ML19327B077

Responds to NRC 890911 Ltr Re Violations Noted in Insp Rept 50-440/89-22.Corrective Actions:Rev to Administrative Procedure,Clarifying Use of Overtime Deviations Approved & Surveillance Instruction M16-T2001 Reperformed Successfully

ML19327B077
Person / Time
Site:	Perry
Issue date:	10/11/1989
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PY-CEI-NRR-1071, NUDOCS 8910250126
Download: ML19327B077 (4)

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P THE CLEVELAND ELECTRIC ILLUMINATING COMPANY P.O. pox of a e TELEPHCNE e PEmmy, oHoo 4 Ast Q10)DS3787 ADDMESS 10 OEN7tR h0AD FMOW CLEVELAND. 341 1960 Serving The Best location in the Nation Al Kaplan PERRY NUCLEAR POWEM PLANT VICE MW BOf NT N A EA8io W P-October 11, 1989 PY-CE1/NRR-1071 L i

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W U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Perry Nuclear Poder 11 ant y Decket No. 50-440 Response to Notices of Viointion 50-440/89022-03 and 50-440/89022-15 and OJ en item 50 440/89022-20 Centlement This letter acknowledges receipt of the Notices of Violation contained within Inspection Report 50-440/89022, dated September 11, 1989. This report identified areas examined by Mr. P. Hiland during his inspection conducted from August 7-23, 1989 of our responso to the Diagnostic Evaluation Team report.

Our response to Notices of Violation 50-440/89022-03 and 50-440/89022-15, and Open item 50-440/89022-20 is attached, please call should you have any additional questions.

Ver t rul e ou s .

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Al Kaplan Vice President Nuclear Group AKinjc Attachment cc: T. Colburn P. Hiland R.C. Knop - USNRC, Region III I q l

8910250126 891011 PDR ADOCK 05000440 G .

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Attcchment 1 PY-CEI/NRR-1071 L Page 1 of 3 i

50-440/89022-03 .

Restatement of Violation 10 CPR 50, Appendix B, Criterion XVI requires in part that measures shall be established to assure conditions adverse to quality are promptly identified and corrected. l t

i; Contrary to the abovei On October 19, 1988, the licensee responded to Notice of Violation '

f 50-440/88012-02 concerning failure to comply with Administrative Controls for overtime hours of unit staff pursuant to Technical Specification 6 2.2.a '

stating that adequate corrective action had been taken to prevent recurrence.

As detailed in the Diagnostic Evaluation Teams Report for the Perry Nuclear ,

rover Plant dated May 1989, Section 3.2.2, a licensee audit identified 9  !

instances between June and Hovember 1986 where administrative controle vere not adhered to. In addition, licensee Audit 89-17, Action Requesta 0002, l dated July 13, 1989, identified cientinued failure to adhere to administrative  ;

controls for overtime hours of unit staff personnel. ,

This is s Severity Level IV Violation (suppleaent 1) /.50-440/89022-03 (DRP)).

i Corrective Actions to Avo!.d Further Violations ,

Operations Section became evare of those deficiencies during a follovup reviev of the ef fectiveness of previous corrective actions on this subject. .

Immediate actions included a management memorandum to the Shift Supervisors instructing them to investigate the possible violations for their crew.  ;

Quality Auditing documented this in their Action Request 89-12-0002, which in turn resulted in this violation. In order to prevent recurrence, a revision to Plant Administrative Procedure (PAP-110) " Shift Staffing and Overtime" vas j approved which further clarifies the identified items, especially the use of Overtime Deviations. This revision stresses that only under unusual  ;

circumstances should deviations from the overtime guidelines be permitted. It  !

details who vill complete the Overtime Deviation Requests and who has the authorization to approve these deviations. Personnel affected by this  ;

revision vill be informed of these changes through the procedure revision training process. Additionally, all managers and first line supervisors vill f be trained to the violation and the lessons learned from this event. .

t Date of Full Compliance Full compliance vill be achieved with the effective date of December 12, 1989 i

( to this revision of PAP-0110.

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• PY-CEI/NRR-1071 L  !

Page 2 of 3 L i

i 50-440/89022-15 .

Restatement of Violation 10 CFR 50, Appendix B, criterion V requires in part that activities affecting  !

quality shall be accomplished in accordance with instructions. t Contrary to the above: t On February 20, 1989, the licensee failed to correctly perform Surveillance  ;

Instruction (SVI)-M16-T2001 which resulted in an inadequate test. The details  ;

of. this violation are contained in the Diagnostic Evaluation Team Report for i

! the Perry Nuclear Power Plant dated May 1939, Section 3.4.1.

i This is li Severity Level IV Vitlatten (Suppler.ent I) (50-440/89002-15(DRP)) ,

Cotrection Actions Taken and Iter.ults Achievard This SV1 var repterforimtd 3n:1 correctly completed prior to the axit of the i t

Diagnostic Team. This item was evaluated in eccordar.cn with the Condition Report process. SVI-M16-T2001 vaa revised per condition P,eport 89-066 to ,

clsrify the conditions for a satisfactory Position Indication Test (PIT). The r operator involved was counseled on the perfrorrance of SVI's.

Correction Actions to Avoid Further Viols,tions Plant Administrative Procedure (PAP-1101) "Incervice Testing cf Pucps and Valves" currently contains directions for a satisfactory valve position verification. In order to further clarify the requirement and to prevent recurrence, the Responsible Eystem Engineers vill perform a comprehensive review of the Pump and Valve It: service Testing Instructions, during which the directions contained in PAP-1101 vill be explicitly included in the individual SVI.

s During operator training this Notica of Violation vill be discussed.

Operators vill be reminded that remote position verification as defined in PAP-1101, is by actual stem position or other local indicator physically connected to the stem.

Date of Full Compliance Full compliance vill be achieved through the processing of the instruction revisions, to be completed by April 4, 1990.

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At10chment PY-CEI/NRR-1071 L Page 3 of 3

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50/440-89022-20  ;

Restatement of open Item  ;

As detailed in Section 3.6.1.3. of the DET inspection report, the inspectors expressed a concern that, since selected areas in the Nuclear Engineering and c Plant Technical departments relied heavily on contractor support, a rapid  !

reduction in contractor support could adversely impact the licensee's ability ,

to accomplish engineering support tasks. The licensee's response to this item stated that a five year plan was under development and that any reductions in ,

staffing size vould be consistent with the goals of that five year plan. The .

inspectors advised the licensee that their response to this item was general l in nature and did not explicitly discuss actions that vould be taken to ,

minimite the impact of rapid contractor support reduction. The inspectors requested and the licensee agreed to provide an edditional response to this item. The subject of contractor support is considered an Open Item ,

(550/89022.20(CRP)) pending receipt and the inspector's review (I the requested additional infoImation.

Diagnostic Evaluation Team Response A fi',e year plan for the Perry Plant is under development. As pcrt of thir effort, a detailed five year plan for engineering support is being developed.

The staffing levels in both the Perry Plant Technical Department and the Nuc' tear Engineering Department vill be adjusted as recessary to support the five yest plan. Any reductions in staffing size vill be consistent with the goals of the five year plan.

Additional Response It is the responsibility of the Managers / Directors to ensure the necessary staff and qualifications to meet ANSI 18.1 requirements. As part of the detailed five year plan for engineering support many actions are being taken to minimize the impact of contractor reduction. Specifically, permanent plant positions for selected contractor personnel are being considered.

Additionally, through the career opportunities program personnel vill be evaluated for assignment to areas where their expertise can be better utilized. Some contractor staff vill be maintained until a sufficient turnover to permanent personnel can be achieved. All of these actions vill be evaluated with the safety of the public and the plant in mind.

NJC/ CODED /2686 l

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