ML20003E454

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Responds to NRC 810303 Ltr Re Violations Noted in IE Insp Repts 50-440/81-03 & 50-441/81-03.Corrective Actions: Training Session held,re-emphasizing Consistent Implementation of Personnel Qualifications
ML20003E454
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 03/27/1981
From: Davidson D
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8104030499
Download: ML20003E454 (2)


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4 t, P o Box 5000 e CLEVELANo. oMio 44101 s TELEPHCNE (216) 622-9300 e ILLUM:N ATING BLOG e 55 PUBLIC SCUAPE Da!wyn R. Davidson wCE PaESCENT systru esostra,%c aso cessraucricN March 27, 1981 Mr. C. E. Norelius, Acting Director Division of Engineering and Technical Inspection U. S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to I. E. Report

Dear Mr. Norelius:

This letter is to acknowledge receipt of Inspection Report Number 50-440/

S1-03, 50-441/81-03, attached *o your letter dated March 3,1981, which I received on March 5, 1981. This report identifies areas examined by Messrs.

J. F. Schapker and R. B. Landsman for inspections conducted January 21 to 23, and January 28 to 30,1981.

Attached to this letter is our response to the one (1) Severity Level V Violation described in Appendix A, Notice of Violatic.7. This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations. - ---

In re9ponse to your request that we describe the actions taken or planned to assure that all contractor inspection personnel (current and future) at the Perry site are properly certified. I trust that sufficient information has been included in the attached response to permit evaluation. The information sub-mitted is true and correct to the best of my knowledge, information and belief.

If there are additional questions, please do not hesitate to call.

Very truly yours, GL 0 .

4'.:Ao / /E,1 n D. R. Davidson Vice President Systems Engineering and Construction ksz Attachment ec: J. Hughes, NRC - Site Mr. G. Fiorelli Division of Resident and Project Inspection U. S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road 0 5

Glen Ellyn, Illinois 60137 $ (

U. S. Nuclear Regulatory Commission c/o Document Management Branch k'a shin 20555 s 10 4 0 3 0 %gton, D. C.

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, RESPONSE TO ENFORCEMENT ITEMS Below is our response to Appendix A, Notice of Violation, of United States Nuclear Regulatory Commission I.E. Report 50-440/81-03; 50-441/81-03.

I. Noncompliance 440/81-03-02; 441/81-03-01 A. Severity Level V Violation 10 CFR 50, Appendix B, Criterion V (Procedures), stat +< in part that, "Acci4

  • Les affecting quality shall be prescribs by documented in4cructions . . . and shall be accomplishea in cccordance with these procedures . . ."

$ CEI Corporate QA Program, Section 0200 requires that examination

and test personnel . . . shall qualify to and be certified to

< the requirements of Regulatory Cuide 1.58 and ANSI N45.2.6.

Contrary . co the above, National Mobile, Creat Lakes and Dick Corporation failed to follow the above procedure by certifying seven inspection personnel who lacked the requL -d prior experience at.the time of certification. Proficiency testing 1ppeared to be

.the main basis for certifying the seven inc, 1 duals. Furthermore,

_ one inspection individual still does not mees the experience requirements of ANSI T45.2.6.

B. . Response

1. and 2. As agreed ~ in the Exit Meeting, CEI is in the process of reviewing 1: - the remaining contractor QC inspection personnel qualifications

. co re-confirm that - the following criteria are being implemented:

a; Proficiency testing shall not be used as the sole bas'is"~

for certification,

b. In cases where the education and experience requirements are not created as absolute, as described in Section 3.1 of ANSI N45.2.6-1973, proficiency testing may;be used to verify com-petency to perform particular. tasks. When this occurs, the 7

[

. certification documentation shall state the limitation of the '

certification' (e.gi, " Level I Receipt Inspection" in lieu of

" Level I Mechanical").

Specific action has been:taken with respect to National Mobile Conctate Corporation. They have been required .co revise the training section of their Quality Assurance Manual to address the minimum education, exper-ience and training requirements which must'be met prior to issuance of

. < a limited certification.'

. A training session was held'within the Construction Quality Engineering

-Unit to -re-emphasize the importance of consistent implementation of the

~

above criteria,:and to avoid ' future .re-occurrences of similar violations.- ,

- Full compliance will' be achieved by May 31,-1981.

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