ML20004A015

From kanterella
Jump to navigation Jump to search
Responds to NRC 810303 Ltr Re Violations Noted in IE Insp Repts 50-440/81-03 & 50-441/81-03.Corrective Actions: Proficiency Testing Will Not Be Sole Basis for Certification But May Be Used to Verify Competency
ML20004A015
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)
Shared Package
ML20004A012 List:
References
NUDOCS 8105110572
Download: ML20004A015 (2)


Text

'

I

k. N%

q P o Bcs 5000

  • CLEytLAND. o+co 44101 e TELEP*.c'.E Q% E22-Mco e sLLUwe.ATAG etDG e 15 P'J eitesCua8E Dahwyn R. Davidson 9 W #*

ettPoEsCE%t svstEw Ew%EE e a%c co%staxtc* March 27, 1931 Mr. C. E. Norelius, Acting Director Division of Engineering and Technical Inspection U. S. Nuclear Regulatory Co=nission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docke t Nos. 50-440; 50-441 Response to I. E. Report

Dear Mr. Norelius:

This letter is to acknowledge receipt of Inspection Report Nu=ber 50-440/

SI-03, 50-441/S1-03, attached to your le tter dated March 3,1931, which I received on March 5,1931. This report identifies areas exa=fned by Messrs.

J. F. Schapker and R. B. Lands =an for inspections conducted January 21 to 23, and January 23 to 30,1931.

Attached to this letter is our response to the one (1) Severity 1.evel V Violation described in Appendix A. Notice of Violation. 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 response 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 infor:ation has been included in the attached response to per=it evaluation. The infor=acion sub-

=itted is true and correct _to the best of =y knowledge, infor=ation and belief.

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

Very truly yours,

-~

e c .d<. /(. a.n n.

D. R. Davidson Vice President Syste=s Engineering and Cons truction ksz Attachnent ec: J. Hughes, NRC - Site Mr. G. Fiore111 Division of Resident and Project Inspection U. S. Nuclear Regulatory Co =1ssion, Region III

'799 Roosevelt Road Glen Ellyn, Illinois 60137 U. S. Nuclear Regulatory Cc_:ission c/o Docu=ent Manage =ent Eranch LPR 1 $$

81051 I om v ashi:ston, c. C. 20555

a. *

- S 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), states in part that, " Activities affecting quality shall be prescribed by documented instructions . . . and shall be accomplished in accordance 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 Guide l.58 and ANSI N45.2.6.

Contrary to the above, National Mobile, Great Lakes and Dick Corporation failed to follow the above procedure by certifying seven inspection personnel who lacked the required prior experience at the time of certification. Proficiency testing appeared to be the main basis for certifying the seven individuals. Furthermore, one inspection individual still does not meet the experience requirements of ANSI N45.2.6.

I B. Response

1. and 2. As agreed in the Exit Meeting, CEI is in the process of reviewing the remaining contractor QC inspection personnel qualifications to re-confirm that the following criteria are being implemented:
a. Proficiency testing shall not be used as the sole basis for certification, i
b. In cases where the education and experience requirements are

! not treated 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

, certification documentation shall state the limitation of the l certification (e.g., ' level I Receipt Inspection" in lieu of

" Level I Mechanical").

Specific action has been taken with respect to National Mobile Concrete l Corporation. They have been required to revise the training section of l their Quality Assurance Manual to address the minimum education, exper-1ence 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 inportance of consistent implementa tion of the above criteria, and to avoid future re-occurrences of similar violations.

3. Full compliance will be achieved by May 31, 1981.

I

. . -