ML19329B123
| ML19329B123 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/30/1976 |
| From: | Roe L TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19329B122 | List: |
| References | |
| 110, NUDOCS 8001300702 | |
| Download: ML19329B123 (5) | |
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[m 30, 1976
-czn int tno V ] August t===%:s EDESGPJ Serial No. 110 LOWELL E. ROE Docket No. 50-346 v,..w.
.at Fecdities Development 141m 250 6242 Mr. James G. Kcppler Regional Director, Region III Directorate of Regulatory Operations U. S. Nuclear Regulatory Commission 799 Roosevcit Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Toledo Edison acknouledges receipt of your July 23, 1976 letter and enclosed inspection report referencing the apparent noncomplianeci with MRC regulations.
These items resulted.from the site inspection conducted by your office on June 8-11, 1976.
Toledo Edison offers the following information regarding these apparent non-compliances, including corrective action and steps taken to avoid further occurrences.
/m\\ Items of Noncompliance A.
Infractions 1.
" Contrary to 10 CFR 50, Appendix B, Criterion V, reuorked cicetrical items were not inspected by the Engineering Inspection Team as speci-ficd in Procedurcs EIP-008-5, Revision.2, dated November 20, 1975 and EIP-008vl Revision 3, dated November 7, 1975."
As stated in the report details, these items are all in the Engineering Inspection Team (EIT) category of Electrical Equipment Exposure to Adverse Environment.
Inspection of adverse environment (systems interaction) conditions was included in the duties of the Engineering Inspection Team as a convenience since this type inspection would have been required by this type of inspection group at about the stage of construction existing at that tino.
For this reason, it was anticipated that any inspection item in this category could be closed properly without an Engineering Inspection Team reinspection for closcout if the inspection item resulted in generation of a Nonconformance Report (NCR) which has a formal self-
-closing mechanism including reinspection if rework is required.
For this reason, Procedure ElP-008-5 was originally written to permit closure of an inspection item in this category uhcre an NCR uns generated.
In our continuing review of the precedures controlling the EIT work, it van decided to maintain uniform procedures for-all categories of inspec-
- [mT tion effort and Procedure EIP-003-5 was revised and Revision 2 issued k_ /
on November 7, 1975 to require reinspection for closure of an adverse 8 ~0 013 0 7d THE TOLEDO EDISON COMPANY tCISON PLAZA 300 MADISON AVENUE TOLEDO OHIO 43G52 SEP 0 1976
Hr. James G. Keppler
,Page 2 Auguqt'30, 1976 j'~ -
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environment item even 'whore an NCR had been generated.
The EIT failed to do this for the items cited.
The EIT has been instructed to follow the procedures explicitly, all previously closed items in this category have been reviewed and rein-spected as necessary for proper procedural closure or reopened to require reinspection prior to closure.
In addition, Procedure EIP-008-5 has been revised by Revision 4 to explicitly stato that where an NCR is generated, a reinspection by the EIT is required prior to closure.
To ensure continued compliance with these requirements, TECo QA will continue to conduct surveillance.
Full compliance for the above activities will be achieved prior to September 1, 1976.
2.
" Contrary to 10 CFR Part 50, Appendix 3, Criterion XVI, the licerisce failed to identify and/or take corrective action for a condition adverse to quality relative to essential channel 1 and 2 cables locat'ed in Cabinet C5716 uhich were found to be in contact with nonessential cables located in the same cabinet."
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Nonessential cables terminating in "Q" cabinets are so identified on s
their termination cards and established procedures require an inspec-tion by Johnson Controls Quality Assurance.
The termination cards for the subject cables had been filed in error in the wrong location and were not routed to the appropriate group for inspection and, as a result, the cable location error in the cabinet was not discovered.
This item was documented on Johnson Controls Nonconformance Report (NCR) #,294, dated 8-6-76.
Rework has been performed in accordance with NCR #294, which was accepted on 8-18-76.
To prevent recurrence, all termination cards have been re-reviewed and the above deficiency was the only one identified.
Furthermore, all personnel have been reinstructed in the proper handling of termination cards.
Full compliance was achieved by August 23, 1976.
3.
" Contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion VII, and Bechtel Specification No. 7749-M-255, Brand Industrial Cervices scalant materials had been installed although it had not been established thatethe material met specification requirements.
Furthermore, this matter had not been identified by the licensee as nonconforming."
/-y A thorough examination was made of documentation concerning scalant material testing requirements requircl by Specification 7749-M-255 V)
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Revision 1.
Since all prototype test results on siliconc foam bloch-out closure material have not been submitted for approval, installation
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Mr. James G..Keppler s '
P, age 3 August 30, 1976 7'~N.,
\\__sI of this matcrial has been postponed in Q-listed'~rcas by a letter a
issued by Bechtel to Brand Industrial Services Co. (Bisco). dated July 2, 1976. The examination also included a thorough review of each item noted in.the report and the results are as follows:
Flame resistance test documentation as specified in Specification No. 7749-M-255 Revision 1 is only required for boot material.
As of this date, boot material has not been received at site.
Certified test results on flame resistance will be available at such time Bisco receives this material.
Chemistry and physical properties and test results have been deleted from the specification.
Italogen content test data is only required for material contacting stainless steel. As of this date, there are no stainless steel 9
installations involving this test data installed in any location at this site., Test data is scheduled to be provided by Bisco prior to September 15, 1976, llose stream testing is now complete,'and the test reports have been officially transmitted to Bechtel for review and approval.
To prevent recurrence, TECo QA has directed Disco to perform a
/' l thorough review of all applicable prototype testing and their test
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results specified in Specification M-255.
In the future, specifi-cation requirements uith regard to documentation will be closely reviewed to assure compliance.
Full compliance for the above ac.tivities will be achieved prior to September 15, 1976.
B.
Deficiency' 1.
" Contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion XVII, neither qualification nor indoctrination and training records were available at the site for Brand Industrial Services (Disco) QA/QC and, production personnel."
All Brand Industrial Services (Bisco) QA/QC and production personnel records, including experience, training, and qualificatitn records, are now located at the site in the Bisco files and are available for inspection.
This item was a finding on TECo's audit of Bisco performed 3/25/76, on Audit #409.
Their personnel records were delivered to site on June 30, 1976.
The Bisco Site Manager will maintain and file records of all naw QA/QC and appropriate production personnel employces at the Bisco site office.
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'Mr. James G. Keppler.
,- : P.aga,4 JAugust 30, 1976
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As arcas are identified where additional training is necessary, Lisco will conduct, document, and impicment training sessions.
Full compliance for the above activity has been achieved.
2.
" Contrary to the requirements of 10 CFR Part 50, Appendix B, Criterion V and Brand Industrial Serviccc, Inc., Quality Control Procedure No. 006, an approved range of acceptabic scalant material densities used for acceptance criteria was not available at the site."
The range of acceptable scalant densitics did not indicate the maxi-mum limit.
Since any density above the established minimum limit provides a better product regarding its function, no maximum limit was specified.
However, a maximum limit has now been established and will be incorporated in the specification.
The addition of the upper limit establishes a range.
A cell structure reference (control
. sample) showing the measured density will be availabic at the site.
Documentation to show its measured density and a certificate of conformance will be issued for the control sample.
In the future, any new material will be monitored for a proper range of acceptable scalant densities.
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, Full compliance for the above activitics will be achieved prior to September 7, 1976.
3.
" Contrary to the requirements of 10 CFR'Part 50, Appendix B, Criteria V, and the Toledo Edison Company QA Manual Section 5.7.3, The Brand Industrial Services, Inc., Sealan,t Material Mixing Procedure No. 207M, was not available at.the site, and had not been approved for use at the site."
Thc Bisco scalant mixing procedure referenced by Installation Procedurc No. 207 had not been transmitted for approval by Bechtel or TECo in order to protect the proprietary nature of this procedure.
Arrange-ments were negotiated with Bisco at uhich time the procedure was made available to Bechtel and TECo for review and approval.
This procedure is maintained at the Bicco site office for review by appropriate per-sonnel, with the cover pages only being retained by Bechtel and TECo to indicate review and approval status.
To prevent recurrence, Bisco will transmit any procedure of proprietary nature to Bechtel and TECo for review and approval as indicated above.
Full compliance for the above activitics will be achieved prior to
' September-1, 1976.
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Mr. James C. ICeppler s
Pays 3 August 30, 1976 4
Deviation
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" Contrary to the FSAR Section 11, Paragraph 11.4.2.1, the installation of the reactor vessel particulate monitor will not provide a representative sampic."
Most right angle bcnds in'the sampic inlet lines between the sample points and the particulate monitors have been replaced with long radius (5 DIA.) bends and all U-bends are long-raolus (5 DIA.).
This arrangement will prevent plate out and is in accord with ANSI N13.1-1969.
The pipe and valving arrangements have been revised such that the pair of sampic lines that enter cach penetration room will run only to the particulate monitor in that room, thus minimi::ing sample run lengths.
Isokinetic sampling is not required for these samples since the samples are being drmm from the containment, net the ventilation system.
FSAR Section 11, Paragraph 11.4.2.1, Revision 20, has been revised to clarify that only the ventilation system samples are isokinetic samples.
Full compliance for the above activity has been achieved.
Yours very truly,
[
Lowell E. Roe, Vice President Facilitics Development LER:ss 6
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