ML20147C027
| ML20147C027 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/17/1978 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20147C019 | List: |
| References | |
| NUDOCS 7810110261 | |
| Download: ML20147C027 (18) | |
Text
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T }' L C L E V h l il b i ! !. C T R I C i L L U M i N AT I N G C U i'.' P A N Y m
ILLUMINATING BLDG. a PUBLIC $0VARE e CLEVELAND OHIO 44101 e TELEPHOM (21 P.O BOX 5000 Senmg The Best Location m inc Nation August 17, 1978 Daiwyn R. Davidson' VICE P7.ESLO(NT * (NGINEtMING.
Mr.'J. G. Keppler Director.
United States Nuclear R'egulatory Ccc: mission i
Region III:
799' Roosevelt. Road.
. Glen Ellyn, IL 60137
Dear Mr.. Keppler:
This letter is to acknowledge receipt of your inspectir'n report number 50-4W/78-02 and 50-441/78-01 attached'to your letter of July 13, 1978, which I received on July 17, 1978. This report identifies areas examined during the inspections conducted January 24 - 26, 1978 and February 2 and 3,1978 by Messrs. I. T.. Yin, K. R. Naidu, G. F. Maxwell, and C. C. Williams.
' Attached to'this letter is our response to the eleven (11) items of
~
This response noncompliance described in Appendix A, Notice of Violation.
,l ds in accordance with the provisions of Section 2.201 of the NRC's " Rules l
of Practice," Part 2, Title 10, Code of Federal Regulations.
As indicated in the third paragraph of your letter, we have, in several instances, referenced corrective steps which we described to you in previous i
correspondence and which have been observed through your subsequent inspections We trust that this approach, as well as our direct responses, at the site.
will satisfy our obligation to respond to each item identified in the Notice of Violation.
In addition, your letter, in paragraph (5), identified a specific concern regarding the adequacy of embedments placed in safety-related concrete poured prior to the stop work actions associated with the Immediate Action Due to the complexity involved with providing Letter of February 8, 1978.
a thorough and comprehensive. analysis, we will respond to this concern in a separate report. Analysis of these embedments has been initiated by At this time we anticipate Gilbert Associates, our architect engineer.
i submitting; the-results of. this annlysis for your review by December 1,1978.
Should there be any-questions or ' concerns, please do not hesitate to call.
Very truly yours,
/ h s v/
L.-
D. R. Davidson Vice President - Engineering
/3;g DRD: par Attachment ~.
r J. W. Fenker W. R. ossman ec:
Quality Assurance-i Management Committee G. W. Groscup P. B. Perry
.Mh/ lC6 b R. E. McNeal J. J. Waldron
RESPONSE To ENFORCEMDIT ITDC Listed below t_re the responses to the noncompliances identified in Appendix A, Notice of Violation, of the United States Nuclear Regulatory Com=ission IE Report No. So-Mo/78-02; 50-41/78-01, i
I.
A.
Infraction loCFR50, Appendix B, Criterion III, states, in part, that " Measures shall be established to assure that applicable rer.tlatory requirements and the design basis... are correctly translated into specifications, drawings, procedures, and instnictions. These measurcs shall include provisions to assure that appropriate quality standards are specified and included in design documents..."
Paragraph 17.1.3.of the Quality Assurance Program documented in the PNFP PSAR states, in part, that " Specifications shall require vendors
. to submit drawings, design data, fabrication procedures and test results as nececsary. Selected vendor documents will be reviewed by GAI. Vendor drawings will be reviewed by GAI engineers for consistency with technical specification requirements and the GAI design intent."
Contrary to the above, measures were not established to assure vendor drawings and procedures were reviewed to ascertain inclusion of applicable regulatory and guelity requirements. For example:
a.
Safety Class 1, 2, and 3 piping Specifications SP-W-4549-ool and SP-527-4549-ool did not include the requirement for the piping vendor (Pu13 man) to submit drawings, design data, and fabrication procedures to GAI, and therefore, these documents were not being reviewed by GAI engineers.
b.
Safety Class 3 piping Specification SP-47-45h9-ool contains the requirements for the piping vendor. (Pullman) to sub=it shop and erection drawings, data sheets and fabrication procedures to GAI a
for review and approval. However, drawings and other instructions being used to install Safety Class 3 piping (vendor "take off" drawings SP-47-ool and PP-304-861) were not reviewed and approved by GAI.
B.
Response
Corrective action:: relative to these matters which were identified in your immediate Action Letter of February 8,1978, were reviewed on February 17 and 18,1978 and found to be acceptable as detailed in United States Nuclear Regulatory Co:nission IE Report No.
50-Wo/78-03; 50-W1/78-02, which was attached to your letter dated March 31,1978. Subsequently, in our letter dated May 1,-1978, we outlined for your review the actions which had been taken.
1 l
~l
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RESPONSE TO ENFORCEMENT' ITEMS Page 2 II.
A.
Infraction 10CTR50, Appendix B, Criterion y states, " 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. Instruc-tions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for detemining that important activities have been satisfactorily accomplished."
Paragraph 17.1.5 of the Quality Assurance Program documented in the PKPP PSAR states, in part, "Each major participant in the project will be required to provide documents which describe the control of their quality-related activities. All participants, including vendors and contractors, shall be required to perfom quality-related activities in conformance with approved instructions, procedures, and drawings rpp3dcable to their phase of the work. Each instruction and procedure will have a detailed description of the activity including quantitative and qualitative acceptance criteria and provisions for documenting the findings or results... CEI shall have the responsibility for overall control of the PNPP quality. Instructions and procedures shall be prepared by CEI or agents to describe the means for achieving the required quality."
Contrary to the above, CEI failed to accomplish activities in accordance with instructions or procedures, failed to require that instructions or procedures include quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished and faiu to require that activities affecting cpality were prescribed by documented instructions or procedures. For example:
a.
Qa at least twelve (12) occasions since October 1976, CEI Construction Quality Control (CQC) did not document deficiencies in Bonconformance Reports (NR's) as required by the CQC Manual; interoffice memorandums vere used instead.
The CQC Manual, Section 16, paragraphs 2.1 and 2.2 states, in part, " Items and activities that do not conform to specifications, drawings an? other project requirements shr21 be identified, documented and corrected. Deficiencies which affect the quality status of material and equipment are reported on Nonconfermance Reports (NR's)..."
b.
On approximately twenty (20) occasiona since April 1977, Great Lakes did not document storage deficiencies in Nonconformance l
Reports as required by procedure AQCP-8 and AQCP-9 l
Paragraph 5.1 of AQCP-8 states, in part," Storage shall be in L
accordance with ANSI N 45.2.2." and AQCP-9, Paragraph 4.1, states
(
in part, "A nonconformance report shall be initiated when structures, systems, or components do not comply to cpecifications, drawings, codes,standardsand/oranydelineatedprojectacceptance criteria."
l l
J RESPCNSE TO ENFORCEMENT ITDG Page 3 Great Lakes' failure to follow the requirements of AQCP-8 was cited once previous 3y as an item of noncompliance in IE Inspection Report No. 50-WO/77-07; 50-442/77-07.
c.
Eighteen (18) containers of coating materials maintained in a Cannon storage area, were not identified with the appropriate quality tags as required by the Cannon QA Program.
The Cannon QA Program,Section I, Paragraph 7.1.6 states, in part, " Accepted matericls are tagged " Accepted" and stored for use."
d.
The audit checklists, which were utilized by CEI during the pre-avard surveys of Pullman and Cannon, contained specific 1
instructions requiring that each block / checkpoint be addressed by the audit personnel and the results documented in the appli-cable block or beside the applicable checkpoint. At least 6CT of the audit checkpoints / blocks were not completed / documented in accordance with the specific audit checklist instructions.
.The Pullman audit was conducted on June 22, 1976, and the Cannon audit was conducted on April 6,1976. The Pullman contract for Safety Class 3 piping was avarded on September 28, 1977, and the Cannon contract for application of coating materials was awarded on August 11, 1976.
e.
Five (5) DICK Corporation QA inspection personnel, who have been working at PNPP since December 1976, did not recesve training and indoctrination as required by procedure FQC-2.1..
Procedure FQC-2.1, Paragraphs 6.1.1 through 6.1.3 state, in part, "The training program shall include:
Indoctrination of personnel with the technical objective of the project and the NPC requirements... Instructions on the use of the procedures, j
codes, and standards that will be used... The Quality Assurance elements that are to be employed, with guidance regarding the limitations and capabilities."
'l f.
U. S. Testing (the test lab contractor) did not have documented instructions or procedures to assure precision weight scales are properly calibrated and adjusted.
g.
National Engineering did not have documented instructions or procedures to prevent the continuous placement of concrete which has excessive slump.
h.
The safety-related piping Manufacturing Surveillance Plan No. 033 being used by the GAI inspector at Pullman's fabrication shop did not define lot size and did not make documented reference to a recognized standard practice; thereby not requiring sufficient quantitative or qualitative criteria for detemining that important activities have been satisfactorily accecplished.
1 1
RESPOUSE TO ENFORCEMENT ITEMS Page 4 i
B.
Response
a.
Corrective actions relative to this matter which was identified in your Imediate Action Letter of Februery 8,19'.9 were reviewed June 6 - 9, 1978 by Mr. J. E. Konklin as detailed in United States Nuclear Regulatory Comission IE Report No. 50-40/78-07; 50-W1/78-06,whichwasattachedtoyourletterdatedJuly7, 1978. Previously, in our letter dated May 1,1978, we outlined for your review the actions which had been taken.
b.
Corrective actions relative to this matter vere detailed in Mr.
Davidson's letter to you dated March 7,1978, stich was sent in response to your letter of February 17, 1978. This letter requested more infomation about out original response to the first violation identified in IE Report No. 50-WC/77-07; 50-M1/77-07, c.
Corrective actions relative to this matter stich was identified in your Imediate Action Lettar of February 8,1978, were reviewed February 17 and 18, 1978 by Messrs. C. C. Williams and I. T. Yin and found to be acceptable as detailed in United States Nuclear Regulatory Ccemission IE Report No. 50-WO/78-03; 50-M1/78-02, which was attached to your letter dated March 31, 1978. Subse-quently, in our letter dated May 1, 1978, we outlined for your review the actions which had been taken.
d.
The preavard surveys of Pullman and Cannon were reviewed and detemined to adequately evaluate the quality programs. These contractors were both required to subnit project-unique programs stich were subsequently reviewed by CEI/QA or others. This requirement was established during both preavard surveys.
The specific checklists used for the Pullman and Cannon preavard surveys have been reviewed, and all blank areas evaluated.
Future uses of this checklist will comply with instructions on the fom.
The particular checklist foms used were designed for auditing manufacturers and were not required to be used by CEI/QA Procedure 8.2, Rev. 2, "CEI/QA Audit Procedure for Contractors" (stich was applicable at the time).
CEI/QA recognized the difference between auditing an existing manufacturing facility and a proposed construction site operation and issued Quality Assurance Instruction 5 3, " Conducting Contractor Preavard Surveys" on December 3,1976.
(The Puftman audit was conducted in June 1976 and the Cannon audit was conducted in April 1976. ?
RESFONSE TO ENFORCDENT ITEMS Page 5 II.
B.
Response
e.
A review of DICK Corporation's on-Site QC personnel qualifications was perfomed. The documentation available was in accordance with that required by FQC 2.1, Rev. O, DICK Corporation has committed to having a more femal indoctrination and training program, including indoctrination to NRC requirements, available on-site by September 10, 1978, f.
U. S. Testing has submitted Calibration Instruction No.16
" Laboratory Scales and Balances (Mechanical)" for review and approval by Construction Quality Engineering.
Resolution of comments was accomplished during a meeting held on August 1, 1978, between the licensee's representatives and U. S. Testing Management. The letter of acceptance vill be issued by August 14, 1978.
g.
National Engineering & Contracting Co. is revising their proce-dure QP 10.1 " Concrete Inspection". This revised procedure is to include the vet slump requirements and will be submitted to Construction Quality Engineering for review no later than August 15, 1978. Until this procedure is approved by CQE and implemented by National Engineering, CQC will be performing 100% concrete plac-1 ing inspection for this contractor.
h.
Corrective actions relative to this matter which was identified in your Immediate Action Letter of February 8,1978 vere reviewed February 17 - 18, 1978, by Messrs. C. C. Williams and I.T. Yin and found to be acceptable as detailed in United Str.tes Nuclear Regulatory Com=ission I.E. Report No. 50-440/78-03;50-M1/78-02, which was attached to your letter dated March 31, 1978. Subse-quently, in our letter dated May 1,1978 ve outlined for your review the actions which had been taken.
III.
A.
Infraction 10CFR50, Appendix B, Criterion VI states, in part, that " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are... used at the location when the prescribed activity is perfomed."
Paragraph 17.1.6 of the Quality Assurance Pngram documented in the PNPP PSAR states, in part, "The Field Constrt :: tion Management Organi-zation Firm shall provide written procedures for the control of docu-ments such as working drawings, specifications, procedures, and in-structions to assure that only the latest revisions will be used for construction and erection. Documents vill be distributed in accor-dance with approved distribution lists."
a e
w
RESPONSE TO ENFOPCEMENT ITE43 Page 6 III.
A.
Infraction, Cont.
- i Contrary to the above, CEI failed to ensure that National Mobile used design Specification SP-14-4549-00, Revision VII, for batching safety-related concrete, which was the latest applicable revision. Specifica-tion SP-14-4549-00, Revision VII was issued on February 15, 1977, approved on June 28, 1977, and received by National Mobile on August 5, 1977, and since the date of receipt, more than 140,000 cubic yards of concrete (batched to SP-14-4549-00, Revision VI) have been placed.
The use of out-of-date and/or unapproved procedures by site contractor (Great Lakes Construction Co.) was cited once previously as an item of noncompliance in IE Inspection No. 50-440/78-06; 50 441/78-05 B.
Response
Corrective actions relative to this matter which was identified in your Imediate Action Letter of February 8,1978 vere reviewed June 6 - 9, 1978 by Mr. J. E. Konklin and found to be acceptable as detailed in United States Nuclear Regulatory Comission I.E. Report No. 50-440/78-07; 50-441/78-06, which was attached to your letter dated July 7,1978.
Ad-ditionally, in our letter dated May 1,1978, we outlined for your review the actions which had been taken.
4 IV.
A.
Infraction 10CFR50, Appendix B, Criterion VII states, in part, that " Measures shall be established to assure that purchased... services, whether purchased directly or through contractors and subcontractors, confom to the pro-curement documents".
Paragraph 1717 of the Quality Assurance Program documented in the PNPP PSAR states, in part, "The procurement of safety class... services shall be performed in accordance with written policies and procedures, Appropriate measures vill be included to evaluate procurement sources, monitor the activities of vendors ar.d contractors, and confim that purchased material confoms with procurement documents... The programs of all participants shall be in accordance with the CEI Quality Program Specifications, the CEI PNPP QA Plan and 10CFP50, Appendix B."
Contrary to the above, measures established by CEI did not assure that the purchased services of several site contractors conformed to procure-ment documents in that the OA programs for these contractors were not in accordance with 10CFR50, Appendix B.
For example:
a.
Great Lakes did not establish an indoctrination and training program as required by contract Specification SP-708-4549-00, b.
PBI Industries did not establish requirements for fonow-up action, including reaudit of deficient conditions, to assure that corrective action has been taken.
RESPONSE TO ENFORCEMENT ITEMS Page 7 IV.
A.
Infraction, Cont.
c.
Cannon did not establish receipt inspection requirements to assure that manufacturer's test / product results, for coating materials, conform to procurement documents prior to release of these materials for use, d.
Pn11mmn did not establish measures to control aavings, related design documents and procedures which were being utilized for the installation of safety-related pipirg. For exaople:
(1) Pullman personnel identified a Safety Class 3 piping insta12a-tion as being in accordance with Drawings No..SP-47-001 and C
No. PP-304-861; these drawings were uncontrolled and unapproved.
The Architect Engineer (GAI) drawing on which these drawings were based, did not have a drawing number, and therefore i
evidence of proper approval and document control could not be demonstrated.
1 (2) Pullman personnel were using an unapproved checklist to perform receipt Anspections of material in an attempt to comply with procedure No. X-5 (3) Pullman personnel possessed and were using a revision of Speci-fication SP-47-4549-001, dated October 24, 1977 This document was not available in CEI's document control center. Further, this document was incomplete in that drawing control and ap-proval requirements had not been established.
(4) Pullman personnel.could not deter =ine, from their records and documents, whether or not they possessed the correct revisions to all of the drawings maintained by them.
j (5) Pullman personnel were installing Safety Class 3 piping without having the applicable drawing (s) available in the area where the work was in progress. Moreover, these personnel vere not knowledgeable as to which drawings were applicable.
B.
Response
4.
a.
Great Lakes Construction Company has issued AQCP-16, Rev.1, dated April 10, 1978, entitled " Indoctrination and Training of Personnel". This procedure was accepted by CLI Construction Quality Assurance on April 19, 1973.
Great Lakes has begun implementation of their training program as described by this procedure.
Full compliance has been achieved, i
W
4 RESPONSE TO ENFORCD4ENT ITD4S Page U B.
Response, Cont.
4.
b.
Corrective Action Request CQA 0434 was issued on February 8,1978 to PBI to withdrav CEI Quality Assurance approval of PBI's safety-related QC/QA program Field Supplement for Erection of Structual Steel. This CAR accompanied Stop Work No. CQA-78-3.
The revised program document dated May 11, 1978 was subsequently approved by CEI Quality Assurance personnel on May 15, 1978, and a Stop Work Release was issued to PBI (SP-85)Section X, Item B.4.,
of PBI's revised program states in part, "A renudit of deficient areas shall be performed within 45 days of the initial audit."
Full compliance has been achieved.
c.
Corrective actions relative to this matter which was identified in your Immediate Action Letter of February 8,1978, were reviewed by Mr. G. F. Maxwell and found to be acceptable as detailed in United States Nuclear Regulatory Commission I.E.
Report No. 50-440/78-03;50-441/78-02, which was attached to your letter dated March 31, 1978. Subsequently, in our letter dated May 1, 1978, we outlined for your review the actions which had been taken.
d.
Corrective actions relative to this matter stich was identified in your Immedia,te Action Letter of February 8,1978, were reviewed April 13 - 14, 1978 by Mr. J. E. Konklin. Based on his evaluation, CEI issued a Stop Work Release on April 14, 1978 to Puuman Power Products which covered SP-44. With this action, the conditions which necessitated Stop Work Notice CQA-78-01 to be issued to Pull-man Power Products on February 8,1978, were considered to be corrected. Subsequently, in our letter dated May 1,1978, we out-lined for your review the actions which had been taken.
V.
A.
Infraction 10CFR50, Appendix B, Criterion IX states, in part, " Measures shall be established to assure that special processes, including velding.
and nondestructive testing, are controlled and accomplished by qualified J
procedures in accordance with applicable codes, standards, specifications, 4
criteria..."
Paragraph 1719 of the Quality Assurance Program documented in the PNPP PSAR states, in part, "Special processes to be used during the manufacture and installation of equipment shall be established and controlled in ac-cordance with approved ;rocedures. Welding,... nondestructive examina-tions and other processes which require unusual care or close control shall be performed in accordance with appropriate written procedures.
Procedures.... will be established to meet the requirements of appli-cable codes and standards... or to meet the requirements cf special process specifications which will be produced for the Perry Nuclear Power Plant Project." '
RESPONSE TO ENFORCEMENT ITEMS Fage y Specification SP-667-4549-00, titled " Fabrication and Delivery of Safety-Related Embedded Steel" in Paragraphs 2:04.2 and 2:10.2 specified that the velding activities should be perfomed and inspected respectively to requirements of AWS D1.1-72.
Contrary to the above, on February 3,1978, fifteen safety-related embed-ments and structural steel columns were found with veldments which did not meet the requirements of the applicable code (AWS D1.1-72). For ex-ample, identification marks were not on parts or joints showing that a velding inspector had inspected and accepted the velds; Nelson Stud Welds, which had been repaired by stick welding,. vere not tested with a hammer stroke and bent to an angle of 15 degrees for its original axis; velds were of poor quality as exhibited by inadequate size, excessive porosity and excessive gouging as defined by the code.
B.
Response
A 10CFR50.55(e) was reported to N.R.C. Region III on February 4,1978 and corrective actions relative to these matters are identified below:
(1) As a result of your findings relative to the embedment and struc-tural steel columns, we contacted N.R.C. Region III and reported the situation as a significant deficiency under 10CFR50.55(e) on February 4,1978.
Our March 6,1978 Interim Report on Nonconform-ing Safety-Related Embedment and Structural Steel identified corree-tive actions initiated relative to this matter.
(2) Additional corrective actions relative to this matter were detailed in Mr. Davidson's letter to you dated May 1,1978 which was sent in response to your Immediate Action Letter of February 8,1978.
Since that time 100% inspection of all safety-related embedments in stock has been completed and 100% receiving inspection of all current shipments of imbedments to the job-site is being performed.
CQC Detailed Procedure DP 11.15, "First Line Inspection of Fabricated Embedments", including the checklists, are being utilized to conduct embedment inspections was reviewed by Messrs. W. Hanse 3 and G. Phillips on June 9,1978 with no problems noted.
Insofar as the structural steel is concerned, the 17 reactor building columns are being repaired and 100% magnetic particle testing of fillet velds has been initiated. The control complex steel, which has already been erected, has been visually inspected by Quality Inspection. In addi-tion to that, 20% of the steel is being magnetic particle tested by PEI under Quality Inspection supervision and utilizing a Gilbert sampling plan.
The annulus platform steel has been visually examined and 20% of it has been selected for 100% magnetic partiM e testing at Levinson Steel.
)
RESPCNSE TO ENFORCEMENT ITEMS Fage 10 VI.
A.
Infraction 10CFR50, Appendix B, Criterion X states, in part, that "A program for inspection of activities affecting quality shall be established and executed... to verify confomance with the documented instructions, procedures, and drawings for accomplishing the activity... Dcamina-tions... shall be perfomed for each work operation where necessary to assure quality."
Paragraph 17.1.10 of the Quality Assurance Program documented in the PNPP PSAR states, in part, "Each organization's inspection program will adhere to the following general requirements:... Documented and approved procedures vill be used to control methods and describe ac-ceptance standards... Quality vill be controlled by inspection or process control or a combination of both as necessary.
Paragraph 3.8.1.6.1.5 of the PNPP PSAR states, in part, that " Require-ments for placing and consolidating concrete are as detailed in ACI 301."
Contrary to the above:
a.
On January 24, 1978, the inspectors observed that the QC inspection being perfomed by CEI and Great Lakes personnel during concrete
)
Pour No. CCO-S1/S6-599 did not verify confomance with documented instructions and procedures (ACI 301-1972, Chapter 8.3.4; Construc-tion Quality Control Inspection Plan No. C-01, Revision 2, SP-20, Checklist Acepetance Criterion II.F; and Construction Quality Con-
)
trol Guideline No. C-4,Section IV, Revision 0) in that improper use of vibrators was not identified and corrected.
b.
On January 25, 1978, the inspectors observed that the QC inspection i
being perfomed by National Engineering personnel during concrete Pour No. IBO-S1-599 did not verify conformance with documented instructions and procedures (ACI 301-1972, Chapters 3.5 and 8.3.4; Construction Quality Control Inspection Plan No. C-01, Revision 2, SP-20, Checklist Acceptance Criteria II.D and II.F; and Construc-tion Quality Control Guideline No. C-4,Section IV, Revision 0) in that improper use of vibrators and the use of concrete with exces-sive slump were not identified and corrected.
B.
Response
Corrective actions relative to these matters which vere identified in your Immediate Action Letter of February 8,1978, were reviewed by Messrs. E. J. Gallagher and K. R. Naidu and found to be acceptable as detailed in United States Nuclear Regulatory Commission I.E. Report No.50-WO/78-03;50-%1/78-02, which was attached to your letter dated May 1,1978,.ve outlined for your review the actions which had been taken.
d RESPCNSE TO ENFORCDENT ITEMS Page 11 VII.
A.
Infraction 3
10CFR50, Appendix B, Criterion XIII, states, in part, that " Measures shall be established-to control the handling, storage, shipping, clean-ing, and preservation. of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."
Paragraph 17.1.13 of the Quality Assurance Program documented in the PNPP PSAR states, in part, "A program of procedures shall be implemen-ted to prevent damage or deterioration of material or equipment during shipping, storage, and handling. Measures established will provide assurance of quality preservation, from fabrication through installa-tion, to preclude deterioration or damage which could adversely affect quality."
Paragraph 4.4.2 and 51 of Great Lakes procedure AQCP-8 states, in part, " Material identification tags shall be affixed to bundles, packs, boxes, cans, or individual parts or pieces in such a manner as to assure positive identification of the material... Storage shall be in accordance with ANSI N 45.2.2."
Contrary to the above:
a.
On January 24, 1978, approximately 20(safety-related) nut and 1 slt assemblies (concrete embedments) and 1/2 pound of weld wire were examined. Both were found to be inadequately stored. For example, the veld wire was laying on a wet floor and the nut and bolt assemblies were submerged in water and were in a rusty con-dition, contrary to Paragraph 2 7.4 of ANSI N 45.2.2-1972. Addi-tionally, the nut and bolt assemblies were not identified with a material identification tag as required by Great Lakes Procedure AQCP-8.
The improper storage of materials by site contractors (National Engineering, Pullman and Kaiser) was cited once previously as an item of noncompliance in I.E. Inspection Report No. 50-WO/77-07; 50-M1/77-07 b.
Great Lakes has not established instructions for inspectird safe-ty related components in storage as required by Paragraph 6.4.2 of ANSI N 45.2.2.
CEI's failure to establish an instruction for inspecting mater-inle (reinforcing steel) in storage was cited once previously as an item of noncompliance in I.E. Inspection Report No. 50-WO/
76-01;50-W1/76-01.
- c. _ Pullman has not established pipe and camponent lifting and hand-ling procedures for site construction activities in progress.
RESPONSE TO ENFORCEMENT ITEMS Page 12 VII.
B.
Response
a.
Great Lakes Construction Co. has revised their Procedure AQCP-16
" Indoctrination and Training of Personnel". This procedure now addresses more fully the necessity of recognizing improper stor-age of safety-related materials and the necessity of maintaining the material identification tagging system on an items other than reinforcing steel and embedded items, which are controlled as described in VII.B.b below.
In addition, the Construction Quality Section will initiate an evaluation of Nonconfomance and Action Requests to determine any trends associated with storage problems. Based on the re-sults obtained, the need for additional audit and/or surveillance of this area vill be detemined and implemented as necessary to assure that storage problems do not persist.
b.
Great Lakes Construction Company AQCP-16, Rev. 1, now specifical-ly addresses storage. Page 4 of Attachment 3 dated February 15, 1978 cceprises a Reinforcing Steel Placement Checklist. Page 5 of Attachment 3 comprises an embedded Metal Placement checklist.
Additionally, GLC hired a full-time QC inspector to handle rebar, instituted a minimum sample plan of 30% on all bars to be increased as conditions warrant. It was detemined that although these pro-visions constituted full address of the described problems, these measures were stin not adequate to provide full control. There-fore, on July 1,1978, a subcontract was let to Wahib Steel which included receipt inspection of rebar for GLC.
Since Wahib Steel has approved procedures and has perfomed effectively for other site contractors and has sufficient manpower to effectively con-trol rebar receipt, full compliance has now been achieved.
c.
Corrective actions relative to this matter which was identified in your Immediate Action Letter of February 8,1978, were reviewed on February 17 - 18, 1978 and found to be acceptable as detailed in United States Nuclear Regulatory Comission I.E. Report No.
50-M0/78-03;50-W1/78-02,whichwasattachedtoyourletter dated March 31, 1978. Subsequently, in our letter dated May 1, 1978, we outlinea for your review the actions which had been taken.
b
r RESPONSE TO ENFORCHENT ITD4S Page 13 VIII.
A.
Infraction 10CFR50, Appendix B, Criterion XV, states, in part, that " Measures shall be established to control materials, parts or components stich do not confom to requirements... These measures shan include,-
as appropriate, procedures for identification, documentation, segre-gation, disposition, and notification to affected organizations."
Paragraph 17.1.15 of the Quality Assurance Program documented in the PHPP PSAR states, in part, " Measures she_n be included in the CEI PNPP QA Program to control nonconfoming materials, parts or components... QA Programs shall be required of vendors and con-tractors of safety class equipment and vill include measures for identification, documentation, segregation, disposition and notifi-cation to affected organizations of nonconfoming materials, parts or components."
Paragraph 6.1.4 of National Engineering procedure QP 15 1 states, in part, "Nonconfoming items shall be tagged and segregated stere ever possible per Section 6.6."
Contrary to the above:
National Engineering failed to document voids on concrete placement IBo-W-43-597 (intemediate building) on a Nonconfomance Report (NR) and identify the specific area with a nonconfomance tag or other means. Furthemore, the following areas where voids existed and which vere documented on NRs had not been identified with noncon-fomance tags or other means: Section 26-26, at approximate eleva-tion 580 feet; Section 22-22, at approximate elevation 581 feet -
6 inches; and Pour No. IBO-W-15-597, B.
Response
Nonconfomance Reports NECC 92, dated January 25,'1978, and NECC 98, dated February 11, 1978, were issued to document the conditions j
described above. Additionally, on major van surface defects, hold tags are being attached to the exposed rebar and the nonconforming portions are being painted.
NECC Procedure QP 151, "Nonconfomance Report Control", has been revised, approved by Construction Quality Engineering, and implemen-ted by the contractor. In part, this revision provides greater em-phasis on the necessity of tagging for the purpose of establishing status of nonconfoming items.
Full compliance has been achieved.
1 J
t RESPONSE TO DiTORCDENT ITEK9
~"
Pa6e 14 IX.
A.
Infraction 10CFR$0, Appendix B, Criterion XVI, states in part, that " Measures sha].1 be established to assure that conditions adverse to quality, such as... deficiencies, deviations, defective material and equip-ment, and nonconfomances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and cor-rective action taken to preclude repetition."
Paragraph 17.1.16 of the Quality Assurance Program documented in the PNPP PSAR states, in part, "A plan for corrective action has been established for the PNPP to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconfomances sre promptly identified and corrected. Participant's programs shall be in accordance with the CEI PNPP QA Plan and 10CFR50, Appendix B.
In the case of signi-ficant conditions adverse to quality, measures shall assure that the cause of the condition is detemined and that corrective action vill be taken to preclude repetition".
Contrary to the above, Great Lakes weekly storage inspection records reveal continuing stora6e problems since April,1977, (a period of 10 months) and measures were not taken to assure the cause of this problem was detemined and corrective action taken to preclude repe-tition. For example, storage problems were found relating to embeds on 15 weekly repo.~ts, to reinforcing steel on 11 weeny reports, and to anchor bolts on 2 weekly reports.
B.
Response
Corrective action relative to this matter were detailed in Mr. David-son's letter to you dated March 7,1978 in item 1, which was sent in response to your letter of February 17, 1978.
The March 7,1978 response was in answer to a similar problem which you had identified in your December 19, 1977 report. The current problem identified in this report was observed during your January 24 - 27, 1978 and February 2 - 3, 1978 inspections. We trust that our response of March 7,1978 vill be satisfactory for both cases.
RESPONSE To tNFORC3IENT ITEMS Fage L)
X.
A.
Infraction 10CFR50, Appendix B, Criterion XVIII, states, in part, that "The audits shall be performed in accordance with the written procedures or check-lists by appropriately trained personnel not having direct responsibi-lities in the areas being audited,... Follow-up action including re-audit of deficient areas, shall be taken where indicated".
Paragraph 17.1.18 of the Quality Assurance Program documented dn the PNPP PSAR states, in part, " Audit procedures will include: responsi-bi2dties assigned, audit frequencies, reporting criteria and levels of management to receive and assess audit findings... Findings will be noted and response checked to ensure resolution of the findings..
. CEI procurement documents shall require that contractors and vendors provide for audit of safety class items within the scope of the acti-vities. These will be internal audits intended to provide evaluation of their functions."
Contrary to the above:
a.
Cannon did not conduct an internal project audit within the first three months of operation at PNPP, as required by the Cannon QA Program.
The Cannon QA Program,Section IV, Paragraph 4.1.1.1 states, in part, "The first internal project audit is scheduled within the first three months of operation of the project in order to assure the Project Quality Control Program is being effectively ad=inister-ed to assure quality."
b.
Three Audit Action Requests pertaining to U.S. Testing which were written by CEI, did not have sufficient follow-up action to as-sure that prompt corrective. action was taken. For example, follow-up action by CEI was not taken until 10 months after the date of the audit (October 7,1976) and as of the date of this inspection (16 months after the audit), follow-up action by CEI was still in-complete.
CEI had specified an action due date of October 21, 1976, for these items.
c.
CEI failed to conduct an audit to verify that the recommended corrective action has been taken relative to National Engineering NR's No. 67 and No. 76. In both cases, the cause of the noncon-formances was identified to be inadequate vibration and recccmended action to prevent recurrence was to instruct the foreman and in-spection personnel how to pq :rly use vibrators. This same con-dition was observed by the RIII inspectors during concrete pours CCO-S1/S6-599 and IBO-S1-599 CEI's failure to verify that the recommended corrective action had been taken by a site contractor (Pn11-1) was cited (against Criterion XVI) once previously as an item of noncompliance in I.E.
Inspection Report No. 50-30/77-07;50-441/77-07.
RESPONSE TO ENFORCEMENT ITDG -
Page 16 X.
B.
Response
a.
Corrective actions relative to this matter which vns identified in your Immediate Action Letter of Februsry 8,1978, were reviewed by Messrs. C. C. Williams and I. T. Yin and found to be acceptable as detailed in United States Nuclear Regulatory Commission I.E. Report No. 50-Wo/78-03; 50-W1/78-02, which was attached to your letter dated March 31, 1978. Subsequently, in our letter dated May 1, 1978, we outlined for your review the actions which had been taken.
b.
All Audit Action Requests open since 1976 are now closed out.
On March 31, 1978, a policy statement was issued by the Senior Engineer in charge of Construction Quality Assurance. This state-ment described the follow-up actions which would be necessary to close overdue Audit Action Requests.
On June 20, 1978, all Quality Engineers were issued a memo describing a method of closer tracking which would necessitate a bi-monthly review of open Audit Action Requests.
CQSP 1603, dated May 1,1978, requires a monthly review of the applicable Action Request Status logs by the Quality Control Super-visor and the Quality Engineering Supervisor to insure follow-up activities are being perfomed in a timely manner.
Full compliance has been achieved.
c.
As a result of this infraction, vibrator indoctrination and train-ing has been perfomed for each safety-related concrete placement at Perry Nuclear Power Plant by the Site Organization Construction Quality Control element since February 28, 1978. This activity will be continued until the applicable contractors adequately ad-dress this subject in their QA programs.
Additionally, in accordance with the CEI commitment in their response to your Immediate Action Letter of February 8,1978, construction Quality Engineering has audited this area in their audits of concrete placements.
RESPONSE TO ENFORCEMDiT ITEMS rage.Lt XI.
A.
Infraction 10CFR50, Appendix B, Criterion XVII, states, in part, that " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include... the results of reviews, in-spections, tests, audits... The records shall also include closely related data such as qualifications of personnel".
Paragraph 171.17 of the 41ality Assurance Program documented in the PNPP PSAR states, in part, " Approved procedures shall establish and control the QA records program of each participant responsible for quality. The QA records relating to qualification of procedures, equip-ment L.nd personnel vill be retained in addition to the results of in-spection, tests, reviews, audits and material certifications'.
Contrary to the above:
QA records relating to qualification of one of Cannon's personnel, a.
who had been applying coating materials to safety-related structures, vere incomplete in that they were not signed off by designated com-pany individuals.
b.
The physical examination records for the Cannon site quality control menager, who has been performing inspection functions at Perry Unite 1 and 2, were not on file in the site quality assurance office as required by the Cannon QA Program.
The Cannon QA Program,Section V, Paragraphs 17.1.1, 17.1.1.14, and 17.13 state, in part, " Quality Assurance Records Generated on the Perry Nuclear Power Plant site are... OBC-N-25... Physical Dcam-ination Records... The origital of all records are stored in a locked fire-proof cabinet in the site Quality Assurance office."
The failure to maintain onsite the qualification records of a site contractor's (National Mobile) QA/QC manager was cited once pre-viously as an item of noncompliance in I.E. Inspection Report 50-440/76-01; 50-441/76-01.
B.
Response
Corrective actions relative to these matters which were identified in your Immediate Action Letter of February 8,1978, were reviewed on February 17 - 18, 1978 and found to be acceptable as detailed in United States Nuclear Regulatory Commission I.E. Report No. 50-440/78-03; 50-441/78-02, which was attached to your letter dated March 31, 1978.
Subsequently, in our letter dated May 1,1978, we outlined for your review the actions which had been taken.
'