ML20024D559
| ML20024D559 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/29/1983 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8308050248 | |
| Download: ML20024D559 (2) | |
Text
T
.,o jj
~
+
P.o. BOX 5000 - CLEVELAND, ohio 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG - 55 PUBLIC SQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN vice mESIDENT July 29, 1983 NUC U A R Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Final Report Concerning Johnson Controls, Inc.
Failure to Adequately Verify Unistrut Corp. [RDC 69(83)]
Dear Mr. Keppler:
This letter serves as the final report on the potential significant deficiency concerning the failure of the Instrumentation Contractor, Johnson Controls Inc. (JCI), to adequately verify implementation of the QA program of their subvendor Unistrut Corporation. This item was originally identified to Mr. Pelke of your office on March 29, 1983, by Mr. E. Riley of The Cleveland Electric Illuminating Company. Our first and second interim reports were filed on April 28, 1983, and June 24, 1983, respectively.
The report includes a description of the potential deficiency, corrective action taken, and completion of our evaluation. As a result of our evaluation, it has been determined that this condition is not reportable pursuant to 10CFR50. 55 (e).
Description of Potential Deficiency During review of Unistrut procurement document package and subsequent re-audit / evaluation of Unistrut Corporation by JCI, it was identified that the requirements of ASME Section III 1974 Edition through Winter 1975 Addenda, Subsection NF, paragraph 2610, had not been imposed on the Material Subvendors.
Paragraph 2610 requires that all Material Manuf acturers document and maintain Quality Systems Programs in accordance with ASME Section III, Subsection NA, Paragraph 3700.
Corrective Action and Completion of Evaluation Project Organization Construction Quality Section issued Corrective Action Request 83-03 to JCI and Nonconformance Report CQC 2670.
AUS i 1983 TMg B30905o24e e3o729 ylO PDR ADOCK 05000440 S
s Mr. JImes G. Kappler July 29, 1983 Corrective Action Request (CAR) 83-03 cited JCI for failure to impose the requirements of Quality Assurance Attachment Specification 709, paragraph 1:05.4 and ASME requirements of NA 3700 on the material manufacturer. As a result of the issuance of the CAR, JCI conducted extensive evaluation on their vendors who supplied component support, ASME Section III - Subsection NF, materials.
Problems associated with the evaluation were documented on Noncon-formance Reports (NR) JCI 230 and 231. Resolution was based on the fact that the material suppliers possessed an ASME "NPT" certificate at the time of purchase.
Possession of the certificate verifies that an acceptable material /
vendor controls program was in existence. Therefore, Code Case 1728 was invoked and the NRs were dispositioned "use-as-is".
In addition to the vendor review, JCI's program for vendor approval was evaluated by the Con-i struction Quality Section.
It was determined that the existing vendor approval program is adequate to implement Specification and Code requirements.
Nonconformance Report CQC 2670 was issued to document the indeterminate status of Unistrut material, both installed and in storage. As a result of the NR, samples of each type of material were supplied to Project Organization by JCI.
These samples were submitted to an independent laboratory for testing. The results of the chemical and physical testing indicated that the material exceeded the requirements of the applicable material specification.
This verified the adequecy of the procurement documents. Therefore, Code Case 1728 was invoked and the NR was dispositioned "use-as-is".
Full compliance has been achieved with all nonconformance and corrective action documentation verified and closed out.
Please call if there are any questions.
Sincerely, Murray R. Edelman Vice President Nuclear Group MRE:pab cc:
Mr. M. L. Gildner U.S. Nuclear Regulatory Commission NRC Site Office e/o Document Management Branch Washington, D.C.
20555 Director Office of Inspection and Enforcement Records Center, SEE-IN U.S. Nuclear Regulatory Commission Institute of Nuclear Power Operations Washington, D.C.
20555 1100 circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 t
--.. -, -,,,