ML20072F183

Responds to NRC Re Violations Noted in IE Insp Repts 50-440/83-11 & 50-441/83-10.Corrective Actions: Johnson Controls Procedure QAS-1802-PNPP, Review & Turnover of Records, Revised to Reflect Present Document Review

ML20072F183
Person / Time
Site:	Perry
Issue date:	06/09/1983
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20072F171	List: ML20072F183
References
NUDOCS 8306270287
Download: ML20072F183 (2)

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• P.o. Box 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLOG. - 55 PUBLICSoVARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PREStOENT June 9, 1983 NUCLEAR Mr. James G. Keppler Regional Administrator, Region III Office of Inupection 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 Response to I.E. Report

Dear Mr. Keppler:

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

83-11; 50-441/83-10, attached to your letter dated May 9, 1983. This report identifies areas examined by Mr. N. Merriweather during his inspection conducted March 28 through April 1, 1983.

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Attached to this letter is our response to the one Severity Level IV violation described in Appendix A, Notice of Violation, dated May 10, 1983. 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.

Our response has been submitted to you within thirty days of the date of the Notice of Violation as you required, and the information submitted 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, k -

M. R. Edelman Vice President Nuclear Group MRE:pab cc: Mr. M. L. Gildner NRC Site Office U.S. Nuclear Regulatory Commission _

c/o Document Management Branch Washington, D.C. 20555 B306270287 830623 PDR ADDCK 05000440 JUN ' 3 g O PDR

RESPONSE TO ENFORCEMENT ITEMS Below is our response to Appendix A, Notice of Violation, of United States Nuclear Regulatory Commission I.E. Report 50-440/83-11; 50-441/83-10:

I. Noncompliance 440/83-11-01 A. Severity Level IV Violation 10CFR50, Appendix B, Criterion V, as implemented by CEI Corporate Nuclear Quality Assurance Program Manual, Section 0500, requires that activities af fecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.

Contrary to the above, Johnson controls Incorporated (JCI - the instrumentation contractor) was performing turnover reviews of purchase orders and installation / fabrication packages without a documented procedure. As a result, those deficiencies which were identified during the review were not being documented and controlled in accordance with JCI's approved QA program.

B. Response

1. Corrective Action Taken and Results Achieved The immediate corrective action taken by Johnson Controls Inc. was to suspend all document review processes that were being performed.

This was directed by the JCI QA Manager via memo to the Quality Engineer responsible for records turnover. Included in the memo were additional instructions specifying that all " Purchase Order Review Forms" be reviewed for the existence of deficiencies. Upon evaluation, if deficiencies were determined to be nonconforming conditions, they were to be documented in accordance with the existing JCI program.

The five deficiencies that were listed for purchase order number 64491-1 were reviewed and evaluated by JCI danagement. As a result of the review it was determined that no nonconforming l conditions existed. This review was documented on the " Purchase Order Review Form".

2. Corrective Actica Taken To Avoid Further Noncompliances

! Johnson Controls procedure QAS-1802-PNPP, " Review and Turnover of l Records," has been revised to reflect the present method of docu-ment review. Included in the revision is specific reference to the " Transfer Unit Deficiency List". The " Transfer Unit Deficiency List" is a list of all deficiencies identified on purchase orders

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and installation / fabrication packages. Deficiencies are evaluated l for nonconforming conditions. Additionally, the procedure emphasizes the requirement for identification and documentation of nonconforming

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l conditions.

NOTE: Transfer Unit Deficiency List and Purchase Order Review Form are synonymous.

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3. Date When Full Compliance Will Be Achieved l Full compliance has been achieved.

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