ML19320D118

Responds to NRC 800521 Ltr Re Violations Noted in IE Insp Repts 50-440/80-06 & 50-441/80-06.Training Program Complies W/Nrc Requirements.Drawing D-220-002 to Be Revised to Show Seismically Adequate Lighting Supports

ML19320D118
Person / Time
Site:	Perry
Issue date:	06/23/1980
From:	Davidson D CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19320D116	List: ML19320D118
References
NUDOCS 8007180591
Download: ML19320D118 (4)

Text

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. t ! n r h E! E C1 PIC li t.U MIN ATIN G CO M P A N Y ILLUMINATING BLOG.

• PUBLIC SoVARE e CLEVELAND OHIO 44101 e TELEPHONE (216) 6231350 m Mall ADDRESS: P.O. BOX 5000

. ou D;lwyn R. Davicison VICE PRE $1DE NT SYSTEM ENGINEE AING AND CONSTRUCTION June 23, 1980 Mr. Gaston Fiore111 Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to I. E. Report

Dear Mr. Fiore111:

This letter is to acknowledge receipt of your Inspection Report Number 50-440/

80-06, 50-441/80-06, attached to your letter dated May 21, 1980, which I re-ceived on May 23, 1980. This report identifies areas examined by Messrs.

J. Hughes and R. B. Landsman during the inspection conducted April 21 through 24, 1980.

Attached to this letter is our response to the two (2) items of apparent non-compliance described in Appendix A, Notice of Violation. This response is in accordance with the provisions of Section 2.201 of the NRC's "N '.es of Practice",

Part 2, Title 10, Code of Federal Regulations.

Please call if there are any questions.

Very truly yours, v's , C Sv'?/ //t D. R. Davidson Vice President System Engineering and Construction ksz Attachment JtJ N 2 71980 00071go $9

D RESPONSE TO ENFORCEMENT ITEMS

' Listed below are our responses to Appendix A, Notice of Violation, of the United States Nuclear Regulatory Commission I. E. Report 50-440/80-06; 50-441/80-06.

I. A. Infraction 10CFR50, Appendix B, Criterion II, requires, in part, that "The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that saitable proficiency is achieved and maintained."

CEI's Corporate Nuclear QA Program Manual, Section 0200 - 1.6 states:

" Procedures shall be established to ensure that personnel performing quality related activities are suitably trained and qualified to per-form their work."

SectJan 2.0 of ANSI N45.2 and Section 2.5.1 of National Engineering and Contracting Company (NECC) Quality Assurance Manual both repeat the above statement.

Section 6.4 of NECC Quality Assurance Procedure Manual (QPM) states, in part, " Construction personnel performing safety-related work shall be indoctrinated and trained by supervisors familiar with site require-ments."

Contrary to the above, NECC is not indoctrinating and training certain construction personnel as required by their quality assurance program.

Furthermore, NECC QPM states that this training need not be documented, which is contrary to the requirements of Criterion XVII.

B. Response Note: Please make the following corrtetions in the first sentence of Section II of this report:

1. " Pour No. 1130-501-721": should read " Pour No.

IBO-S01-721" (Date 4/22/80)

2. " Control Complex Building" should read " Intermediate Building" 1 and 2. After the NRC Inspector questioned the placement crew, the NRC Inspector was advised by the NECC's QC inspector that prior to start of this placement, the three craftsmen signed a document, The NECC QC in-spector showed the NRC Inspector this document, which:

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. RESPONSE TO ENFORCEMENT ITEMS

1. E. REPORT 50-440/80-06; 50-441/80-06

, PAGE 2

1. Is entitled " PROPER TECHNIQUES : 0R VIBRATING CONCRETE USING AN INTERNAL VIBRATOR";

2. Lists seven (7) criteria regarding proper use of internal vibrators;

3. Is included in NECC Procedure QP 10.1, Rev.13, Attachment 8.11; and

4. Is reviewed with the labo..r; an a weekly basis as well as to applicable new employees (k?: Procedure QP 10.1, Rev. 13, Attachment 8.3. Item 2.7).

The craftsman who was questioned has been esployed by NECC at PNPP for more than two years, and has been vibrating concrete for approximately the same period of time. In addition, there are on file, commencing February, 1979, the aforementioned documents regarding proper use of internal vibrators signed by the craftsman who was questioned.

This exceeds the requirements of ANSI N45.2 and Section 2.5.1 of NECC QA Manual.

NECC Procedure QP 2.1, Revision 3, Item 6.4 states: " Construction personnel performing safety-related work shall be indoctrinated and trained by supervisors familiar with site requirements. This training may be formal or informal and need not be documented." NECC conducts both formal and informal training sessions. There is documented evidence available for review regarding formal training sessions with NECC craftsmen. Informal training sessions, i.e., not documented, may also be given, This provision is included to provide for immediate correction by the foreman or QC inspector, of improper methocs while an activity is in process.

, 3. With this explanation of the implementation of indoctrination and training provisions in NECC's procedures, and because no deficiencies in concrete vibration techniques were noted during the NRC inspector's observation of this work,-we submit that suitable proficiency is achieved and maintained in this ts'hnique by the administration of the training described and that we t e in full compliance with NRC re-quirements.

e e-' ' y

RESPONSE TO ENFORCEMElfr ITEMS I. E. REPORT 50-440/80-06; 50-441/80-06 PAGE 3 f

II. A. Infraction 10CFR50, Appendix B, Criterion II, states, in part, that "The applicant shall identify the structures, systems, and components to be covered by the Quality Assurance Program."

Perry Nuclear Power Plant PSAR, Section 1.2.3, commits to compliance to Regulatory Guide 1.29, Seismic Design Classification, which re quires seismic Category 1 classification for equipment needed to main-tain the control room within safe habitability limits for personnel.

Contrary to the above, lighting fixture supports installed in tha control room were not designated as seismic Category 1, therefore, not designed to meet these requirements.

B. Response

1. An investigation has been made to determine the seismic adequacy of the control room lighting fixture supports. Seismic loads have been conservatively calculated for tFe clamping mechanisms using peaks of the Control Complex elevacion 654' floor response cu rves. Tests have been performed by B-Line Systems, Inc. on the three (3) beam clamps being used. As a minimum, normal installation practice would result in the clamps being tightened to " finger tight" plus 1/2 turn, using the corresponding test values result in a minimum factor of safety of 1.6. Drawing D-220-002, Revision F, will be revised to indicate that the attachment methods for safety-related building attachments are seismically adequate.

2. The inspection and monitoring of L. K. Comstock work activities provides assurance that good installation practice is employed by this contractor. Engineering Change Notices are being issued to L. K. Comstock (SP-33 and 34) to revise the drawing as indicated above.

3. Full compliance will be achieved by July 15, 1980, t