ML19262B960

Responds to NRC 791121 Ltr Re Violations Noted in IE Insp Repts 50-440/79-10 & 50-441/79-10 on 791016-18.Corrective Actions:Training Program for Test Personnel Revised & Tagging Process Strengthened Before Unit Release

ML19262B960
Person / Time
Site:	Perry
Issue date:	12/21/1979
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19262B957	List: ML19262B960
References
NUDOCS 8001220289
Download: ML19262B960 (5)

Text

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e, ILLUMINATING BLDG. e PU8uc SoVARE e CLEVELAND, oHlo 44101 e TELEPHONE (216) 6231350 e MAIL ADDRESS: P.o. BOX 5000 Datwyn R. Davidson viCE PAESIDENT SYSTEM ENGINE ERING AND CONSTRUCTION December 21, 1979 Mr. Caston Fiore111 Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. 71 ore 111:

This letter is to acknowledge receipt of your Inspection Report Number 50-440/79-10; 50-441/79-10, attached to your letter dated November 21, 1979, which I received on November 26, 1979. This report identifies areas examined by Messrs. J. E. Konklin, K. R. Naidu, G. F. Maxwell, and a. F. Suermann during the inspection conducted October 16 through 18, 1979.

Attached to this letter is our response to the three (3) items of non-compliance described in Appendix A, Notice of Violation. This response is in accordance with the provisions of See-ton 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.

Should there be any questions, please don't hesitate to call.

Very truly yours, I

M D. R. Davidson Vice President System Engineering and Construction ksz Attachment

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j RESPONSE TO ENFORCEMENT ITEMS Listed below are our responses to Appendix A, Notice of Violation, of the United States Nuclear Regulatory Commission I. E. Report 50-440/79-10; 50-441/79-10.

I. A. Infraction 10CFR50, Appendix B, Criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

CEI Project Administration Manual, Section 1003, Revision 0, dated September 29, 1978, Paragraph 1.2 states in part, " Pro-curement documents shall require that the examination and test personnel of...U. S. Testing...shall qualify and certify personnel to approved procedures which meet Regulatory Guide 1.58 and ANSI N45.2.6."

Contrary to the above, on October 16-18, 1979, the inspector observed that:

a. U. S. Testing Company Procedure UST-TQ-1 " Training and Qualification of Inspection, Test and Audit Personnel "

Revision 9, dated March 23, 1979, did not meet the intent of ANSI N45.2.6 in that the procedural requirements for Level I, II and III background experience and education were less stringent than the minimum recommended by ANSI N45.2.6.

b. U. S. Testing Company failed to follow the above procedure in certifying three inspection personnel who lacked the required prior experience at the time of hire and whose records failed to demonstrate what other relevant factors were considered .in assigning the level of inspection cap-ability as an exception to the procedure.

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1 B. Response i

1. U. S. Testing is recertifying all Technicians assigned to PNPP in accordance with U. S. Testing Procedure UST-TQ-),

Rev. 9. Documentation of required training, as administered by U. S. Testing supervisory personnel, documentation of prior experience or education as applicable, and documen-tation of any other relevant factors considered prior to certification is being included in each individual's qual-ification record.

2. UST-TQ-1 will be revised to reflect requirements as stated in ANSI N45.2.6-1973. Additionally, this revision will describe the training program administered by U. S. Testing supervisory personnel which provides assurance of an indi-vidual's capability of performing various tests and will specify any other relevant factors to be considered prior to certification of test personnel. Development of this training program and identification of other relevant factors will take into account the nature and scope of the work to be performed and the importance of the item or service involved.

3. Full compliance will be achieved by January 31, 1980.

II. A. Infraction 10CFR50, Appendix B, Criterion XIV requires, in part, that measures shall be established to indicate, by use of markings such as stamps, tags or labels, the status of inspections upon individual items of the nuclear plant. The PNPP PSAR Chapter 17, Section 17.1.14.1 and CEI Corporate Nuclear Quality Assurance Program, Section 1400, Paragraph 1.1, requires that the inspection status of safety class components be controlled in accordance with approved procedures. An applicable CE1 PNPP Construction Quality Section Procedure, numbered 1502 (dated May 1, 1978),

Paragraphs 5.2.2 and 5.2.3, requires that, if nonconforming materials are released for limited use, such materials be clearly identified and tracked.

Contrary to the above, on October 17-18, 1979, five nonconforming safety-related motor operated valves were found not to be clearly identified as nonconforming or conditionally released. Three of these valves had been installed, one was being installed and the other valve was in storage.

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, B. Response

1. All safety-related motor operated Salves and any other equipment identified as nonconforming which has been re-leased to installing contractors for limited use prior to resolution of the nonconformance has been tagged in the field as conditionally released. The tag being used iden-tifies both the status of the item and the limitations of the release. The installing contractors have been directed to assure that the status tag remains on the item until notification is received from the PNPP Project Organization that status is no longer indeterminate.

2. At this time, approval of conditional release of an item can be obtained only upon demonstration that construction progress would preclude placement of the item in its intended location in the structure at a later date. A Project Adminstration Procedure is being developed jointly by the Construction Quality Section, the Nuclear Engineering Section, and the Nuclear Construction Section. This procedure will more clearly define the criteria for conditionally releasing an item to assure stricter adminstrative control of items released to installing contractors prior to the owner's resolution of nonconforming conditions.

3. Full compliance will be achieved by January 31, 1980.

III. A. Infraction 10CFR50, Appendix B, Criterion XVI, states in part, that " Measures shall be established to assure that conditions adverse to quality...

are promptly identified and corrected." The CUI Corporate Nuclear Quality Assurance Manual, in Section 1600 " Corrective Action", contains an identical requirement.

Contrary to the above, the licensee failed to take prompt cor-rective action either to obtain or have another onsite organi-zation obtain an "N" Certificate authorization for the Perry ASME Code work requiring such an authorization, or to take steps to seek relief from the Code requirement for an "N" Certificate authorization.

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e I and 2 The decision relative to "N" Certification involved a thorough review and .cluction of ASME requirements based on Code Editions and addenda applicable for Perry Project. This included system and component design, procurement and installation. It also involved an assessment of the existing Perry 10CFR50 based program vs. an ASME based program which would be required for an "N" Certificate of Authorization.

This process confirmed project compliance with ASME Codes and that the existing management and QA/QC systems adequately cover the inspection and documentation of the work. Applicable Code editions and addenda for Perry do not require an "N" Certificate holder. A decision has been made not to acquire an "N" Certificate of Authorization for Perry Project. Efforts are underway to correct minor inconsistencies and errors in assigning applicable code addenda to individual components and installation controls.

3. Full compliance will be achieved by March 15, 1980.

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