your letter dated July 25, 1983. This report identifies areas examined by Messrs. J. N. Kish. T. E. Vandel, and G. F.

Maxwell during their inspection conducted April 4-8, 13-15, May 10-13, and June 15, 1983, at the Perry Nuclear Power Plant.

Attached to this Actter is our response to the one (1) Severity Level V Violation described in the Notice of Violation dated July 25, 1983. 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, k

M. R. Ed man Vice President Nuclear Group MRE:pah Attachment cc: Mr. M. L. Gildner USNRC Site Mr. R. C. Knop, Chief Projects Branch 1 Division of Project and Resident Programs U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road ,

Glen Ellyn, Illinois 60137 l l

U.S. Nuclear Reguletory Commission l c/o Document Management Branch l Washington, D.C. 20555 8308180397 830812 PDR ADOCK 05000440 G PDR

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J RESPONSE TO ENFORCEMENT ITEM Below is our response to the Notice of Violation appended to United States Nuclear Regulatory Commission I.E. Report 50-440/83-13; 50-441/83-12.

Noncompliance 440/83-13-01; 441/83-12-01.

A. Severity Level V Violation 10CFR Part 50, Appendix B, Criterion II, requires a quality assurance  ;

program be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures or instructions and that the applicant regularly review the status and adequacy of the program.

The Cleveland Electric Illuminating Company (CEI) Corporate Nuclear Quality Assurance Program Manual (QAM), Section 0200, Revisions 0 through 3 (in ef fect until September 15, 1982), requires that the Quality Assurance Advisory Committee perform quarterly reviews of the program and to report the results of these reviews, in writing, to upper level CEI management.

Contrary to the above, this committee conducted only two meetings during 1981. Additionally, the meeting documents did not include any review of ongoing program activity as required even though several significant program deficiencies were reported during 1981 by the monthly performance analysis reports. Furthermore, a formal charter was created and approved in June 1982 for the Quality Assurance Advisory Committee activities.

This charter prescribed semiannual meetings to be conducted contrary to the then current Revision 3 of the QAM.

B. Background Information The Quality Assurance Advisory Committee (QAAC) is established to conduct reguint review and evaluation of the Quality Assurance program and advise the Vice President-Nuclear on the adequacy of the scope, implementation, and effectiveness of the Quality Assurance program. The QAAC is able to fulfill this function by conducting reviews of the Corporate Nuclear Quality Assurance Program (CNQAP) and major changes, overviewing the development and implementation of NQAD procedures and reviewing documenta-tion such as internal audits, NRC Inspection Reports, assessments of Quality Assurance Program Effectiveness and Performance Analysis Reports.

The QAAC was not established in response to the regulatory requirement to periodically assess the adequacy of the Quality Assurance program but was established to provide advice to management on quality assurance matters.

Management does assess the adequacy of Quality Assurance program quarterly via a documented "Assessa.cnt of Quality Assurance Program Effectiveness".

This quarterly assessment has been described by ~ and performed in accordance with Project Administration 0204, since February 1979. Performance Analysis Reports and Assessments of Quality Assurance Program Effectiveness have continually addressed QA problems. These reports are management tools and are supported by separate administrative systems 'o track, monitor and control the . status of any deficiencies discussed. Each month the Manager of NQAD prepares a Performance Analysis Report to the Vice President-Nuclear.

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Although the attachment to this monthly report discussing each contractor's performance was deleted in April of 1982, monthly assessments of each contractor continue to be maintained and are used as input for the NQAD Performance Analysis Report and the quality Assessments of Quality Assurance Program Effectiveness. This was done to better focus management attention on contractor performance that was out of the ordinary.

C. Response

1. Corrective Action Taken and Results Achieved In response to the noncompliance cited above, the following explanation is set forth.

In 1981, the QAAC had scheduled four meetings. The March and June meeting were held on site. The June meeting emphasized the need to evaluate the Operations QA program and during the third quarter of 1981, three members of the QAAC (including the Managers of Quality Assurance and Perry Plant Departments) visited three operating nuclear power plants. The December 1981 meeting was postponed until January of 1982. The QAAC met four times in 1980, eight times in 1982, and has met already six times in 1983.

The charter for the QAAC existed as a paragraph in Section 0200 of the CNQAP until June of 1982 when a separate, more detailed charter was developed. The revised charter required a semi-annual QAAC meeting frequency. The CNQAP requirement of quarterly QAAC meeting was not revised until September of 1982.

2. Corrective Action Taken To Avoid Recurrence The charter of the QAAC was revised in July of 1983 to again require quarterly meetings.

3. Date When Fu11 Compliance Will Be Achieved Full compliance has been achieved.

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