ML19208D118
| ML19208D118 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/01/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19208D116 | List: |
| References | |
| 50-440-79-03, 50-440-79-3, 50-441-79-03, 50-441-79-3, NUDOCS 7909280010 | |
| Download: ML19208D118 (3) | |
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Appendix A NOTICE OF VIOLATION The Cleveland Electric Docket No.30-440 Illuminating Company Based on the inspection coaducted on July 10-12, 1979, it appears that certain of your activities were in noncompliance with NRC requirements, as noted below. These items are infractions.
1.
10 CFR 50, Appendix B, Criterion X, requires that, a program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
The PNPP PSAR Chapter 17, Section 17.1.10 statec in part that,
" Quality will be controlled by inspection.
Appropriate mandatory hold points.
. shall be identified.
. and activity may not proceed beyond.
Records shall be maintained describing results and verifying that inspections were performed.
The Newport News Industrial ASME Nuclear QA Manual Rev. C, dated October 10, 1978, Section 10.1500 states, in part, that "Each step of the Manufacturing Installation Instruction (MII) will receiv verification signature and date on completion, including all.
QA hold points. The.
. Superintendent will sign off.
installation steps."
Contrary to the above, the NRC inspector observed numerous instances in which contractor personnel failed to execute the program for inspection by failing to verify conformance per documented instructions and procedures. The inspector reviewed four contractor MII's used for the ins allation of some ten pieces of safety related components such as: Reactor Vessel (Unit 1), RHR and LPCI discharge heads and suction barrels, RCIC pump and turbine, Reactor Vessel anchor stud installation, and Control Complex Chiller baseplate modification.
The inspector noted numerous and widespread examples of the following in 3 of 4 procedures:
Both QC and Trade signatures were missing for work completed.
a.
(Some 12 steps of the Reactor Vessel Alignment procedure during Unit 1 Installation. One complete operation of the Vessel anchor stud installation - Step 600.)
b.
QC and Trade signatures out of sequence.
(Some 7 steps of Unit 1 LPCI grouting operation were signed by QC 15 days prior to trade signoff. One operation step of the Chiller baseplate modification was signed by QC 3 days prior to Trade signoff.)
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Appendix A,
c.
QC signatures by themselves for work completed. No Trade signoffs.
(Two extensive operational steps of Reactor V,essel preps for installation and alignment and lubrication.
Seventeen steps for the location and alignment of LPCI discharge head and suction barrel.)
d.
Required QC Hold Points ignored. No QC signatures on completed work signed off by Trades. QC required.
(1) On the grouting operation of seven pieces of safety related components, 37 steps completed with no QC signoff.
(2) On the alignment of safety related suction head and barrel of (B) RHR, three staps with no QC signoff.
(3) One operational step for each of five safety related suction head to barrel installations with no QC signoffs.
These examples indicate a breakdown in the inspection verification system.
Completed work verfication cannot be confirmed.
2.
10 CFR 50, Appendix B, Criterion XIII, states, in part, that " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."
The Cleveland Electric Illuminating Company (CEI) Corporate QA Manual - Introduction Section and Section 1300 states, in part, "This manual.
. provides a QA program which complies with the regulatory requirements of 10 CFR 50, Appendix B, ANSI N45.2.2 and those regulatory guides.
CEI Contract Specification SP38-4549-00 dated July 16, 1976, Paragraph 5:06.2.c commits the Installation Contractor, Newport News Industrial (NNI), to the requirements of ANSI N45.2.2, Handling and Storage of Items of a Nuclear Plant.
ANSI N45.2.2, Section 3.5.1, states, in part, " Caps and plugs shall be used.
to protect threads and weld end preparations." Section 6.4.2 of ANSI N45.2.2 states, in part, " Covers removed for internal access at any time for any reason shall be immediately replaced and resealed after completion of the purpose for removal." Section 6.2.2 of ANSI N45.2.2 states, in part, " Cleanliness and good house-keeping practices shall be enforced at all times.
." Section 6.5 of ANSI N45.2.2 sta;es, in part, "ltems released from storage and placed in their final locations within the power plant shall be inspected and cared for in accordance with the requirements of JU
Appendix A -
Section 6 of this standard..
ANSI N45.2.2, Section 3.2.3(1),
Criteria 7 states, in part, that all openings into items shall be capped, plugged, or sealed.
Newport News Industrial Equipment Maintenance Instruction 1240-F-S002, Section 7, commits NNI to the administration and control of a program of field storage and protection of safety related equipment. The reporting system lists items such as:
Corrosion or Rust Visible Equipment Openings Sealed Connecting Flanges Protected Heater in Operation Contrary to the above, on July 10-12, the NRC Inspector observed the following:
Unit 1 Safety Related RHR and LPCI pump discharge heads and a.
suction barrels presented connecting machined surface flanges that were unprotected from possible physical damage. Visible rust was present on the connecting flange machined surfaces.
Widespread rust was present on the internal surfaces of the discharge heads. Equipment openings were not sealed to the environment.
Installation threaded studs were exposed to rusting and unprotected from possible physical damage from construction activities.
b.
Unit 1 RCIC pump and turbine space heater was not operating as required by NNI Instruction 1240-F-S002. The environmental storage enclosure was open to atmosphere.
The NNI Field Maintenance Records of tF. subject equipment did c.
not report or record the conditions listed on Items 1 and 2.
NNI Surveillance Records were updated one half day prior to the NRC Inspection and did not reflect the conditions. The reporting requirements in regard to corrosion, protective covers, sealed openings, and heaters are listed in NNI Equipment Maintenance Instruction 1240-F-S002, Rev. G, dated May 1, 1979.
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