IR 05000440/1986007
| ML20203G428 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/21/1986 |
| From: | Neisler J, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20203G426 | List: |
| References | |
| 50-440-86-07, 50-440-86-7, NUDOCS 8604290068 | |
| Download: ML20203G428 (26) | |
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w U. S. NUCLEAR REGULATORY COMtISSION
REGION III
' Report No. 50-440/86007(DRS)
Docket No. 50-440 License No. CPPR-14 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio
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Inspection Conducted: February 19 through March 12, 1986
Inspector: J. H. Neisle , ,[ '/dh /7/- 3 / - &#d l Date Approved By: M. Eh Operational Programs V2./k Irate Section Inspection Summary Inspection on e through March 12 r bru_ary__19_lnspection Areas Inspected: Followup of"al,l_1986_jReport illt gations received from
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No.hestern 50-440L86007j0R_Sjl Reserve Allianc Results: No violations or deviations were identifie PDR
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G ADOCK 05000440 PDR
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DETAILS e P_rso_ns Contacted
- Shuster, Manager, QA
- Riley, General Supervisor, QA
- Cimorelli, Lead Quality Engineer
- Ferrell, Licensing
- T. Heatherly, Licensing
- E. Parker, Unit Supervisor Pipe /I&C
. *M. Kritzer, Unit Supervisor, Civil Quality A. Slezak, Security T..Mahon, Security A. Thelon, Engineering R. Mathys, Lead Quality Engineer The inspector also contacted other licensee and contractor personnel during the course of this inspectio ' * Denotes those persons attending the exit intervie .- (Closed) Allegation RIII-86-A-0025 The NRC received a petition pursuant to 10 CFR 2.206 from the Western Reserve Alliance (WRA) dated February 4,1986, requesting actica by the-NRC-regarding-the Perry Nuclear Power Plant. The petition included 48 allegations regarding the adequacy of construction of the plan On March 19 and 20,1986, the NRC (Region III), through the Western Reserve Alliance, contacted two of the allegers in an attempt to
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detern.ine if any new or relevant information was available. The first alleger claimed responsibility for allegations 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 37, and 41. This individual provided no new or relevant information,-in fact, most of the information provided was hearsay. The second alleger claimed responsibility for allegation , 43, 44, and 45. This individual did not provide any new or. relevant information. In fact, the.NRC staff had previously reviewed these allegations on numerous occasion In addition to the NRC's routine review and inspection of these allegations, the NRC also reviewed CEI's response to these allegations, dated February 19, 1986, copy attache It should also be noted that allegations 1 through 12 were all related to or were believed to be related to the Radwaste Systems. The Radwaste systems are not safety-relate i
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The NRC's review and inspection of these allegations was as follows:
Allegation 1:
With regard to NRC regulations, the Final Safety Analysis Report (FSAR),
Environmental Safety Report (Safety Evaluation Report) NUREG 88.7, which
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'was made specifically for Perry and 10 CFR 50 workers allege there has been less than the previous connitment by CE NRC Review:
The inspector reviewed CEls changes to the FSAR and their conmitment for the construction of Perry. The 23 amendments to the FSAR have been reviewed by the NRC and any issues segarding changes in CEI's conmitments have been resolved. The acceptances / approvals by the NRC are documented in the Perry SSER Supplements. The licensee's adherence to its coninitments is the purpose of each NRC inspection. NRC Region III conducted approximately 120 inspections at Perry during the past two year In addition, there have been two Constructicn Assessment Team inspections, one Integrated Design team. inspection, and audits by the NRR reviewers from Power systems, Instrunentation and Controls systems, Equipment Qualifications, and Fire l Protection branches. The inspector also reviewed the licensee's procedures, PA 1603, and PAP 0520, governing changes to the FSAR, Conclusion:
Based on the inspector's review of FSAR changes, the licensee's procedures for controlling changes, the number and variety of inspections performed at Perry by the NRC, and the lack of specific infonr.ation from WRA as to which conmitments were degraded, this allegation was not substantiated.
l Allegation 2:
CEI made connitment for radiation waste management system (SER). _ Workers allege that in fact there exists no real quality system, no quality progra NRC Review:
The inspector reviewed the FSAR connitments and the licensee's procedures establishing the quality program for the construction of the radwaste system. Procedures reviewed included: PA-0210. " Surveillance and Inspection of Non Safety-Related Systems and Components"; PA-1505,
" Deficiency Control"; PNPP-6047, "CQS Non-Safety Surveillance / Inspection Report and Checklist"; and PNPP-6408, "QC Checklist for Non Safety Seismic l- Supports." The inspector also reviewed inspection reports, surveillance reports, and deficiency reports pertaining to the radioactive waste syste As a result of the above review, the inspector determined that quality assurance activities for the construction of the radioactive waste system l met the requirements of the applicable Code and the Regulatory Guides.
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Also, see Allegation 3 for additional details as to applicable Codes and l Regulatory Guides.
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T Conclusion:
The inspector determined that the QA program requirements were adequately defined in specific procedures, that the program had been properly implemented, and documented for the radioactive waste system at Perr Based on the above this allegation was not substantiate Allegation 3:
CEI led the NRC to believe CEI was conmitted to Regulatory Guide 1.14 The NRC was led to believe that CEI was connitted to this plan in its entirety. Workers allege that there was only random QC at best. There are many welds that would not meet code requirement NRC Review:
The inspector reviewed the licensee's connitments to Regulatory Guide 1.143 in Chapters 1 and 11 in the FSAR. The licensee conmitted to Regulatory Guide 1.143 with exceptions that the radioactive waste system would be non safety-related Quality Group D as defined in Regulatory Guide 1.26. Further that the system would be built in accordance with ANSI B31.1, Power Piping Code, as stated in Regulatory Guide 1.143, Table 1. Therefore, the Radwaste systems are not safety-related and as such are not required to meet the same stringent controls of a QA program as a safety-related system. That is, only certain elements of a QA program are required to be cet. These controls are properly identified through conmitments in the FSAR. These conmitments and exceptions were all approved by the NRC. The licensee fully met these requirements. The inspector reviewed installaticn and inspection docun.entation attesting to the waste systems' compliance with Regulatory Guide 1.143 and ANSI B31.1. Welders working on this system were qualified in accordance with ASME Section IX, the same requirements as for welders working on ASME systems. In sunmary, the inspector determined that the licensee's conmitments and any exceptions were approved by the NRC; that adequate inspections were perfonr.ed by qualified inspectors; that welding was perfcrmed by qualified welders; and that adequate documentation existed to formally furnish the necessary evidence attesting to the fact the required QA program requirements were me Conclusion:
Based on the review of the licensee's approved conmitments, installation and inspection records, and inspector and welder qualifications, this allegation was not substantiate A_1_ legation 4:
Workers allege that the above conditions have been permitted because CEI has fraudulently classified the waste management system. Workers say the class system that CEI has designated for the waste managerrent system is not in compliance with FSAR commitments. This impropriety has been committed by CEI deliberately to avoid safety requirements, workers alleg e NRC Review:
The radioactive waste system is classified as a nonsafety-related system in FSAR Table 3.2.1. This Table states that the system-is built to the' requirements of ANSI B31.1, Power Piping Code. Architect / Engineer specifications and drawings for the rad waste system specify that it is to be. fabricated, installed, inspected, and tested to ANSI B3 The inspector detennined from review of the above that the radwaste system is properly classified as nonsafety-relate Conclusion:
Based on the inspector's review of system classification requirements and the radwaste system design, this allegation could not be substantiated.
l Allegation 5:
CEI connitted itself to the 1979 Regulatory Guides. Under these guides, they may not have to build Class 3 section or specification, but they are supposed to have a particular QC/QA program. Workers allege they do not have such programs in these area .
NRC Review:
l The inspettor reviewed the licensee's conmitments and the quality program for the radioactive waste system as stated in Allegations 2 and 3 above and determine:' that the quality program appropriately met the licensee's approved connitrrents in FSAR Tables 1.8 and 3. Conclusion:
i Based on the inspector's review of the quality program and Perry FSAR connitments, this allegation was not substantiate Allegation 6:
In these areas welds have been installed below standard and there is a bad valve problem, workers alleg NRC Review:
A similar allegation was previously reviewed by the NRC concerning j inadequate welds related to the radwaste system. That allegation was not i substantiated (see Inspection Report No. 50-440/86010).
The inspector, however, reviewed weld inspection and surveillance reports, results of turnover walkdown inspections, test engineer walkdowns, and
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preoperational test results. Also, review of hydrostatic tests performed L at 150% of design pressure did not reveal any valve or weld joint failures
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weld Portions of the system were operating during the visual inspection; therefore, leaking welds or problem valves would have been readily identifiable. In Allegation 3 above, the inspector determined that welders and inspectors were qualified to the appropriate code or standard to assure quality workmanship. Preoperational testing verified system operability and did identify some problems with some valves. The valve problems were documented, appropriate corrective action was taken, and the problems were properly resolved in accordance with CEI's QA program. Also, see Allegaticns 16 and 17 below for specifics related to valve problem Conclusion:
The final installed welds and valves treet the requirements of the applicable codes including (ANSI B31.1) Regulatory Guide 1.143, other applicable standards, and licensee procedures. This is based nn the inspector's review of the documentation noted above, visual inspection, and results and review of the above noted similar allegation. Based on the foregoing, this allegation could not be substantiate Allegation 7:
Every weld that was bad on every valve that was not up to par was thus classified by CEI as a non safety item. Under this classification of non safety item, it really meant no Q NRC Review:
The inspector's review of Table 3.2.1 in the Perry FSAR revealed that all of the radioactive waste system was classified as nonsafety-relate This includes all welds and valves. Review of QA records for this system revealed that the licensee's QA group had performed 1,336 surveillances on the radioactive waste system and issued 617 deficiency reports. The inspector reviewed selected surveillance and deficiency reports and found them to be acceptable. The deficiency reports had been properly dispositioned and adequately closed. QC visual inspections had been perfomed on the welds required by ANSI B31.1 and Regulatory Guide 1.143, with all welds being final accepted. The inspector reviewed records of the hydrostatic tests perforred on this system and found no evidence of weld or valve failure or any significant leakage resulting from the pressure applied during the hydrostatic test. The inspector also performed visual inspection of the welds it this system and identified no defective welds nor did the inspector find any leakage on the portions of the system that was operating during this inspectio Conclusion:
Based on the inspector's review of weld and valve requirements, quality documentation, and visual inspection of welds and valves in the radioactive waste system this allegation was not substantiate Allegation 8:
There were many problems with the hydrostatic test NRC Review:
Western Reserve- Alliance (WRA) did not identify specific problems with the hydrostatic tests. The inspector reviewed the test procedures, results of the hydrostatic tests and determined that the tests met the requirements of the governing Code, ANSI B31.1, for the radwaste systems. These tests were also witnessed by QA personnel and the State Inspector. Any problems identified during the hydrostatic testing were corrected and retests were subsequently conducted with all systems passing the final tes The hydrostatic test for all safety-related systems were witnessed by QA/QC personnel and the ANI. Additionally, the NRC received selected test results and found them to be acceptabl Conclusion:
Based upon the hydrostatic test results meeting the requirements of the applicable Code, this allegation was not substantiate Allegation 9:
CEI did not even have state inspectors in regard to these test NRC Review:
The inspector reviewed randomly selected radioactive waste system hydrostatic test reports. Each report had been signed by a Certified Ohio State Inspector attesting to having witnessed the test. For ASME Code system fabrications, installation, and testing, the third party inspection is performed by the licensee's or contractor's Authorized Nuclear Inspector (ANI). Therefore, all required tests are witnessed by an appropriate third party, the State of Ohio or the ANI. The ANI is in fact the agent of the State for ASME Code activities. The radwaste system (nonsafety-related) is a non ASME system and therefore was properly inspected by the authorized State representativ Conclusion:
Each of the hydrostatic tests reviewed by the inspector had been witnessed by a State Inspector; therefore, this allegation was not substantiate A1_1_egation 10:
There are problems with the G-50 system. This is the liquid rod (SIC)
waste system. Workers allege that the way the system is currently set up radioactivity will be put into Lake Eri (Howmuch? Unanalyzed by CEI . . .)
m NRC Review:
Western Reserve Alliance (WRA) did not identify specific problems with the hydrostatic tests. The inspector reviewed the test procedures, results of the hydrostatic tests and detennined that the tests met the requirements of the governing Code, ANSI _B31.1, for the radwaste systems. These tests were also witnessed by QA personnel and the State Inspector. - Any problems identified during the hydrostatic testing were corrected and retests were subsequently conducted with all systems passing the final tes The hydrostatic test for all safety-related systems were witnessed by QA/QC personnel and the ANI. Additionally, the NRC received selected test results an'i fcund them to be acceptabl Conclusion:
Based upon the hydrostatic test results meeting the requirerents of the applicable Code, this allegation was not substantiate Allegation 9:
CEI did not even have state inspectors in regard to these test NRC Review:
The inspector reviewed randoraly selected radioactive waste system hydrostatic test reports., Each report had been signed by a Certified Ohio State Inspector attesting to having witnessed the test. For ASME Code system fabrications, installation, and testing, the third party inspection is performed by the licensee's or contractor's Authorized NuclearInspector(ANI). Therefore, all required tests are witnessed by an appropriate third party, the State of Ohio or the ANI. The ANI is in fact the agent of the State for ASME Code activities. The radwaste system (nonsafety-related) is a ncn ASME system and therefore was properly inspected by the authorized State representativ Conclusion:
Each of the hydrostatic tests reviewed by the inspector had been witnessed by a State Inspector; therefore, this allegation was not substantiate Allegation 10:
There are problems with the G-50 system. This is the liquid rod (SIC)
waste system. Workers allege that the way the system is currently set up radioactivity will be put into Lake Erie. (Howmuch? Unanalyzed by CEI . . .)
NRC Review:
The liquid radwaste system is designed to collect and clean potentially radioactively contaminated water collected from various plant systems.
Af ter cleaning, most of the water is recycled for plant use; by design, some water containing radioisotopes is expected to be released into Lake Erie. The radioactive releases to Lake Erie are limited by the licensee's technical specifications which prescribe the permitted radioisotope concentration and quantities in water released to the lake, and the permitted modes of releas The inspector reviewed liquid radioactive waste system drawings D-302-732 and D-302-734. These drawings depict the G-50 system piping in the radioactive waste complex. The as-built drawings show no unmonitored or unanalyzed liquid effluents from the radioactive waste complex. The initial design had one pipe connected to the sanitary sewer. The inspector verified that this pipe has been severed and blank flanges installed so that no effluent paths exist to the sewer. An additional pipe was installed for flushing the system prior to preoperational testing, but was removed when flushing was completed. This temporary piping was used to discharge flush water into Lake Erie and to clean the system. This water was not, however, radioactive. The piping removal was verified by the NRC inspecto Conclusion:
Based on the inspect or's review of applicable drawings and inspection of-the radioactive waste complex, this allegation was not substantiate Allegation 11:
By law it should be noted in the FSAR any tirre there is a lessening of CEI's conmitment to NRC rules. CEI has made several changes to its commitments to the NRC rules, but they have not reported them in the FSA NRC Review:
The inspector's reviews concerning the licensee's alleged changing of their conmitnents to the NRC and the reporting of the changes are discussed in Allegation 1 abov C_onclusion:
Based on the review of Allegation 1, this allegation also was not substantiate Allegation 12 CEI said they would have a system of alarms that would go off in the rod (SIC) waste room control and the main control room at the same tine. Although CEI made the commitment to the NRC, CEI decided not to have the dual system of alarms installed as promised. CEI never reported this change in their plans to the NRC. This is a lessor commitment than was originally told to the NRC.
NRC Review:
The inspector's review of the Perry FSAR revealed that the change in alarm locations was reported in FSAR amendment No. 20. This change to the FSAR was reviewed and accepted by the NRC. This was effected after it was determined that operators would be on duty in the radioactive waste control room 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> each day so that annunciation in the plant control room was not needed. Human factor studies recommended removal of annunciation from the main control board to prevent reactor operator distraction by alarms that were redundant to monitored alarms in other locations in the plant.
Conclusion:
Based upon the inspector's finding that the change in alarm point location was reported to and reviewed by the NRC, this allegation was not substantiated.
Allegation 13:
CEI mentioned in the FSAR its plans to deal with beta and gamma radiation. Subsequently, CEI changed it plans to include only gamma radiation. CEI never reported this subsequent change in the FSAR.
NRC Review:
The Perry Radiation Protection Program was previously reviewed by the NRC (See Inspection Reports No. 50-440/85027 and No. 50-440/85068). These inspections included radiation protection and radwaste program reviews and inspection of preoperational testing of radwaste systems. No specific matter concerning improper changes to the FSAR, or improper changes to the Perry Nuclear Power Plant's (PNPP) radiation protection prcgram, as they relate to beta and ganna monitoring were identified during the review performed in response to this concern. The PNPP's radiation protection program has been evaluated by the NRC and found to be in compliance with regulatory requirement It was roted during this review that acceptable administrative changes were made to Chapter 11 of the FSAR to more correctly describe certain monitors as gamma monitors and beta monitors rather than beta-ganma monitors. The NRC's routine inspection program will continue to monitor Perry's radiation protection and radwaste program <
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- Conclusion
Based on the above, this allegation was not substantiate Allegation 14:
- In the containment building, regarding steel penetration and pipes, the
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welds are cracke NRC Review:
CEI's QA program requires inspection of penetrations and piping in accordance with 10 CFR 50 Appendix B and the ASME Code. These activities were properly cortpleted as required. This specific potential problem
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was previously identified to and reviewed by the NRC as a 10 CFR 50.55(e)
Construction Deficiency Report No. 50-440/85022-EE (see Inspection Report No.50-440/85072). Leak tests and ultrasonic examination by two separate
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ASME certificate holders did not find the suspect welds to be cracked.
!- The NRC reviewed the licensee's corrective action and found it to adequately resolve this issu Conclusion:
This issue had been previously evaluated and closed by the NRC, therefore this allegation was not substantiated.
l l Allegation 15:
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Boots around the penetrations were redesigned to expand a little more; l
some of the penetrations go in and out at an angle. The pressure is
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going through the penetration and this is the only seal. There are plastic seals around the penetrations. If the plastic boot around the
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penetration fails, the system could belch and radiation could go ou This.is true because even though there is negative pressure, the system cculd still belch. Also, it is possible that in some cases there may
- not be negative pressur If this were to occur, radiation would just
- leak out. Most nuclear plants use metal boots, but CEI uses plastic t because it is faster, workers allege. These are in the containment vesse NRC Review
The drywell boot seal problems and the resolution of those problems were l previously inspected by the NRC (see Inspection Report No. 50-440/86002).
The seals were redesigned and retested during the drywell structural l integrity test (see Inspection Report No. 50-440/85061). No seal failures-were observed at the required 30 psig test pressure. Plant technical specifications require the seals-to be tested periodically. The boot seals were evaluated by NRR and determined to be adequate to assure drywell integrity.
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Should the alleger's postulated event occur, no radiation would be released to the environment since the drywell and the boot seals are located inside the containment.
Conclusion:
The redesigned boot seals have been tested at 1.25 percent of drywell design pressure, inspected ar.d evaluated by the NRC, and are located inside containment so that should leakage of the seals occur, this would not result in release of radioactive materials to the environmen Based on these facts this allegation was not substantiated.
Allegation 16:
Workers allege dresser valves are a fiasco (rod (SIC) waste system). This can be seen by looking at DAR 2.12. These are vent valves and drain valves to drain radiation. (Some of these valves are already 10 years old.)
korkers allege that the design of the valve is not any good. The rework program of CEI reworked 100 of these valves. They put the redesigned valves through a test. It is called an inservice leak rate test. Many of the redesigned valves failed the test. These are small bore valve NRC Review:
Deficiencies in Dresser Corporation diaphragm seal globe valves were reported to NRC pursuant to 10 CFR 50.55(e). This construction deficiency (Item 50-440/84047-EE) was inspected and closed in a previous NRC Inspectio (See Inspection Report No. 50-440/85089). The deficiency resulted from inadequate clearances between the valves disc cap and disc guide and in some of the smaller sized valves undersized disc springs. The NRC verified that all the valves were properly reworked and adequately tested. In addition, the valves operated successfully during the performance of final (p>reoperational testin The inspector also reviewed the licensee's rocedure PTI-GEN-P0009, " Dresser Valve Operability Testing." This ocedure requires periodic testing of these diaphragm seal globe valves d ring plant operation C .nclusion:
Ba,k sed on the licensee's reporting of the valve deficiency, the NRC's in pection of the licensee's valve rework program, and results of a su cessful preoperational testing program, this allegation was not su istantiate All egation 17:
Workers allege that the Borg-Warner valves (rod (SIC) waste system) are causing a lot of trouble. This can be seen on DAR 2.13. (Some of these va' ves are already 10 years old.) The x-rays of the valves do not match up wiyh the valves (compared with what is currently installed). Later they fopnd they would not open or close properly. These valves would not work
except when they were in a vertical position. They were designed to work in the horizontal position but they would not work in that position. Some of these valves are 20 inches in diamete NRC Review:
The mismatched radiograph issue was previously reviewed by the NRC (see Inspection Report No. 50-440/84006, 10 CFR 50.55(e), Item 50-440/83018-EE).
During radiographic film interpretation, a mismatch between site radiographs and vendor radiographs was identified. All Borg-Warner valve manufacturers radiographs and site radiographs were compared subsequent to the discovery
'of the radiograph mismatch. The results of this review revealed that the radiographs for two valves were inadvertently mismarked and interchanged at Borg Warner. The mismatch of film for these valves was corrected. One other valve was found to not match the radiograph, this valve had been machined following radiograph Additionally, the gate valve binding issue was also previously reviewed by the NRC (see Inspection Report No. 50-440/85080, 10 CFR 50.55(e),
Item 50-440/84048-EE). During testing, binding and/or disengagement of valve gates was observed. Each of the valves was reworked and the valve operationally tested. It was also noted that some of the valves installed in a near horizontal position were not functioning properly due to gate guide rail positioning. These valves were properly reworked and subsequently successfully teste Conclusion:
Based on previous NRC inspections of these deficiencies and satisfactory completion of their associated corrective actions, this allegation was not substantiate Allegation 18 CEI has on occasion used nonconformance reports to make design changes,
, as opposed to the appropriate design change request foms. An ASME experienced engineer should be able to find many examples of such situation i '
NRC Review The inspector reviewed Gilbert Interface Manual 4-0500 Appendix P and CEI procedure QAP-1500 " Nonconforming Material Parts and Components".
This manual and procedure pe M t the use of nonconformance reports that are dispositioned "use-as-is" cod repair" resulting in changes to the original design. EacP '# h nonconfomance reports is evaluated by the architect /enginev > A1.) , assure that the condition falls within the design requirements. wnen v% nonconfonnance report is evaluated and approved by the AE it becomes a design change according to the process described above. Based on the review of the approved Manual and procedure and review of selected nonconformance reports, the inspector determined that these changes are in accordance with the Perry Quality Assurance Progyom. This practice is acceptable to the NRC. The NRC did not find any examples of inappropriate use of NCRs in the ASME Code are r
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Conclusion Based on the inspector's review of Perry procedures and selected NCRs and the conclusion that the NCR system was properly implemented, this allegation was not substantiated.
Allegation 19 Men in certain unions that have been tied tc corruption and organized crime activity have tried to prolong their jobs by sabotaging many items at the Perry Plant.
NRC Review:
The inspector reviewed 19 incident reports on file at the plant security section that dealt with damaged parts or components. These reports were of incidents of broken gauge glass on panels, fire alarm boxes, or of broken locks or hasps. None of the reports contained material that would indicate that the damages had been effected with the intent of prolonging jobs. Additionally, the NRC or CEI did not find any evidence of sabotage at the Perry plant.
Conclusion:
Based on the inspector's review of incident reports that provided no evidence that items had been damaged to prolong jobs and no evidence of sabotage, this allegation was not substantiated.
Allegation 20:
During the ILRT (S!C) test, CEI was trying to get up to 30 lbs. psi yet they could not even make 12 or l CEI did not know where the leaks were.
NRC Review:
The NRC believes the alleger was referring to the SIT not the ILRT. The test that requires 30 PSIG is the Structural Integrity Test (SIT), not the Integrated Leak Rate Test (ILRT). The ILRT test pressure is 11.3 PSI During the initial SIT, the drywell boot seals leaked. The boot seals were replaced with a new seal design (see Allegation 15 above) and the SIT was successfully performed at 30 PSIG. This test was observed and accepted by the NRC (see Inspection Report No. 50-440/85061).
Conclusion:
Based on the NRC's witnessing the successful completion of the SIT test, this allegation was not substantiate Allegation 21:
Workers allege that while working at Perry Nuclear Power Plant they have seen smoking of marijuana and drinking of intoxicant NRC Review:
This allegation is not within the scope of the NRC's regulations. However, the inspector reviewed the licensee's drug control program. The program includes drug and alcohol abuse issues in the employee's handbook given to each employee, aberrant behavior recognition training for_ supervisors and personnel screening programs for both licensee and contractor personne In addition, the licensee performs periodic surveys with drug detection dogs onsite and in the parking areas outside the plant security are During construction, some drug / alcohol related problems were identifie The licensee was responsive to these problem Conclusion Although this allegation is not within the NRC's purview, this allegation was somewhat substantiated. The licensee's program has identified some drug and alcohol related problems. The licensee has been responsive to these problems. Based on the inspector's review of the site drug and alcohol control program and its results, this program appears to be an adequate substance abuse progra If WRA has specific infonnation relative to drug use at Perry, this information should be provided to the licensee and local law enforcement agencies as appropriat Allegation 22:
Workers allege they have seen welders taking tests illegally at the power site, with no supervisio NRC Review:
Welder qualification testing has been previously inspected by the NRC during numerous routine inspections, during a Construction Assessment Team (CAT) inspection, and in response to previous allegations (see Inspection Report No. 50-440/85023). No evidence of illegal welder testing was identified in any of these inspection efforts. Additionally, the licensee and its contractors performed QA audits and surveillances of the welders qualification activities. All welds also received some type of nondestructive testing to verify weld quality. The NRC has also inspected numerous welds and found the overall quality to be acceptabl Conclusion:
Based on previous NRC inspection, the licensees QA program implementation results in this area, and the lack of substantiation of previous allegations, this allegation was also not substantiate Allegation 23:
I Workers allege they have seen contractors overloading jobs, while workers just sat around fcr days doing nothing.
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NRC Review:
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This allegation is not within the scope of NRC regulations and has no safety significanc .
-Allegation 24:
Workers allege they have been approached by members of Local 744 and
" asked if I wanted some cocaine."
NRC Review:
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-Same as Allegation 21 abov Allegation 25:
Workers allege they turned the above information over to the FBI and have heard nothing sinc NRC Review:
This allegation should be addressed to the Federal Bureau of Investigatio Allegation 26:
Workers allege they saw men who " stayed loaded on cocaine the whole job."
NRC Review:
Same as Allegation 21 abov Allegation 27:
Workers allege that foremen knew about men being stoned on cocaine because the men "did not hide it." Yet there is no evidence that the foremen did anythin NRC Review:
Same as A11egaticn 21 abov Allegation 28:
Workers allege that uncertified welders would use the names of certified welders on welding jobs when the certified welders were not even on site. The foremen at the plant site were the ones who approved and encouraged such activit m
NRC Review:
The inspector reviewed weld inspection procedures, weld records, and weld filler material control procedures. Inspection procedures require verification of welder certifications. Welds are stamped with the welder's identification number and weld records identify the individual performing the weld. The weld material control procedure requires the welder to present the employee identification badge bearing his picture, his welder identification stamp number, and weld rod issue slip before he can withdraw the rod from the weld material issue station. At the end of each day he must turn in weld rod stubs equal to the number of weld rods he was issued during that day. The procedures controlling welding and welding materials would preclude an uncertified welder from welding for a welder who was not on site. The entire welding process is within the QA program including inspections, surveillances and audits. All safet-(NDE)y-related required by welds also receive the appropriate the code welding required nondestructive and nonsafety examinations welds are
. inspected as required by governing procedures and Codes. A similar allegation (Region III 85-A-0065) was previously reviewed by the NRC (see Inspection Report No. 50-440/85023). That inspection revealed that one welder had used another welder's welding electrodes. Administrative actior, was taken against both welders. Both welders were, however, detennined to be adequately qualified for the process in which they actually welde Thus, the welding process was not compromised and has no impact on qualit Conclusion:
Based on the inspector's review of procedures controlling welding, inspection weld material issue, weld records, rod issue slips, and other various QA program activities and records, this allegation was not-substantiate Allegation 29:
40,000 tons of reinforcement rod was wrongly ordered and then sent to the scrap yard by truc NRC Review:
This is not a safety issue and is not within the scope of NRC regulation Allegation 30:
Insulation - 500 penetrations were installed wrong. Sleeves should have been put on before insulation. Now the insulation will break up from the pipes moving back and fort NRC Review:
The inspector reviewed Engineering Change Notice (ECN) 29310-98-59 and Field Question Forms relative to penetration sleeve omission. The Engineering Change Notice and the field question responses from the architect / engineer
authorized each change to each penetration. The sleeves were omitted from those penetrations in which the pipe movement was restricted. The inspector determined that the penetration sleeves / insulation were not installed incorrectly and that each change was properly documented and reviewed and approved by the proper engineering organization. Visual inspection of the pipe penetration assemblies by the NRC revealed no insulation damage (See-Inspection Report No. 50-440/86005).
Conclusion:
Based on the inspectors. review of proper documentation supporting the design changes to the penetrations and a visual inspection that revealed no damage, this allegation was not substantiate Allegation 31:
Portions of the containment vessel are now susceptible because the sprinkler system came on for undisclosed, accidental, or unknown reasons.
i-NRC Review:
The inadvertent initiation of one ring of the containment spray system during preoperational testing was previously reviewed by the NRC (see Inspection Reports No. 50-440/85010; No. 50-440/85017; No. 50-440/85053 and No.50-440/85056). The inspector reviewed quality inspection documentation issued by the licensee's quality organization. These documents related to inspections which had been performed to assess damage to equipment following the spray actuation. No damage to equipment was observed during
'the inspections. The inspector ascertained from equipment qualification reports that the equipment and components inside containment are environtrentally qualified to LOCA conditions and therefore spraying the containment with distilled water would have no deleterious effect on the equipmen Conclusio Based on previous NRC inspections, the inspector's review of quality documentation and environmental qualification reports, this allegation was not substantiate Allegation 32:
Power outage in the plant caused evacuation and cause of the outage is uncertai NRC Review:
Isolated power outages during construction as a result of construction activities are not uncorrmon. There was no evidence that any specific outage affected the quality of safety-related work or testing activitie A discussion with the alleger on March 14, 1985, did not provide any information that impacted quality or safet Conclusion This allegation was substantiated based on fragmented infonnation, but had no impact on _ Quality activities, thus no safety significanc EAllegation 33:
~The quality of the paint job at the plant site is not uniform. In some areas of the: plant the paint is already starting to come off. One can see this on the equipment hatch at the top of the unit. Other paint should have been taken off but was no NRC Review:
Allegations (Region III 85-A-0152 and Region III 85-A-0171) regarding coatings at Perry, including the equipment hatch, were previously reviewed by the NRC (see Inspection Reports No. 50-440/85064 and No. 50-440/85084).
No violations of NRC regulations were identified during these inspection In general, although some problems were identified during the coatings application and some subsequent defects were also identified, these problems were all appropriately identified and proper corrective actions were take Conclusion:
Based on-previous NRC inspections results of related or similar allegations,
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this allegation was not substantiate Allegation 34:
'CEI' negotiations with unions were in part responsible for bad feelings between unions. Situations arose when carpenters were supposed to give
- orders to laborers. This resulted in no one bringing cut boards to the appropriate local. Thus, CEI had to permit the union to go back to their old way of doing things. This -type of management caused waste, confusion, bad feelings and lack of concentration on meeting health and safety standard NRC Review:
This allegation concerns a labor relations issue not an NRC regulatory issue.
Allegation 35:
Local 744 of the Boilermakers hired unqualified men under the direction of Louis Jewels, President of the local, to work at the Perry plan They were paid journeyman wages but should have been paid apprentice wages. Numerous workers have stated that this occurred because of corruption in Local 744 and the International. Numerous workers have stated that vast sections of the plant do not meet NRC standards because
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of this activit i
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NRC Review:
The wages of workers and corruption in labor unions are not within the NRC's regulatory responsibility. CEI's Quality Assurance Program like the Quality Assurance Program at all nuclear plants, is a multi-tiered defense-in-depth approach to ensure quality. The various levels of assurance begin with established procedural controls together with quality craftsmanship, coupled with quality inspection and quality audits to achieve the desired level of quality. This multi-tiered program involves several independent assurances in that each contractor applies his own individual QA system with the licensee applying QA oversigh In addition, inspections and audits are also performed by the contractor's ANIS and the NRC. For example, at Perry, the inspector has determined by review of welder qualification procedures that qualifications for welders that are received from offsite sources are not accepted for work onsit All welders are qualified to site procedures by each contractor onsit Each contracter's welder qualification is approved and continually monitored by the contractor's and the licensee's Quality Assurance Department. The actual welding activities are performed by qualified welders in accordance with approved procedures. Additionally, all safety-related work is inspected by qualified inspectors, including NDE examiners and the ANI. These activities are also audited by the untractor, the licensee, the ANI, and inspected by the NRC. The overall quality systems ensure that CEI's commitments and work activities to NRC and industry standards are thereby complied with. The NRC is confident that CEI's commitments for the Perry Plant were complied with and that an adequate level of quality was achieve Conclusion:
Based on lack of specific information, including a discussion with the alleger on March 19, 1985, and historical inspection activities the portion of the allegation regarding the plant meeting appropriate standards was not substantiate Allegation 36:
A lot of voids existed in the bioshield wall. These were fixed, but not properl NRC Review:
Voids in the Perry bioshield wall were reported to the NRC pursuant to 10 CFR 50.55(e) in two separate reports (Items 50-440/81010-EE and 50-440/81018-EE). The voids were repaired using architect / engineer approved methods for concrete repair and were previously inspected and closed by the NRC (see Inspection Report No. 50-440/84002). This inspection concluded that the licensee took proper corrective action and adequately repaired the voids. This action, including the patching method and application, was found to be acceptable to the NR Conclusion:
Based on the results of previous NRC inspections, this allegation was not substantiated in that the repairs were in fact proper and correc Allegation 37:
Stealing is very widespread at the Perry plant. Even CEI personnel are involve NRC Review:
This issue is not within NRC regulation A11egation 38:
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The standard procedure regarding the way welding is done and inspected at Perry is not in compliance with current NRC codes.
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NRC Review:
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The licensee in the FSAR comitted to comply to the welding requirements of various nationally recognized Codes and standards. The inspector's review of welding procedures and weld inspection procedures revealed that welding and inspection is performed in accordance with applicable codes and standards. Safety-related pipe is welded in accordance with Section III of the ASME Boiler and Pressure Vessel Code, non safety-related pipe welding is governed by ANSI B31.1, Power Piping, and structural welding performed according to the American Welding Society Structural Welding Code, AWS D The inspector verified that the weld procedures reflect the licensee's commitments in the Final Safety Analysis Report (FSAR). The various contractor's Quality Assurance Program requires inspections and QA audits of these welding activities. Additionally, CEI performed QA audits and QA surveillances of these activities. The Authorized Nuclear Inspector also reviewed the various procedures to determine their compliance with the Code and perfortned inspections of the welding activities. These welding and inspection procedures and controls have also been historically reviewed for content and implementation by the NR Conclusion:
Based on review of the licensee's comitments in the FSAR and welding and inspection procedures, the inspector concluded the welding controls and inspection activities met those Codes and procedures. Therefore, this allegation was not substantiate Allegation _39:
There were irregularities in the welding tests that were give at Perr Indications are that some men took the test for other men who were unqualified. Some men took a welding test that took a day, while others were permitted to take as long as a wee <
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NRC Review:
The inspector's review of welder qualification procedures revealed that the person attempting to qualify must present positive identification in the form of a picture badge prior to beginning a qualification test and his/her test sample is marked with their identification number. Each step of this activity is verified by a Welding Quality Control Inspector and periodically by the Authorized Nuclear Inspector and the licensee's construction quality inspectors. As for some persons taking more time than others, neither AWS D1.1 or ASME Section IX Subsection QW 320 place a limit on time to take a test or the number of retests required to obtain qualification. Also see Allegation 22 above for a similar allegation and additional information.
Conclusion:
Based on the inspectors review of welder qualification procedures and pertinent codes and in concert with Allegation 22, this allegation was also not substantiated.
Allegation 40:
The polar crane in Unit I rides on a support beam above the reactor. The beam that the wheels of the polar crane ride on is defective. This beam came into the plant in sections. The welds that were made in the plant are good welds. The welds on the beam that were made outside the plant or fabricated by vendors are bad. Thus the rail that the polar crane rides on is defectiv NRC Review:
The polar crane welding deficiencies were previously inspected by the NRC (see Inspection Reports No. 50-440/82006 and No. 50-440/83009). These reports document the fact that some of the welds were defective, the problems were properly identified, adequately inspected, subsequently repaired, and properly reinspected. The polar crane welding issue was further inspected by the NRC in response to allegation AMS-RIII 85-A-0125 (see Inspection Report No. 50-440/85078). That allegation was not substantiate Conclusion:
Based on previous NRC inspections relative to this issue, this allegation was rot substantiate Allegation 41:
QC inspectors were harassed and intimidated in an attempt to get them not to report QC violation __ . .
NRC Review:
Allegations of QC inspector harassment and intimidation were previously reviewed by the NRC (see Inspection Reports No. 50-440/83037; No. 50-440/84007 andNo.50-440/85085). These inspections did not substantiate any harassment or intimidation of QC inspectors as alleged by any of the sources of the NRC's infonnation. Also see Allegation 42 belo Conclusion:
Based on the NRC's previous inspections in this area, and lack of findings related to harassment or intimidation, this allegation was not substantiate Allegation 42:
This harassment and intimidation of QC inspectors took place and affected the quality of in nction at the diesel generators of Unit 1. Unit 2, and the 620 control con 41e NRC Review:
This allegation was also previously reviewed by the NRC (see Inspection l- Reports No. 50-440/83037, No. 50-440/84007, No. 50-440/85032, No. 50-440/85045 and No. 50-440/85071). These inspections revealed no evidence of harassment or intimidation. Allegations regarding inspections in the 620'
I level of the Control Complex and Diesel Generators Buildings were included in a motion to reopen Perry hearings filed with the Atomic Safety and l Licensing Board (ASLB) by Ohio citizens for Responsible Energy on l November 30, 1983. The motion was dismissed by the ASLB by LPB-84-3,
! 19 NRC 282 (1984) on January 30, 1984. Also see Allegation 41 abov .
_ Conclusion:
Based on previous NRC inspections in this area and the ASLB decision of i- January 20, 1984, this allegation was not substantiate Allegation 43:
The main control room suffered from a serious lack in terms of number of QC inspectors for the job. Due to the shortage of QC inspectors, the verification work that should have been done (regarding all electrical work, power modulators, and instrumentation) was not done in the main control roc NRC Review:
Allegations regarding inadequate QC inspection in the control room were previously inspected by the NRC resulting in one item of noncompliance (see Inspection Report No. 50-440/84007). Adequate corrective action was taken and this violation was subsequently reinspected and closed out (see Inspection Report No. 50-440/85032). Additional inspections of the control
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room electrical work and inspection activities were also performed by the NRC with no adverse findings (see Inspection Reports No. 50-440/85032, No. 50-440/85038, No. 50-440/85062 and No. 50-440/85067). The inspector also verified that the licensee had perfonned three complete reviews and inspections of the control room electrical wiring using the construction quality group and a walkdown inspection of safety devices by the operations qLality group. The control systems were also successfully tested during the preoperational testing program.
Conclusion:
Based on previous NRC inspections including a prior review of this allegation, the inspectors' review of licensee quality assurance activities, including numerous reinspections, and a successful preoperational program, this allegation was not substantiated.
Allegation 44:
Due to overwork, the two QC inspectors were not allowed to see the computer room at elevation 638. The program was just not set up to deal with this.
NRC Review:
The NRC inspector's review of installation specifications drawings and FSAR Table 3.2.1 revealed that the plant computer was non safety-relate Procedures for the computer systems inspection required these inspections to be performed by the licensee's quality control inspectors. The licensee restricted access to the computer room to only those persons having a need to enter the room to protect this high cost equipment from construction damage. The inspector determined that the two contractors QC inspectors had no need for access to see the computer room since they had no duties in the roo Conclusion:
Based on the computer room's not containing safety-related components and contrartor QC inspectors having no duties in the computer room, this allegation was not substantiate A_1_ legation 45:
There are problems with emergency service water regarding peckerheads terminations. The vendor side is different from the Gilbert drawing The rotation for the motor is opposite to industry drawings. The rotation for the motor is 99-100% different frcm Gilbert drawing Workers say they feel it is 100% because they have never seen one that was correct. The concern of the workers is that this situation could cause them to run backeards and "you would have a hot reactor."
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NRC Review:-
The inspector reviewed results of emergency service water pump initial checkout and run-in testing and the system preoperaticnal test. Each of these tests revealed that the motors were rotating properly. Additionally there is no requirement that the " Vendor side" terminations have to be like Gilbert drawings. The " Vendor side" is required to be in accordance with-the procurement specifications and vendor drawings. Any field changes to either side are identified and the respective drawings appropriately
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revised. The NRC found no problems in either the testing or in the drawing area Conclusion:
Based on review of pump motor initial and preoperational testing that proves correct pump rotation, this allegation was not substantiate Allegation 46:
In the containment vessel there are numerous and serious cracks in the first 60 feet of stainless steel clad. There are cracks in the other parts.of the stainless steel clad, but the first 60 feet of the lower portion is extremely bad. This would be in the area of the No. I ring and No. 2 ring. There are "a lot of cracks in the double bar around the first ring, the bottom of it."
NRC Review:
Sensitization of stainless steel cladding in the suppression pool was reported to the NRC on October 6, 1980, as a 10 CFR 50.55(e) item (440/80008-EE). This item was inspected by the NRC and it was determined that the corrective action was appropriate,-adequate and complete (see Inspection Report No. 50-440/85035). Microfissuring (cracks) in the stainless steel cladding heat affected zone in the containment vessel near some plate welds was also reported on November 12, 1981, to the NRC as a 10 CFR 50.55(e) Item (440/82010-EE). This item was also inspected by the NRC and it was determined that the corrective action was a adequate and complete (see Inspection Report No. 50-440/83032)ppropriate,
. The cladding fissuring and containment issue and the licensee's corrective action and commitments for future inspections of the containment welding and cladding has been reviewed and accepted by NR It is also worthy to note that only 20 feet of the containment is clad with stainless steel not more than "60 feet" as indicated by the allege Conclusion:
Fissuring in the cladding in the containnent was reported to the NRC and the licensee's analysis and corrective actions were reviewed and accepte The allegation was substantiated as to the existence of the cracks but does not identify an unreviewed or unresolved safety questio l
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Allegation 47:
The welds in the fuel pool are bad. Do tests here. Look at the weld They are ba NRC Review:
The inspector reviewed liquid penetrant examination results, visual inspection results, weld records, vacuum box tests of the upper pool, results and the results of tests of the leak chases around weld Additionally _ pressure tests were performed on the lower pool, test results revealed no leakage. At the time of the inspection, the fuel pool was filled with water and there was no indication of weld leakage at the leak chase Conclusion:
Based on the inspector's review of nondestructive examination results of the welds and no visible indications of water in the leak chases, this allegation was not substantiate Allegation 48:
The question was raised: "Why did they fix the bad crane gridder in Unit 2 but not in Unit I?" It is alleged that the Unit 1 crane gridder is ba NRC Review:
The Unit 1 polar crane is addressed in Allegation 40 abov Conclusion:
Based on the inspector's review of documentation during the investigation of Allegation 40 the above allegation was not substantiate . Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection and sunmarized the scope
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and finding of the inspection. The licensee acknowledged the inspectors corrrents . The inspector also discussed the informational content of the inspection report with regard to docunients or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar