ML20070B268
| ML20070B268 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/02/1982 |
| From: | Wilt D CLEVELAND ELECTRIC ILLUMINATING CO., SUNFLOWER ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8212090495 | |
| Download: ML20070B268 (50) | |
Text
M COSSMPONDENCh 000KETED USNRC g gg g h959 UNITED STATES OF AMERICA . _ u c,7 3 7 .
NUCLEAR REGULATORY COMMISSION T.Yi -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-440-OL 50-441-OL CLEVELAND ELECTRIC ILLUMINATING COMPANY, et al (Perry Nuclear Power Plant, Units I and II)
SUNFLOWER ALLIANCE INC. et al BRIEF IN OPPOSITION TO STAFF'S MOTION FOR
SUMMARY
DISPOSITION ON ISSUE THREE (QUALITY ASSURANCE) .
The NRC Staff has filed a Motion for' Summary Disposition on Issue Number Three. Issue Number Three is:
Appiicant has an inadequate quality assurance program that has caused or is continuing to cause unsafe construction..
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Sunflower Alliance Inc. et al opposes this Motion for the reasons that follow.
PART ONE 10 CFR 2.749 provides for Summary Disposition of issues. The standard for considering Motions for Summary Disposition is this: the documents filed show that there is no genuine issue as to any material fact and that the moving party is entitled to a decision as a matter of law. 10 CFR 2.749(d).
Quality Assurance is authorized by 10 CFR 50.34. 10 CFR Part 50,"
Appendix B goes into more detail concerning qaality assurance requirements.
The definition of quality assurance is as follows:
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l 8212090495 821202 h PDR ADOCK 05000440 U 0 PDR 1
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. 2-As used in this appendix, ' quality assurance compromises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service. Quality assurance includes quality control, which compromises those quality assurance actions related to the physical characteristics of a material, struct'ure, component, or system which provide a means to control the' quality of the material, structure, component, or system to pre-determined requirements.
Thus, quality assurance deals with the actions taken by Applicant to assure quality in the material, the structure, the components and/or the systems that go into the Perry plant. These actions must cover a wide variety of conditions from the plant itself (in terms of the plant as a whole as one system) to those individual component parts that make up the plant.
The quality assurance function is described in 10 CFR Part 50, Appendix B as follows:
The quality assurance functions are those of (a) assuring that an appropriato quality assurance program is established and effectively executed and (b) verifying, such aa by checking, auditing, and inspection, that activities affecting the safety related functions have been correctly performed...
Thus, the essential thrust of Issue Three is this: (1) Has Applicant established a QA plan that assures that the components of the plant as well as the plant as a whole will perform satisfactorily in service? (2) Has this plan been effectively instituted?
PART TWO It has been established that the basis of Issue Three deals with the Stop Work Order of February, 1978. Thus, the basis of the contention deals with the QA violations in February, 1978 and whether or not the QA violations
. identified in ' February, 1978 have been corrected. Therefore, we must first identify the A violations that were identified in February,1978. To do that s
we turn to the February, 1978 Stop Work Order.
The exhibits attached to this Brief are all official documents issued by the NRC. As such official documents, they are evidence under 10 CFR 2.743 (h).
As evidence, they can be used to suppcrt this Brief and oppose the Motion filed by the NRC Staff. Thus, unless otherwise identified, the exhibits which shall be used as evidence for purposes of this proceeding qualify as evidence.
Attached to this Brief as exhibit "A" is a copy of the February 8, 1978 Stop Work Order. This letter speaks.of concerns regarding the quality assurance program at Perry and refers to an inspection that took place January 24-26 and February 2-3, 1978. The repoct itself is attached as exhibit "B".
The pages referred to in the citatiens in this Brief are added to the exhibit on the bottom of the paga.
Pages B(4) - B(16) is the Notice of Violation issued by the NRC.
The violations, in terms of the quality assurance programs, are summarized as follows:
- 1) Measures were not established to assare vendor drawings and procedures were reviewed to ascertain inclusion of applicable regulatory and quality requirements. See page B(4).
- 2) Applicant failed to acccmplish activities in accordance with instructions or procedures, failed to require that instructions or procodures include quantitative cr qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished and failed to require that activities affecting quality were prescriSed by documented instructions or procedures. See page B(5) .
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- 3) Applicant did not assure that the purchased services of several site contracto'rs conformed to procurement documents in that the QA programs for these contractors were not in accordance with 10 CFR 50, Appendix B.
See pages B(8) and B(9) . .
- 4) Applicant did not assure that special processes, including welding...and non destructive testing are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria... See page B(10).
- 5) Applicant did not establish a program for inspection of activities affecting quality to verify conformance with the documented" instructions, procedures, and drawings for accomplishing the activity... Examinations...
shall be performed for each work operation where necessary to assure quality.
See page B(11).
- 6) Applicant did not establish measures to control the handling, storage, shipping, cleaning, and preservation in accordance with work and inspection instructions to prevent damage or deterioration. See page B(12).
- 7) Applicant did not establish measures to cor. trol materials, parts or components which do not conform to requirements. See page B(13).
- 8) Applicant did not establish measures to assure that conditions adverse to quality, such as... deficiencies, deviations, defective material and equipmant and nonconformances are promptly identified and corrected.
See page B(13) .
- 9) Applicant did not have audits performed in accordance with the written procedures or checklists by appropriately trained personnel not having direct responsibilities in the areas being audited. See page B(14).
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- 10) Applicant did not maintain sufficient records to furnish evidence of activitie s af fecting quality. See page B(15) .
These are the areas of concern set forth in the February, 1978 inspection. In order for the Staff's Motion to be granted by this Board it must be clear that the violations set forth above have been corrected and have not been repeated.
If, as Sunflower contends, these QA violations have occurred subsequent to the February,1978 Stop Work Order, then, the basis of the contention has been met.
Since the basis of the contention has been met, the Board can, under the terms of the contention, examine subsequent QA violations committed by Appi cant.
In this manner, this Board can determine, under the express " terms of the contention, if Applicant has -an inadequate quality assurance program that has caused or jus continuing to cause unsafe construction.
There are some unique twists to Applicant's QA program. Initially, we must observe that the current QA plan of Applicant is not contained in the PSAR. Rather, the QA program is a result of the February,1978 IAL. The current QA program then is subject to the Board's jurisdiction under the contention, as admitted, because it was born as a result of the February, 1978 IAL. Another interesting fact is that the current QA program may not, as yet, have been approved by NRR. The current QA program of Applicant, a creature of the Fecruary, 1978 IAL, was not submitted to NRR until at least as late as September 1, 1982. The undercigned does not know if NRR has approved it, yet.
Further, the Contractor Qaality Program Requirements for Safety Related Installations / Erection, which are the QA Specifications for contractors and the contractors QA programs will be reviewed to verify compliance with Applicant's QA program. Thus, it appeares that neither the Applicant's QA program nor the QA program of Applicant's contractors have been approved. Since both come from
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the after-birth of the February, 1978 IAL, this Board has jurisdiction of both and we may review more recent inspection reports to determine if Applicant has in fact learned its lessons. See attached Exhibit "C".
Many inspections have occurred since the February, 1978 1AL. Many of these reports have alraady been filed with this Board. Sunflower has filed two additional motions since the initial hearings to expand the QA contention.
These Motions have been denied. However, it now appears based on the information set forth in Exhibit "C", that it is not necessary to expand the contention since the February, 1978 IAL is the underlying basis of Applicant's current QA programs. The inspections that have taken place since the February,1978 IAL clearly demonstrate that the QA violations by Applicant have not ceased and in fact have continued. Thus, the Motion filed by Staff is clearly unwarranted and must be denied because the Staff, as a matter of law, is not entitled to judgment.
Exhibit "D", which is attached, is an excerpt from a July 13, 1982 SALP covering the period July 1, 1980 to September 30, 1982. Mr. Keppler, Region III Administrator, wrote in part as follows:
.:.However, it was and still is our opinion that the multitude of problems identified in the electrical area could be systemic warranting an assessment of l other contractor activities. We believe you also I recognized this potential when you outlined your corrective action program for the problems in the electrical area and included a reassessment of management controls ove other contractors. We believe the words' . . . management control systems were ast totally effective...' put our concerns in the right perspective. As we have discussed before, it is "-important to have comprehensive and effective controls over activities to insure quality construction.
Based upon our findings in the electrical areas, there was an obvious breakdown in the control of activities warranting both your and out attention... See page D(2) .
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- 7-What were the problems that prompted these remarks?
Exh'ibits D(3) through D(10) are attached which demonstrate the infractions in the QA program. Remember, this is the new QA program created as a result of and from the effects of the February,,1978 IAL. Exhibits D(3)
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through D(5) demonstrate repeat violations of the same violations identified in the February,1978 IAL. These include:
- 1) Failure to follow approved (procedures;
- 2) Failure to control storage of materials;
- 3) Failure to keep areas clean and free of debris; More serious violations are found commencing on page D(6). The violations on page D(6) taken together reflect deficiencies in the implementation of the quality assurance program in that problems are not identified in a timely manner. The same problems were identifiad in the February,1978 IAL. The current QA program of Applicant, which is an extension of the February, 1978 IAL, is violated time and time again.
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! QA violations are not isolated events at Perry. Exhibit E is an i
inspection report dated September 27, 1982 and eaxpresses concern about QA.
This report is relevant to the February,1978 IAL because the QA standards shown to be violated in Exhibit "E" were created'ar a result of the February, 1978 IAL. Region III of the NRC wrote:
We are concerned that even though your continuing assessment of the electrical contractor's per-formance showed degradation of the quality assurance program, you failed to investigate in a prompt manner the elements contributing to the poor performance and require adequate corrective action to upgrade the program.
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The Notice of Violation in Exhibit E covers the following failures:
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- 1) Applicant failed to provide design control measures for verifying or checking the adequacy of design;
- 2) Applicant failed to prescribe by documented instructions, pro-cedures,'and drawings of a type appropriate to the circumstances of activities affecting quality;
- 3) Applicant did not establish measures to control the issuance -
of documents, such as drawings, including changes thereto, which prescribe all activities affecting quality;
- 4) Applicant failed to establish measures for the* identification
! and control of materials, parts, assemblies.
- 5) Applicant failed to establish a program for inspection of activities affecting quality and executed by or for the organizations l
performing the activity to verify conformance with the documented instructions, procedures, and dre41ngs for accomplishing the activity;
- 6) Applicant failed to establish measures' to control the har ' ling, storage, shipping, clesning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration.
- 7) Applicant failed to establish measures to control parts or components which do not conform to requirements in order to prevent their inadvertent use of installation)
- 8) Applicant failed to establish measures to assure that conditions adverse to quality such as nonconformances are promptly identified and corrected.
This contention is grounded in the February,1978 IAL. The current QA program of Applicant, such as it is, is grounded in the February, 1978 IAL.
Sunflower has identified violations in the QA program in 1982 that were found and. identified'in 1978. The_evideace in this case as demonstrated in this Brief and in the attached exhibits clearly demonstrate serious problems with the Applicant's QA program. The problems have gone on now for four years and in many cases are the same problems. Thus, it has been shown that the Applicant's~QA program is inadequate and that it has caused and is coc-inuing to cause unsafe construction. Staff's Motion must be denied.
Respectfully submitted, 4/7M / I' '
Da fel D. Wilt', F,Q. ' "
A torney for Sunflower Alliance Inc.
P.O. Box 08159 Cleveland, Ohio 44108 (216) 249-8777 PROOF OF SERVICE The undersigned certifies that a copy of this Brief has been sent to all persons on the Service List on this day of December, 1982.
1/rnzl < / , er -
p6iilel D. Wilt,/EW ~
/ Attorney for Sunflower Alliance Inc.
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,a s s co UP!ITED STATES
. ,a.# % g. ,4 NUCLEAR REGULATORY CO!.'f.*lSSION .*
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FEB ~0 81978 1.
Docket No. 50-440 Docket No. 50-441 ,
If,y} The C1cveland Electric Illu=inating $
Co=pany
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Vice President-Engineering Post Office Sox 5000 Cleveland, OH 44101 f..j ppi{
Gentlemen:
This refers to the telephone conversaticas between It. D. Davidson I e
and other rechers of your staff and 12. Heishman and other ce: bars of *
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=ystaffonFebruary7and8,1978,relativetoourconcernsregardingh the implementation of your quality assurance progran at Perry nuclear Pever Plant, Units 1 and 2, identified during our inspection conducted January 24-26 and February 2-3, 1978.
Based on our telephone cenversations, ve understand that the Cleveland Electric Illuminating Company (CEI) has taken or vill - @
take the actions delineated below and that t'.c star'us and/or results of these actions will be reported,to our offd_e by telephone !
followin'g their co:pletion. Additionally, .:e ur/derstand that with j respect to items 1 through 5 below, ther. acti/ities vill not be
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", /. resumed until your corrective action has been/ reviewed and detemined i
l'd to be acceptable by the NRC. In this rega;d$ NRC inspectors vill '
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, be at 'the Perry site on February 9, M78,_'.t'o _revi.e.v. your actions. .
rescrding items 3 and 5 prior to the,placep,ent.of,sa.fety related concrete.
- 1. Field erection of saf ety related yard piping (SP-47-4549-001) '
by PPP has been stopped and vill not be resu=ed until:
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- a. Deficiencies in PPP's cuality assurance program and imple=,enting procedures in the areas of design docu ent control and piping erection and handling have been corrected.
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The site QA/QC organizations; have, been provided with
.25j; clear'and ~ specific instructions relative to which drawings and associated i_nst[ ructions (GAI vs PPP) are
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- .. 3 ' to be used as the basis for.detegpining that GAI's
' d esign criteria have .been ne, t.
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- c. A GAI qualified piping engineer has been sent to the 22-;.?] site to review and approve'PPP doyeloped procedures and
~; W.RL drawings for the erectioh of pip {pg. GAI approval of If -- ;-
' all procedures and drasyng's vill;be made prior to installaticr.
of yard piping. In add (pio,n, for ;the previously placed yard piping procedures Epd drawings.'.till be reviewed and approved by this engine [r'. Tnese,t;eatures s-ill re=ain in effect until CEI evaruates GAI's.idnsign review requirements defined in S?-47-454c-001 and PSAR, z_ .
][jj Section 17.1.3.3.b and the results of-their evaluation are reviewed by the NRC. -
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- Q[Ej! d. 100% GAI resident inspection has been instituted on all
.4ME safety related pipe being fabricated. These nessures
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1083... c will re=ain in effect until CEI can demonstrate to the Ar3 satisf action of the NRC that the existing sa:pling
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?? inspection procedure meets A :SI N45.2, Sectien 11, ar required by PSAR, Section 1.2.3.
- 2. Field erection of safety related plant piping (SP-t4-454c-051) by Pullcan Power Products (PPP) has been stopped and vill n:t
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- be resumed until: ~'
N- a,. Requirements f or GAI's review and appraval of P,P,P's
- ?yh3 drawings and associated instructions Sor the piping
;6{... governed by Specification No._SP ,44-45 9-001 haye,been
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- b. Items 1.a,1.b and 1.d. above .have been cc picted.
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- 3. Installation of saf ety related embedcents a:id. structural cteel, supplied by PBI Industries and its'sub'ontractors, hac bet:
c ef2 stopped. Neither activity vill be , resu=.ed until the .;.e ci' '_c caterial to be used has been evaluated:apd Eeterr.ined to set
,t the specified require =ents of A'JS D,.,1.1 ' 1572 prior to pisce=ent.
i/ 4 This vill be acco:plished through parforcance of one of tne
."j following inspections, as applicable:
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.. FEB 0 81978 .4. '.n - - . tp' # , The Cleveland Electric gj g Illuminating Co:pany
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A*eW idsf a. 100% CQC inspection of all =aterial in a proposed . e.2v:2,
. . . , concrete pour prior to concrete place =ent. .
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]?,1% b. 100% CQC inspection before any saterici is released rp ~
fro = a site organization storage f acility. _2$ud s
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{ f..f c. 100% CQC receiving inspection on all material.
.:[g Ite=s a, b and e above vill be perforced in accordance
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with approved procedures, as required by the CEI QA Program. Additionally, the program inaiequacies which allowed this =atter to occur vill be evaluated and corrected by CEI and discussed U? vith the NRC bef _re altering the ceasures established above. su.. ' [.[21.1 4. Safety related work, perforced by your coating contractor, gi)$,{ 0. B. Cannen & Son, Inc. has been stcpped and vill not be , "2E$ resumed until deficiencies in their quality assurance progra: i and implementing procedures in the areas of verificatics of h:2#) y++
=aterials prior to use, qualification of personnel and r"- perfor ance of audits have been corrected. .a
- 5. Placenent of safety related concrete by each of your contractors ~
2" has been ter=inated and no contractor vill resu=e this work f until: __ w. f.g a. Full ti=e CQC inspectors are assigned to enforce a ngi}., nr.v slump procedure. (When one truck is out of slu p, *
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$F(.3 that vill trigger a slurp test of every additional ; br5j ecifica. tion. k.d trucksubsequent The until the slump is brought. slump test vithin, f a11'ur'es.'.
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vill"re_sp's'ulIi67
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kh.ES concrete being vasted. Once 'aITIFu~ck t 'slunp is t'esfed 'd' : '..m.. s ..
- within specification the nor=al testing frequency vill
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b. Field instruction by CQC inspectors has been given to
- ; all concrete vibrator operators, their fore an and the l
r'] particular contractor QA and QC personnel involved.
. I) ' c. CQA vill audit the perfornance of iters a and b, above. -
f:3 \.. inese nessures will remain in effect until t*ge acticas .i; described below are taken by CEI and applicable concractors , .yd$.I./I and are reviewed by the NRC. - %;f.1 . y?t.f a. Establish pr:cedures to' pre:Inf e place .ent of nen:enferning pg*;;;
- concrete, as identified by ax uzsite slunp; and s .
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' b. ' Establish ' training / retraining requirements to ensure proper consolidation during place =ent by the correct use of
_.. vibrators. - b 6.. CEI vill establish an effective contract specification control syste= and vill evaluate the acceptability of the placerent h f .~- of concrete batched by the National Mobil Co:pany to a superseded design specification during the tice period from August 5, 1977 until the present date.
.' 7. CEI or an independent agent will perform audits of the onsite - .s.
organizations covered by the CEI quality assurance program _ (including the Construction Quality Assurance (CQA) and Construction Quality Control (CQC) Elements) to determine the adequacy of established indoctrination, t raining and l i'M retraining progrs=s, and the i=plenentation of these programs. ! ffj f, Additionally, specific e=phasis vill be placed en the identification _ and documentation of nonconformances to gainfully utilize your established nonconfor ance trend analysis system.
- 8. 'CEI or an independent agent vill evaluate the existing program, procedures and methods governing the activities described below to determine the cause of items 1 through 6 above and to deter =ine ['
.why these had not been identified by the respcnsible corporate / site-organizations. I }.% a' . Qualification and program audits of the contractors 4gi performing' safety related work; and -
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- b. Verification of compliance with all aspects of the CEI I' 8
' ', 7. quality assurance plan and the determination of its N' q effectiveness. * $ The results of this evaluation vill b~e factored into the CEI
- quality assurance plan and implementing manuals and procedures which are currently being revised.
With respect.to ite=s 6, 7 and 8, your action vill be completed by May 1, 1978.
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g*i ,. Plcese infom us i=:ediately if your u .dcrstanding of these ite=s
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.i 1.s.. d$.fferent from that stated above. .
m . lfG ', 5 . . Sincerely, n;<.-n .: s - e
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. July 13, 1978 N . Docket No. 50-440 - -
Il Docket No. 50-441
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M The Cleveland Electric ,
',, 11l'uminating Con:pany . ,. ATTN: Mr. R. M. Ginn-
- v. . President ,
.. ; P.O. Box 5000 ; Cleveland, OH 44101 3 2- . 3 / ) Gr't5 - lL.g.-Jcb;s~s ,f ,
Gentlemen: c7A "2 5 , . 30 ftcnccyrip, This refers to an inspection conducted by members of my staff during .i.M[g! 3,? [' - . January and February 1978 of construction activities at the Perry 1, .1 Eit e . As discussed with you and members of your staff during our
=,1 meeting on March 1,1978, we found major deficiencies in several
.j different construction activities underway by your contractors which, in our view, showed a major breakdown in the quality assurance program of Cleveland Electric Illuminating Company. Maior quality j,
".: assurance deficiencies were found in the areas of placement or_ ,I joncrete. storane os r-nrarials- fabricneinn ed e -*4nn nf piping _
. . . installation of embedmente and <:ernceural <: r a al . ann 14carinn n# -
conting materinis- nnd 4ndnrer h eien and trainh of personnal- %;;,. . Such a breakdown raises serious questions regarding the adeqtiacy of ih
..D construction at the Perry facility, v.g.. g.
b , As a result of this inspection, on February 8,1978, we issued an
;-; 1 Immediate Action Letter confirming the'stop work orders issued by 0 l~ your company in several safety related areas. Subsequent inspections .. l by our office and your May 1, 1978 letter have provided information ,. ij regarding actions underway to correct the noncompliance. .V 7- The " Criteria for Determining Enforcement Action" which was provided j to NRC licensees by letter dated December 31, 1974, delineated the - enforcement actions available to the NRC as including ad=inistrative ' -j]i ~
actions in the form of written notices of violation, civil monetary
's i penalties, and orders pertaining to the modification, suspension or- ,
..U , revo' cation of the license. The results of this inspection were J.h reviewed by our Regional and Ecadquarters staffs for escalated
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enfordement action. Recognizing that the Perry site is still in the ~ c'.f early stages of construction, and recognizing' Cleveland Electric "'?.*?j Illuminating Company top management's co=mitment to take positive lj;q corrective measures, we have concluded that a Notice of Violation is 6.t. '
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J _ ,- * (._ 3 [ [], O W The C1Eveland Electric NH:._ Illuminating Company July .13, .1978 ch. .
- the apprHpriate enforcement action at this time. Some of these corrective steps were described in your May 1,1978 letter, and these . and others have been observed in subsequent inspections at the site.
M ., We hope your awareness that we considered escalated enforcement action at this time will be an added incentive to assure that the g. p ,. corrective steps initiated will continue to be' carried out. In this regard, we plan to continue co=prehensive inspections of construction 93 hj' activities at the Perry site and, if we observe quality assurance
;'g- problems of the magnitude found during the January and February 1978 ~
wi inspection,.we will initiate escalated enforcement action. .
.l '
The items of noncompliance identified during this inspection are set
*'O .: . ; forth in Appendix A. This notice is sent to you pursuant to the T :' provisions of Section 2.201 of the NRC's " Rules of Practice," Part Xi 2, Title 10, Code of Federal Regulations. Section 2.201 requires "6 .
you to submit to this office, within thirty days of your receipt of Mii this notice, a written statement or explanation in reply, including
- d for each item of noncompliance: (1) corrective action taken and the fed ! results achieved; (2) corrective action to be taken to avoid further
{.]
,.; .- . 1' nonco=pliance; and (3) the date when full compliance will be achieved.
Because of our concern that the Cleveland Electric Illuminating Company
-quality assurance program, and that of the contractors, may not be adequate to identify safety related problems in the further construc-tion of the Perry units, we request that, in addition to responding .e
- to the specific items of nonco=pliance in Appendix A, please describe -
f~ changes to the management control system that you have implemented or planned to ensure that the Perry Units can be built safely and accor,d-gG ing to requirements. We recognize that you described some corrective K.Z5 actions in your May 1, 1978 letter. To the extent that information h applies, you need not repeat it in this letter provided you make clear @j$d . and specific references to the appropriate part of the previous K .' correspondence.
- gx l C. Additionally, we'are concerned regarding the adequacy of the embedments
,y placed in safety related concrete poured prior .to the stop work actions b.' associated with the It=sediate Action Letter of February 8,1978. 9.;1 Please provide us with an analysis of.the adequacy of these embedcents to perform their intended function, and tha action you have taken er plan to take as a result of this analysis. m; . ss In accordance with Section 2.790 of the NRC's " Rules of Practice," 4 Part 2, Title 10, Code of Federal' Regulations, a copy of. this letter, y p' the enclosures, and your response to this letter will be placed in
~. the NRC's Public Docu=ent Roo=, except as follows. If the enclosures
.' contain information that you or your contractors believe to be Ra proprietary, you must apply in writing to this office, within twenty 4.% days of your receipt of this letter, to withhold such information
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p e r; . l3 The Cleveland Electric i. N-C
' X11u=inating Co=pany - 3- July 13,1978
~.h1 Wj - - W+..> n yd from public disclosure. The application must include a full statement l 7:~ ' - of the reasons for which the infor=ation is considered proprietary, and should be prepared so that proprietary information identified in .['. t the application is contained in an enclosure to the application. [ ,, We will gladly discuss any questions you have concerning this li; .. . . inspection. a .- g;' Sineerely, - em rari: - - Mi t , w' s < $.}' James C. Keppler ~ Y.' ' Director .~~ .
~
L
Enclosures:
- 1. Appendix A, Notice of Violation
, .. I . 2. IE Inspection Reports $.y No. 50-440/78-02 and M No. 50-441/78-01 ?-h.e.: (. . .r ,
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..,- 3. ., . Appendix A .
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.. NOTICE OF VIOLATION J~ The Cleveland Electric Docke't No. 50-44Q
. ' .c.;:.i Illuminating Co=pany Docket No.~50-441-
..g ;4"s*~f .- . .
97.y This refers to the inspection conducted by representatives of the
.M.2 Region III (Chicago) office at the Perry Nuclear Power Plant (PNPP)
_ Perry, Ohio, of activities authorized by Construction Pereits No. CPPR-148 and No. CPPR-149. fc. . During this inspection conducted on January 24-26 and February 2-3, J- ; 1978, the following apparent items of noncompliance were identified.
.f, Items 1 through 10 are infractions and item 11 is a deficiency. .
.: . a -
F f ,
- 1. 10 CFR 50, Appendix B, Criterion III states, in part, that
.4 " Measures shall be established to assure that applicable regulatory
- N \ requirements and the design basis . . . are correctly translated into specifications, drawings, nrocedures, and_ instruc31ons.
~y ^ _
These measures shall include provisions to assure that appropriate
, ,.,;. quality standards are specified and included in design documents. . 4
-l .
g.;,' . Paragraph 17.1.3 of the Quality Assurance Program documented in the PNPP PSAR states, in part, that " Specifications shall requ, ire r . .' vendors to submit drawings, design data, fabrication procedures
'and test results as necessary. Selected vendor documents will be reviewed by GAI. Vendor drawings will be reviewed by CA1
, gyjj engineers for consistency with technical specification require- . ( .2'y.i ' ments and the GAI design intent."
. .nf. a. ..
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. Contrary to the above, measures were not established to assure q.10 vendor drawings and procedure.s were reviewed to ascertain inclusion cf. applicable regulatory and quality requirements.
W.\h For example: ,
' ?% *
~? a. Safety Class 1, 2, and 3 piping Specifications SP-44-4549-001 1-* , and SP-527-4549-001 did not include the requirement for the 3.I ,
piping vendor (Pullman) to submit drawings, design data, and
.q fabrication procedures to GAI, and therefore, these ,
. t.y.. '
documents were not being reviewed by GAI engineers. o
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M ; determining that important activities have been satisfactorily accomplished." .
"?" -
Paragraph 17.1".5 of the Quality Assurance Program documented in f<l.= the PNPP PSAR states, in part, "Each major participant in the g;d project will be required to provide documents which describe the di control of their quality related activities. All participants, d including vendors 'and contractors, shall b anuired m perform h, ,guality Inlated activities in conformance with a_p2 roved instructionc, lb .grocedures, and dAs applicable _ to their phase of the uark. Each instrue Hwnd pro'~ce~d'u~re will have a detailed descrintiom-W.7, y? . o h activity includine cuantit_ative and cualitative acceptance 43,. criteria and pr,ovisions for documenting the findings.or results -
. . . . CE1 shall have the responsibility for overall control of
%.t]- d the PNPP quality. Instructions and procedures shall be irepared by y CEI or agents to describe the means for achieving the required $ffi quality." My . Contrary to the above, CEI failed to accomplish activities in T.f - accordance with instructions or procedures, failed to require that 2 instructions or procedures include quantitative or.-qualitative p?l! acceptance criteria for determining that-important activities have-hyi, , been satisfactorily accomplished and failed to require that activities M4 . affecting quality were prescribed by documented' instructions or $} l'; . procedures. For example:
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M.s. a . h.E l Appendix A ,
'3-
- ~
M .. . Y a.' On at least twelve (12) occasions since October 1976, CEI "5 Construction Quality Control (CQC) did not document defici-I,j , encies in Nonconformance Reports (NRs) as required by the CQC
- a. Manual; interoffice, memorandums were used instead.
- 1h:
I The CQC Manual, Section 16, Paragraphs' 2.1 and 2.2 states, in
" . ,.]
part, " Items and activities that do not conform to specifications
~ ~C drawings and other project requirements shall be identified,
, documented and corrected. Deficiencies which affect the quality status of material and equipment are reported on Nonconformance Reports (NRs) . . . .". s
- b. .On approximately twenty (20) occasions since April 1977,
. , Great Lakes did not document storage deficiencies in Non-
.g..g .
confonnance Reports as required by procedure AQCP-8 and gjy] AQCP-9. . c .---t . . 17.:. A l **
.; p . Paragraph 5.1 of AQCP-8 states, in part, " Storage shall be in
$y$) accordance with ANSI N45.2.2," and AQCP-9, Paragraph 4.1, states,'
-@ in part, "A nonconformance report shall be initiated when struc -
'--- ! . tures, systems or . components do not comply to specifications.
. drawings, codes, standards and/or any delineated project 7 ,
' acceptance criteria." "
, Great 1.akes' failure .to follow the requirements of AQCP-8 was cited once previously as an item'of noncompliance in IE. inspec-tion Report No. 50-440/77-07; 50-4'41/77-07.
' . :..$,2 - ,
.$lh; c. Eight'een (18) containers of coating materials mainteined in a Ml
,j Cannon storage area, were not identified with the appropriate quality tags as required by the Cannon QA Program.
l,.f. The Catinon QA Program, S,ection I, Paragraph 7.1.,6 states, in L2 .. part, " Accepted materials are tagged " Accepted" knd stored fnr IE..-N+ use."
- d. The audit checklists, which were utilized by CEI during the pre-award surveys of Pullman and Cannon, contained specific .
instructions requiring that each block / checkpoint be addressed i, by the audit personnel and the results documented in the. 4 7- applicable block or~ beside the .pplicable checkpoint. At
.g. least 60% of the audit checkpoints / blocks were not completed /
lf . documented in accordance with the specific audit checklist
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si i .. . ins t' ructions. The Pullman au'dit was co ducted o EJune 22,
~
s 1976,.and the Cannon nudit was conducted on April 6, 1976. s .s The Pullman contract for Safety. Class 3 piping was awarded on
,1,@ . September 28, 1977, and the Cannon contract for appli, cation .WC.f '
of coating materials was awarded on August 11, 1976.' l$Ni$ ' '
'y, _
/ e. Fivei(S)' Dick ' Corporation QA inspection personnel, who have.
v.g - - been working at PNPP since , December,1976, did not receive
- 4. .v. y , training and indyctrination as required by procedure FQC-2.1.
*h.:b ,
Procedure F0r-2.1, Paragraphs 6.1.1 through 6.1.3 state, in part, "The training program shall in,:1ude: Indoctrination of personnel witli the technical objective of the project and the
. NRC requirements . . . . Instructions on the use of the 1:.y l procedures, codes, and standards that will be used. . . The
- 2?C Quality Assurance elements that are to be employed, with.
.gf guidance ,regarding the limitations and capabilities."
h,! s'.-! S.Testi$,(thetestlabicntractor)didnothavedocu-
.nted instructions or procedures to assure precision weight g]
O.1;
- e scales are<properlys calibrated and adjunt3d
~
'g. National Engibeering did not have documented instructions or procedurescofpreventthecontinuousplacementofconcrete
~ which has exciss(vc. slump. .
7
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@.,D7 'h. The safety;related.~ piping Manuf acturing Surveillance Plan No.
MG 033 b'eing used by\the GAI iSQector at Pulhan's f abricstion yf'y; ishop did not define , lot' size and did not u.ake~ documented UWO ' - - reference to a recognized standard' practice; thereby not
?ff9.5 . requiring sufficient quantitative ' or qualitative' criteria for
. determining that important activities have been satisfactorily.
.n::S , accomplished..
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4? '. 3. 10 CFR 50, Appendix'B, Criterion VI states, f.n part, that " Measures
~* shall be established to control the issuance of' documents, such as Y. ' instructions, procedures, and drawings, iricluding changes 'thereto, These measures,
'J -
whicK prescribe all activities affecting quality.
'M shall assure that documents, including changes, are. . . used at
.M .- th'e location when the prescribed activitylis perf crned."
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T. iE?C .. Paragraph 17.l.6 of the Qt.ality Assurance Program documente?(in
.v.4 9.~i *the PNPP PSAR states, in part, "The Field Construction Mandement
'.Tj - Organization Firm shall provide written procedures for the control of documents such as working drawings, specifications, proceduret,
$ and instructions to assure that only the latest revisions 'will be iG -
used for construction and erection. , Documents will be distributed
,-/d
. 4tl.1 .. .
in accordance with approved distributiop li,sts."
~421
.u s
~Q Contrary' to the above, CEI f ailed to ensure that National Mobile M'i . used design Specification SP-14-4549-00, Revision VII, for batching safety related concrete, whi.ch was the latest applicable revision.
~~
{ Specification SP-14-4549-00, Revi.sion VII was issued on February 15,
+. I 1977, approved on June 28, 1977, and received by National Mobile on
.. August 5, 1977, and since the date of receipt, more than 140,000
.'.7.L . cubic yards of concrete (batched to SP-34-4549-00, Revision VI) -
have been placed.
~M'E The use of out-of-date and/or unapproved p'r'ocedures by site con-d,j l tractors (Newport News and National Engineering) was cited once
' 2W4 i W!.D previously as an item of noncompliance in IE inspection No. 50-MOj 440/77-06; 50-441/77-06.
. . .p.
- -t-
..- 4. 10 CFR 50, Appendix B, Criterion VII states, in part, that " Measures 2 shall be established to assure that purchased . . . services, whether purchased directly or through contractors and subcon-
- i tractors, conform to the procurement documents."
Paragraph 17.1.7 of the Quality Assurance Progran documented in JM,1,l the PNPP PSAR states, in part, "The procurement of safety class 2 '!.
... services shall be performed in accordance with written
- l.'{$)y policies and procedures. Appropriate meaEures will be included to I ' f
- evaluate procurement sources, monitor the activities of vendors and l &g .
; contractors, and confirm that purchased material conforms with
#M - procurement documents . . . . The programs of all participants
"$.I} -
shall be in accordance with the CEI Quality Program Specifications, the CE1 PNPP QA Plan and 10 CFR 50, Appendix B." US:, i' ,, Contrary to the above, measures established by CEI did not assure that the purchased services of several site contractors conformed i l7: [ l t . .:.' .
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to procurement documents in that the QA programs for these contractors
~ were not in accordance with 10 CFR 50, Appendix B.
l/ For example: h "
- a. Great Lakes did not establish an indoctrination and training
[-y program as required by contract Specification SP-708-4549-00. ,
- b. PBI Industries did not establish requirements for fo' .owup '
d.e (7 action, including reaudit of deficient conditions, to assure r'" that corrective action has been taken. - - I
- c. Cannon did not establish receipt inspection requirements to I assure that manofacturer's test / product results, for coating materials, conform to procurement documents prior to release
%g of these materials for use. .
; n.
t,. . d. Pullman did not establish measures to control urawings, related.
~1! design documents and procedures which were being utilized for -;.f ,
the.in'stallation of safety related piping. For example: ;
~
an A i,, (1) Pullman personnel identified a Safety Class 3 piping h/ (f.' installation as being in accordance with Drawings No. SP-47-001 and No. PP-304-861; these drawings were uncon-
'- , trolled and unapproved. The Architect Engineer (GAI) j drawing on which the'se drawings were based, did not have -
[ff i l a drawing' number, and therefore evidence of proper approval j 4 -- and document control could not be demonstrated. R. ,. + I q . g P (2) Pullman personnel were using'an unapproved checklist to gJ perform receipt inspections of material in an attempt to d ' comply with procedure No. X-5. t , (3). Pullman personnel possessed and were using a revision of f ' Specification SP-47-4549-001, dated October 24,.1977. This document was not available in CEI's document control , Si center. Further, this document was incomplete in that . F < drawing control and approval require =ents had not been , af3 established.
- i~< (4) Ptillman personnel could not determine, from their records
~
and documents, whether or not they possessed the correct p - revisions to all of the drawings maintained by them. k w r . b.g *
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".',(5) Pullman personnel were installing Safety class 3 piping without having the applicable drawing (s) available in
.- the area where the work was in progress. Moreover, these
, .,. j . , personnel were not knowledgeable as to which drawings
..M were applicable.
?
; 7,'.]J
.b -
- 5. ' 10 CFR 50, Appendix B, Criterion IX states, in' part, " Measures 7 shall be established to assure that special processes, including welding . . . and nondestructive testing, are controlled and
{,'l' 1 accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards,-specifications,
~
h criteria. . . ."
'T Paragraph 17.1.9 of the Quality Assurance Program documented in the
":.. PNPP PSAR states, in part, "Special processes to be used during the.
19 manufacture and installation of equipment shall be established and .
- ,.Ml controlled in accordance with approved proceduies. Welding, . . .
$.'j j nondestructive examination and other processes which require ' v:g unusual care or close control shall be performed in accordance with
. . . . . appropriate written procedures. Procedures . . . will be established
-4 .
to meet the requirements of applicable ' codes and standards. . . or to meet the requirements of special process specifications which will be. produced for the Perry Nuclear Power Plant Project." Specification SP-667-4549-00, titled 'iFabrication and Delivery of
. Safety Related Embedded. Steel" in Paragraphs 2:04.2 and 2:10.2 specifies that the welding activities should be performed.and inspected respectively to requirements.of AWS Dl.1-72.
h [ ff4 : Contrary to the above, on February 3, 1978, fifteen safety related F,* ,. M embedments and structural steel columns were found with veldments jl,.',{;-, * , . which did not meet the requirements.of the applicable code (AWS l .t---:. Dl.1-72). For example, identification marks.were not -on parts .or joints showing that a ' welding inspector had ' inspected and accepted
- 7. the velds; Nelson ^ Stud Welds, which had been repaired by stick
$j ,
welding, were not tested with a hammer stroke and bent to an angle
$ ., , of 15 degrees for its original axis; welds were of poor quality as
; .. ' exhibited by inadequate si::e, excessive porosity and excessive gouging as defined by the code.
C: 6 .< l* . l-q: . v r. : .
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4 .
%. 6. 10. CFR.50, _ Apperidix B, Criterion X states, in part, that "A program Tj. foi inspection of activities af fecting quality shall be established
.y 'and' executed. . . to verify conformance with the documented instrt.c-
~
2 tions, procedures, and drawings for accomplishing.the acedvity.'. . S- Examinations . . . shall be performed for each work opera' tion where ; 3 - necessary to assure quality." -
.p- . . ,.3 Paragraph 17.1.10 of the Quality Assurance Program documented in 2:j the PNPP PSAR states, in part, "Each organization's inspection t program will adhere to the following general requirements: . . .
9 Documented and approved procedures will be used to control methods K and describe a::ceptance standards. . . Quality will be controlled
... by inspection or. process control or a combination of both as necessary.
T Paragraph 3.8.1.6.1.5 of the PNPP PSAR states, in part, that " Require-
$'i ments for placing and consolidating concrete are as detailed in ACI .
301." W j Contr'ry a to the above: ,- R;p' a. On January 24, 1978, the inspectors observed that the QC inspectic !
%.- being performed by CEI and Great Iakes personnel during concrete l Pour No. CCO-Sl/S6-599 did not verify conformance with documented {
h{ instructions and procedures (ACI 301-1972, Chapter 8.3.4; Con- -
- . , struction Quality Control' Inspection Plan No. C-01, Revisign 2, E ,;,
SP-20. Checklist Acceptance Criterion II.F; and Construction Qual: ( h' '- Control Guideline No. C-4 .Section IV, Revision 0) in that im-proper use of vibrators was not identified and corrected. ( b.}_ ls f -f
- W
- b. On January 25, 1978, the-inspectors observed that' the QC inspectii being performed by National Engineering personnel during
@:..- concrete Pour No. 1BO-Sl-599 did not verify conformance with ! M documented instructions and procedures. (ACI 301-1972, Chapters k
- 3.5 and 8.3.4; Construction Quality Control Inspection Plan No.
$ C-01, Revision 2, SP-20, Checklist Acceptance Criteria II.D and II.F; ard Construction Quality Centrol Guideline No. C-4, Section hQ IV, Revision 0) in that imoroner use of vibrators and the use of !q .- concrete with excessive slumo were_not identified and corrected.
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h ST
- 7. 10 CFR 50, ppendix B, C,riterion XIII states, in part, that " Measures
'shall be established to control the handling, storage, shipping,
$+ cleaning, and preservation of material and equipment in accordance wit {E
[D a-A work and inspection instructions to prevent damage or deterioration."
. ~d g:. Paragraph 17.1.13 of the Quality Assurance Program documented in the
.. PNPP PSAR states, in part, "A program'of procedures shall be imple-gn '
mented to prevent damage or deterioration of material or equipment /Cd during shipping, storage, and handling. Measures established will [.Q ~~ provide assurance of r,uality preservation, from fabrication through . installation, to preclude deterioration or damage which could adverselp
, affect quality." .-
[~' Paragraph 4.4.2 and 5.1 of Great Lakes procedure AQCP-8 states, in part, " Material identification tags shall be affixed to bundles, f,.. ;J . packs, boxes, cans, or individual parts or pieces in such a manner 3.4l as to assure positive identification of the material . . . Storage - Wh shall be in accordance with ANSI N45.2.2."
~
JM:L hM,li Contrary to the- above: h$. I
;,,]' a. On January 24, 1978, approximately 20 (safety related) nut and "- ~ bolt assemblies (concrete embedments) and 1/2 pound of weld q -
wire were examined. Both vere found to be inadequately stored.
, For example, the weld wire was laying on a wet floor,and the
,, l nut and bolt assemblies were submerged in water and were in a j,
rusty condition, contrary to Paragraph 2.7.4 of ANSI N45.2.2-1972. Additionally, the nut and bolt assemblies were not (- identified with a material identii k ation tag as required by $=h,il 8 . Great Lakes Procedure AQCP-8. QU 4J, .,. The improper storage of materials by site contractors (National
, Engineering, Pullman and Kaiser) was cited once previously as an h7T. -
item of noncompliance 'in IE Inspection Report No.- 50-440/77-07; ,.jC 50-441/77-07). , d.,e
'.U b. Great I.akes has not established instructions for inspecting N' ,
, safety related c.omponents in storage as required by Paragraph t
.. . ,. '6.4.2 of ANSI N45.2.2. . 'a [ , CEI's f ailure to establish an instruction for inspecting J. " materials (reinforcing steel) in storage was cited once previous 1p @ as an item of noncompliance in IE Inspection Report No. 50-440/76- $ n . 50-441/76-01. 9.:*(.' . W' c .
~. .c .
5
- l -
Pf o . U~ ~ ~ ~~~~ ** ne~ n _ _
4 fl1 mf - J'* , Appendix A . c."', Pullman has not established pipe and component lifting and handling procedures for site contruction activities in progress. 2.N-] ., 6. 10 CFR 50, Appendix B, Criterion XV, states, in part, that " Measures
?.; shall be established to control materials, parts or components
. which do not conform to requirements . . . These measures shall include, as appropriate, procedures for identification, docu=entation,
'] . segregation, disposition, and notification to affected organizations."
-l Paragraph 17.1.15 of the Quality Assurance Program doc ~umented in the PNPP PSAR states, in part, " Measures shall be included in the CEI PNPP QA Program to control nonconforming materials, parts or components. ... QA Programs shall be required of vendors and contractors of safety class equipment and vill include measures for
...: identification, documentation, segregation, disposition and notifica-75-11 , tion to affected organizations of nonconforming materials, parts or l.;gi! components." . 03' *
- yj - Paragraph 6.1.4 of National Engineering procedure QP 15.1 states, m- it. part " Nonconforming items shall be tagged and segregated where
~ ~
ever possible per Section 6.6." Contrary to the above: ,
.}
- National Engineering failed to document voids on concrete placement
~ 1BO-W-43-597 (intermediate building) on a Nonconformance Report (NR)
-;< and identify the specific area with a nonconformance tag or other #l means. Furthermore, the following areas where voids existed and
,R S which were documented in NRs had not been identified with nonconform-Section 26-26, at approximate elevation 9h' p ance tags'or other means: 580 feet; Section' 22-22, at approxi= ate elevation 501 feet-6 inches; and Pour No.1BO-U 15-597. F.v I W ' l-
- 9. 10 CFR 50, Appe., dix B, criter. ion .XVI, states in part, that " Measures
.ie
,- j.[ shall be established to assure that conditions adverse to quality, a such as . . . . deficiencies, deviations, defective caterial and equipment, and nonconformances are promptly identified and. corrected.
In the case of significant conditions adverse to quality, the O measures shall assure that the cause of the condition is determined and correctiva action taken to preclude repetition."
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Appendix A *:,,' ?, . .
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.% Paragraph 17.1.16 of the Quality Assurr- e Program documented in ' f. ,,the PNPP PSAR states, in,part, "A plan for corrective action has ~ ~
- . :f. been established for the PNPP to assure that condit' ions adverse to
] .Y quality such as failures, malfunctions, deficiencies, deviations,
- @ defective material and equipment, and nonconformances are,promptly j , ,3 e identified and corrected. Participant's programs shall be in accordance with the CEI PNPP QA Plan pnd 10 CFR 50, Appendix B.
- [. 27.t ,
In the case of significant conditions' adverse to quality, measures ! -G24, ~ shall assure that the cause of the condition is determined and that
- 0.{ .w corrective action will be taken to preclude repetition."
.. e Contrary to the above, Great 1.akes weekly storage inspection
)
' ,,; records. reveal continuirg storage problems since April, 1977,
.: (a period of 10 months) :.nd measures were not taken to assure the cause of this problem was determined and corrective action
,,. taken to preclude repetition. .For example, storage problems l 1.g.' vere found relating to embeds on 15 weekly reports, to reinforcing-steel on 11 weekly reports and to anchor bol,ts on 2 weekly reports. -
@ M. .dl!
.?I.y 10. 10 CFR 50, Appendix B, Criterion XVIII, states, in part, that
'3.d "The audits shall be performed in accordance with the written 1 0:I1 procedures or checklists by appropriately trained personnel not
! ."/j
~
having direct responsibilities in the areas being audited. . . . t Followup action including re-audit of' deficient areas, shall be j . taken where indicated."' i , ;. Paragraph 17.1.18 of the Quality Assurance Program document'ed *
- .in the PNPP PSAR states,..in part, " Audit prccedures will include:
; responsibilities assigned, audit frequencies, reporting. criteria Vh and levels of management to receive and assess audit findings . ., .
Findings w'ill be noted and response checked to ensure resolution _$,3kN
~'9 of the findings . .. CEI procurement, documents chall require that
/M .
contractors and vendors provide for audit of safety class itees
.S within the scope of the activities. These will be internal audits t Y.\ - intended to provide evaluation of. their-functions;"-
' Contrary to the above:
..y ; . .
,' a. Cannon did not conduct an internal project audit within the
'first three months of operation at PNPP, as required by the
- g ..,
.. .- Cannon QA Program.
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j]j Appendix A 12 - DW
.5
"~ ** The Cannon QA Program, Section IV, Paragraph 4.1.1.1 states,
", in part, "The first , internal project audit is scheduled within
- the first three months of operation of the project in order to assure the Project Quality Control Program is being effectively
~' , administered to assure quality." ,
b b. Three Audit Action Requests pertaining to U. S. Testing which hh]g ..
~
vere written by CEI, did not have sufficient follovup action r
.2 'to assure that prompt corrective action was taken. For example, f ollovup action by CEI was.not taken until 10 months af ter the date of the audit (October 7,1976) and as of the date of this '?
inspection (16 monthe af ter the audit), followup action by CEI 6- was still incomplete. CEI had specified an action due date of
- g. . .
October 21, 1976, for these items.
- c. CEI failed to conduct an audit to verify that the recommended ~
i ,l j3hp ~ corrective action has been taken relative to National Engineering s'! NRs No. 67 and No. 76. In both cases, the cause of the nonconformances was identified to be inadequate vibration _and
- Tj'
' 2 ; .'
recommended action to prevent recurrence was to instruce *ka
, , ' foreman and inspection personnel hou en penpe-k. use vibrators. -- 1 y'Ihis same condition was observed by the RIII pectors during U~ ' Y concrete pours CCO-S1/S6-599 and 1BO-S1-599.
c CEI's f ailure to verify that the reco= mended corrective ^ action had been taken by a site contractor (Pullman) was - cited (against Criterion XVI) once previously as an item of noncompliance in IE Inspection Report No. 50-440/77-07; 50-441/77-07.
- jn-;
WT iY 11. 10 CFR 50, Appendix B, Criterion XVII, states, in part, that 4 ;. "Suf ficient records shall be maintained to furnish evidence of HA , - activities affecting quality.. The records shall include . . the The records [?'
- results'of reviews, inspections, tests, audits . . .
shall aJso include closely related data such as qualifications of L'
~' personnel." ,
? P'aragraph 17.1.17 of the Quality Assur nce Program documented in the PNPP PSAR states, in part, " Approved procedurer shall establish and control the QA records program of each participant responsible l . .. 7- ,, g i.e* i a.c O~e f.n_. aJ
. . .; , : . . ',.- .. ' : . . .. . . :.',: j;
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- ~ .' s.10 : s
. . .. . s . .-.'. -: . . .,:. .. .. ?.:-:
. .. .ac Appendix A . .
w. h -,
- fo's quality. The QA records relating to qualification of pro -
cedures, equipment and personnel will be retained in addition to the results of inspection, tests, reviews, audits and material C. . '- *
"* certifications." ,
D. .. . Contrary to the above: _
.Y a. QA records relating to qualification of one of Cannon's personnel, who had been applying coating materials to safety related structures, were incomplete in that they were not '. signed,off by designated company individuals. . b. The physical examination records for the Cannon site quality control manager, who has been performing inspection functions at Perry Units 1 and 2, were not of file in the site quality
- assurance office as required by the Cannon QA Program.
The Cannon QA Program, Section V, Paragraphs 17.1.1, 17.1.1.14,
"$j - and 17.1.3 state, in part, " Quality Assurance Records Generated
' on the Perry Nuclear Power Plant' site are. .... OBC-N-25 . . .
Physical Examination Records . . . . The original of all records J, ,l, is are stored in a locked fii e-proof cabinet in the site Quality Assurance office." ( ..
- The failure to maintain onsite the qualification records of.a site contractor's (National Mobileh QA/G manager was cited i
once previously as an item-of noncompliance in IE Inspection
- l- . Report 50-440/76-01; 50-441/76-01.
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gf- (6) Licensee's Quality Assurance Program i (a) Objective The objectives of this assessment were to determine: i 1
'That the lice'nsee's Quality Assurance Program, including all. amendments, has been approved by NRR.
4 2 if the licensee has control of changes to the submitted Quclity Assurance Program. , j if the Quality Assurance Manual'is consistent with the approved Quality Assur6nce Program. (b) Discussion A review was conducted of the licensee's Corporate Nuclear Quality Assurance Program. The current Quality Assurance Program and the Quality Assurance Organization are not reflected in the PSAR and are a result of an Immediate Action Letter (IAL) issued by Region III on Febru-ry 8, 1978. As part of the closecut of the IAL, the res ised Quality Assurance Program, CEICo implementing Quality Assurance Procedures, and contractors' Quality Assurance Manuals were reviewed and accepted by the Region III staff. The Quality Assurance Program was not submitted to NRR. The licensee has stated that they will revise the Quality Assurance Program to clarify Regulatory Guide and ANSI Standard commitments and will submit the Quality Assurance 1 Program to NRR for approval by September 1, 1982.
- Open Item (50-440/82-09-01; 50-441/82-08-011
( The submittal of the licensee's Quality Assurance Program for review and approval by NRR is considered to be an open item. The licensee also stated that the " Contractor Quality Program i Requirements for Safety Related Installation / Erection," which are the Quality Assurance Specifications for contractors and the contractor's Quality Assurance Programs will be reviewed l to verify compliance with the CEICo Quality Assurance Program. i, These reviews are to be completed by January 1, 1983. i: Open Item (50-440/82-09-02; 50-441/82-08-02) ., The licensee's review of the contractors' Quality Assurance l' Programs is considered to be an open item. l l l l 11 ,,__ - M.'s _, _ __ -_ . l
# UNITED STATES 8 'n NUCLEAR REGULATORY COMM!SSION 7 I REGION lli
$ # 799 ROOSEVELT ROAD
/ GLEN ELLYN. lLLINOIS 60137
%{* . .
- f July 13, 1982 Docket No. 50-446I Docket No. 50-441 The Cleveland Electric Illuminating Company ,
ATI'N: Dalwyn R. Davidson , Vice President - System Engineering and Const:uction Post Office Box 5000 Cleveland, OH 44101 Gentlemen: This refers to the management meeting held by me and other NRC representatives with you and other representatives of The Cleveland Electric Illuminating Company on April 2,1982 to review the results of the NRC's assessment of the utility's regulatory performance at the Perry Nuclear Generatirig Station in connection with NRC Hanual Chapter 0516 - Systematic Assessment of Licensee Performance (SALP) covering the period July 1 1980 to September 30, 1982. A preliminary copy of the SALP Report was provided for your review in advance of our meeting. The final SALP Report including the SALP Board Chairman's letter to you and your written comments concerning the report is enclosed. In addition to the assessments and recommendations made by the SALP Board con- . tained in the enclosed SALP Report, I wish to give you my overall observations and assessment relative to the utility's regulatory performance during the assessment period.
- 1. With respect to the SALP ratings, the Regional SALP Board views the Cate-gory 2 rating as the rating which it anticipates most licensees will achieve. A Category 1 rating is given only for superior performance and there is reasonable expectation that it will continue. A Category 3 rating is given when the licensee's performance-is considered minimally -
acceptable and identified weaknesses warrant special licensee management and NRC attention.
- 2. It is my view that the overall regulatory performance of the Cleveland Electric Illuminating Company at the Perry Nuclear Generator Station is satisfactory. I concur in the SALP Board's conclusion that management attention and involvement in correcting NRC identified problems appear to be assertive, timely, and effective.
- 3. In regard to your comments concerning the oyerseeing of contractor activi-ties, we agree that the identified concerns dealt primarily with the coating contractor early in the assessment period and the electrical contractor
. J,! ,
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The Cleveland Electric Illuminating 2 July 13, 1982 Company subsequent to the assessment period. However, it was and still is our opinion that the multitude of problems identified in the electrical area could be systemic warranting an assessment of other contractor activities. We believe you also recognized this potential when you outlined your cor-rective action program for the problems in the electrical area and included a reassessment of management controls over other contractors. We believe the words ".... management control systems were not totally effective...." put our concerns in the right perspective. - As we have discussed before; it is important to have comprehensive and effectfve controls over activities to insure quality construction. Based upon our findings in the electrical area, there was an obvious. breakdown in the control of activities warranting both your and our attention. I am pleased that you have addressed these concerns. We will follow your progress in this regard. In accordance with Section 2.790 of the NRC's " Rules of Practice " Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the SALP Report will be placed in the NRC's Public Document Room. No reply to this letter is required; however, should you have any questions concerning these matters, we will be pleased to discuss them with you. Sincerely, A ~Q James G. Ieppler--- Regional Administrator
Enclosure:
SALP Report No. 50-440/82-08 and No. 50-441/82-07 cc w/ enc 1: DMB/ Document Control Desk (RIDS) Resident Inspector, RIII Harold W. Kohn, Power Siting Commission Daniel D. Wilt, Attorney Helen W. Evans l State of Ohio Robert M. Quillin, Ohio Department of Health (% ! t:.m]
IV. PERFORMANCE ANALYSES
- 1. Soils and Foundations
, The licensee is not rated in this area. No inspections were performed in thi,s area.
- 2. Containment and Other Safety-Related Structures
- a. Analysis Ten inspections were performed and incluhed concrete placement, structural steel installation, containment liner fabrication, and placement of the containment dome. In one of those in-spections three items of noncompliance (infractions) were identified as follows:
(1) Failure to follow procedure in saepling, temperature determination and holding time during a concrete pour. (2) Failure to verify or record concrete truck agitating revolutions or discharge time. (3) Excessive use of proficiency testing as a substitue for prior experience in certifying QC inspectors (two of four samples of one contractor). In a followup inspection, a repetitive noncompliance (Severity Level V) was identified concerning the use of proficiency testing to certify QC inspectors. These noncompliances are not indicative of programmatic breakdowns. The corrective action was effective after clari-fication of the NRC position.
- b. Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears satisfactory, no significant strengths nor weaknesses were identified.
- c. Board Recommendations None
- 3. Piping Systems and Supports
- a. Analysis Sixteen inspections were performed and included piping and support system design, welding, non-destructive examination, e
7 4 ,O' <:) 3
fabrication and installation. The following items of noncom-pliance were identified: (1) Infraction for failure to follow approved welding procedure requirements in that the weld bead width exceeded the specifications. (2).. Infraction.for failure to follow approved procedures and allowing piping to be " cold sprung" or prestressed into a fitup position. (3) Severity Level V violation concerning failure to select proper shim thickness so that the total thickness being radiographed under the penetrometer is essentially the same as the total weld thickness. (4) Severity Level V violation for failure to control welding material in that the welding material storeroom was found unlocked, unattended, and a 1.5 foot hole had been cut in one wall. The four items of noncompliance, which were identified in four separate inspections, represent isolated problems. They are not indicative of a major breakdown in the quality assurance program. In each case the licensee was responsive in initi-ating appropriati corrective action. The corrective action associated with using improper shim thickness in radiographing shop welds is still in progress. This problem was limited to one piping contractor. The licensee has setup and is implementing a detailed review of , the radiographs. The full significance of this review has not been determined, but at this time it is not expected to be a major problem.
- b. Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears sati' factory, no specific strengths nor .
weaknesses were identified.
- c. Board Recommendations None
- 4. Safety-Related Components
- a. Analysis Six inspections were performed. The following items of non-compliance were identified: /-
5 f'
(1) Infraction for failure to protect the reactor pressure vessel anchor bolts in that water and debris were allowed to accumulate. (2) Severity Level V violation for failure to follow approved procedures.in that reactor vessel internals were installed
". in rain.
These noncompliances appear to be isolated instances and were adequately addressed by the licensee.
- b. Conclusions '
The licensee is rated Category 2 in this area. The licensee's performance appears satisfactory, no specific strengths nor weaknesses were identified.
- c. Board Recommendations None
- 5. Support Systems
- a. Analysis Two inspections sere performed in the area of heating, ventila-tion, and air conditioning systems. Observations of ventilation systems for the containment and for electrical switchgear were made to determine that the installation of seismic supports were in accordance with procedures, drawings, and specifications. No items of noncompliance or deviations were identified. ,
- b. Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears to be satisfactory, no specific strengths nor weaknesses were identified.
- c. Board Recommendations t None
- 6. Electrical Power Supply and Distribution
- a. Analysis l
During the evaluation period, five routine inspections by region based inspectors and inspections by the resident l inspector were performed. The major inspection effort was devoted to the installation of cable trays, conduit, and electrical equipment including pump motors, a switch gear cabinet, motor operated valves and a battery charger. p l 6 :D s_ s_/ l
, Followup was conducted on IE Circular 79-17, 79-20 and 78-08 (Environmental Qualification of IE equipment). One of the inspections at the end of the evaluation period was devoted to cable pulling activities. The following items of noncom-pliance were identified relative to installation of the battery charger and cable pulling activities:
(1) Severity Level V nencompliance for failure of the in-sta11ation drawings and/or procedures to provide the size and torque values of the hold down bolts. (2) Severity Level VI noncompliance for failure to follow approved procedure as indicated by the following two examples: (a) Class 1E cables were not protected from the sharp edges of cable ties. (b) Medium voltage armored power cables were installed in their exclusive cable trays without a nominal spacing of 3/8 inch between adjacent cables. Approximately one month subsequent to the SALP, evaluation period, quality control problems associated with electrical installation work were identified during an investigation initiated October 27, 1981. The investigation was initiated as a result of allegations; however, its scope was extended beyond the initial. allegations when other problems were identified. The investigation identified potential items of noncompliances (currently under review for appropriate enforcement action) related to inadequate procedures and
~
QC inspection activities, drawing errors and administrative breakdowns in the performance of audits and handling of non-comformance reports. Taken individually these findings may. not represent major problems, but collectively they reveal deficiencies in the implementation of the quality assurance program in that problems are not identified and corrected in a timely manner. l The initial phase of the investigation resulted in the issuance of a Confirmation of Action Letter on November 18, l 1981. This letter confirmed the licensee's action to suspend - the pulling of all safety-related cables by the electrical I L i 7
contractor pending resolution of the identified problems. The licensee was responsive to the identified problems and initiated corrective action. However, continuing investiga-tion and inspections identified other problem areas. These concerns were expressed in a management meeting held on February 10, 1982. In response to NRC concerns expressed in the management meeting, the licensee outlined and initiated an overall corrective action program as indicated in a letter dated February 18, 1982. This new corrective action program will include a review of the control sydtems for all onsite safety-related contractors.
- b. Conclusion The licensee is rated Category 3 in this area. The results of the investigation indicate the licensee has not made effective use of resources in that procedures and policies are occasionally violated, some reviews and corrective action have not been timely, a breakdown in design control is evident, and some audits are not timely. The results of the investigation indicate that the basic findings existed during the evaluation period.
- c. Board Recommenda~tions Even though the licensee has outlined and initiated a corrective action program as indicated in a letter dated February 18, 1982, the Board recommends continued attention by bot!. licensee and NRC in this area. The NRC should "
. devote available resources to assure that the licensee's l corrective action program is effective in correcting both past and future problems.
- 7. Instrumentation and Control Systems l
- a. Analysis Three. inspections were performed,.one was devoted to test and measurement equipment and the installed plant instru-mentation calibration program. The other two inspections included observation of safety-related level instrumentation installation in the condensate storage tank and the installa-tion of safety-related piping in the containment dome for l .the hydrogen gas analyzer systen. No items of noncompliance or deviations were identified. The licensee exhibited effective planning by taking action to establish calibration programs and log checks at an early stage of the construction program and has been responsive to NRC comments. ,
o b) 8EI 1.
- b. Conclusions The licensee is rated Category 2 in this area. The licensee's performance appears satisfactory.
- c. Board Recommendations None.
- 8. Licensing Activities
- a. Analysis The licensee respanses are above average. While the licensee relies on the NSSS vendor and architect engineer (A/E) for input, the licensee has a competent technical staff onsite to furnish responses and review the NSSS vendor and A/E responses. If the licensee has any problem with NRC requests he asks for clarification and this enhances the quality of his responses.
Responses to NRC review questions on FSAR submittals were delivered within the time frame specified. Most letter requests are also responded to within the time frame specified. In a few cases, NRC request dates have been missed due either to the quantity of effort required or to the licensee's un-certainty of the NRC request. The licensee makes a concerted effort to be very responsive. During meetings with NRC, the licensee has been cooperative and the appropriate technical persons were available to make the meetings a success.
~
The utility licensing staff members have an excellent working knowledge of the applicable regulations, guides, standards and generic issues. They attend many NRC sponsored functions and stay current with NRC policies. In summary, the licensee has been characterized by NRC as being knowledgeable, cooperative, technically competent, agressive, responsive, and an effective communicator in the area of licensing activities.
- b. Conclusions The licensee is rated Category 1 in this area.
- c. Board Recommendations None 9
LlJ l
. 9. Reporting Requirements and Corrective Actions
- a. Analysis As part of an inspection performed early in the evaluation period one item of noncompliance was identified relative to not reviewing a Part 21 report for reportability under 10 CFR 50.55(e). This ~'
deficiency lead to a reevaluation by the licensee of their inter-nal procedures for reporting. As a result of this reevaluation and further discussions with NRC staff, the licensee has streng-thened his procedures to promote increased awareness of report-ing requirements. This increased awareness is evident in the twenty seven 10 CFR 50.55(e) reports submitted 'in the 15-month evaluation period compared to eight reports issued in a previous 12-month perJod.
- b. Conclusions The licensee is rated Category 1 in this area. Effective licensee management attention and involvement were demon-strated by taking what appeared to be minor evidence of a potential programmatic problem and strengthening the entire program. -
- c. Board Recommendations None
- 10. Preservice Inspections-
- a. Analysis ,
Three inspections were performed and no items of noncompliance or deviations were identifed. Management controls of the NDE contractor's preservice inspection program, procedures, material and equipment were adequate. A review of the NDE contractor's personnel qualifications and training records indicated that his personnel met at least the minimum standards required for NDE performance. Observations of licensee and NDE activities indicate that the overall effectiveness and attitude are satisfactory.
- b. Conclusion l
The licensee is rated Category 2 in this area. I c. Board Recommendations None
.i.
(3c} 10 {j f
. 11. Protective Coatings -
- a. Analysis Inspection efforts identified quality deficiencies that resulted in the issuances of an Immediate Action Letter by 1TRC and a-Stop Work Order by the licensee against the nuclear
_ coating contractor, Metal Weld. Three Severity Level V noncompliances of the licensees quality assurance program were identified. These noncompliances included failure to follow established procedures, failure to establish controls for tools, gages and other devices and' failure to completely indoctrinate, train and qualify. individuals to perform as Level I and Level II inspectors. The licensee actions to correct these deficiencies were responsive and timely. These actions also appear to have been effective since no further problems have been identified in the latter half of the evaluation period. L. Conclusions The licensee is rated Category 2 in this area. The licensee performance appears to be satisfactory, no fur.ther problems have been identified.
- c. Board Recommendations None e
(~ . (' {}
, Appendix NOTICE OF VIOLATION Cleveland Electric Illuminating Docket No. 50-440 Company Docket No. 50-441 As a result of the investigation conducted during the period October 27, 1981 - March.19, 1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), tn'e following violations were identified:
- 1. 10 CFR 50, Appendix B, Criterion III, states in part, "The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews . . . performed by individuals or groups other than those who performed the original design ..."
CEI Corporate Quality Assurance Program Section 0300 states in part, "CEI performs a design coordination function consisting o,f selected reviews and design control monitoring program ... These procedures shall assure that ... Design activities are conducted in a planned and systematic manner ... Perry Safety Analysis Report requirements have been appropriately addressed in design documents ... Design requirements can be controlled and inspected and/or tested to specified acceptance criteria." CEI Specification, Electrical Installations, requires compliance _ with the AWS D1.1 Codes. - Contrary to the above, Gilbert Associates (the Architect Engineer) failed to adequately review Gould Inc. Drawings E,35-51-958 E231 and E233, in that the review failed to determine that the " plug weld" specified to weld 7/16" diameter holes in the switchgear did not meet the AWS D1.1 Code requirements. This resulted in welds being made which did not meet the specified code requirements. l This is a Severity Level IV violation (Supplement II). l l ts L-
Appendix 2 .
- 2. 10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, and drawings of a type appropriate to the circumstances y.. q and shall be accomplished in accordance with these instructions, procedures ...'!
- a. Gilbert Associates Incorporated Drawing D-215-001, Revision J, Criterion 13, states in part, "The total of all bends between pulling points in any run of conduit shall not exceed 270*;
sufficient pull boxes are shown on drawings to meet this { criteria." Further CEI letter PY-50/33-5357, to L. K.*Comstock, dated January 20, 1981, instructs Comstock to use the pull boxes as pulling points. Contrary to the above, the instructions were not incorporated into the procedure and on November 16, 1981, the inspectors observed cable being pulled through a conduit with bends totaling more than 270' (by at least 160') without using the installed pull o boxes as pulling points.
- b. Paragraph 3.2.24 of L. K. Comstock Procedure No. 4.3.3 states in part, " Care shall be exercised in supporting coils to prevent !
kinking or exceeding the, minimum bend training radius . . ." Contrary to the above, LKC Cable Pulling Procedure 4.3.3 was not appropriate to the circumstances in that it did not prescribe alternate methods to store partially pulled cables to preclude violating the established minimum bending radii. As a result the inspectors observed cables identified as 1M32R8B, IM32R9B, , and IM32R11B coiled, and suspended by a single tie wrap in such a manner that the bend radii of the inner turns of subject cables were less than the minimum bend radii established by the I manufacturer. l
}
i
- c. Paragraph 5.2.6 of the L. K. Comstock Procedure No. 4.11.1, Nonconformance Items and Corrective Action, states in part,
" Initiated NRs may be voided by the QA Manager or his designee ..."
i L,.
_ - - - - _ . -.. _ . - ~ . . - - -. - . . =_ _ _ - . i
. Appendix 3
- - i
. Contrary to the above, L. K. Comstock Nonconformance Reports No. 531 and No. 454 (dated February 25, 1981 and November 21, 1980 respectively) war.e voided by QC inspectors who were not authoriz,ed to do so. -
- d. The L. K. Comstock Company Quality Assurance Manual requires j separate positions for a QA Manager and a QC Supervisor.
Contrary to the above, from April 1981 until February 1, 1982, one individual holding the position of QA/QC Supervisor was - filling the positions of QA Manager and QC Supervisor. The lack of adequate staffing contributed to L. K. Comstock's poor per-formance. f e. The manufacturer of cable tray hardware materials, in their letter ! dated December 20, 1978, specified a maximum allowable torque of 45 ft. Ibs. to tighten 3/8"-16 3/4" rib neck carriage bolts supplied for the cable tray splice joints. i contrary to the above, L. K. Comstock's applicable cable and conduit installation procedures were not appropriate to the cir-cuestances in that this torque requirement was not incorporated. Additionally, further inspections revealed there were no records to indicate that this requirement was met for any cable tray
- installed prior to this inspection (examples of improperly torqued bolts are discussed in paragraph 5.C below).
This is a Severity Level IV violation (Supplement II). ,
- 3. 10 CFR 50, Appendix B, Criterion VI, states in part, " Measures shall be established to control the issuance of documents, such as ...
drawings, including changes thereto, which prescribe all activities affecting quality ..." L. K. Comstock Procedure No. 4.2.1, Drawing and Specification Document Control, states, in part, in Paragraph 3.5.4, " Returning void drawings, the recipient shall sign the Field Drawing Transmittal (Form 52A - Void Issue Returned Line) and return it with the void drawings to the Document Control Coordinator," and in Paragraph 3.6, " Void drawings will be returned by recipients from the field by the General Foreman within two (2) working days of the issuance date noted on the Field Drawing Transmittal Form."
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t Appendix 4 Contrary to the above, L. K. Comstock Company failed to return the voided copies of six drawings (Gilbert Associates, Inc. Nos. 4549-58-027;- 4549-58-028;.4549-58-030; 4549-58-031; 4549-58-032; and 4549-58-033). Revision 1 of each of these drawings was found at'a L.'K.Comstock foreman's wo'rk area on the 620' elevation of the Control Complex instead of the most recent Revision (revision 4). Revision 1 was issued in 1977 and Revision 4 was issued in 1981. This is .a Severity Level V violation (Supplement II). .
- 4. 10 CFR 50 Appendix B, Criterion VIII states in part, "Heasures
, shall be. established for the identification and control of materials, j parts ... assemblies. These measures shall assure that identifica-tion of the item is maintained by heat number, part number, serial l number or other appropriate means, either on the item or on records - traceable to the item, as required throughout fabrication, erection, installation, and use of the item." The CEI Corporate Nuclear Quality Assurance Program Section 0800, in paragraph 1.2, states, in part, " Measures shall be established to implement the following requirements . . . Identifying and controlling material, parts and components including partially f abricated sub-assemblies or subdivided materials to preclude the use of incorrect or defective items." Contrary to the above, the electrical contractor, L. K. Comstock Corporation, failed to establish adequate measures to control pur-chased hardware such as bolts, nuts, and cable mounting bases and - store them in-the stockroom in such a manner that defective items , could not-be traced to the app,ropriate documentation or shipment i to preclude the use of incorrect or defective items. l This is a Severity Level IV violation (Supplement II).
- 5. 10 CFR 50, Appendix B, Criterion X, states, in part, "A program for inspection of activities affecting quality shall be established and _
executed by or for the organisation performing the activity to verify conformance with the documented instructions,-procedures, and drawings - for accomplishing the activity." l l
Appendix 5
., a. CEI Corporate Nuclear Quality Assurance Program, Section 1000, Paragraph 1.1 states in part, "A program for inspection shall be established by CEI to ensure that all safety-related components ...
affect 4ng those items' meet the required quality standards." Contrary to the above: (1) The electrical contractor failed to inspect the inside diameter of the containment vessel nozzles and the concrete shield wall penetrations to verify that concentricity and/or dimensional tolerances were within the limits established by the manufacturer. (2) An inspection program to verify the adequacy of installation of the 4160 volt /480 volt switchgear and the 480 volt Motor Control Centers (including the sequence of assembly such as, shimming, torquing of bolts, fitup and welding) was not established and therefore not performed.
- b. The electrical contractor's (L. K. Comstock) Cable Pulling Procedure, Section 4.3.3.1.10, rcquires verification that raceways are clean and free from abrasions and sharp edges which might cause cable damage during cable installation.
Contrary to the above, the NRC inspectors observed sharp edges and burrs in the following cable trays:
. Tray B1313, elevation 604'.
. Tray B1303, elevation 574'. '
. Tray B1324, elevation 620'.
. Tray A3021, elevation 620'.
Several safety related cables had been instal' led in cable trays B1324 and B1303.
- c. L. K. Comstock's Cable Tray Installation Inspection Checklist Form #17, Item 1.6, requires verification that bolts are tight on splice joints.
Contrary to the above, the following cable trays contained improperly seated bolts: l
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. Appendix 6
. (1) Cable tray A1699 located at Column Line D-11 at elevation 599' in the Auxiliary Building. Three out of eight splice bolts observed were not properly seated. This cable tray
- contains cables.
(2) ' Cab'le tray 1E21H1A located at Column Line F-8 at elevation 579' in Room No. 2 of the Auxiliary Building. Two out of eight splice bolts observed were not properly seated. This is a Severity Level IV violation (Supplement II). -
- 6. 10 CFR 50, Appendix B, Criterion XIII, states in part, " Measures shall be established to control the h'andling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deter-foration."
- a. CEI Construction Quality Assurance Procedure No. 2-1301 in Paragraph 1.2.3, states in part, " Monitor housekeeping on a -
continual basis while performing storars and maintenance inspections. Forward any deviation noted on an Action Request, to Project Safety Supervisor." , Contrary to the above, the inspectors observed that the protective covers on the Reactor Core Isolation Cooling and Residual Heat Removal instrument panels had deteriorated and the storage and maintenance inspection had not identified this condition prior to the NRC inspection. ,
- b. CEI Specification N. SP-33-4549, Procurement Specification for Electrical Installations, paragraph No. 2:16.1, states in part, "The contractor shall keep the premises clean at all times during i the progress of the work and shall remove dirt and rubbish as I
directed by the Site Organization ..." Contrary to the above, on December 4, 1981, the inspectors observed potential fire hazards, consisting of large amounts of paper and other combustible materials, on the scaffolding in the Unit I annulus at elevation 649'. CEI was notified of this potential fire hazard on December 4, 1981. Licensee personnel advised Region III the hazard would be removed by E l l t l- . ~ - - - . . - - . _ _ . , - - , . - _ - . . . . . - . . , _ . . . . . . . . . , . . . . . , . . . , , _ . , . . .,. . ~ . , ,. ,
Appendix 7 J December 7, 1981. On December 10, 1981, Region III personnel reinspected this same area and found a fire had occurred. Interviews revealed that the licensee did not know when the fire started or when it was extinguished. There was no damage to safety related equipment as a result of the fire. This is a Severity Level IV. violation (Supplement II).
- 7. 10 CFR 50, Appendix B, Criterion XV, states in part, "Heasures shall be estab.lished to control ... parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation: These measures shall include, as appropriate, proce-dures for identification, documentation, ... and notification to affected organizations. Nonconforming items shall he reviewed and accepted, rejected, . . . in accordance with documented procedures."
CEI Corporate Nuclear Quality Assurance Program, Section 1500, Revision 2, Paragraph 1.1 states in part, "Nonconformance Reports shall be used to identify materials, parts, components, structures or systems which are not in compliance to the requirements of specifications, codes, drawings, and detailed installation' or manu-facturing program requirements." L. K. Comstock Procedure No. 4.11.1, Nonconformance Items and Ccrrec-tive Action, paragraph 5.5.1 states in part, ". . . Nonconforming Items are either segregated, eurked, or identified with a Hold Tag (Attach-ment No. 7), to indic. ate their status and prevent inadvertent use or installation." Contrary to the above, 4.16 KV switchgear with hold down welds known to be nonconforming by the licensee were not identified and controlled with Hold Tags. This is a Severity Level V violation (Supplement II).
- 8. 10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, and drawings of-a type appropriate to the circumstances ...
and shall be accomplished in accordance with these instructions, i procedures ..." l I F h l _, _ - - - - - , , . - , - - . , . . _ , - - - . , - ~
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. Appendix 8 .c , . a. CEI Electrical Installation bpecificatpon SP-33-4549.-00 requires a one inch minimum-separation between conduits containing Class '
1E circuits and conduits containing Ncn Class 1E circuits. , Contra y to the above: - (1) Installed Class 1E conduit 1R331024A and Non-Class 1E conduit 1021R36X, did not meet the one inch separation requirement. (2) Class 1E conduit 1R33R516A was separated by 1/2 of an inch - from non-Class IE con'duit 1R52W91X located at elevation ss' 568' in the Auxiliary Building above the RCIC instrument ' panel 1H22-P017.
- b. CEI Electrical Installation Specification SP-33-4549-00 requires
, a minimum horizontal and vertical sepatration of six inches _
',tetween conduits of different divisions in cable spreading rooms.
' ~
Contrary to the above: (1) Division 3 conduit 1R33A129C has installed separated by 2-1/2 inches from Division 2 conduits 2R33R919B and'
'1C11B3B at elevation 639' in'the cable spreading room.
(2) Division 2 conduits 1R33R788B,1R33R786 Band 1R33R92k3 were installed separated by 1 1/2 to 3 1/2 inches frop Division 3 conduits 1R33C2809C and 1R?3C2071C at elevation 636' in the cable spreading room. (3) Division 2 conduits 1R33R920B and 1R33C3033B were separated by 3 1/2 inches from Division 3 conduits 1R33R2071C, IR33C2809C, ' 1R33C29140, and 1R33A129C located at elevation 638' in the cable spreading room. i w (4) Division 2 conduit 1R33T329B was separated by 1 1/2 inches from Division 3 conduit 1R33T330C-located at elevation 638'
-in the cable spreading room. -
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Apprndix 9 'T (5) Division 2 conduit IRS 3T329B was separated by 2 1/4 inches from Division 3 conduit 1R33C291C located at elevation 638' in the cable spreading room. CEI Elecirical Installation Specification SP-33-4549-00 requires c. that the minimum separation may be reduced to one inch for conduits of redundant divisions when routed through wall and floor penetrations. 1 Contrary to the above, Division 1 conduit 1R33C1098A was separated by 3/4 of an inch from Division 3 conduit 1R33R334C through a floor penetration at elevation 606' in Room 1 of the Auxiliary Building. This is a Severity Level IV violation (Supplement II).
- 9. 10 CFR 50, Appendix B, Criterion XVI, states in part, "Heasures shall be established to assure that conditions adverse to quality, such as
... nonconformances are promptly identified and corrected."
CEI Corporate Nuclear Quality Assurance Program, Section 1600, Paragraph 1.2.b states in part, " Requests for corrective action shall include address of the action required to correct the adverse condi-tion and to preclude continuation or recurrence......The NQAD shall verify compliance to corrective action measures through audit, sur-veillance and inspection of project organizations and other QA evalua-tion and control techniques such as nonconformance trend analyses." Contrary to the above, eight L. K. Comstock Nonconformance Reports written during the period August 14-November 20, 1981, indicated the , reason for the nonconformances was inadequate attention to installa-tion details by L. K. Comstock personnel. These Nonconformance Reports were not reviewed to trend the reason (s) for the inattention to installation details. Prompt corrective action was not taken. This is a Severity Level V violation (Supplement II). Pursuant to the provisions of 10 CFR 2.201, you are required to s thmit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good c.use shown. - Dated' ) V J hh b},/ ames Regional G. Administrator Keppler 1 7
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