IR 05000440/1983013
| ML20024E320 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/09/1983 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Bloch P, Bright G, Kline J Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8308100233 | |
| Download: ML20024E320 (15) | |
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August 9, 1983 Peter B. Bloch, Esq., Chairman Dr. Jerry R. Kline
Administrative Judge Administrative Judge
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Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Mr. Glenn 0. Bright Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555
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In the Matter of CLCVELAND ELECTRIC ILLUMINATING COMPANY, ET AL.
(Perry Nuclear Power Plant, Units 1 and 2)
Docket Nos. 50-440 OL, 50-441 OL
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Dear Eoard Members:
J With try 'etter to U.e Licensing Board of May 6,1983 I enclosed copies of two of inc three documents that had been requested by Chairman Bloch.
i I rtcted that I would provide copies of the third document to the Board
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and interested pretics after it became available. That document, the report of the quality assurance inspection at Perry that was initiated by the NRC Staff in April 1983 (Report 8312 dated July 25,1983),
is enclosed.
Sincerely,
James M. Cutchin IV (
Counsel for NRC Staff i
Enclosure:
As stated
REGION til
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'JUL 2 5 1983
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Docket No. 50-440
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i Docket No. 50-441
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The Clevelan'd Electric Illuminating Company ATTN:
Mr. Murray R. Edelman
.i Vice President
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Nuclear Group Post Office Box 5000 Cleveland, OH 44101 Gentlemen:
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This refers to the special safety inspection conducted by Messrs. J.
N. Nish, e.vi T. E. Vendel of the Region III office, and G. F. Maxwe]] of the Region 11 of fice on /.pril 4-8; 13-15, May 10-13, and June 15, 1983, of activities at Perry Nuclear Power Flant authorized by NRC Construction Licenses No. CFPR-148 and No. CPPR-149 and to the discussion of our findings with Mr. C. M. Shuster and members of your rtaff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during
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the inspection.
Within these areas, the inspection consisted of a selective
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examinatico of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.
A written response is required.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s)
will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of
the date of this letter.
Such application must be consistent with the re-quirements of 2.790(b)(1).
If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s), and your response to this letter will be placed in the Public Document Room.
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The Cleveland Electric Illuminating
Company
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The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
We will glad,1y discuss any questions you have concerning this inspection.
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Sincerely, noriginal SI ned by J. F. Stre'eter"
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S J. F. Streeter, Chief Engineering Branch 1
Enclosures:
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1.
Appendix, Notice of Violation 2.
Inspection Reports
No. 50-440/83-13(DE)
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Nc. 50-441/83-12(DL)
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REGION III==
Report No. 50-440/83-13(DE); 50,441/83-12(DE)
Docket No. 50-440; 50-441 License No. CPPR-148; CPPR-149 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name:
Perry Nuclear Power Plant, Units 1 and 2 Inspection At:
Perry Site, Perry, OH Inspection Conducted: April 4-8, 13-15, May 10-13, and June 15, 1983 d. MM
,jYl@3 Inspectors:
J. N. Kish Jm j
G. F. Maxwell (Region II)
T E 57f(J T
f glfM T. E. Vandel Approved By:
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Management Programs Section
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Inspection Summary Inspection on April 4-8, 13-15, May 10-13, and June 15, 1983 (Reports No. 50-440/83-13(DE); 50-441/83-12(DE))
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Areas Inspected:
Special, announced inspection by Region II and Region III inspectors of the licensee management of the Quality Assurance Program, licensee auditing activities, and quality assurance progra;n activities of three safety-related contractors onsite. The inspection involved a total of 203 inspector-hours onsite by three NRC inspectors.
Results: One item of noncompliance was identified:
(failure to periodically assess the adequacy of the quality assurance program - Paragraph 2).
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DETAILS 1.
Persons Contacted
Cleveland Electric Illuminating Company (CEI)
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- M. Edelman, Vice President, Nuclear - Cleveland Electric Illuminating Co.
- T. Boss, Supervisor, Construction Audit Group
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Cimonelli, Electrical Quality Engineer i
J. Connelly, Unit Supervisor K. Currier, Document Control Coordinator D. Ernest, Engineering Aide
- V. Higaki, Electrical Quality Engineer A. Jones, Project Licensing
- R. Jadgchew, General Supervision, Licensing
- K. Kaplan, Senior Engineering Technician
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- J.
Kerr, Unit Supervisor
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- M. Kritzer, Unit Supervisor J. Kline, Manager, Nuclear Engineering Department
- G.
Leidich, Senior Engineer
- P. Martin, General Supervisor, Engineering
- R. Matthys, CQS, Lead Piping
- E. Riley, General Supervisor, CQS
- C. Shuster, Manager, Quality Assurance
- F. Stead, Manager, Nuclear Engineering Department
- E. Sterle, Construction Manager
- T. Swansiger, QA Engineer i
- S. Tulk, Quality Engineer
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- J. Wack, CQS Engineer
- H. Walls, Senior NDE Administration
- B. Walrath, General Supervising Engineer, CQS Pullman Power Products Company (PPP)
M. Lipscomb, Training Coordinator
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J. Miller, QA Manager D. Sebastion, Lead Internal Auditor R. Rutkowski, Drawing Coordinator Metalweld, Inc.
R. Garret, QA Manager Pittsburgh Bridge and Iron (PBI)
J. Annulies, QA Construction Manager Kaiser Engineers, Inc. (KEI)
P. L. Gibson, Project QC Manager D. L. Howard, Director, Quality Assurance
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Gilbert Associates, Incorporated (GAI)
N. Barker, Vice President and General Manager R. Lewis, Manager, QA Programs Nuclear Regulatory Commission (NRC)
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L. Gildner, Senior Resident Inspector, Construction
- Denotes.those persons attending one or more of the exit briefings s
held on April 8, 15, May 13, and an exit meeting held on June 15, 1983.
2.
Program Areas Inspected a.
Quality Assurance Program A review of the licensee Quality Assurance Program was conducted.
This review covered (1) the inclusion of licensee commitment to regulatory guides / codes and standards, (2) adequacy of management review and assessment of the program, and (3) control of program revisions.
(i) Commitments to Regulatory Guides:
A comparison was made of the regulatory guides listed in Appendix I of the QAM to:
(1) the inclusions of commitment details in the relevant sections of the QAM and/or relevant sub-tier Project Adminis-trative Procedures (PAPS), (2) the historical revisions of the QAM for continuity of the inclusions, and (3) the FSAR Chapter
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1.8 commitment information.
It was determined that the QAM did not uniformly provide
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commitments to the applicable regulatory guides and that at best only a few were found in the QAM.
Most Appendix I listed regulatory guides were found to have been acknowledged in PAPS, some with such disclaimer wording as, (ie; " Project position in response to regulatory guide 1.94 and ANSI N45 2.5").
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In response to discussions held with the CEI Vice President -
Nuclear, a revision to the QAM was promised to provide commit-ment details in the QAM and in addition the new revision would i
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also include a document hierarchy triangle depicting the I
commitment documents and the sub-tier implementation documents.
This revision was completed and issued on April 12, 1983, and was subsequently reviewed by the NRC Inspectors during the course of the inspection.
(ii) Program Revisions A side-by-side comparison was made of the QAM from the original 1978 version (Revision 0) through all revisions up to and including the most recent revisions currently in use.
It was revealed that:
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(1) The manual now adequately includes commitments to the applicable regulatory guides (2) Changes were significant in Section 0200 of the manual regarding the management assessment of the Quality Assurance Program commitments in Paragraph 1.4 as to meetings frequency, documentation and subject coverage.
This item is' identified and discussed further in the next paragraph.
(3) A heirarchy of QA program documents figure is now included.
New NRC requirement, regarding submittal of QA Program t
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changes for regulatory review by the Regional offices, had been added to the QAM.
No significant reduction in program controls were identified other than the Section 0200 changes.
(iii) Management Program Review The licensee's review and assessment of the status and adequacy of the Quality Assurance Program was reviewed. The QAM Section 0200 provides, in paragraph 1.4, for the management review and evaluation of the Quality Assurance Program procedural require-ments.
Consistently, from the original revision through Revision 3 of the QAM section, the requirements have remained the same and required that the QA Advisory Committee (QAAC)
shall perform quarterly reviews and report the results to top CEI management and that the reviews shall be documented and shall incorporate the input provided by the following:
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(1) Personal assessments of QA agent representatives on the committee (2) Audit trend analysis provided by PQS Quality Administra-tion
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(3) Nonconformance trend analysis provided by CQS Quality Engineering (4) Corrective action request evaluations provided by CQS and PQS General Supervising Engineering (5) Evaluations provided by outside audit groups or QA task forces which may be organized by the QAAC to provide specialized input.
(6) Conventional management, appraisal, and analysis techniques.
These finite requirements were in effect until issuance of Revision 4 which became effective on September 15, 1982.
The specific requirements, deleted from the QAM Section 0200, were redefined and incorporated into a charter that was approved and authorized during June 1982, that committed to biannual meetings to be held and reported.
In response to questioning, licensee personnel indicated that they had issued a Program Revision Notice (PRN) in June 1982, revising the current QAM section to be compatible with the newly issued chart. However, they were unable to provide a copy of any such issue notice nor was the QAM section revised until
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September 1982; thus, two conflicting procedure instructions appeared to be in effect fer approximately two months in 1982.
The NRC Inspector reviewed the activities of the QAAC committee for the year of 1981 with the following results:
(a) Two meetings were held and results documented during the year of 1981; one held on March 5-6, 1981 and the second on June 11-12, 1981.
(b) A letter was issued by the Nuclear Quality Assurance
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Department (NQAD) Manager on August 4, 1981, advising of the upcoming scheduled meeting and outlining the objectives for the meeting. This meeting was never held, nor were any other meetings held by the Committee during the remainder of 1981.
During the review of the monthly and quarterly Performance Analysis Reports (PARS), which were provided routinely to the licensee management, the Inspector learned that the Manager NQAD had been reporting significant QA problems in these reports previously during 1981. For example, Pullman Power Products had been rated unsatisfactory for the year in most of the monthly reports due to problems related to material control, inspector qualifications, and QC inspections. The inspector additionally learned that in April 1982, the format of the periodic reports (PARS) had been altered. The change eliminated supporting detailed data, resulting in a loss of ability to ascertain status of contractor performance or disposition of deficiencies by licensee management.
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There was no evidence that these kinds of problems were being considered and/or evaluated by the Committee.
In response to questions by the~NRC Inspector, it was learned from the Gilbert Associates, Inc. (GAI), Vice-President and General Manager Quality Assurance Division, (a member of the QAAC Committee), that quarterly PARS were available to the Committee and were reviewed by the Committee (though not documented).
The GAI Vice-President also informed the inspectors that an informal undocumented meeting was held offsite in September 1981, in lieu of a regular scheduled meeting.
This failure to conduct quarterly meetings for the express purpose of reviewing the QA Program and reporting the results to CEI management, as committed to in the CEI Quality Assurance Manual is considered to be an item of noncompliance with 10 CFR Part 50, Appendix B, Criterion II (440/83-13-01; 441/83-12-01).
b.
Licensee Program Controls Licensee procedures and activities related to programmatic controls were reviewed.
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(1) Design / Document Control The following procedures and documents were reviewed:
(a) QAM 0300 - Design Control (b) QAM 0600 - Document Control (c) PAP 302 - FDI and FDDR Control (Field Design Instructions and Field Design Document Revision)
(d) PAP 605 - Drawing File Control
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The Document Control Center has the responsibility for receipt of and distribution of revisions to drawings, Engineering Change Notices (ECNs), and Drawing Field Variance Authoriza-tions (FVAs). Additional responsibilities include the retrie-val and disposition of obsolete drawings.
Two drawings were selected at random for review to check for proper status control. Each drawing was stamped with the FVA and ECN control numbers. A check with the document control center to compare the control numbers indicated the drawings were the current revisions and had correct FVA and ECN control numbers.
(ii) Contractor Controls (1) Electrical Contractor The NRC Inspector conducted an in-depth evaluation of the licensee's controls over the site electrical contractor
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(L. K. Comstock). The evaluation included a review of the licensee audits of the contractor's implementation of their QA Program, licensee surveillance inspections of electrical construction activities, Corrective Action Requests and Stop Work Notifications written by the li-censee against the electrical contractor, and audits conducted by the electrical contractor. The details of the above reviews and evaluations are as follows:
(a) Audits conducted by CEI of L. K. Comstock (LKC)
construction activities were evaluated for the time period between mid-1980 and mid-1982. The most significant audits were documented in audit report numbers AR 452, AR 553, and AR 684. They were con-ducted during October 1980, October 1981, and May 1982, respectively.
The three audits were considered as being the most significant in that they demon-strated an evaluation of LKC implementation of their entire QA Program as it relates to each of the criteria of 10 CFR 50, Appendix B, and the supple-menting regulatory guides which address the various ANSI standards (i.e., ANSI N45.2, N45.2.2, N45.2.6, and N45.2.12).
The other CEI construction audits of LKC activities included audits of the implementing
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procedures related to qualification and certification of Q.C. inspection personnel, cable and conduit in-stallation, maintenance of class 1E hardware and
equipment, and the installation of electrical raceway
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support anchor' bolts.
(b) CEI Surveillance Inspection Reports (SIR), document-
ing the activities of LKC overview, were reviewed for the time period of mid-1980 until mid-1982. CEI
revised the format and style of writing the SIRS in
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August 1981.
In general, the reports from mid-1980 until August 1981, were very brief and described the daily overviews of LKC by the assigned CEI inspectors.
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After August 1981 until mid-1982 the reports (SIRS)
were utilized as a summary form to document more specific and detailed information.
The reports docu-j ment such surveillances as Class IE cable pulling activities, Class 1E equipment installation, electr-
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ical equipment maintenance, housekeeping, overview of LKC Q.C. inspector activities, the use of specialized electrical tools, cable terminations, cable tray
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installations, conduit installations, electrical craft work activities, LKC personnel training, personnel l
qualification, records review, and filing. The
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inspector observed that in general, the SIRS were
useful to the responsible CEI personnel.
(c) Audits conducted by LKC during mid-1980 until mid-1982
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were reviewed and evaluated to determine if they
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depicted an overall evaluation of the implementation i
of their QA Program.
As a result of the above evaluations, the inspector observed:
l (d) CEI audit report 452, item AR001 concerning inadequa-
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cies of the LKC audit program was opened on October 23, 1980 and remained open until on or about
_ November 18, 1982.
(e) Audit item AR006, also identified in the above report, concerned how LKC was to control their records to comply with the records storage requirements of ANSI N45.2.9, was opened on October 21, 1980, and remained open until June 11, 1982.
i (f) LKC self audit report items Q-82-02-256-1 and-2, and Q-82-02-257-1, -3 and -4 were opened on December 31, 1981, and remain open.
The LKC audit items that remain open are asssociated with
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findings relative to improper control of equipment cali-bration, not adequately controlling out-dated procedures,
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inaccurate certification records, equipment storage, and failure of Q.C. to witness maintenance activities.
(2) Mechanical and Piping Contractor
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The NRC insp,ector conducted a review of the licensee's controls for the site mechanical and piping contractor, Pullman Power Products Inc. (PPP). The evaluations and review included a review of the licensee audits of the contractor implementation of their QA program and
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surveillances of their construction activities, corrective action by the licensee (including the trend analysis
program), and audits conducted by the contractor. The
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details of the review and evaluations are as follows:
(a) Audits of the contractor, conducted by CEI, were i
reviewed along with related Corrective Action Reports (CARS) for the period mid-1980 through mid-1982.
CARS of interest which were reviewed included 0502, 0503, 0505, 0507, 0509, and 0510.
These CARS identi-fied errors which were addressed by the contractor and completely corrected in a timely fashion. The corrections were also verified and closed by the licensee.
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Three audit reports which were reviewed included 81-03 (August 31, 1981), 82-04 (February 19, 1982)
and 82-17 (June 18, 1982).
The last audit required
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that certain purge dam material be removed from the site.
The inspector observed that the item was closed out as accepted without verification of com-
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pliance, but with a note that the CQA should be advised when accomplished.
(b) The licensee's Corrective Action Program for Pullman Power Products was reviewed by the inspector to determine the status and effectiveness of the program.
In addition, PPP's Nonconformance Report Program was
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reviewed.
As part of the PPP NCR inspection review, the inspector reviewed Procedure No. XV-2, " Procedure
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for Handling Nonconformances (Field)". The inspector noted that Pullman uses a form known as an NR infor-mation sheet to supplement the basic NCR form. The NR information sheet is used to initiate an NCR if conditions warrant. There are no instructions for documenting that the disposition of the NR-has been verified. The NR sheet does contain a signature block
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with the heading " Disposition Verified" on it.
The lack of any instructions or Pre-requisites for signing
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this block off has led to some problems in the area of properly closing out NCR's and verifying their disposition.
Pending further review of this area, this is considered
anunresolveditem(440/83-13-)d-02;441/83-12-02).
(c) The inspector also reviewed Audit Reports, Corrective Action Reports (CARS), and trending pertaining to PPP.
Several reports identified deficiencies relating
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to positive verification of corrective action. Speci-fically, they are as follows:
Issue CAR Report #
Item #
Date Finding 543
6/19/81 Could not provide documentation for l
verifying NR PPP 463 and 468.
630
12/4/81 PPPs system for NR close out does not provide for positive verification
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7/8/82 Procedure XV-2 fails
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to provide direction and detail for PPP controlling non-con-
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formances.
l Although CEI realized that a problem existed in the area of verifying dispositioning of NRs, as evidenced by the Audit Reports above, the Corrective Action i
recommended did not prevent the continuing occurrance i
of these problems. Licensee personnel stated that
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all three audit reports have been closed out.
The Corrective Action Program will be reviewed further regarding status and effectiveness. This is considered an unresolved item (440/83-13-03; 441/83-12-03).
(d) Review of the contractor auditing activity for the same period established that the PPP audits were quite effective with significant items being identified and
corrected.
Report number 7026-1-82 for February 22-26,
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1982, noted and corrected the use of an unapproved
hydrostatic test procedure. Surveillance activity by PPP appeared to be equally effective. Surveillance
reports reviewed included QASS-1 (August 5, 1981),
QASS-2 (February 9, 1982), QASIA (January 21, 1982),
QASIA (February 2, 1981) and QASIA (March 3, 19,82),
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l (e) Trend Analysis Program review of the licensee's audit findings also indicated a large number of deficiencies in the procedures the licensee was auditing.
Speci-fically, 25% of the deficiencies could be classified as inadequate procedures. This fact was not detected by the, Trend Analysis Program committed to in Proce-dure No. 1602 of the Corporate Nuclear Quality Assurance Program.
Pending further review of this matter by the inspector, this is considered an Unresolved Item 40/83-13-04, 441/83-12-04).
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(f) Documents reviewed included:
CEI computer printout on Audit Report Findings
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related to PPP.
(Program #E7887558 during the period mid-1980 through mid-1982).
Pullman Power Procedure XV-2 " Procedure for
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Handling Nonconformances (Field)" - September 16, 1982.
Audit Report Number 703 of July 8, 1982 (Items
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1 and 23).
Audit Report Number 543 of June 19, 1981 (Item 1)
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Audit Report No. 630 of December 4, 1981 (Item 6)
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CEI Procedure Numer 1602, " Trend Analysis" -
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November 2, 1982 Licensee program and program controls appeared to be adequate and effective except for the cited violation in paragraph 2.1.(iii).
3.
Contractor Program Control l
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l The NRC inspector conducted a sampling review of licensee contractors program and controls for activities being conducted for Perry Nuclear
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Power Plant. The contractors reviewed were Pullman Power Products, Inc.
(Mechanical / Piping Contractor), PBI Industries (Structural Erection i
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Contractor), and Metalweld, Inc. (Coating Contractor).
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The review included the following:
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Organization and independence of the QA/QC inspection activity.
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Qualification and Certification system for inspections c.
Staffing of QC inspectors d.
Utilization of program controls for drawing document control, nonconformance control and corrective action.
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Auditing and surveillance activities
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The licensee's auditing and surveillance activities of the contractors
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were quite effective in identifying and correcting, on a timely basis, concerns and deficiencies.
Training and qualifications activities of PPP inspectors and craf t
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i personnel were observed to be in the process of being upgraded with i
larger training facilities-and with improvements in the training system.
l The upgrading appeared to be beneficial.
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Contractor Controls and implementation for document control, nonconform,
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ances, corrective action appeared to be under good control for all con-
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tractors except for the unresolved items addressed in Paragraph 2.b.(ii)(2).
The NRC inspector recognized the effective performance by the Perry site organization whose auditing and enforcement program had achieved signif-
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icant improvement in contractor performance during the period beginning l
in early 1982 to present.
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4.
Unresolved Items
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Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved Items disclosed during this inspection are discussed in paragraph 2.b.(ii)(2).
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Exit Interview The inspectors met with licensee personnel (denoted in Paragraph 1)
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conducted at exit briefings conducted on April 8, 15, May 13, and
the exit meeting on June 15, 1983. The inspectors summarized purpose
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i and scope of the inspection. The findings were acknowledged by the
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licensee.
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