ML20076C078

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Responds to NRC Re Violations Noted in IE Insp Repts 50-440/83-19 & 50-441/83-18.Corrective Actions: Memo Voiding All Bolting Insps for Installed Panels Issued
ML20076C078
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 08/12/1983
From: Edelman M
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Little W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076C074 List:
References
NUDOCS 8308220211
Download: ML20076C078 (3)


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P.o. Box 5000 - CLEVELANo, oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLDG. - 55 PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT August 12, 1983 NUCLFAR Mr. W. S. Littl e, Chief Engineering Branch 2 Division of Engineering 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

Dear Mr. Little:

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

83-19; 50-441/83-18 attached to your letter dated July 15, 1983. This report identifics areas examined by Mr. N. Merriweather of Region II during his inspection conducted June 20-24, 1983, at the Perry Nuclear Power Plant.

Attached to this letter is our response to the one (1) Severity Level IV Violation described in the Notice of Violation dated July 15, 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. If there are additional questions, please do not hesitate to call.

Very uly yours mL, k

. R. Edelman Vice President Nuclear Group MRE:pab Attachment cc: Mr. M. L. Gildner USNRC Site Mr. R. C. Knop, Chief Projects Branch 1 -

Division of Project and Resident Programs U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C. 20555 AUG 151983 8308220211 830816 DR ADOCK 05000440 PDR

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RESPONSE TO ENFORCEMENT ITEMS Below is our response to the Notice of Violation appended to United States Nuclear Regulatory Commission I.E. Report 50-440/83-19; 50-441/83-18.

I. Noncompliance 440/83-19-01 441/83-18-01 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 affecting 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) removed and reinstalled safety-related instrument panel no. 1H22-P015 without a documented procedure. This resulted in the panel being reinstalled without requiring a reinspection by Quality Control. The reinstalled installation was observed to be deficient in that holddown nuts (attached to Nelson studs) were either missing or were not torqued to design specification (snug-tight).

B. Response

1. Admission or Denial of Alleged Violation We concur that safety-related instrument panel no. 1H22-P015 was removed after the inspection for panel setting had been completed.
2. Reason for Admitted Violation JCI Construction Scheduling did not communicate with the JCI Quality Assurance Department as required by their procedure QAS-1101-PNPP, paragraph 4.2.1B and paragraph 5.2.
3. Corrective Action Taken and Results Achieved The immediate corrective action taken by the Johnson Controls Incorporated (JCI) QA Manager was to issue a memo voiding all bolting inspections for all installed panels. The memo was placed in the applicable. installation / fabrication (I/F) packages and previous inspection documentation was annotated as cancelled.

Cancellation of previous inspections assures that the item will be reinspected. .

Review of several panel installation / fabrication packages which have recently been turned over to Site Organization has verified the adequacy of the method of corrective action. All turned over installations were re-verified and documented as acceptable by JCI.

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4. Corrective Action Taken To Avoid Further Noncompliance The directive from the JCI OA Manager further stated that final inspection of panel installation is to be performed and documented at final walkdown.

JCI Procedure CAS-1101-PNPP, entitled " Control of Inspections", is presently in the process of being updated to address new requirements of the contract. When revised, a statement will be added to clarify the existing requirements. The clarification will specify that rework situations of installed installations require OA notification for assignment of new inspection hold points.

5. Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 30, 1983.