IR 05000440/1985028
| ML20127A774 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/12/1985 |
| From: | Neisler J, Tani K, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20127A736 | List: |
| References | |
| 50-440-85-28, IEB-79-01B, IEB-79-1B, IEB-84-02, IEB-84-2, IEC-81-13, NUDOCS 8506210252 | |
| Download: ML20127A774 (9) | |
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U.S. NUCLEAR REGULATORY C0!EISSION
REGION III
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l Report No. 50-440/85028(DRS)
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Docket No. 50-440 License No. CPPR-148 Licensee:
Cleveland Electric Illuminating Company i
P.O. Box 5000 Cleveland, OH 44101 l
Facility Name:
Perry Nuclear Power Plants, Units 1 and 2 j
Inspection At:
Perry Site, Perry OH Inspection Cor...ed: May 13-17, 1985 h
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i Inspectors:
J. H. Neisler
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Approved By:
C. C. Williams, Chief 6 !/J [If Plant Systems Section Date Inspection Sumery Inspection on May 13-17, 1985 (Report No. 440/85028(DRS))
l Areas Inspected:
Electrical component procedures, installation and records; cable installation and termination; IE Bulletins and Circulars, Construction Deficiency Reports and 10 CFR 21 reports; and items identified during previous inspections. The inspection involved 64 inspector-hours onsite by two NRC inspectors.
Results: No violations or deviations were identified during this inspection.
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DETAILS 1.
' Persons Contacted
Cleveland Electric Illuminating Company
- C. Shuster, Quality Assiirance Manager E. Riley, General Supervisor, CQA
- R. Vondrasek, General Supervisory Engineer J. Haddick, Junior Engineer Reliability and Design Assurance
- S. Tulk, Unit Supervisor, NQAD G. Grueneberg, Inspector QQS
- F. Stead, Manager Engineering, NED
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- L. Beck, General Supervisor Engineering, EED
- R. Segen, Quality Engineer, PQV
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- K. Cimorelli, Lead QE, Electrical, NQAD
- G. Parker, Unit Supervisor, CQS
- R. Matthys, Lead QE, Piping /I&C
- K. Pech, General Supervisor Engineer, NCES s
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- V. Higaki, Unit Supervisor, Electric /I&C, 0QS
- K. Kaplan, Senior Engineering Technican, PAQS W. Boyd, QI, CQS j
- Denotes those persons attending exit interview.
2.
Licensee Action On Previously Identified Items (Closed) Unresolved Item No. (440/84-18-01(DRS)):
It was previously sidentified during an earlier inspection, that the sensing lines for the Reactor Low Water Level Signal did not have the required 1/4" flanged restricting orifices installed as required by Construction Drawing No. 0814-605, Sheet 1, Revision F.
The inspector further observed that
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.there,were no tags on the sensing lines to indicate that the 1/4" orifices had not been installed and would be installed at a later date.
These instrument sensing lines are part of the pressure boundary design and the 1/4" restricting orifice are required so as to meet current design requirements of 10 CFR 50, Appendix A, Criterion 55 and 56, and
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Regulatory Guide 1.11 for instrument sensing lines.
The inspector reviewed the licensee corrective action as follows:
a.
A Gilbert / Commonwealth memo from Mr. A. R. Killian to Mr. R. B. Matthys dated October 12, 1984. This memo was written as a response to the questions raised by the NRC inspector in inspection Report No. 84-18.
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An inter-office correspondence of Johnson Controls dated October 24, 1984, from Mr. Dip Sengmpta to Mr. Dan Duff. This letter discussed the reverification of restricting orifices.
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It also indicated that JCI has completed the reverification of all 1/4" restricting orifices in the reactor building, indicated
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Inspection / Surveillance Report No. 2881, dated September 9, 1984, indicated that line No. A3/B9/C3 which is connected to panel i
1H22-P004 was verified and observed to have the required restricting orifice in place.
The inspector reviewed two Field Material Request (FMR) and two Weld Material Request (WMR) No._32029 and 32030. These FMRS'
and WMRS' documents indicated that the orifice was installed and welded welds Nos.127 and 128 into place as specified in the isometrics.
Based on our review of the above information, this item is considered closed.
3.
Inspection and Enforcement Bulletins (IEB)
(Closed)IEB79-01B. Supplements 1, 2 and 3.
Environmental qualificatior of Class IE electrical equipment has been reviewed and accepted by NRR in Supplement 5 to the Perry Safety Evaluation Report, NUREG-0887 (SSER No. 5) with the exception of Outstanding Issue No. 4.
The issue of environmental qualification of Class IE electrical equipment has been reviewed by NRR and is being tracked in the SER, the inspector has no further questions in this area and considers this bulletin to be closed.
(Closed) IEB 84-02.
Failures of General Electric type HFA relays in use in Class IE safety systems. The inspector examined Field Disposition Instructions (FDI) Numbers WNNV and Work Authorizations (WA) 84-4685, -
84-4560, 84-4561 and 84-5284. These documents provided instructions and authorization to replace the HFA relay coils with GE Century series coil assemblies, No. 184C4137 according to General Electric Service Information Letter SIL-44. All coils in safety-related HFA relays have been replaced with the Century series coil assemblies as of November 12, 1984, according to GE letter 84-4183. This bulletin and IEB 76-02 are considered to be closed.
4.
Inspection and Enforcement Circulars (IEC)
The inspector determined that the following inspection and enforcement circular had been received by the licensee; reviewed for applicability; responsibilities for necessary corrective actions assigned; and that actions described in the circular has been accomplished.
(Closed) IEC 8113. Torque switch bypass circuit for safeguard service valve motors.
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5.
Construction Deficiency Reports-10 CFR 50.55(e) Reports (Closed) 84027-EE (DAR169) Limitorque valve cperator rework. During followup inspection of Limitorque Valve Operators, in response to problems identified at other nuclear facilities with this type of valve operators, the licensee identified numerous deficiencies. To correct the deficiencies, the licensee instituted a comprehensive rework program for the 225 operators in Unit I and those common to both Units 1 and 2.
The inspector examined rework documentation and determined that all the valve operators had been reworked, the deficiencies corrected, the reworked valves tested and turned over to the operating and preoperational test organization. No failures of valve operators have been identified since completion of the rework program. This item is considered to be closed.
(Closed) 81002-EE (DAR 46) NAMC0 limit switches manufactured without an acceptable quality assurance program.
The switches have been replaced by switches manufactured under an approved NAMC0 quality assurance program.
The inspector examined Gilbert Associates audit report of NAMCO, conducted April 10 and 11,1984, and Gilbert inspection reports attesting to the 100%
witnessing of the assembly, electrical test, mechanical test, leak test and packaging of the replacement switches at the NAMC0 plant. This item is considered to be closed.
(Closed) 82003-PP, 82019-EE (DAR106).
Incorrect wipe setting of normally closed contacts on some HFA relays converted from normally open by General Electric shop and/or field personnel. Qualification of the relays were perfonned with calibrated contacts. A relay with less than the specified minimum wipe setting will not fall within the component qualification limits. The inspector's review of completed FDI WNNV revealed that when coil assemblies were replaced, the contact wipe was calibrated / adjusted as required by attachment B, Supplement 4 to SIL-44.
Completed FDI WNQA required and documented the adjustment of both normally open and normally closed contacts. TWP-I-006 established acceptance criteria for contact wipe between 0.046 and 0.093 inches.
NCR No. PQ5 0012 was issued to track the calibration of HFA relays and was closed October 26, 1984. All issues were satisfactorily resolved and this item is considered to be closed.
6.
Electrical Procedures Review The inspector reviewed the following L. K. Comstock electrical procedures to verify that procedures had been established to control storage and issue of materials, special processes, rework, installation and testing of electrical components and materials:
LKC Procedure 4.3.30, PGCC Control Room Work and Inspection, Revision B, dated December 1, 1984 LKC Procedure 4.3.32, Rework Procedure, Revision A dated December 14, 1984
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LKC Procedure 4.3.22, Core Drill ng, Revision B dated November 21, 1984 LKC Procedure 4.7.0, Control of Special Processes, dated April 27 1978 LKC Procedure 4.7.6, Storage, Issue and Control of Welding Materials, Revision A, dated March 27, 1985 LKC Procedure 4.3.33, Housekeeping, Revision 0, dated November 18, 1982 LKC Procedure 4.3.18, Meggering and Continuity Testing, Revision A, dated September 12, 1984 LKC Procedure 4.3.16, Wire and Cable Receipt, Handling, Storage and Issuance, dated August 11, 1982 LKC Procedure 4.7.5, Liquid Penetrant Examination, dated January 21, 1983 LKC Procedure 4.7.8, Magnetic Particle Examination-Dry Method, dated March 11, 1982 The inspector determined that these procedures provided adequate controls in the areas addressed to assure that the work can be satisfactorily completed, examined and corrective actions performed.
No violations or deviations were identified in this area.
7.
Electrical Components Installation The inspector observed completed work relative to the installation of motors, 4160 volt switchgear, 480 volt load centers, Motor Control Centers, DC distribution cabinets, batteries, battery chargers, inverters, and diesel generator control panels. Components included in this inspection included:
Motor Control Center 1R24-50019 Motor Control Center OR24-50036 4160 Volt Switchgear Cabinet 1R22-5009 4160 Volt Switchgear Cabinet 1R22-5002 4160 Volt Switchgear Cabinet 1R22-5004 Unit Substation Transformer Cabinet /480 Volt Load Center 1R23-5009 Unit Substation Transformer Cabinet /480 Volt Load Center 1R23-50012 Battery 1R42-5002, battery rack, charger, panel and inverter
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Diesel Generator Control Panel 1H51-P054A HPCS Pump Motor RCIC Pump Motor LPCS Pump Motor RHR Pumps Motors A and B DAS Panel 1H22-P113
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The inspector observed that minimum electrical separation requirements were not maintained in DAS Panel 1H22-P113 between Reactor Protection System Wiring and wiring of the class IE redundant system inside the upper left corner of the panel. This separation violation remains i
unresolved pending inspection by the licensee of other panels to determine whether this violation of separation requirements is an isolated incident or a generic issue pertaining to this vendor
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(440/85028-01(DRS)).
No violations or deviations were identified in this area.
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Electrical Components Installation Records Review l
The inspector reviewed quality assurance record packages relative to the installation of electrical components. Record packages include receipt and material certification documentation; storage, handling, and
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identification; inspection records documenting that components were installed as specified; weld records; insulation resistance test records;
in-place storage maintenance records; material traceability documentation;
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bolt torque inspection records; fit-up records; certificates of compliance; nonconformance reports; work authorizations; and inspection reports.
Electrical components included in this document review are listed in Paragraph 7 above.
No violations or deviations were identified in this area.
9.
Instrument Installation
During this inspection period, the NRC inspector observed the completed installations and reviewed records for the work and inspections performed by the licensee on the Reactor Trip System.
Included were activities such as installation work and inspection; control of nonconforming conditions and components; cleanliness and housekeeping; and identification and
location. The results of this inspection was as follows:
a.
Instrument Sensing Line Walkdown and Records Review The inspector selected reactor pressure and water level sensor No. B21-D004A which is connected to sensing lines A2 and A3 and is routed to Panel No.1H22-P004. The inspector performed a walkdown f
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inspection of the sensing lines and observed that there were two hold tags attached denoting two outstanding nonconformance reports (NCRs)
on sensing line No. A3. These NCRs documented slope problems with the sensing line. While reviewing these NCRs' (Nos. P0905389 and P0905392), the NRC inspector noted that approximately 200 other slope and dimension deficiencies had been documented on NCR's. This indicated an unusual number of deficiencies on sensing lines signifying a possible generic problem. The inspector questioned the licensee to determine if these adverse construction findings had been reviewed for reportability as required in 10 CFR Part 50.55.(e). The licensee responded that they did not find it necessary to report these construction deficiencies as a 50.55(e) in accordance with their procedures. The following corrective action regarding this issue
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has been initiated by the licensee:
(1) General Electric was requested in to provide assistance in analyzing and evaluating the slope and dimensional deficiencies as documented in letter No. PY-GEN /CEI-2222 dated September 18, 1984.
(2) Corrective Action Request No. 37, 38 and 84-12 were issued to address these deficiencies on the sensing lines (CAR No. 38 was issued September 19,1984).
(3)
Individuals that were involved in the construction, installation and inspection of these sensing lines were reindoctrinated to the requirements of procedure No. QAS-1001-PNPP, Visual Inspection.
(4) The licensee initiated a trend analysis of these deficiencies and the results of this analysis are documented in a memo dated September 25, 1984.
(5) The licensee also comitted to implement a slope verification program to establish a " cold" and " hot" slope baseline. This commitment is documented in a letter from the Perry Contract team to the project manager dated October 10, 1984.
The licensee has identified 60 slope nonconforming conditions in addition to the 200 identified earlier.
The corrective action in (5) above should help in identifying problems during the continuing heat-up test that the licensee is currently conducting.
It appears that the licensee's corrective action has adequate control of this problem. However, the NRC Region III staff plans to followup on this issue, this is considered an open item (No. 440/85028-02(DRS)).
b.
Installation and Inspection Records Review The inspector reviewed work and installation records for sensing lines No. A2 and A3 and instrument rack No. 1H22-P004 and 1H22-P027.
Documents reviewed by the NRC inspector included weld data reports
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and isometrics I/F work packages for these two instruments racks.
The inspector also reviewed Field Material Request (FMR) and Weld Material Request (WMR) for these sensing lines and instrument racks.
No violations or deviations were identified in this area.
c.
Nonconformance Record Review The inspector also reviewed nonconforming conditions and components that were identified by the licensee during installation inspections.
The following is a list of some of the NCRs' reviewed by the inspector:
JCIF-1826 Revision 1, dated September 15, 1984
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(SlopeDeficiencies)
00C-792 Revision 0, dated April 10, 1984
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(Defective Transmitter Fitting)
00C-699 Revision 1, dated February 24, 1984
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(Transmitter Qualification)
0QC-1019 Revision 0, dated August 28, 1984
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(Reversed Transmitter Connections)
00C-700 Revision 1, dated February 24, 1984
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(Transmitter Qualification)
0QC-1103 Revision 0, September 20, 1984
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(Damaged Transmitter Cover)
TAS-055 Revision 0, dated December 16, 1983
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(IEEEQualificationnotmet)
These and other NCRs' that were reviewed by the NRC inspector were either dispositioned as " Scrap", " Repair" or " Rework." The disposition of these NCRs were determined to be adequate.
No violations or deviations were identified in this area.
d.
Cleanliness and Housekeeping Review During inspection of instrument sensing lines No. A2 and A3, the inspector observed that all three instrument racks (1H22-P004, 1H22-P015, and 1H22-P027) were dirty, with pieces of steel bars, rope and other debris on the reeks. This item was previously addressed in NRC inspection report (440/85010).
The NRC inspector understands that housekeeping is an ongoing activity. However, additional attention should be applied by the licensee to this area.
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10. Cable and Termination Installation Observation / Review During this inspection, the NRC inspector reviewed the storage, receipt and inspection of special cables, safety-related cables and Other types of cables.
Inspection was performed in two storage areas.
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The licensee's electrical contractor (L. K. Comstock) has three storage areas designated for cable storage (Turbine Power 2, Turbine Power 1 -
Ramp 2A, and Auxiliary 1 - Ramp 2A). Cable storage requirements appeared to be adequate. A review of the receipt inspection records indicated that the licensee at one time did not provide proper and adequate receipt inspection as required by procedures and Receipt Inspection Report Check List No. DNPP 5646 Revision 2/84. This lack of proper and adequate inspection was identified by L. K. Comstock when 25 reels of special cables were issued for field installation.
L. K. Comstock identified that the reels were damaged, cable ends were not sealed to prevent moisture from entering the cable's inner jackets and the reels and cables were insufficiently identified. These deficiencies were documented on NCR No. P033-5193 dated April 12, 1985. This NCR was subsequently adequately dispositioned.
The NRC inspector observed that the cables that were released for installation had no records (at the time of this inspection) to indicate that the cables were qualified to IEEE-323-1974 and other specifications referenced in Purchase Order No. P-6135-Z.
Pending a review of qualification records for these cables, this is considered an open item (No. 440/85028-03(DRS)).
11. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. An unresolved item is discussed in Paragraph 7 of this report.
12. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Sections 9 and 10, 13. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection and summarized the scope and findings of the inspection. The licensee acknowledged the inspectors' comments.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary.
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