ML19256E181
| ML19256E181 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/01/1979 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19256E176 | List: |
| References | |
| FOIA-79-410 NUDOCS 7910290485 | |
| Download: ML19256E181 (15) | |
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j THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY
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ILLUMINATING SLDG e PUSUC $0UARE e CLfVELAND. OHIO 44101 e TELEPHCNE (216) 623 1350 MAIL ADORESS: P. O 80x 5000 Serving The Best Location in the Nation Dalwyn R. Davidson VICE PRt560ENT. ENGINEEmMG May 1, 1978 Ib WO Mr. James G. Keppler, Director U.S. Nuclear Regulatory Cv ission Regiou III Office of Inspection b' ' Y f and Enforcement 799 Roosevelt Road Glen Ellyn, Illinois 600137
Dear Mr. Keppler:
This letter is our response to your I= mediate Action Letter of Febmary 8, 1978. The I==ediate Action Letter addressed eight areas of concern.
The first five items have been resolved with the members of your staff, as a result of inspections on site and review of the actions taken on our part. In order that this letter be co=plete, I have attached as Appendix 1 a brief su-ey of the first five ite=s and resolution status.
With respect to Ite=s 6, 7 and 8 of your letter, a thorough reviev vas undertaken both internally and with the use of an outside auditing team, in order for us to address these concerns.
Item 6 of the February 8, 1978 I==ediate Action lette in part identifies the need to establish an effective contract specifications control system.
In response to this concern, the system was reviewed including auditing of all project and safety-related contractors files.
In the audit of the existing files deficiencies which were found, have been corrected and all files updated including control copies. De
" Specifications" include attach =ent Specifications, Engineering Change Notices, and Field Variance Authorizations.
The system was then reviewed and several modifications were made. In general these consisted of the following:
A.
The system now utilizes s, control number distribution with return receipts required. All distribution responsibilities are now at the Site Docu=ent Control Center.
B.
The specifications status system is in part monitored on a eccputerized/teminal system identified as NEWSPEC. Fiel Ok Variance Authorizations are presently monitored manually.g
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A maintenance system was established which centralizes the responsibility for inputting of all new or change in-formation through the Site Document Control Center. he
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p Mr. James G. Keppler May 1, 1978 system provides for continuous monitoring of specification status, however, periodically, at a minimum quarterly, a status review will be conducted as spelled out in a project procedure. In addition, audits by Site Quality Assurance vill be performed to verify correctness.
C.
The project and contractor files were updated including elimination of zeror copies.
D.
Procedures vere developed to define the system and spell out the mechanics to operate it. In addition, instructions have been developed for personnel operating the system.
E.
All project and construction personnel received training and indoctrination presentations. Included were the familiarization with the procedures and scoping of responsibilities.
With the i=ple=entation of the above ve consider we have in place an effective system for assuring the timely and controlled distribution of specifications. All safety-related construction contracts are included and non-safety and equip ent contracts vill follow.
An evaluation was performed to determine the acceptability of the concrete batched by National Mobile Co=pany to a superseded design specification during the time period from August 5,1977 to February,1978. The result
. of this evaluation by the cognizant design engineer concluded that the concrete produced to revision VI of SP-14 h549-0000 vill ratisfy the design requirements. Each of the 31 modifications that ve2e made in revision VII of SP-14-4549-0000, vere evaluated. These modifications were in the following general areas:
1.
Expansion and clarification to re=ove redundencies and resolve conflicts.
2.
Modification of certain procedural changes that do not affect quality.
3 Modification of certain require =ents to facilitate field conditions without sacrificing quality.
Most of these modifications incorporated into revision VII had been previously issued as ECN's applicable to revision VI. It is our opinion and that of the responsible design ecgineer, that production of quality concrete at the Perry Plant was not affected by any re-vision of the specification being held by the batch plant contractor.
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Mr. James G. Keppler May 1, 1978 Item 7A. An evaluation of the indoctrination and training program was made. It was concluded that the program needs improvement.
Accordingly CEI will restructure the indoctrination and training program to include a unifom approach to indoctrination and training for various organizations, including contractors. Outlines vill be co=pleted by =id-May and the schedule for i=plementing training sessions vill be co=pleted by the third week of May. Regular in-doctrination sessions vill be started during May and vill continue on a regular basis as defined in the indoctrination and training outline.
Item 73. During our evaluation it was deter =ined that the concon-for=ance reporting system as i=plemented on the site, is an effective system. There have been occasions however where docu=ents other than nonconformance reports have been used to note problem areas. F.ffective i==ediately, a policy statement has been issued that only noncon-for=ance reports will be utilized in defining nonconfor=ing conditions.
Item 8.
To evaluate our program effectiveness, a special Quality Assurance Task Force was established consisting of represeatatives from Gilbert Associates, Inc., Kaiser Engineers, CEI and ar independent QA consultant Mr. J. P. Jackson of Management Analysis Co=pany. The
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Special QA Task Force has performed a thorough evaluation including on-site and off-site audits.
This Task Force issued an Interim and a Final Report evaluating the
'overall effectiveness of our program. The methodology of the Task Force was to conduct indepth interviews with all key project personnel plus audit selected contractors and site ele =ents (CQA, CQC and FC}O),
and the home office departments (NED, Purchasing, and NQAD).
The Task Force then evaluated the results of these audits and interviews with respect to the effectiveness of the program. This translated into specific findings relative to the appropriate 10CFR50, Appendix B criteria and the FNFP PSAR Chapter 17 co==itments.
Reccx:=endations were provided and a plan has been established based on these findings in order of priority which addressed relative significance to the action necessary to i= prove our program effectiveness. The priorities the=selves were based on:
a.
Those items which were critical to the overall corrective action program and required top manage =ent priority, b.
Those actions which vere required for QA progrs= i=plementation, c.
Those actions required for improve =ent to the CA program.
The following conditions were identified as a result of our evaluations as those that have contributed to the causes of the ite=s identified as Ite=s 1 through 6 in the I= mediate Action Letter.
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Mr. James G. Keppler It-May 1, 1978 A.
The CEI QA Program is defined in many different manuals.
There is no single manual that defines critical controla necessary to i=plement the QA program on a corporate basis. This lack of definition as to who is responsible has resulted in confusion as to primary responsibility in implementing the program.
B.
The techniques for resolution of conflicts has not prsvided timely response to noted problem areas. Additionally, the degree, of =anage=ent involved in resolving problem areas within the CEI QA program has not been co=ensurate with the need for resolution of CA program issues.
C.
Thereorganizationof1977which=ergedthaSiteQA/QC activities, created voids in certain areas of the QA pro-gram which should have included redefinition of responsibilities, particularly in the area of surveillance / inspection and audits.
D.
Each contractor is held totally responsible for total QA pro-gram, without consideration for the integration of CEI QA/QC functions with those of tb ue contractors.
Cc=ensurate with the priority of the recomendations CEI has acco=plished those items which were identified as critical to the overall corrective action program and required top mana6e=ent priority. The following
, seadzes the changes initiated and co=pleted.
1 Item 1 -- The QA/QC organization at the site has been re-organized to unify it under the direction of a General Supervising Engineer. In addition the assign =ents have been revised so as to provide a single responsible quality engineer for each contractor.
Item 2 -- The Site Quality Manuals are in the process of being consolidated reflecting the redefined responsibilities and procedures of the site QA/QC organization.
Item 3 -- A QA Advisory Cc=mittee has been established to assist the CEI Nuclear Quality Assurance Department Manager with inputs and recceecdations to key program de-cisions, orientation t.f QA concepts and methods as well as accessing overall cc rporate support by CEI/GAI/KEI to the direction taken by the Nuclear Quality Assurance Department Manager.
This ce==ittee will be ce= prised of Mr. M. R. Edel=an, Manager of the Nuclear Quality Assurance Department, Mr. N. R. Barker, Manager of Construction QA at Gilbert Associates, Mr. E. V. Knox, Corporate QA Manager of Kaiser Engineers.
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Mr. James G. Keppler May 1, 1978 Item 14 -- The Nuc1. ear Quality Assurance Department Manager has establishe1 a plan ttich provides a schedule for co=pleting modification to the QA program.
Weekly meetings have been scheduled to track and report progress to upper =anage=ent.
Additionally, the Nuclear Quality Assurance Depart-
=ent Manager has established a program of quarterly reviews to CEI top =anagement to incorporate the inputs from the Advisory Cdttee, as well as, re-view the QA proi;~am through evaluation of audits, corrective action reports and other =anagement tools.
Ite= 5 -- The Nuclear Qaality Assurance Department has been reorganized to reflect the findings and reco==endations of the Audit Task Force. Attach =ent 2 depicts the rivised organization and lists the primary responsi-bilities of the key individuals involved.
Item 6 -- CEI has established a schedule for the restructuring of the audit. program, both at the Site, cur con-tractors and our QA agents.
Item 7 -- CEI has established and has started the i=plementation attheSiteofanintegratedinspection/ surveillance prog am.
The program includes vitness points tied to contractors inspection planning docu=ents and includes in-process surveillance inspections, as well as, surveillance inspection of co=pleted work. The surveillance inspection planning vill be approved by a responsible Quality Engineer. Co=plete i=plementation is anticipated by =id-June.
Item 8 -- The receivi g inspection program has been expanded beyond a count and da-age check and is now based on input of quality engineering to 6eter=ine on a case by case basis the necessary inspection required.
I=plementation has been started with co=plete i=plementation anticipated by mid-June.
Item 9 -- The NQAD Manager vill use the formal =anagement chains to resolve conflicts, with the corporate QA program clearly indorsing his authority to resolve quality issues. The corporate quality assurance management co=nittee has been redefined as a emication vehicle.
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Mr. James G. Keppler May 1, 1978 In addition, actions that were identified by the Task Force and dee=ed necessary, but not yet co=pletmi, are as follents:
1 CEI has strengthened our quality assurance program, by co=pleting the ite=s described previously.
In addition we purpose to reissue our Corporate Quality Assurance Manual to reflect these i= prove =ents as well as clearly define the interfaces between all departments perfoming quality related functions. This manual vill reiterate the strong CEI co==it=ent to the QA progra= indicating that the manual =ust be followed by all persons involved with respect to the Perry Project, and that changes will be considered and processed i==ediately if the situation varrants. The manual vill clearly provide guidance on how CEI will address with Regulatory Guides identified in the PSAR. Scheduled ec=pletion date for issuance of this
= anvil in August,1978.
2.
CEI vill evaluate the effectiveness and expertise of pre-sently available in-house personnel, consistent with the revised departmental organization. CEI will e= ploy ex-perienced quality assurance personnel in the key supervisory roles as defined on the revised organizatica cha::t, as shown in Attach =ent 2 of this letter. This eva.i.uation vill be co=pleted by June 1.
CEI will continue to draw upon Gilbert Associates and Kaiser personnel for support as'.dee=ed necessary by the Nuclear QA Department Manager.
3.
CEI will restructure the audit program and cooniinate the audit review reports frc= all ele =ents. The audit program will cover all aspects of the program including ag ots, design activities, construction activities as well as uternal CEI activities. This revised audit program vill serve as the backbone for the Nuclear Quality Assurance Department Manager as a tool to access the effectiveness of our overall QA pro-gram. This is anticipated to be i=ple=ented by June 1.
4.
CEI will p mvide direct support to selected contractora in theQA/QCareawhereitisdeter=inedbytheresponsible qualif y engineer that such support is needed. This will prevent de= ands on contractors to establish QA progrs=s that are beyond their capabilities to imple=ent effectively.
This will be i=plemented on as needed basis.
5 Additional detailed reco==endations for i=provement in the CEI QA Program based on the Special QA Task Force have been reviewed and vill be included as appropriate in the revised QA Manual. These are anticipated to be co=pleted
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by August 1, 1978.
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Mr. James G. Keppler May 1, 1978 In summy the three month accessment made of our program by the out-side auditing team plus our own evaluations as te our effectiveness have provided beneficial input to all parties involved.
Significant improvements have been made and vill continue to be made to make our pregram overall more effective.
I will provide cloce attention to the development of the revised QA Manual and review the effectiveness of our overall quality assurance program. With the cdtments that
<e have made and, the changes that have been i=plemented, we feel that our quality assurance program vill provide a effective means of controlling quality on the Perry Project to insure the plant is built to aplicable standards and designs.
Very truly yours, d,
Dalvyn Davidson Vice President - Engineering DRD:ge Attacb=ents 122zi 187
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SU! NARY OF ACTION TAKE:7 ON IMEDIATE ACTION T2 TIER ITE:G 1-5 RACKGRCUND Based on concerns noted in Ite:ns 1-5 of the NRC I=ediate Action Letter of February 8, 1978, nu=erous actions have been taken and these actions have received concurrance during various NRC inspections. The following is provided as a suT..ary of these activities. NRC letter of March 31, 1978 Inspection Report No. 50-MO/78-03, 50-Wl/78-02 provide additional detail and NRC evaluation on these actions.
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.J Item 1 and 2.
Safety-Related Piping Fabrication and Installation
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Deficiencies noted by the NRC, prompted CEI G Elements to stop work on Pullman Power Products in the areas of safety-related pipe fabrication, yard piping installation, and plant piping. Several modifications to the specifications and the quality program requirements were initiated by CEI, GAI, and PPP. These measures included Pull =an initiat-in6 procedures for " Document Control" and " Design Control" which were submitted to and approved by the CM Ele =ent.
Pn11 man fabrication and erection drawings have been sub=itted to GAI Design Engineer for review and approval in accordance with these procedures. Gilbert Engineering has issued an ECN to SP-M which establishes the requirements for the Design Engineer's review of contractor's piping drawings.
This area has been monitored by C M to assure that these require-nents are being =et.
Pullman has imple=ented a procedure for " Field Handling of Materials and Equipment" which was approved by the CM Element. C@ has witnessed Indoctrination and Training classes conducted by Pullman on CA Program Requirements. These classes were docu=ented and are to continue on a reSular basis.
Pullman has since e= ployed a training officer on site to conduct these classes.
One hundred percent surveillance inspection was imple=ented by the GAI Resident Inspector at Pullman's Williacsport, Pennsylvania shop. On March 16, 1978, Mr. R. L. Spessard of NRC Region III approved the use of a sa=pling plan per MSP-033, Rev. 3, and CEI letter dated March 9,1978.
CEI letter dated February 18, 1978 established the require-ment for the GAI Design Engineer to:
1.
Review 100% safety Class I spool drawings.
2.
Sa=pling per MSP-033, Para. C 3d applied to spool drawings only for safety Class II and III.
Subsequent NRC review of these corrective action measures resulted in the release of Pn11 an Power Products for safety-related work.
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Item 3.
PBI Industries Safety-Related Structural Steel and Embedments 3
The installation procedural controls on safety-related estcdrenta and structural steel have been modified to assure co=pliance to AWS D.1.1-1972 prior to placement. The CQC element has superimposed an inspection program of 100fo verification of the vendor's and our manufacturing assurance inspection programs.
These additional inspection measures include 100% receiving in-spection of all new embed =ents and structural steel delivered to the site,100% inspection of all embed =ents and structural steel currently in inventory prior to their issur e to contractors, and for those ite=s previously issued,1007. Anspection of all embed =ents and structural steel prior to their placement.
These currently established measures have been reviewed and found acceptable by NRC inspectors as indicated in the March 31, 1978 report (50-40/78-03,50-W1/78-02).
To establish compliance at the vendor's facilities the CEI vendor assuraou program has been increased to include 100% surveillance of all embed =ents and structural steel being fabricated. Finally, the vendor's inspection program has been altered to include the additional detailed acceptance criteria provided by the Design Engineer.
When PHI and its subsidiaries are released to resume shi r.ents, and I
all existing inventory has been inspected, an evaluation shall be performed to detemine the future procedural controls for assuring co=pliance to AWS D.1.1-1972. This evaluation and reco= ended course of action shall be discussed with the NRC prior to being implemented.
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] Item 4.
O. B. Cannon Nuclear Coatings As a result of the deficiencies noted by the NRC, CQA issued a Stop Work Notice and Corrective Action Request (CAR) to 0. B. Cannon.
The CAR identified five deficient conditions in their QA program and i=ple=enting procedures in the areas of verification of materials prior to use, qualifications of personnel, and performance of audits.
The contractor's response to the Corrective Action Request included:
(1) the correction of coating applicators' qualification records in accordance with 0. B. Cannon procedures; (2) the inspection status tagging of all cans and cartons of coating r.aterials in the storage area; (3) the missing physical ex-a=ination record was returned to O. B. Cannon's site QC file; (4) the O. B. Cannon QC canual was revised to include the re-view and approval of manufacturers' material certification; and (5) the contractor's first internal project audit was perfomed.
The contractor's i=ple=entation of these corrective acticas was verified by CQA and a partial stop work release for Class II coating work (non-safetyrelated)wasissued.
Then Februn g 18, 1978, the NRC reviewed O. B. Cannon's QA progra= and procedural i= prove =ents and observed the corrective actions taken.
As a result of this review and observation, the ERC inspector concluded that safety-related coating work could be pe=itted to resume.
Sub-sequentially, a full stop work release was approved and issued by CQA.
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Ite: 5 Safety-Related Concrete Placement Prior to resuming safety-related concrete placement by each of our four place =ent contractors, several QA program adjustments were made.
These changes included a new slu=p testing procedure which requires, upon detection the high/lov slu=p, the suspension of placement and the sampling of'each truck until slu=p is back within specified li=its.
An indoctrination and training meeting was held with contractor's vibrator operators and a procedural requirement was added to rebrief and provide attestation of vibration operator training prior to each place =ent.
The CQC detailed procedures and inspection plans were re-vised to reflect imple=entation of 100% CQC inspection of contractor preplace=ent inspection activities. CQA performed detailed program audits of each contractor and CEI =anage=ent met with contractor mana6e=ent to e=phasize their contractural obli ations with respect 6
to quality control.
Upon completion of these activities, and the review and inspection of preplace=ents by HRC inspectors, contractors were individually released to place safety-related concrete. Then, in addition to continued 100%
CQC inspection, CQA perfor=ed audits of preplacement and place =ent activities by both the contractor and CQC on all safety-related pours.
A subsequent CQA evaluation of these audits was reviewed by and agreed to by the NRC on April 14, 1978 and the CQA audit frequency on two of the contractors (National En5 ceering and Great Iakes) was reduced to 1
one audit per week.
As of this response date, the other two contractors (S & M and DICK Corporation) shall continue under the CQA audit of every place =ent program until several pours can be made by each or5anization and a level of confidence is established.
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A_TTACFJENT 2 ORGANIZATIONAL RESPONSIBILITIES D
(A) Construction Quality Section - GSE 1.
Coordinate all site quality ibactions 2.
Primary contact Nuclear Regulatory Cdssion inspections 3.
Responsible for all line supervisory functions (B) Quality Engineering (Construction Quality Section) 1.
Contractor quality assurance progrs=s 2.
Establishing inspection require =ents 3.
Coordination and disposition of nonconfomance reports 4.
Obtain correction action 5.
Contractor; procedure review 6.
Receivin6 inspection plan 7.
e.uditcontractors/Siteorganization 8.
Review procurement documents 9
Analysis and reports trends
- 10. Establish site quality assurance records require =ents
- 11. Coordinator off site quality infomation requests (C) Quality Ad=inistration (Construction Quality Section) 1., Audit tracking T
2.
Indoctrination and training 3.
Quality =anual control 4.
Quality wtrance records 5.
Nonconfor=ance Report control (D) Inspection (Constructica quality Section) 1.
Surveillance inspection 2.
Receipt inspections 3.
Documentation of inspections 4.
Prepare Nonconfomance Reports (E) Progrs= Quality Section - GSE 1.
Coodinate all design, procurement, manufacturing activities 2.
Responsible for agents quauty assurance efforts, inc. Pri=arily GAI/QAProgram 3.
Responsible for all line rupervisory functions 1224 194
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ATTACHMENT 2 -*
T (F) Quality Engineering (Program Quality Section) 1.
Review of contracts 2.
Vendor preavard meetings 3.
Support audit program li.
Quality engineering support to Nuclear Engineering Department
- 5., Quality engineering support to Purchasing
- 6. ' Safety Analysis Report reviews (G) Quality Assurance Administration (Program Quality Section) 1.
Audits 2.
Indoctrination and training 3.
Procedures 18 Records 5.
Scheduling and expediting (H) Operational Quality Assurance (Program Quality Section) 1.
Operations qualit assurance program planning 2.
Startup and Test quality assurance support (I) Quality Assurance Advisory Cc=sittee
' 1.. Input on quality assurance program policy
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2.
Input on quality assurance methods and techniques 3
Qual'ityassurancemanagementforGAI/KEIsupport 1224 195
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