IR 05000440/1982008

IE Mgt Meeting Repts 50-440/82-08 & 50-441/82-07 on 820402. No Noncompliance Noted.Major Areas Discussed:Systematic Assessment of Licensee Performance for Jul 1980-Sept 1981. Util Overall Regulatory Performance Satisfactory

ML20055B509
Person / Time
Site:	Perry
Issue date:	03/31/1982
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055B504	List: IR 05000440/1982008 ML20055B503 ML20055B510
References
50-440-82-08, 50-440-82-8, 50-441-82-07, 50-441-82-7, NUDOCS 8207220435
Download: ML20055B509 (21)

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U. S. NUCLEAR RL ULATORY C0}D11SSION ,

REGIO!! III SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE s

The Cleveland Electric Illuminatir.g Company

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PERRY NUCLEAR GENERATING STATION, UNITS 1 AND 2 Docket Nos. 50-440 and 50-441 s-Report Nos. 50-440/82-08 and 50-441/82-07

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Assessment Period July 1, 1980, to September 30, 1981 s

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CONTENTS Page SALP Board Chairman Letter to Licensee lii

.- Licensee Comments vi

- Introduction ................................................. 1 I Criteria ..................................................... 2 II Summary of Results ................ . ........................ 3

' I Performance Analyses . . . .............. ....................... 4 Supporting Data and Summaries ................................ 12 A. Noncompliance Data ........................................ 13 B. Licensee Report Data ...................................... 14 C. Licensee Activities ....................................... 14 D. Inspection Activities ..................................... 14 E. Investigations and Allegations Review .................... 14 F. Escalated Enforcement Actions ............................. 15 G. Management Conferences .................................... 15 t

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Docket No. 50-440(DEPOS)

Docket No. 50-441(DEPOS)

The Cleveland Electric Illuminating Company ATTN: Dalwyn R. Davidson Vice President System Engineering and Construction Post Of fice Box 5000 Cleveland, OH 44101 Gentlemen:

This is to confirm the conversation between your Mr. R. L. Vondrasek and our Mr. P. R. Wohld scheduling 1:00 p.m., April 2, 1982, as the time and date for the meeting to discuss the Systematic Assessment of Licensee Performance (SALP) Report for the Perry Nuclear Generating Station. The meeting will be held at your corporate office in Cleveland, Ohi Mr. James G. Keppler, Regional Administrator and members of the NRC staff will present the observations and findings of the SALP Board. Since this meeting is intended to be a forum for the mutual understanding of the issues and findings, you are encouraged to have appropriate representation presen As a minimum we suggest that Mr. D. R. Davidson, Vice President, System Engineering and Construction, Mr. M. R. Edelman, Manager, Nuclear Engineering, and R. L. Farrell, Manager, Nuclear Quality Assurance be in attendanc Enclosure 1 to this letter summarizes the significant findings identified by the SALP Board's evaluation of the Perry Nuclear Generating Statio While the SALP Board is concerned about the effectiveness of your controls over contractor activities, it believes that you have been responsive and that these concerns are being adequately addressed by the NRC through the normal inspection and enforcement programs. Consequently no response to this letter is require Enclosure 2 is a preliminary copy of the SALP Report.for your review prior to the meetin iii

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The Cleveland Electric Illuminating 2 Company If you wish to comment upon the evaluations presented in the SALP Report your comments should be submitted to this office within twenty days of the SALP meeting; otherwise it will be assumed that you have no comment The Regional Administrator will issue the SALP Report including your comments, if any, after the meetin 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, the SALP Report, and your comments, if any, will be placed in the NRC's Public Document Room when the SALP Report is issue The comments requested by this letter are not subject to the clearance pro-cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511 If you have any questions concerning the SALP Report we will be happy to discuss them with yo

Sincerely, J. A. Hind, Director Division of Emergency Prepardness and Operational Support Enclosures: Summary of Significant Findings Perry SALP Report (5 copies)

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Resident Inspector, RIII

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ENCLOSURE 1 Summary of Significant SALP Report Findings for the Perry Nuclear Generating Station, Units 1 and 2 During the SALP 2 evaluation period of July 1, 1980, to September 30, 1981, management attention and involvement in correcting NRC-identified problems appeared to be assertive, timely and effective. The interface with the NRC on licensing matters was very ef fective in resolving licensing issue Notwithstcnding these positive observations, management control systems were not totally effective in overseeing contractor activities as evidenced by the NRC identifying problems which should have been found and corrected by the licensee. An example was the licensee's failure to identify problems relating to work by the coating contractor. Further evidence was identified subsequent to the assessment period when the licensee failed to adequately identify and correct problems with the electrical contractor1 . The SALP Board notes the February 18, 1982, letter to James G. Keppler from D. R. Davidson, Vice President, System Engineering and Construction, out-lining a program to evaluate and strengthen the quality performance of each safety-related contractor presently working on the site. The SALP Board agrees that this program is necessary to improve the effectiveness of the licensee's oversight of contractor activities and self-identifica-tion and correction of problem At the time of a SALP Board meeting it is a matter of standard practice for the Board to analyze all available information concerning significant matters occurring prior to, during and subsequent to the assessment perio This assures that Board recommendations which affect allocation of NRC and licensee resources are based on the most current indicators of the quality of licensee performanc V

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I. INTRODUCTION The NRC has established a program for Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic' basis and evaluate licensee performance based upon these observations. SALP is supple-mental to normal regulatory processes used to insure compliance to the rules and regulations. SALP is intended from a historical point to be sufficiently diagnostic to provide a rational basis: (1) for allocating future NRC regulatory resources, and (2) to provide mean-ingful guidance to licensee management to promote quality and safety of plant construction and operatio A NRC SALP Board composed of managers and inspectors-who are knowledge-able of the licensee activities, met on February 19 and March 22, 1982, to review the collection of performance observations and data to assess the licensee performance in selected functional area This SALP report is the Board's assessment of the_llcensee safety per-formance at the Cleveland Electric Illuminating Company, Perry Units I and 2, for the period July 1, 1980, to September 30, 198 The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held April 2, 198 J

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II. CRITERIA The licensee performance is assessed in selected functional areas depending whether the facility is in a construction, preoperational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria were used to assess each functional are . Management involvement in assuring quality 2. Approach to resolution of technical issues from a safety standpoint 3. ' Responsiveness to NRC initiatives Enforcement history Reporting and analysis of reportable events Staffing (including management) Training effectiveness and qualification liowever, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The'defini-tion of these performance categories is:

Category Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieve Category 2. NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respa . to operational safety or construction is being achieve Jategory Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and con-siders nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or con-struction is being achieve j

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III. SUMMARY OF RESULTS Functional Areas Category 1 Category 2 Category 3 Soils and Foundations Not Rated Containment and Other X Safety-Related Structures Piping Systems and Supports X Safety-Related Components X Support Systems X Electrical Power Supply X and Distribution Instrumentation and Control X Systems Licensing Activities X Reporting Requirements and X Corrective Actions 1 Preservice Inspections X 1 Protective Coatings X

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IV. PERFORMANCE ANALYSES Soils and Foundations The licensee is not rated in this area. No inspections were performed'

in this are . Containment and Other Safety-Related Structures Analysis Ten inspections were performed and included concrete placement, structural steel installation, containment liner fabrication, and placement of the containment dom In one of those in-spections three items of noncompliance (infractions) wer identified as follows:

(1) Failure to follow procedure in sampling, temperature determination and holding time during a concrete pou (2) Failure to verify or record concrete truck agitating revolutions or discharge tim (3) Excessive use of proficiency testing as a substitue for prior experience in certifying QC inspectors (two of four samples of one contractor).

In a followup inspection, a repetitive noncompliance (Severity Level V) was identified concerning the use of proficiency testing to certify QC inspector These noncompliances are not indicative of programmatic breakdowns. The corrective action was effective after clari-fication of the NRC positio Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears satisfactory, no significant strengths nor weaknesses were identifie Board Recommendations None Piping Systems and Supports Analysis Sixteen inspections were performed and included piping and support system design, welding, non-destructive examination,

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fabrication and installation. The following items of noncom-pliance were identified:

(1) Infraction for failure to follow approved welding procedure requirements in that the weld bead width exceeded the specification (2) Infraction for failure to follow approved procedures and allowing piping to be " cold sprung" or prestressed into a fitup positio (3) Severity Level V violation concerning failure to select proper shim thickness so that the total thickness being radiographed under the penetrometer is essentially the same as the total weld thicknes (4) Severity Level V violation for failure to control welding material in that the welding material storeroom was found unlocked, unattended, and a 1.5 foot hole had been cut in one wal The four items of noncompliance, which were identified in four separate inspections, represent isolated problems. They are not indicative of a major breakdown in the quality assurance progra In each case the licensee was responsive in initi-ating appropriate corrective actio The corrective action associated with using improper shim thickness in radiographing shop welds is still in progres This problem was limited to one piping contractor. The licensee has setup and is implementing a detailed review of the radiographs. The full significance of this review has not been determined, but at this time it is not expected to be a major proble Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears satisfactory, no specific strengths nor weaknesses were identifie Board Recommendations None 4. Safety-Related Components Analysis Six inspections were performed. The following items of non-compliance were identified:

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(1) ' Infraction for failure to protect the reactor pressure vessel anchor bolts in that water and debris were allowed-to accumulat (2) Severity Level V violation for failure to follow approved procedures in that reactor vessel internals were installed in rai These noncompliances appear to be isolated instances and were adequately addressed by the license Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears satisfactory, no specific strengths nor weaknesses were identifie Board Recommendations None 5. Support Systems Analysis TWo inspections were performed in the area of heating, ventila-tion, and air conditioning systems. Observations of ventilation systems for the containment and for electrical switchgear were made to determine that the installation of seismic supports were in accordance with procedures, drawings, and specifications. No items of noncompliance or deviations were identifie Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears.to be satisfactory, no specific strengths nor weaknesses were identifie Board Recommendations None 6. Electrical Power Supply and Distribution Analysis During the evaluation period, five routine inspections by region based inspectors and inspections by the resident inspector were performed. The major inspection effort was devoted to the installation of cable trays, conduit, and electrical equipment including pump motors, a switch gear cabinet, motor operated valves and a battery charge ]

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Followup was conducted on IE Circular 79-17, 79-20 and 78-08 (Environmental Qualification of IE equipment). One of the inspections at the end of the evaluation period was devoted to cabic pulling activities. The following items of noncom-pliance were identified relative to installation of the battery charger and cable pulling activities:

(1) Severity Level V noncompliance for failure of the in-sta11ation drawings and/or procedures to provide the size and torque values of the hold down bolt (2) Severity Level VI noncompliance for failure to follow approved procedure as indicated by the following two examples:

(a) Class 1E cables were not protected from the sharp edges of cabic tie (b) Medium voltage armored power cables were installed in their exclusive cable trays without a nominal spacing of 3/8 inch between adjacent cable Approximately one month subsequent to the SALP evaluation period, quality control problems associated with electrical installation work were identified during an investigation initiated October 27, 1981. The investigation was initiated as a result of allegations; however, its scope was extended beyond the initial allegations when other problems were identified. The investigation identified potential items of noncompliances (currently under review for appropriate enforcement action) related to inadequate procedures and QC inspection activities, drawing errors and administrative )

breakdowns in the performance of audits and handling of non-comformance reports. Taken individually these findings may not represent major problems, but collectively they reveal deficiencies in the implementation of the quality assurance program in that problems are not identified and corrected in a timely manne The initial phase of the investigation resulted in the issuance of a Confirmation of Action Letter on November 18, 1981. This letter confirmed the licensee's action to suspend the pulling of all safety-related cables by the electrical

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contractor pending resolution of the identified problem The licensee was responsive to the identified problems and initiated corrective action. However, continuing investiga-tion and inspections identified.other problem areas. These concerns were expressed in a management meeting held on

, February 10, 198 In response to NRC concerns expressed in the management meeting, the licensee outlined and initiated an overall corrective action program as indicated in a letter dated

, February 18, 1982. This new corrective action program will include a review of the control systems for all onsite safety-related contractor l l Conclusion a

The licensee is rated Category 3 in mais area. The results ;

of the investigation indicate the licensee has not made l

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effective use of resources in that procedures and policies i are occasionally violated, some reviews and corrective action have not been timely, a breakdown in design control is

evident, and some audits are not timely. The results of

the investigation indicate that the basic findings existed during the evaluation period.

Board Recommendations

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Even though the licensee has outlined and initiated a corrective action program as indicated in a letter dated

, February 18, 1982, the Board recommends continued attention

{ by both licensee and NRC in this area. The NRC should devote available resources to assure that the licensee's corrective action program is effective in correcting both past and future problem . Instrumentation and Control Systems 5 Analysis Three inspections were performed, one was devoted to test and measurement equipment and the installed plant instru-mentation calibration program. The other two inspections included observation of safety-related level instrumentation installation in the condensate storage tank and the installa-tion of safety-related piping in the containment dome for the hydrogen gas analyzer syste No' items of noncompliance or deviations were identified. The licensee exhibited effective planning by taking action to establish calibration programs and log checks at an early stage of the construction program and has been responsive to NRC comments.

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. Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears satisfactor Board Recommendations None 8. Licensing Activities Analysis The licensee responses are above average. While the licensee relies on the NSSS vendor and architect engineer (A/E) for input, the licensee has a competent technical staff onsite to furnish responses and review the NSSS vendor and A/E responses. If the licensee has any problem with NRC requests he asks for clarification and this enhances the quality of his response Responses to NRC review questions on FSAR submittals were delivered within the time frame specified. Most letter requests are also responded to within the time frame specifie In a few cases, NRC request dates have been missed due either to the quantity of effort required or to the licensee's un-certainty of the NRC request. The licensee makes a concerted effort to be very responsiv During meetings with NRC, the licensee has been cooperative and the appropriate technical persons were availabic to make the meetings a succes The utility licensing staff members have an excellent working knowledge of the applicable regulations, guides, standards and generic issues. They attend many NRC sponsored functions and stay current with NRC policie In summary, the licensee has been characterized by NRC as being knowledgeable, cooperative, technically competent, agressive, responsive, and an effective communicator in the area of licensing activitie Conclusions The licensee is rated Category 1 in this are Board Recommendations None

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. Reporting Reauirements and Corrective Actions Analysis As part of an inspection performed early in the evaluation period one item of noncompliance was identified relative to not reviewing a Part 21 report for reportability under 10 CFR 50.55(e). This deficiency lead to a reevaluation by the licensee of their inter-nal procedures for reporting. As a result of this reevaluation and further discussions with NRC staff, the ~ licensee has streng-thened his procedures to promote increased awareness of report-ing requirements. This increased awareness is evident in the twenty seven 10 CFR 50.55(e) reports submitted in the 15-month evaluation period compared to eight reports issued in a previous 12-month perio Conclusions The licensee is rated Category 1 in this area. Effective licensee management attention and involvement were demon-strated by taking what appeared to be minor evidence of a potential programmatic problem and strengthening the entire progra Board Recommendations None 10. Preservice Inspections Analysis Three inspections were performed and no items of noncompliance or devir 4ons were identifed. Management controls of the NDE contract ar's preservice inspection program, procedures, material and equipment were adequate. A review of the NDE contractor's personnel qualifications and training records indicated that his personnel met at least the minimum standards required for NDE performance. Observations of licensee and NDE activities indicate that the overall effectiveness and attitude are satisfactor Conclusion The licensee is rated Category 2 in this are Board Recommendations None

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11. Protective Coatings Analysis Inspection efforts identified quality deficiencies that resulted in the issuances of an Immediate Action Letter by NRC and a Stop' Work Order by the licensee against the nuclear coating contractor, Metal Weld. Three Severity Level V noncompliances of the licensees quality assurance program were identified. These noncompliances included failure to follow established procedures, failure to establish controls for tools, gages and other devices and failure to completely indoctrinate, train and qualify individuals to perform as Level I and Level II inspectors. The licensee actions to correct these deficiencies were responsive and timely. These actions also appear to have been effective since no further problems have been identified in the latter half of the evalu/ ton perio Conclusions The licensee is rated Category 2 in this area. The licensee performance appears to be satisfactory, no further problems have been identifie Board Recommendations None

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. SUPPORTING DATA AND SUMMARIES Noncompliance Data Facility Nare: Perry, Unit 1 Docket No. 50-440 Inspections No. 80-11 through 80-29 81-01 through 81-14 Noncompliances and Deviations *

Severity Levels Categories Functional Areas I II III IV V VI Vio Infr. Def. De . Soils and Foundations Containment and other (1) (3)

Safety-Related Structures Piping Systems and (2) 1 Supports Safety-Related 1 Components Support Systems Electrical Power (1)(1)

Supply and Distribution Instrumentation and Control Systems Licensing Activities Reporting Requirements (1)

and Corrective Actions 1 Preservice Inspections 1 Protective Coatings (3)

TOTALS 2 g i 4 1

Numbers in parenthesis indicate noncompliance common to both unit *

This total does not include one environmental monitoring deviation applicable to both units which was not included in this SALP evaluatio .. .,

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. SUPPORTING DATA AND SUMMARIES Noncompliance Data Facility Name: Perry, Unit 2 Docket No. 50-441 Inspections No. 80-10 through 80-27 81-01 through 81-09 Noncompliances and Deviations!

Severity Levels Categories Functional Areas I II III IV V VI Vio Inf Def. De . Soils and Foundations Containment and other (1) (3)

Safety-Related Structures Piping Systems and (2) 1 Supports Safety-Related 1 Components Support Systems Electrical Power (1)(1)

Supply and Distribution Instrumentation and Control Systems Licensing Activities Reporting Requirements (1)

and Corrective Actions 1 Preservice Inspections 1 Protective Coatings (3)

TOTALS 2 7 1 5 1

2 Numbers in parenthesis indicate noncompliance common to both unit The total does not include one environmental monitoring deviation applicable to both units which was not included in this SALP evaluatio J

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L B. Licensee Report Data Construction Deficiency Reports (CDRs)

TVenty seven CDRs were submitted by the licensee under the require-monts of 10 CFR 50.55(c). Approximately one half of the CDRs were under the licensee's control. Four were the result of Part 21 reports issued by the licensee's suppliers or contractors. See Section IV.9 of this report, for observations concerning 10 CFR 50.55(c) report . Part 21 Reports Four Part 21 reports issued by the licensee's suppliers and contractors were addressed in CDRs issued by the license C. Licensee Activities Unit 1 and Unit 2 were reported by the licensee as being 72% and 40%

complete, respectively, as of September 1981. The project test program was reported as 26% complete. In August 1981 the licensee shifted emphasis from a general to system construction mod Inspection Activities There were no NRC team inspection or review efforts. Routine inspection effort by the NRC has continued throughout the evaluation perio Investigations and Allegations Review Four allegations were received during the evaluation period as follows: In September 1980 an allegation that the liner plate was improperly sandblasted was received by the licensee. No items of noncompliance were identified in a subsequent NRC investigatio . In December 1980 a former weld engineer alleged to the NRC that a weld had been improperly made and nothing had been done to identify and correct the problem. No weld problems were identified in a subsequent NRC inspectio . In July 1981 a former security guard alleged to the NRC that the site security force was involved in drug use, theft, and other improperties. NRC advised the alleger that the NRC does not impose any security requirements prior to receipt of fuel at a construction sit . 'In September 1981 a contract employee made the following allegations to the NRC:

(a) False assumptions were used in pipe stress calculation __ j

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(b) Criteria utilized for pipe stress calculations were not verifie (c) Concrete in the Service Water Building would not hold supports for an instrument lin Items (a) and (c) were not substantiated; however, Item (b) was substantiated and a Severity Level V violation was identifie F. Escalated Enforcement Actions Civil Penalties None were issue > Orders None were issue Immediate Action Letters NRC RIII issued an Immediate Action Letter to the licensee on January 28, 1981, regarding protective coating work. All corrective actions required by the Immediate Action Letter were completed in a timely manner and documented by NRC in Inspection Report N /81-05; 50-441/81-0 G. Management Conferences October 1, 1980, results of the previous SALP were presented to the license .. o,

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