ML20148N145

Responds to 781003 NRC Ltr Re Violations Noted in Inspec Repts 50-440/78-12 & 50-441/78-11.Corrective Actions:Plans for Vessel Cleaning,Cooperatins W/Contractors to Follow Procedures,Weld re-inspection

ML20148N145
Person / Time
Site:	Perry, Comanche Peak
Issue date:	11/07/1978
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7811270022
Download: ML20148N145 (6)

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( ~ THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY-ILLUMINATING BLDG. e PUBLIC SQUA;ti a CLEVELAND. OHIO 44101 e TELEPHONE (216) 623 1350 s MAIL ADDRESS: P. O BOX 5000 ,

Serving The Best Location in the Nation Dalwyn R. Davidson tflCE PRESIDENT . ENGINEERING November 7, 1978 Mr. Robert F. Heishman Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Heishman:

This letter is to acknowledge receipt of your inspection report number 50-WO/78-12;50-W1/78-11attachedtoyourletterof October 3, 1978 which I received October 5, 1978. This report identifies areas examined by Messrs. J. E. Konk11n, K. R.

Naidu, I. T. Yin, and E. J. Gallagher during the inspection conducted August 22-24, 1978.

Attached to this letter is our response to the three (3) items of noncompliance described in Appendix A, Notice of Violation.

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.

Please do not hesitate to call if I may be of further assistance.

Very truly yours, nan D. R. Davidson Vice President - Engineering DRD:ge Attachment C>l 78112700 12- DSI9%

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RESFONSE To ENFORCEMENT ITEMS Listed below are the responsec to the noncompliances identified in Appendix A, Notice of Violation, of the United States Nuclear Regulatory Commission I.E.

Report No. 50-440/78-12;50k41/78-11.

I. A. Infraction loCFR50, Appendix B, Criterion XIII states, in part, that

" Measures shall be established to control the handling, storage, shipping, cleaning, and preservation of material and equipment in accordance with work and inspection in-structions to prevent damage or deterioration."

Paragraph 17.1.13 of the PNPP PSAR states, in part, "A program of procedures shall be implemented to prevent damage or deterioration of material or equipment during shipping, storage, and handling. Measures established vill provide assurance of quality preservation, from fabrication through installation, to preclude deterioration or damage which could adversely affect quality."

Contrary to the above, Cleveland Electric Illuminating Company (CEI) failed to assure that General Electric (GE) the supplier of the Reactor Pressure Vessel (RPV) and Chicago Bridge & Iron Nuclear (CBN) Memphis, the manufacturer and subcontractor to GE, adequately implemented shipping and cleanliness procedures to maintain and pre-serve the internal cleanliness of the Unit 1 RPV; the RIII inspector observed foreign material in the RPV, samples of which the licensee collected and analyzed. The preliminary analysis indicated such items as, insects, pieces of magnetic and nonmagnetic steel, fragments of paper towels, molding sand, white paint, and cotton fibre tape.

B. Response

1. Newport News Industrial Corporation generated a Noncon-formance Report (No. 38-6) to document the noncompliance.

Samples of the foreign material removed from the vessel were subjected to spectrographic and visual analysis and were found to be typical manufacturing process debris.

The analysis and the nonconformance report were issued to General Electric as the NSSS Supplier.

Remaining loose materials have been removed to establish the vessel's condition at a cleanliness level suitable for the future (field) installation of internals and modification of nozzles.

s Page 2 RESMNSE TO ENMRCD{ENT ITD4S At the time of this writing, CEI Quality Assurance personnel attribute the cause to lack of reeleaning measures by CBIN after the N-2 and N-10 nozzle modifications. These modifications were made after the " final" cleaning and before shipment to Ferry. This logic is reinforced by the lack of c1 caning documentation after the nozzle modifications.

Arrangements have been made with GE and NNIC to scrub the vessel walls utilizing the approved GE Final Cleaning Pro-cedure ZZAZ537, with GE approved solvents, and under GE supervision.

The memoranda generated as a result of these actions were attached to the September 7, 1978 letter from J. M. Lastovka' to J. E. Konklin of your office.

2. In order to prevent reoccurance of the problem with Unit 2, CEI Quality Assurance personnel performed first-line inspection activities at CBIN between August 27 and September 1, 1978. This coverage consisted of inspection of the internals and externals, final closure, application of the N-2 purge, the loading, securing and covering of the vessel in the barge. Results of the inspection were satisfactory, allowing the vessel to be shipped. The vessel was subsequently unloaded on site on October 21. Internal receipt inspection will be conducted when the vessel is set in mid-December.

3 Final scrubbing and flushing of RPV #1 will be accomplished upon completion of the installation of the internals, which is currently scheduled for July 1979 II. A. Infraction 10CFR50, Appendix B, Criterial V states, in part, " 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 . . ."

Paragraph 17.15 of the PNPP 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 perform quality-related activities in conformance with approved instructions, procedures, and drawings applicable to the phase of the work. Each instruction or procedure will have a detailed description of the activity including quantitative and qualitative acceptance criteria and provisions for documenting the_ findings of results . . . CEI shall have the responsibility for overall control of the PNPP quality . . ."

RESP 0iiSE TO ENFORCEMENI ITD4S Page 3 Contrary to the above, the following examples of failure to follow specifications, instructions, and procedures were identified:

a. Paragraph 5.05.4 of Specification SP-38 states, in part, "The detailed erection procedures shall be submitted to the Site Organization for review, record, and approval at least four weeks prior to commencement of erection unless otherwise specified . . ." Contrary to this, on August 23, 1978, Newport News Industrial Corporation (NNI) was utilizing a Manufacturing Installation Instruction (MII) 1240-NC-1005 for the installation of the Unit 1 Reactor Pressure Vessel (RPV) which did not identify that the Cleveland Electric Illuminating (CEI) Site Organization reviewed and approved the MII prior to the commencement of the erection.

b. Paragraph 6.2.8.3 of the Ph"PP Construction Quality Section Procedure (CQSP) 1001, dated May 1, 1978, states, "A hold point requires a contractor to cease work until that hold point is inspected or waived in writing by a Quality Control Supervisor or his designee." Contrary to the above, the inspector observed that the " hold points" established by the CQC organization, which were incorporated in MII 1240-NC-1005, Revision C, had not been transferred to Revision B (which was being used to document inspections), and had not been completely signed off. Furthermore, lack of signatures of designated licensee's representatives, is contrary to Section 10 of the NNI QA Manual, which on Page 2 of 11 in paragraph 10.1500 states " Implementation of MII's: Each step of the MII will receive a verification signature and date of completion including all examinations, tests, inspections, and Authorized Nuclear Inspector, customer and QA hold points."

B. Response 1.a. At the time of the NRC inspection, August 23, 1978, neither the Site Organization or NNICO classified the MII as a

" detailed erection procedure" which required prior approval for usage by the contractor. The specific procedures (i.e.,

welding, testing, inspection, or erection) had been reviewed and approved by the Site Organization prior to usage by the Contractor. The MII was treated as a sequencing document which provided an interface between the various specific procedures to ensure that the correct work procedure was called out to the field construction personnel.

, s RESPONSE TO ENFORCEMENT ITD4S Page 4 l 1

l 1.b. Memos have been generated by the appropriate management I (CEI/CQS and NNICO) to reaffirm the mandatory policy for l establishing, observing, and signing off customer hold points. It has been determined that the referenced hold points were observed by the Contractor and Construction Quality Control but in both organizations the personnel involved failed to adhere to the program requirements. ,

(Ref: Attachments to J. M. Lastovka's September 7,1978 '

l letter to J. E. Konklin) 2.a. To clarify this area, a change has been initiated that MII's shall be initially reviewed and approved by the Site 1 Organization prior to use by the affected contractor.

2.b. This was issued on August 28, 1978 to all CQC and CQE personnel reaffirming the CQS position on the use of hold and witness points. A copy of the memo was also attached to the September 7, 1978 letter from J. M. Lastovka to J. E. Konklin.

3.a. Full compliance will be achieved by December 15, 1978. i 3.b. Full compliance has been achieved.

III. A. Infraction 10CFR50, Appendix B, Criterion IX states, in part, " Measures shall be established to assure that special processes, including welding

. . . and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria . . ."

Paragraph 17.1.9 of the PNPP PSAR states, in part, "Special pro-cesses to be used during the manufacture and installation of equipment shall be established and controlled in accordance with approved procedures. Welding, . . . nondestructive examination 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 special process specifications which will be produced for the Perry Nuclear Power Plant Project."

Contrary to the above, on August 23, 1978, the RIII inspector observed that eight welds in the RPV pedestal and sacrificial shield areas did not meet the requirements of AWS Dl.1-74 Code inspection criteria; weld history records of the welds indicate that they were inspected and accepted.

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RESFONSE TO ENFORCEMENT ITEMS Page 5 B. Response

1. NCR 96-191 was generated by NNICO to identify that eight nonconforming velds identified by the RIII inspector.

NNICO also reinspected similar Bioshield velds for AWS code compliance and identified numerous other deficiencies on the Bioshield. Action Request 084 was written by Quality Engineering to identify the quality program concerns raised by NCR 96-191. The recommended corrective action was threefold: (a) evaluation of NNICO Instruction 948-N-N002, visual inspection, for adequacy, (b) inspection of similar velds to establish the scope of the (c) retraining of NNICO visual inspectors. The NNICO response to the Action Request only identified Bioshield valls for reinspection, this was unacceptable to~ Quality Engineering which rejected the response and requested a broader range of inspection. NNICO has re-viewed the instruction and: conducted additional training for visual inspection personnel. Due to the scope of the rein-spection program, NNICO has asked for and received additional ,

timetocompletetheverificationofothervelds.-(i.e., l Containment Liner Plate, Vent Structure, Weir Wall.)

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2. A final corrective action program vill be developed after the results of the reinspection program are evaluated by NITICO and CEI Construction Quality Engineering. AR 084 vill remain I open until the inspection program provides sufficient information to reaffirm project confidence in the velding and the veld (visual) inspection program. Additional nonconfomance reports will be generated as needed to track and repair any other veld problems noted as part of the reinspection program.

3 Full compliance vill be achieved by December 15, 1978.

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