ML19256E179

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Immediate Action Ltr Discussing 790207 & 08 Telcons Between D Davidson & R Heishman Re Implementation of QA Program Examined During 780124-26 & 0202-03 Insps.Lists Activities Requiring Corrective Action
ML19256E179
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 02/08/1979
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Davidson D
CLEVELAND ELECTRIC ILLUMINATING CO.
Shared Package
ML19256E176 List:
References
FOIA-79-410 780208, NUDOCS 7910290478
Download: ML19256E179 (5)


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UNITED STATES sna macu g#s NUCLEAR REGULATORY COMMISSION j, g{?.,j q

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f cLEn zu.vn, stunois sour FEB D 81978 Docket No. 50-440 Docket No. 50-441 The Cleveland ctric Illuminating Company ATTN: Dalwyn R. Davidson Vice President-Engineering Post Office Box 5000 Cleveland, OH 44101 Gentlemen:

This refers to the telephone conversations oetween Mr. D. Davidson and other members of your staff and Mr. Beishman and other members of my staff on February 7 and 8, 1978, relative to our concerns regarding the i=plementation of your quality assurance program at Perry Nuclear Power T ant, Units 1 and 2, identified during our inspection conducted Januar;

' '!6 and February 2-3, 1978.

Based on our telephone converr.tions, we understand that the Cleveland Electric Illuminating Company (CEI) has 'taken or will take the actions delineated below and that the status and/or results of these actions will be reported to our office by telephone following their completion. Additionally, we understand that with respect to items 1 through 5 below, these activities will not be resumed until your corrective action has been reviewed and determined to be acceptable by the NRC.

In this regard, NRC inspectors vill be at the Perry site on February 9,1978, to review your actions regarding items 3 and 5 prior to the placement of safety related concrete.

1.

Field erection of safety related yard piping (SP-47-4549-001) by PPP has been stopped and will not be resumed until:

Deficiencies in PPP's quality assurance program and a.

implementing procedures in the areas of design document co_ntrol and piping erection and handling have been corrected.

1224 176

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..G, The Cleveland Electric FEB 0 81978 Illuminating Company b.

The site QA/QC organizations have been provided with clear and specific instructions relative to which drawings and associated instructions (GAI vs PPP) are to be used as the basis for determining that GAI's design criteria have been met.

c.

A GAI qualified piping engineer has been sent to the site to review and approve PPP developed procedures and drawings for the erection of piping.

GAI approval of all procedures and drawings will be made prior to installation of yard piping.

In addition, for the previously placed yard piping procedures and drawings will be reviewed and approved by this engineer.

These measures will re=ain in effect until CEI evaluates'GAI's design review requirements defined in SP-47-4549-001 and PSAR, Section 17.1.3.3.b and the results of their evaluation are reviewed by the NRC.

d.

100I GAI resident inspection has been instituted on all safety related pipe being fabricated. These measures will remain in effect until CEI can demonstrate to the satisfaction of the NRC that the existing sa=pling inspection procedure meets ANSI N45.2, Section 11, as required by PSAR, Section 1.2.3.

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2.

, Field erection of safety related plant piping (SP-44-4549-001) by Pullman Power Products (PPP) has been stopped and will not be resumed until:

a.

Requirements for GAI's review and a'

. of PPP's drawings and associated instructions for the piping governed by Specification No. SP-44-4549-001 have been reestablished; and b.

Items 1.a. 1.b and 1.d, above have been completed.

3.

Installation of safety related embedments and structural steel, supplied by PBI Industries and its subcontractors, has been stopped. Neither activity will be resumed until the specific material to be used has been evaluated and determined to meet the specified requirements of AWS D.l.1 - 1972 prior to placement.

This will be accomplished through performance of one of the following inspections, as applicable:

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FEB 0 81978

. The Cleveland Electric Illuminating Company 100% CQC inspection of all material in a proposed concrete pour prior to concrete placement.

a.

100% CQC inspection before any material is released from a site organization storade facility.

b.

100% CQC receiving inspection on all material.

c.

Items a, b and c above will be performed in accordance QA Program.

with approved procedures, as required by the CEI d discussed to occur will be evaluated and corrected by CEI an with the NRC before altering the measures established above.

Safety related work, performed by your coating contractor, O. B. Cannon & Son, Inc. has been stopped and will not be 4.

resumed until deficiencies in their quality assurance program f

and implementing procedures in the areas of verificatien o

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d materials prior to use, qualification of personnel an performance of audits have been corrected.

Placement of safety related concrete by each of;your contracto.

has been terminated and no contractor will resume t 5.

until:

Full time CQC inspectors are assigned to enforce a(Wh a.

new slu=p procedure.

l that will trigger a slump test of every additiona i

truck until the slump is brcught within specificat on.

The subsequent slump test failures will result in that Once a truck slump is tested concrete being wasted.

ill within specification the normal testing frequency w be adopted.)

Field instruction by CQC inspectors has been b.

particular contractor QA and QC pe.sonnel invo.'ved.

CQA will audit the performance of items a and b, above.

c.

These mear res vill remain in effect until the ac and are reviewed by the NRC.

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Establish procedures to preclude placement of nonconform

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concrete, as identified by excessive slu=p; and a.

1224 178

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O FEB 0 81978 The Cleveland 31ectric Illuminating Co=pany b.

Establish training / retraining requirements to ensure proper consolidation during placement by the correct use of vibrators.

6.

CEI will establish an effective contract specification control system and will evaluate the acceptability of the placement of concrete batched by the National Mobil Company to a superseded design specification during the time period from August 5, 1977 until the present date.

7.

CEI or an independent agent will perform audits of the onsite organizations covered by the CEI quality assurance program (L luding the Construction Quality Assurance (CQA) and Construction Quality Control (CQC) Elements) to determine the adequacy of established indoctrination, training and retraining programs, and the implementation of these programs.

Additionally, specific emphasis will be placed on the identification and documentation of nonconformances to gainfully utilize your established nonconformance trend analysis system.

8.

CZI or an independent agent will evaluate the existing program, procedures and methods governing the activities described below to determine the cause of items i through 6 above and to determine

, why these had not been identified by the responsible corporate / site organizations.

a.

Qualification and program audits of the contractors performing safe.ty related work; and b.

Verification of compliance with all aspects of the CEI quality assurance plan and the determination of its ef.fectiveness.

The results of this evaluation will be factored into the CEI quality assurance plan and implementing manuals and procedures which are currently being revised.

With respect to items 6, 7 and 8, your action will be completed by May 1, 1978.

  • %s 1224 179

IMMEDIATE ACTlDN LETIER

'O' na Cleveled zieceric

-s-FEB 0 81978 Illuminating Company Please inform us imediately if your unde.rstanding cf thasa items is different from that stried above.

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Sincerely, 4

James G. Keppler Director cc:

W. P. Ellis, FC&EB Iana Cobb, Plans &

Analyses X entral Tiles Reproduction Unit NRC 20b PDR Local. fDR NSIC TIC U. Young Park, Pcwer Siting Cosnission i

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