IR 05000440/1978013

Forwards IE Inspec Repts 50-440/78-13 & 50-441/78-12 on 780920-22 During Which No Items of Noncompliance Were Noted

ML20148R167
Person / Time
Site:	Perry
Issue date:	10/26/1978
From:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
Shared Package
ML20148R172	List: IR 05000440/1978013
References
NUDOCS 7811300251
Download: ML20148R167 (2)

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NUCLEAR REGULATORY COMMISSION ff 1, i REGloN lll

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OCT 2 6 .378 Docket N ()

Docket No. 50-441 The Cleveland Electric Illuminating Company ATTN: Mr. D. R. Davidson Vice President - Engineering Post Office Box 5000 Cleveland, OH 44101 Gentlemen:

This refers to the inspection conducted by Messrs. J. E. Konklin, E. W. K. Lee, G. F. Maxwell and J. Hughes of this of fice on September 20-22, 1978, of activities at the Perry Nuclear Plant Project, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-148 and No. CPPR-149 and to the discussion of our findings with Mr. M. R. Edelman, Mr. G. W. Groscup and others of your staff at the conclusion of the inspectio The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne No items of noncompliance with NRC requirements were identified during the course of this inspectio In accordance with Section 2.790 of the NRC's " Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room, except as follow If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this of fice, within twenty days of your receipt of this letter, to withhold such information from public disclosur The application must include

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a full statement of the reasons for which the information is con-sidered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.

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The Cleveland Electric -2- OCT 2 6 .378 Illuminating Company i

We vill gladly discuss any questions you have concerning this inspectio

Sincerely, o

R. F. Heishman, Chief Reactor Construction and Engineering Support Branch

Enclosure:

IE Inspection Reports No. 50-440/78-13 and No. 50-441/78-12

REGION III==

Report No. 50-440/78-13; 50-441/78-12 Docket No. 50-440; 50-441 License No. CPPR-148; CPPR-149 Licensee: The Cleveland Electric illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Units 1 and 2  ;

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Inspection At: Perry Site, Perry, OH Inspection Conducted: September 20-22, 1978 Inspectors: . E Ko

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W. Hayes, n /0 2 f[,9 Approved By: D f Proj ects Section ,

l Inspection Summary l

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Inspection on September 20-22, 1978 (Report No. 50-440/78-13; 50-441/78-12)

Areas Inspected: Licensee action relative to previous items of noncom-pliance and unresolved items (Units 1 and 2); licensee action relative

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to RIII Immediate Action Letter of February 8, 1978 (Units 1 and 2);

ongoing construction activities (Units 1 and 2); concrete embedment inspection activity (Units 1 and 2); QA implementing procedures relative to electrical components and systems (Units 1 and 2); QA implementing procedures relative to electrical cables and termination (Units 1 and 2);

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l work activities and quality records relative to electrical cables and

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terminations (Unit 1); QA implementing procedures relative to safety-related piping (Units 1 and 2); QA implementing procedures and work activities relative to safety-related piping welding (Units 1 and 2).

The inspection involved a total of 88 onsite inspector-hourc .y four NRC inspector Results: No items of noncompliance or deviations were identifie .. . - . . . . . _ . . ._ ._ .-- - -_-__ - -_ __-__-__ I DETAILS l

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Persons Contacted Principal Licensee Employees J

• R. Edelman, Manager, Nuclear QA Department

• G. W. Groscup, Manager, Nuclear Engineering Department

• R. Boals, General Supervisor, Construction

• D. Fitzpatrick, Site Construction Manager

• J. M. Lastovka, CQS General Supervising Engineer

• P. P. Narducci, CQS Quality Engineering Supervisor

• Riley, Manager, Contracts Administration Other Personnel

• J. Kacer, CQS Quality Control Supervisor (KEI) ,

• P. L. Gibson, CQS Quality Administration Supervisor (KEI)  !

• T. L. Arney, CQS Lead Quality Engineer (GAI)

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• G. J. Gibson, CQS Lead Electrical Quality Engineer (GAI)

• J. J. Connelly, QCS Lead Civil Quality Engineer (GAI)

• W. Mehaf f ey, CQS Lead Mechanical Quality Engineer (GAI)

• R. E. Crofton, CQS Lead Piping Quality Engineer (GAI)

• E. M. Wilcox, Senior QA Specialist (TECo)

• M. Pepp, Construction Quality Section (KEI)

The inspectors also contacted other licensee and contractor employees, including members of the quality, technical and engineering staff * Denotes those who attended the exit intervie Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (440/77-02; 441/77-02) - Effects of CEI reorgan-izatio The previous RIII Report noted that the effects of the CEI QA/QC reorganization at that time had not been addressed in the applicable QA document Since the CEI QA Program and QA/QC organization have recently been restructured as a result of the RIII Immediste Action Letter of February 8, 1978, and since the restructured program and organization are under review by RIII with regard to the resolution of Item 8 of the Immediate Action Letter, this previous unresolved item from 1977 is no longer pertinent, and is hereby close <

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(Closed) Unresolved Item (440/77-07-6; 441/77-07-6) - Temperature control in containment The previous RIII Report raised a question concerning provisions for temperature control in the containments during liquid pene-trant testing. During this inspection, the inspector reviewed NNIC Instruction 465-NC-N003, Revision C, dated August 15, 1977, titled " Liquid Penetrant Inspection." Section 7.2 of Instruction 465-NC-N003 requires that liquid penetrant examination be done within a range of 40 F to 125 F, and discusses the use of local heating or cooling as required to maintain the temperature within the specified range. This item is considered to be resolved.

I (Closed) Noncompliance (440/78-02-02; 441/78-01-02) - Lack of Great Lakes indoctrination and training procedure The previous RIII Report noted that no indoctrination and training procedures had been established by Great Lakes Construction Compan During this inspection, the inspector reviewed Great Lakes Procedure No. AQCP-16, Revision 1, dated April , titled " Indoctrination and Training of Personnel," which delineates the required training for specific levels of personnel capability. This item is considered to be resolve (Closed) Noncompliance (440/78-02-21; 441/78-01-21) - Calibration require-ments for U.S. Testing weight scales. The previous RIII Report noted that U.S. Testing (UST) did not have procedural requirements regarding cali-bration of precision weight scale During this inspection, the inspector reviewed UST Calibration Instruction Nc. CI-16, Revision 0, dated February 13, 1978 and accepted by CEI QA on August 10, 1978, titled

" Laboratory Scales and Balances (Mechanical) ." Instruction CI-16 contains requirements for calibration of weight scales, including frequency of calibration and traceability of reference standard weights to standards maintained by the National Bureau of Standards. This item is considered to be resolve (Closed) Noncompliance (440/78-04-02; 441/78-03-03) - Inadequate Dick Corporation procedures. The previous RIII Report noted that there were inadequate Dick Corporation procedural provisions for review of QC inspection plans to ensure that required drawings and specifications are liste During this inspection, the inspector reviewed Dick Corporation l Quality Control Procedure FQC-14.1, Revision 3, dated August 28, 1978, titled "FQC Inspection Report," and CEI letter to Dick Corporation, dated September 20, 1978, which accepts Revision 3 of FQC-14.1 with minor comments. Revision 3 of FQC-14.1 now contains requirements to ensure that all required drawings, specifications, FVA's, ECN's and NR's are listed on the inspection report (plan). This item is considered to be resolved. It should be noted that the above discussion refers to Part b of the noncompliance. Part a, which involved cold-forming of rebar with-

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out an approved procedure, was previously resolved by RIII Report (440/78-05; 441/78-04).

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Section I

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Prepared by J. E. Konklin Reviewed by D. W. Hayes, Chief Projects Section 1. Review of Licensee Action on Previous Inspection Findings The Region III inspector reviewed the licensee actions relative to the resolution of specific noncompliances and unresolved items which had been identified in previous RIII inspection reports, and which were still in an open status prior to this inspection. The items reviewed, and the licensee actions relative to the resolution of each item, are discussed in the foregoing section of this repor . Review of Embedment Inspection Program Previous RIII Reports (78-11; 78-10) and (78-12; 78-11) discussed the embedment inspection program being conducted by CEI, and designated an Unresolved Item (440/78-11-01; 441/78-10-01),

pending resolution of the findings of CQA Audit Report No. 52 and completion of the evaluation of the adequacy of in-place embed-ments. During this inspection, the inspector reviewed, with the CQE and CQC Managers, the licensee actions to date relative to resolution of the findings of Audit Report No. 52. At the con-  !

clusion of the review, the licensee stated that all of the . Audit Report findings will be resolved and corrective actions implemented by October 15, 197 With regard to the evaluation of the adequacy of in-place embedments, the previously committed date of December 1, 1978 for completion of the analysis is still considered by the licensee to be attainabl GAI has been requested by CEI to perform the evaluation. On September 6, 1978 CEI provided to GAI, for use in the evaluation, l J

a data package which includes inspection results of equipment foundation embed frames, survey results on fillet-welded studs, a summary of embed inspection reports, information regarding studs broken during bending, and studies of nonconformance reports issued on embedment To obtain additional technical data for use in the evaluation, CEI is planning to contract with Nelson Division of TRW for a stud tensile testing program, which will include pull tests on 60 to 70-5-

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I samples from embedments presently on-site, with all of the types of 1 significant def ects which have been identified during the embedment )

inspection progra This unresolved item regarding the embedment inspection program will i l

remain open under the previous designation, noted above, pending further review during future inspection f

I CEI Quality Control and Quality Engineering Surveillance of Concrete Contractors

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As a result of the RIII Immediate Action Letter of February 8,1978, I j

the licensee initiated 100% quality control (CQC) inspection of I contractor activities relative to safety-related concrete place-  !

ments, and quality assurance (CQA, now CQE) audits were instituted on 100% of the contractors' and CQC's inspection activities with regard to these placement During an RIII inspection on April 13 and 14, 1978, as documented in Report (440/78-05; 441/78-04), it was agreed that the 100% CQC involvement would be maintained on the activities of all four con-crete placement centractors until a greater confidence level was achieved by the licensee with regard to each contractor. In l addition, it was agreed during that inspection that the 100% CQA l l

(now CQE) involvement would be maintained for S&MC and Dick Corporation, and that the CQA audit schedule would be reduced to a normal level for the other two concrete placement contractors, Great Lakes Construction and National Engineerin l I

During this inspection, the CQC ..anager and the Lead Quality Enginecr discussed with the RIII inspector a planned reduction of CQC surveil-lance on the four concrete contractors to a normal leve A total of 297 inspections and 63 audits were performed by CQE/CQC i on the four safety-related concrete contractors during the period March 1, 1978 to September 20, 1978. The RIII inspector selected on a random basis, and reviewed, 50 of the inspection reports and 25 of the audit reports, and noted that the performance of the four contractors improved significantly during the six month period l under review. Based on this review, and on the discussions noted i

above, the inspector agreed with the planned return to normal inspection and audit levels by CQC and CQ . Status of Plant Construction Activities The inspector observed on-going work activities and equipment status in the Unit 1 and 2 containment buildings and auxiliary buildings,

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J the intermediate building, the control complex, the fuel handling building, and the rebar storage yard The safety-related structural concrete work is approximate 19 50% complete for Containment No. 1, 45% complete for Containment N % complete for the Control Complex building, 62% complete for Auxiliary Building No. 1, 42% complete for Auxiliary Building No. 2, and 44% complete for the tunnel work by S6M Safety-related structural steel fabrication work is approximately 45% complete for Containment No. 1, 30% complete for Containment No. 2, 63%

complete for the Control Complex, 8% complete for Auxiliary Building No. 1, and just recently underway for Auxiliary Building No. Safety-related piping fabrication and installation activities by Pullman are still at a low level, and the safety-related electrical work by Comstock is just beginnin No items of noncompliance or deviations were identified.

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• l Section II l l

Prepared by E. W. K. Lee Reviewed by D. H. Danielsen, Chief Engineering Support Section 2 l Saf ety Related Piping - Review of QA Procedures (Units 1 and 2) j The inspector reviewed Pullman Power Products (PPP) Nuclear Quality l Assurance Program tbnual dated May 16, 1978, included Supplements j

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dated August 23, 1978, (this manual was revised recently and has

not been approved by the licensee or the Authorized Inspector), two )

Gilbert Associates Incorporated specifications and 15 PPP procedures  !

re3ative to safety related piping work activitie The procedures l reviewed included document control; receiving inspection; identifi- l cation; handling; storage; shipping and preservation; cleanliness control; erection and installation; hydrostatic testing; generation

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! and record keepin The inspector determined that the QA Program Manual and the procedures meet the PSAR commitments, 10 CFR 50, Appendix B and the applicable code requirements. It was further determined that the procedures meet the QA Program Manual and the l specification requirement No items of noncompliance or deviations were identifie . Saf ety Related Piping (Welding) - Review of QA Procedures (Units __1 and 2)

The inspector reviewed 19 Pullman Power Products (PPP) procedures related to welding of safety related piping. The procedures

reviewed included control of weld data sheets including hold points; qualification of welding procedures, welders, NDE and inspection personnel; calibration of equipment; control of preheat and interpass temperatures, post weld heat treating; repair of defects and control of welding materials. The inspector detennined that the procedures

meet PSAR commitments, QA manual, 10 CFR 50, Appendix B, and the applicable code requireeents, except that handling of returned welding materials needs to be clarified in either Procedure N VI-5 or No. VIII-3. The inspector stated that the matter of handling of returned welding materials is considered unresolved

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pending a review of the revised procedure. (50-440/78-13-01;

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No items of noncompliance or deviations were identified.

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. Safety Related Piping (Welding) - Observation of Work Activities (Unit 1 and Common to Units 1 and 2)

The inspector observed welding of the root pass of Unit 1 Essential Service Water System Weld No. 17 on Isometric No. 1-P45-19 and Common to Units 1 and 2 Essential Service Water Weld No. 11 on Isometric No. 0-P45-38. It was determined that: (1) proper welding procedures were used, (2) walders were currently qualified and (3) physical appearances were acceptabl No items of noncompliance or deviations were identifie I,

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. - Section III

Prepared by G. F. Maxwell

, Reviewed by R. L. Spessard, Chief Engineering Support

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Section 1 1. _CEI Action Taken Relative to RIII Immediate Action Letter of February 8, 1978 - Units 1 and 2 Relative to Item 8 of the RIII Immediate Action Letter of February 8, 1978:

(1) The inspector reviewed the CEI Corporate Quality Assurance Manual, which was submitted to RIII on August 8, 197 (a) The details of the manual were discussed with the CEI' Quality Assurance Manager who informed the I inspector that CEI plans to make certain revisions I to Sections 0100, 0200, 0900 and 1000 of the l manua l l

(b) The inspector compared the contents of the tbnual l (Policy statement, Sections 0100 through 1800 and l

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Appendix I, II and III) with the requirements of l 10 CFR 50, Appendix B and ANSI N45.2-197 l (c) The inspector noted that CEI has committed (through  ;

Appendix I of the CEI Corporate Quality Assurance Ibnual) to comply with Regulatory Guides 1.28, 1.37, l 1.38, 1.54, 1.58, 1.64 and 1.74. The inspector observed that the Project Administrative Procedures (PAPS), through which the commitments to Regulatory Guides 1.30, 1.39, 1.88, 1.94, 1.116 and 1.123 are made, have not yet been fully develppe It should be noted that the degree to which CEI has committed to comply with the above listed Regulatory Guides is delineated in the applicable PAP noted in Appendix I of the CEI Corporate Quality Assurance Program. In general, the Regulatory Guides / Standards which CEI has imposed on their contractors will be and/or have been listed in the applicable contract specifications.

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(2) The inspector informed the licensee that Item 8 of the RIII Immediate Action Letter of February 8,1978 (the only item of the letter remaining open) will remain open pending receipt and satisfactory review of the approved PAPS 1001, 1002, 1301, 0202, 0901, 1003, 0301, 0201, 1701, 1004, 1005, 0401 and the revised Sections 0100, 0200, 0900 and 1000 of the CEI Corporate Quality Assurance Manua No items of noncompliance were identifie . Quality Assurance Program Review - Electrical - Units 1 and 2 The inspector reviewed selective sections of the ERNST-COMSTOCK QA/QC Manual. ERNST-COMSTOCK (E-C) is an electrical contractor with installation / inspection responsibilities for Class 1E electrical equipment at the Perry Nuclear Plant. Those sections l

l which were selected and reviewed are as follows:

(1) Organization Structure and QA Personnel (reviewed E-C procedures 4.1.4 dated June 27, 1978, 4.1.2 dated June 1, 1978 and 3.2.1 dated June 1, 1978).

(2) Procurement Document Control (reviewed E-C procedures i

4.4.1 dated February 2, 1978, 4.11.1 dated August 1, 1978 and 4. 6.1 dated March 6,197 3) .

(3) Work and Quality Inspection Procedures (reviewed E-C procedures 3.1.1 dated June 1, 1978 and 3.1.3 dated March 28, 1977).

(4) Material Control (reviewed E-C procedures 4.10.1 dated April 27, 1978, 4.10.2 dated June 1, 1978 and 4.1 dated August 1, 1978).

(5) Document Control (reviewed E-C procedures 3.1.1 dated i June 1, 1978, 3.1.3 dated Fbrch 28, 1978, 4.2.1 dated June 1, 1978 and 4.2.2 dated June 1, 1978).

(6) Special Processes (reviewed E-C procedures 4.7.0 dated April 27,1978 and QA 1.0.1, paragraph 4.7) .

Test Control (reviewed E-C procedure QA 1.0.1, paragraph l (7) )

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l (8) Control of Measuring and Test Equipment (reviewed E-C procedure 4.9.1 dated June 1, 1978).

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(9) Quality Records (reviewed E-C procedures 4.10.1 dated April 27, 1978, 4.13.1 dated June 1, 1978 and QA 1.0.1, paragraph 4.13).

(10) Corrective Action (reviewed E-C procedure 4.11.1 dated August 1, 1978 and CQAP 5.1C dated February 2, 197 The procedure addresses the processing / control of hardware nonconformances which require corrective action).

(11) Audits (reviewed E-C procedure 4.14.1 dated June 1,1978) . The inspector compared the above procedures with the Quality Assurance requirements which are specified in the CEI/E-C l contract specification, SP-709-4549-00 dated August 12, 1974; l

10 CFR 50, Appendix B and ANSI N45.2-197 (1) The inspector had concurns about the procurement require-ments imposed on subcontractors, as prescribed in Comstock's procedure E-C 4.4.1, dated February 2, 197 Further review indicated that CEI Quality Assurance personnel had previously identified the same concerns in PNPP Audit Report No. 126 (dated August 4, 1978)

AR-001, AR-002 and AR-00 At this time, the inspector has no further questions about this matter.

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(2) The inspector also had concerns about Ernst-Comstock's procedures for corrective action. The inspector was informed, by CEI Quality Assurance personnel, that E-C has been instructed to revise the applicable procedures to assure that the requirements of SP-709-4549-00, paragraph 1:06.15.2 have been clearly addressed for both hardware and software conditions which are adverse to qualit At this time, the inspector has no further questions about this matte The inspector was informed by the licensee that E-C will not be responsible for the testing of Class 1E electrical equip-men Rather, CEI will establish a test group that will be responsible for the testing of Class lE equipmen No items of noncompliance were identifie _. . - - - _ . _ _ . - _ . .. - _ _ _ . _ _ __ . _ . _ _ _. _ ..- - _._ ...

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Section IV Prepared by J. Hughes Reviewed by R. L. Spessard, Chief Engineering Support Section 1 Independent Inspection A meeting was held by RIII inspectors with approximately 30 Quality Assurance / Control and Engineering personnel involved with instal-lation of Class lE electrical and instrumentation components at the Perry Plant. The personnel included were employed by Cleveland Electric Illuminating Company, Kaiser Engineering, Inc., Johnson Controls and Ernst-Comstock Company. The purpose of the meeting was to discuss past electrical and instrumentation problems identi-fled by IE inspectors at other construction sites and to place into perspective the key role which QC inspectors and installers must pla Through these discussions both public and plant safety may be enhan:ed and undue licensing delays may be avoided in the future. The agenda included: A brief description of the NRC's electrical and instrumentation inspectors responsibilities to both the public and licensee; A discussion of specific electrical and instrumentation problems previously identified by RIII inspectors at other construction site A handout was provided; A discussion of generic quality program deficiencies, such as records and documentation, audits, nonconformance reports, and training; and A discussion on the importance of verifying the validity of supplier certificates, as delineated in Section 10.2 of ANSI N43.2.1 . Review of Electrical Quality Assurance Implementing Procedures

_( Raceway Supports) Ernst-Comstock Electrical Contractors (E-C) is responsible for the installation of Class 1E electrical components and equipmen The RIII inspector reviewed the following implementing pro-cedures:

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(1) Control of Special Process, Section 4.7.0; )

(2) Welding Procedure and Welder Qualifications for Struc- I l

tural Attachments, Section 4.7.1;

! (3) Storage, Issue, and Control of Welding ?bterials, Section 4.7.6; (4T Test and Inspection P.rocedure Magnetic Particle Exami-nation, Section 4.7.8'; and (5) Hanger Fabrication and Installation, Section 4.3.1 I

1 No items of noncompliance were identifie l l

3. Electrical (Raceway Supports) - Observation of Work Activities

, The RIII inspector made a tour of Ernst-Comstock (E-C) laydown

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areas. The inspector observed the following: l (1) The material used for raceway supports (hangers), and conduit was protected from adverse environment and physical damag (2) Material identification and control of issue from storag (3) Nonconforming materials were identified by hold tags and segregated in a hold are The RIII inspector observed the fabrication of seismic Class 1E raceway supports (hangers). The observation included:

(1) Fit-up of material; (2) Welding; (3) Magnetic Particle Examination test of the finished welds; and (4) Verification that the detail drawings in use were current  !

revision I The RIII inspector observed the installation of raceway I supports (hangers) located at the lower level of the Control Couplex Buildin The observation included:

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(1) Correct location by layout drawings; (2) Welding of the gussets to the building structural steel; (3) Welding of supports (hangers) to the gussets; (4) Magnetic particle Examination test of finished welds; (5) Weld rod control and. issue to the craft personnel; and (6) Verification that the installation drawings were current revision I No items of noncompliance were identifie . Electrical (Raceway Supports) - Quality Records The RIII inspector reviewed QC records pertaining to fabri-cation and installation of raceway supports (hangers).

(1) Welder's qualification tests are in accordance with E-C procedure, Section 4.7.1 and AWS D1.1-7 (2) Weld rod is being issued and stored in accordance with E-C procedure Section 4. (a) The inspector reviewed weld rod issue cards, for heat numbers, lot numbers and amount issued and re tu rne (b) E-C QC is maintaining a log for the weld rod storage oven; the inspector verified that the temperature is being maintained at 250 1 25 F. Rod type and heat and lot numbers are marked on the ove (c) The RIII inspector verified that the magnetic par-ticle equipment (MT-024) had a current calibration sticker, The RIII inspector reviewed the qualification and training records for two Ernst-Comstock (E-C) Non-Destructive Exami-nation personnel. The records shot; the personnel are qualified in accordance with E-C procedure, Section 4. The RIII inspector reviewed records pertaining to the fabri-cation of raceway supports (hangers). These included:

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(1) Cable tray support drawings 55-213-111, sheet No. T8, revision A; SS-213-lli, sheet No. T56, revision A; and SS-213-121, sheet No. T64, revisio The drawings have the QC inspector's initial, welder's ID, fitup, visual and magnetic particle test result (2) Magnetic particle examination report was found to be in accordance with E-C procedure, Section 4.7.8; the accep-tance criteria is AWS D1.1-75. The report identifies equipment, calibratio'n data, type of powder and test result No items of noncompliance were identifie Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations. An unresolved item disclosed during the inspec-tion is discussed in Section li, paragraph Exit Interview The inspectors met with site staff representatives (denoted under Persons Contacted) at the conclusion of the inspection on September 22, 1978. The inspectors summarized the purpose and findings of the inspection. The licensee acknowledged the findings reported herei I l

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