ML20128C388
| ML20128C388 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/17/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0049, PY-CEI-OIE-49, NUDOCS 8505280281 | |
| Download: ML20128C388 (6) | |
Text
3 THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P.O. BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800
- ILLUMINATING BLDG. - 55 PUBLIC SOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT NuctE^ a May 17, 1985 PY-CEI/OIE-0049 LQ e
Mr. R. L. Spessard, Director Division of Reactor Safety U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket No. 50-440; 50-441
Dear Mr. Spessard:
This letter is to acknowledge receipt of Inspection Report 50-440/85014 attached to your letter dated April 17, 1985.
This report identifies areas examined by Mr. R. A. Westberg during his
!nspection conducted March 12-15 and 25-29, 1985, at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated April 17, 1985.
This response is in accordance l
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 truly yours,
%M h
Murray R.
Edelman Vice President Nuclear Group MRE:sab I
Attachment cc:
Mr. J. A. Grobe USNRC Site, SBB50 N
Mr. D.
E. Keating gy 2 0 USNRC Site, SBB50 U.S. Nuclear Regulatory Commission Document Control Desk d\\
l Washington, D.C.
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RESPONSE TO ENFORCEMENT ITEMS y
Below is-our response to the Notice of Violation appended to United States Regulatory Commission I.E. Report 50-440/85014.
1.
Noncompliance 440/85014-03A&B A.
Severity Level V Violation 3
10CFR50, Appendix B, Criterion V, as implemented by the Cleveland Electric. Quality Assurance Plan, requires that (1)_ activities affecting quality shall be prescribed by documented instructions,. procedures, or drawings, of a type appropriate to the circumstances and shall be
. accomplished in accordance with these~ instructions, procedures, or drawings, and (2) instructions, procedures
.or drawings shall include appropriate quantitative.or qualitative acceptance criteria for determining the
~
important activities have been satisfactorily accomplished.-
Contrary to the above, the inspector identified the following:
-1.
The critical characteristics of items, to be verified during receiving inspection, were'not specified by the procurement documents as required
.by PA-0407, Attachment-2.
t 2.
Vendor supplied identification numbers were not positively verified as required by NQADP-1002, e
Paragraph 6.2.4.
i 3.
Procedure No. NQADP-0702 did not provideladequate guidance to ensure the validity of supplier qual-ity certificates.
4.
Material conformance tags were not marked with~the shelf life expiration date as required by PAP-0701, x
Paragraph 6.2.7.
B.
Response
1.
Noncomoliance examnle'440/85014-03A.
a.-
Corrective Action Taken and Results Achieved 1 Procedure PA-0407' requires identification of critical characteristics for Commercial Grade Items i
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iRESPONSE TO ENFORCEMENT ITEM e
MAY 17, 1985 PY-CEI/OIE-0049 LQ PAGE 2
-only.
Per'PA-0407, the Procurement Document-
' Engineering Evaluation Basis (PDEEB) document contains the listing of these characteristics.
Critical characteristics are being_ identified for Commercial Grade Items previously evaluated on PDEEBs to supplement the PDEEBs prior to new j
procurement of the. item.
Quality Control Record
.j 1
Cards.(QCRC) will be generated,.or revised, as appropriate, to transmit inspection / testing i
requirements to Receipt Inspection.
i After identification of critical characteristics for Commercial Grade Items' received, an evaluation of these items will be made to determine the basis l
for acceptability.
Verification testing and/or l
vendor surveys will be performed as appropriate.
Verification testing for 0-rings purchased
- Commercial Grade is presently in-process.
A sample lot of 0-rings has been selected and sent to a qualified testing laboratory for material verifi-cation.
NR OPQC 1441 has been generated identi-fying all Commercial Grade O-rings as nonconforming 1
pending receipt of the test results.
b.
Corrective' Action Taken to Avoid Further
(
Noncompliance Commercial Grade PDEEBs presently issued are having critical characteristics identified.= All organiza-tions involved in the identification and/or verifi-cation of critical characteristics for Commercial.
Grade Items have been notified of this requirement b
and instructed to comply with procedures.
Procure-ment Quality Engineering personnel have addition-(.
ally been instructed to ensure that critical' characteristics are appropriately identified for all future procurement of Commercial Grade' Items.
c.
Date When Full Compliance Will~Be Achieved Full compliance will be achieved by August 1, 1985.-
2.-
Noncompliance example 440/85014-03B.
NOTE:
This noncompliance incorporates items 2, 3, and 4 identified in the Notice of Violation.
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RESPONSE TO ENFORCEMENT' ITEM MAY 17, 1985
-PY-CEI/OIE-0049 LQ PAGE 3 a.
.O-Ring Identification Numbers 1.
Corrective Action Taken and Results Achieved The d'iscrepancy between the Apple Rubber Product Part numbers identified on the Certifi-cate of Conformance (COC) and the Dowdy Rubber Co. part numbers identified on the packing list was identified by Receipt Inspection at the time of inspection and brought to the attention of the Responsible Qaality Engineer.
Investi-gation by the QE determined that this discrep-ancy was not significant.
Both part numbers were based on the SAE AS-568 standard with the 1 Apple Rubber Product. numbers having an ARP prefix in place of the AS prefix.
Acceptance of the receiving documentation by.the QE is noted.on the Receiving Inspection Report and COC by his signature and date.
2.
Corrective Action Taken to Avoid Further Noncompliance This discrepancy developed as a resultiof evaluating 0-ring part numbers listed in the Apple Rubber Products parts catalog and using these numbers in the Purchase Order.
The 0-ring supplier with whom P.O. Q-2171-41_was placed only supplies 0-rings from the Dowdy Rubber Co.
This error in the part number has been corrected.
To prevent recurrence, 0-rings are now ordered by the AS-568 number.
3.
Date When Full Comoliance Will Be Achieved Full compliance has been achieved.
b.
Supplier Quality Certificates 1.
Corrective Action Taken and Results Achieved The program addressing verification of the validity of supplier quality certificates has
.been addressed in instruction 81-0707.
This instruction requires that an evaluation be performed of suppliers providing quality certificates.
The evaluation will consist of 1
one or more of the following:
supplier program i-re e
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RESPONSETTO ENFORCEMENT ITEM MAY:17,~1985-.
PY-CEI/OIE-0049.LQ PAGE 4 5
review, plant inspection / surveillance, product verification, and information from external sources.
Surveys have been conducted of two (2) O-Ring distributors with the results determining that the certificates supplied are acceptable.
. :2.
Corrective Action Taken to Avoid Further Noncompliance The program for evaluating the validity of supplier quality certificates has been established in' instruction 81-0707.
3.
Date When Full Compliance Will Be Achieved V
Full compliance will be achieved by June 21, 1985,-through implementation of instruction 81-0707.
c.
Shelf Life 1.
Corrective Action Taken and Results Achieved' Applicable shelf life expiration dates are now.
identified on Material Conformance tags at receipt inspection.
Receipt Inspection-personnel have been instructed to specifically address shelf life requirements during their inspection activities when shelf life
. requirements are identified on the purchase order and/or QCRC.
Shelf life expiration dates are being assigned to parts in the Warehouse when applicable.
~,
Parts identified as having shelf life require-ments will be tracked per instruction SMI-0006.
Prior to full implementation of this program, Receipt Inspect _ ion personnel will review shelf life applicability and shelf life expiration dates against program requirements at the time
.of issuance.
2.
Corrective Action Taken to Avoid Further Noncompliance Shelf life requirements are presently being i
identified on the QCRC under the category
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R'ESPONSE.TO ENFORCEMENT ITEM MAY 17, 1985 PY-CEI/OIE-0049 - LQ
. PAGE 5 f
" Documentation".
The QCRC form is being revised to add a specific " Shelf Life" category.
J' 3.
Date When Full Compliance Will Be Achieved Full implementation of the shelf life program will be achieved by August 1, 1985.
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