ML20038B671
| ML20038B671 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/20/1981 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20038B668 | List: |
| References | |
| NUDOCS 8112090007 | |
| Download: ML20038B671 (3) | |
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T H E C L E V E L A N D E L i. C T R I C
' t i. U.M I N A T I N G C O M P A N Y P.o. BOX 5000 e CLEVELAND. OHIO 44101 e TELEPHONE (216) 620-9800 e ILLUMINATING BLDG e
55 PUBLIC SoVARE
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Dalwyn R. Davidson WCE PRESIDENT November 20, 1981 SYSTEM ENGINEERING ANO CONSTRUCTION Mr. C. E. Nore11us, Director Division of Engineering and Technical Inspection 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. Norelius:
This letter is to acknowledge receipt of Inspection Report Number 50-440/81-14; 50-441/81-14, attached to your letter dated October 23, 1981.
This report identifies areas examined by Messrs. R. Gardner and R. Mendez during their inspection conducted September 29 to October 2, 1981.
Attached to this letter is our response to the one (1) Severity Level VI Violation described in Appendix A, Notice of Violation, dated October 23, 1981.
This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Our response has been subnitted to you within thirty days of the date of the Notice of Violation as you required, and the information submitted is true and correct to the best of my knowledge, information and belief.
If there are additional questions, please do not hesitate to call.
Very truly yours, 1
A D. R. Davidson Vice President Systems Engineering and Corntruction DRD:pab Attachment cc: USNRC - Site Mr. R. L. Spessard, Director Division of Resident and Project Inspection U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C.
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6 RESPONSE TO ENFORCEMENT ITEM Below is our response to Appendix A,. Notice of Violation, of United Statea Nuclear Regulatory Commission I.E. Report 50-440/81-14; 50-441/81-14 I.
Noncompliance 440/81-14.01 s
A.
Severity Level VI Violation 10 CFR 50 Appendix B, ' Criterion V, states. in part,' " Activities affecting quality shall be prescribed by documented... procedures...
and shall be accomplished in.accordance with these... procedures..."
CEI Corporate Nuclear Quality Assurance Program, Section 0500, Revision 2, paragraph 1.1 states in part, "The Cleveland Electric Illuminating Company requires that activities affecting quality...
shall be prescribed in and accomplished by documented... procedures..."
Contrary to the above, the following instances of failure to follow procedures were identified:
a.
Paragraph 3.2.24 of L. K. Comstock cable pulling procedure 4.3.3 states in part, "When cable pulling is completed, the cable shall be coiled and supported to keep. cable off the floor to prevent cable damage...The coil shall be tied so that the cable does not support the coll and the cable shall be protected so'that the tie does not damage the cabic jacket."
Contrary to this requirement, the inspectors observed Class 1E cables coiled at Power Generation Control Complex (PGCC) termination cabinets 1H13-P743 and 1H13-P746 which were not protected so that sharp edges on the cable 'coli support ties would not damage the cable jackets. As a result, the cable jacket on coiled cable IP45V-19A was damaged by the single cable tie which supported this cable. Furthermore, the jackets on several other coiled cables were observed to be impinging on 4
the sharp edges of their respective cable support ties.
i b.
Paragraph 3.2.17 of L. K. Comstock procedure 4.3.3 states in part, " Class 1E medium voltage armored power cable...shall be installed in their exclusive cable tray with a nominal spacing of 3/8" between adjacent cables."
I Contrary to this requirement, the inspectors observed that medium voltage armored power cables installed in Class 1E cable trays A106, B256, and B268 were spaced such that direct contact was maintained between adjacent cables.
B.
Response
1.
Item a.
I L. K. Comstock initiated Audit Finding Number 925 to document this instance of inadequate implementation of procedural requirements.
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1 In response to this finding, L. K. Comstock installed 2' x 4' wooden planks perpendicular to Unit 1 Control Room PGCC termi-nation cabinets to provide better protection and support cable
-coils.
This support method will also be'used for the Unit 2 Control Room when those cable pulling activities begin. Upon receipt of notification from L. K. Comstock.that this problem
.had been corrected, Construction Quality.Section Inspection personnel conducted a surveillance to confirm completion of corrective action. The Construction Quality Section will continue to monitor this activity to assure procedural compliance.
Full compliance was achieved November 4, 1981.
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Item b.
1 L. K. Comstock initiated Audit Finding Number 935 to document that the nominal 3/8" spacing requirement for. Class 1E medium voltage armored power cable had not 'been met.
In response to this finding the cable was respaced to ' meet the procedural requirements.
During L. J:. Comstock Quality Control verification of corrective action, four other instances of violation of the nomina 1' spacing requirement were identified and subsequently corrected. The-Construction Quality Section will continue to monitor this
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activity to assura procedural compliance.
Full. compliance was achieved on November 19, 1981.
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