ML20070S375
| ML20070S375 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/27/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20070S374 | List: |
| References | |
| NUDOCS 8302040366 | |
| Download: ML20070S375 (17) | |
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P O ECA !X0 Serving The Best L.ocation to ti e s'.'arica Oc tober 27, 1982 Ca'..3 n R. Cavidson
-:IF !!; CENT 5 5'FV f *, GIN!iR.NG AN? CCNSTRUCTioN Mr. James G. TNppler Regional Adninistrator, Region III Of f ice of Inspection and Inforcenent U.S. ';uclear Regulatory Cennission 7C9 Po:sevelt Road l
Glen Ellyn, Illinci.;
53137 4
RE:
Fetry Nuclear ?cwer Plant Docke t ' sos. 5C-440; 50-441
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Response to I.E. Report Cear 'f r. :: apple r:
This le::et is o ackn:w'eige receipt of Inspec:i:n Repor ':unber 50-440/
1982.
This 31-19; 5 0-t:1/31-19 e::sched to yeur letter dated Septenber 27, identtfies stess exa.ined by '! esses. C. D. Scaund, K. R. Naldu, C. H.
report
- leil and C. C..?illians cf f our s taf f during their inves tigation conducted Oc:eSer 27, 1981, throgh 'farch 19,19S2 A::achnent A te this 16::er is our response to the six (6) Severity Level IV and :Sree (3) Severity Letel V Vicla; ions described in the Notice of Violation.
Th' response is in accordance with the provisions of Section 2.201 of t'he In
';F.C's "F.ules of ?ractice," Part 2, Title 10, Ccde of Federal Rc3ula tions.
addi t loc, A:'.achnen: 3 includes infernation in response to the Unresolved Itens that were identified in this report.
If there are additional questions, please do not hesitate to call.
Sincerely, 5
M4.. s$+dL
- 's Dalwyn R. Davidson Vice President Systen Engineering and Construction i
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ATTACHMENT A RESPONSE TO ENFORCEMENT ITEM Below is our response to the Notice of Violation appended to United States Nuclear Regulatory Co= mission I.E. Report-50-440/81-19; 50-441/81-19.
I.
Noncompliance 440/81-19-16; 441/81-19-16 A.
Severity Level IV Violation 10CFR50, 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 perfo rmance, 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 perforts a design coordination function consisting of selected reviews and design control monitocing program...These proceduces shall assure that... Design activities are conducted in a planned and sys tema tic manner... Perry Safety Analysis Report requirements have been appropriately addressed in design documents... Design requirements can be controlle. and inspected and/or tested to specified accep tance criteria."
CEI Specification, Electrical Installations, cequires compliance with the AUS Dl.1 Codes.
Contracy to the above, Gilbert Associates (tha Architect Engineer) failed to adequar0y 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 Dl.1 Code requi.ements. This resulted in welds being 5
made which did not meet the specified code requirements.
B.
Response
Action Request #457 was' written to document this concern.
This action request has been closed out and verified.
Subsequently the equipment was velded down using fillet welds at the frame, and the original " plug" welds were abandoned in piece. The design engineer and switchgear vendor have approved the revised design.
A memorander was issued by Gilbert Associates to all Perry Project electrical and s tructural departments cettecating the correct pro-ceduce for cauting and review of vendor drawings.
This itec 's censidered te be resolved.
(.r hii" II.
Noncompliance 440/82-19-01; 441/82-19-01 A.
Sevecity Level IV Violation-10CFR50, Appendix-B, Critorion V, states in-part, "Activitias affecting quality shall.be prescribed by documented instructions, 3
procedures, and drawings of a type appropriate to the circumstances...
y and shall be accomplished in accordance with these instructions, procedures..."
a.
Gilbert Associates, Incorporated, Drawing Dv215-001, Revision J, Criterien 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 drawin3s to meet this criteria."
Further, CEI letter PY-50/33-5357, to L. K..Coms tock, dated January 20, 1981, instructs Comstock to use the pull boxes as pulling points.
Contracy to the above, the ins tructions 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 boxes as pulling points.
b.
Paragraph 3.2.24 of L. K. Cocs tock Procedure No. 4.3.3 s tates in part, " Care shall be exercised in supporting coils to prevent kinking or exceeding the minimun bend training radius..." '
Contrary to the above, LKC Cable Pulling Proceduce 4.3.3 was not appropriate to the ciccumstances in that it did not prescribe alternate tethods to stora partially pulled cables to preclude violating the established minimun bending cad 11.
As a result, the inspectors observed cables identified as IM32R8B, 1M32R9B, and 1M3.2R113 coiled, and suspended by a single tie wrap in such g
a man,er that the bend cadit of the inner turns of subject cables were less than the minimum bend radii established by the manufacturer, c..
Pacagraph 5.2.6 of the L. K. Comstock Procedure No. 4.11.1, Nonconformance Items and Corrective Action, states in part,-
"Initfated NRs may be voided by the QA Manager or his designee..."
Contrary to the above, L. K. Coms tock Nonconformance Reports No. 331 and No. 454 (dated February 25, 1981, and November 21, 1980, respectivel;l.were voided by QC inspectors who were not authorized to do so.
d.
Tne L
- h. Cemstock Company Quality Assucance Manual requires sepacate pcsi: ions ice a QA Managec~ and a QC Supervisor.
Centracy :o :he abcre, ' from April 1931 until February 1, 19S2, one inditidual hciding the position cf QA/QC Supervisoc was fLtting ::e pcs L: Lens of Q4 "anager and OC Supe cv tsoc.
The lack ef adequi:+ s :sf f ;n; c.,n t r ibu: - :.: L.
,. Coms tock's poor p e c to rms..c e.,
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C The manufacturer of ' cable tray hardware _ materials, in their e.
lettee dated December 20, 1978, specified a maximum allowable torque of 45 ft. lbs, to tighten 3/8"-16 3/4" rib neck carriage bolts supplied for the cable tray splice joints.
Contrary to the above, L. K. Comstock's applicable cable and conduit insta'lation procedures were nct appropriate to the circumstances in that this torque requirement was not incor-porated.
Additionally, further inspections _fruaaled there were _
~"~no records to ;rdicate that this requirement was met for any_
cable tray instal'ied prior to this inspection (examples of improperly tocqued bolts are discussed,in paragraph 5 C belowb B.
Respons\\$
L. K. Comstock procedure 4.3.3 has been revised to incorporate a,
the Engineering request or use'bf pull points.
The cable concern was documented on Nonconformance Report LKC 810 and the ~
cable was determined not to be over tensioned.
The 270* Jonduit critecia is not directly related to cable pulling, but is rather a criteria for conduit installation.
To ensure the. cable ins tallation is satisfactocy,f cable pulling
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tensions are continuously moni.to' red 'during the cable pull.
The criteria (as defined on drawing D215-001, Rev.-J) were met for
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' the conduit installation.
'Crar t. sad inspector training has been performed to the revised p rocedure.
This item is considered to be resolved.
b.
L. K. Cemetock proceduce 4.3.3, paragraph 3.2.25 has been revised co cequire two points to suspen" coiled cab'es, and on January 5,1982, to change " training" to " bending". Tha cables 5
observed and all other Class lE cables utilize suspension methoca jLn accordance with the revised ptocedure.
The Project organization nas =dusequently verit rea witn the nanuf acturers
~
that the utilization of training radius for colling cables is accep tab le.
Training of Quality Control and craf t personnel has been con-ducted and documented.
Additionally, Engineering (NCES) has j
added personnel to provide emphasis on procedure review.
This ite Ltohc ren'.ed.
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Action Eequest ua55 was. genera:ed by Construction QualityThe Engineering and 5,as since been eerified and closed out.
' _. K. Ccmstock Quality Centr ; Msnager has signed, reviewed, and verified the previous ; proper;. c ided ncnconformance ceports.
Additic. ally, L. K. Cc s tack pec: educe 4.11.1 has been revised to clar'fy voidin; r e q u '. r eme n : 5.
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Training to revised procedure has been conducted and documented.
The item is considered to be resolved.
d.
Corrective action for this condition was reviewed by.the. inspector as discussed on Page 65 of this I.E. Report and no additional response is required.
The lack of torquing requirements was initiated by Nonconformance e.
Report CQC 2344 dated 9-11-31 and cn DAR 068 as a potential significant deficiency.
The use of electric impact wrenches was discontinued and calibrated manual torque irenches subs tituted.
LKC Procedure 4.3.1 has been revised to incorporate torquing criteria of 35!15 f t.
lbs.
^
These criteria were developed in conjunction with our corrective action relctive to the Final 10CFR50.55(e) Report [RDC 37(81)}
dated January 15, 1982.
This ite: is considered to be resolved.
II:. Noncompliance 443/31-19-23; 411/81-19-23 A.
Severity level V Violation 10CFR50,.sppendix B, Criterion VI, sta:es in part, " Measures shall' he established to control the issuance of documents, such as...
d rawings, including chan;es thereto, which prescribe all activities affecting quality..."
L. K. Consteck Procedure No. 4.2.1, Crawing and Specification Document Control, s ta :es, in part, in Paragraph 3.5.4, " Returning void drawings, the recipient shall sign the Field Drawing Transmittal (Form 52A -
Cold Issue Returned Line) and retura ir. with the void drasings -to S
the Document Control Coordinator," and in Paragraph 3.6, " Void drawings will be returned by recipients from the field by the General Foreman withi:. two (2) working days of the issuance date noted on tne Field Drawing Transmittal Form."
Contrary to the above, L. K. Comstock Company falled to return the voided copies of six drawings (Gilbert Associates, Inc., Nos. 4549-58-027; 1549-33-028; 4549-58-030; 4549-58-031; 4549-58-032; and 4549-53-033). Revision 1 of each of these drawings was found at an L. K. Const:ck forecan's work area on :he 620' elevation of the Control Cotplex ins tead of the mos t recent Revision (Revision 4).
Revision 1 was issued in 197 7 and Re tision a was issued in 1981.
3.
Responso inve s : L;a:.cn cf $his proble-revas'ed that all revisions of the d
n drawings.rera properly issued :n the f ; eld by L. K. Cems tock Document Con:enl.
'.s drawing sta:us indica :es :ha: field personnel were in r e ceip :
f :.e drawings a->
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- 41sc indicates previously
- i.s. era subs. w e;;1;.
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(=e L. K. Comstock has completed an inventory on all vendor prints and all drawings have been brought up to date. An Engineering review of the drawings indicated that the revisions did not affect the equipment installation.
Construction Quality -Engineering performed Audit #635 and additional sEF7eillances and determined that this is not a genkric problem.
This item is considered to be resolved.
IV.
Noncompliance 440/81-19-19; 441/31-19-19 4
A.
Severity Level IV Violation 10CFR50, Appendix 3, Criterion VIII, states in part, " Measures shall be established for the identification and control cf materials, parts... assemblies.
These ceasures shall assure that identification of the item is maintained by heat number, part number, serirl number or other appropriate ceans, ei:her on the item or on ' ecords r
traceable to the item, as required thredghout tabrication, erection, ins talla t ion, and use of the' item."
15e CEI Corporate Nuclear Quality Assurance Program Section 0800, in paragraph 1.2, s:ates, in part, " Measures shall be established to implement the following requirements... Identifying and controlling material, parts and components including partially fabricated sub-assemblies or subdivided ca terials :o preclude the use of inco.crect or defective items."
Contrary to th.: above, the electrical cc:.:cactor, L. K. Comstock Corporation, failed to es:ablLsh -adecua:e ceasures to control purchased hardware such as bolts, nuts, and cable mounting bases and s tore them in the stockroom in such a canner that defective items could not ce traced to the appropriate documentation or shiptent to 5
preclude the use of incorrect or defective items.
3.
Response
e L. K. Comstock Quality Assurance program is written and imple-s-
such that raterials are traceable,and' controlled up to receipt mens on Site.. To ob tain clarificat;on of the' technical requirements for traceabil
, CAR S2-09 was writ ten,~ cesponded to, and closed. The traceability. thodolcgy wi:hJn~'the L. K Coestock QA program was evaluated as acc table.,.
L. R. Cons:cek reorga..~ -ed and recenfigured their warehouse to clearly segres--
and cc..
al taterials. A Cons truction Quality EngineerLac.adi: vas c:nduc. d to cerify L. E. Constock's actions
- :he above concern.
and no f 'ddings.:ere (ssued relet {ce Th L L e-is censidered c he rescice:.
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L V.
Noncompliance 440/81-19-03; 441/81-19-03 A.
Severity Level IV Violation 10CFR50, Appendix B, Criterion X, states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the locumented ins tructions,. procedures, and drawings for accocplishing the activity."
CEI Corporate Nuclear Quality Assurance Program, Section 1000, a.
Paragraph 1.1 states in part, "A program for inspection shell.tue established by CEI to ensure that all safety-related components...
affectinz those itees neet the recuired quality standards."
Contrary to the above:
- 1) _The electrical contractor failed to inspect the inside
-diame ter of the contalw.c..: ve=cel nozzles and the concrete shield wall penetrations to verify that concentrici ty and/or dimensional tolerances were within the limits establisnea oy the canufacturer.
- 2) An inspection program to verify the adequacy of installation of ti.e 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.
Tne elec trical contractor's (L. K. Cc s tock) Cable Pulling Procedure, Section 4.3.3.1.10, requires verification that raceways are clean and free fec: abrasions and sharp edges which night cause cable damage during cable installation.
Contrary to the above, the NRC inspectors observed sharp edges and burrs in the following cable trays:
Tray 31313, elevation 604'.
Tray 31303, eleva tion 574'.
Tray 31324, elevation 620'.
Tray A3021, elevation 620'.
Several safe ty-rela ted cables had been ins talled Ln cable trays 31324 and 31303.
L. K. C:nstack's Cable Tray Ins tallation Inspect ion Checklis t c.
Fo rm "17 I:e= 1.6, requires verification that bolts are tigh t on splice jcinte.
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Contrary to the above, the Collowing cable trays contained improperly seated bolts:
- 1) Cable tray ^1699 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) Ccble tray 1E21H1A located at Column Line F-8 at elevation 579' in Roo= No. 2 of the Auxiliary Building.
Two out of eight splice bolts observed were not pr,operly seated.
3.
Response
a.
1)
L. K. Co= stock Procedure 4.3.10 has ' zen revised to clarify t
pene tration it.stallatice. inspection criteria.
Per revised Westinghouse installation instructions, the install'ation dimensions and tolerances documented on Field Questions 12139, 12173, 12230,.12249, and 12295 were evaluated and deter =ined to be acceptable by Nuclear Cons truction Engi-neering Section (NCES). A plan was developel to sddress the adequacy of inspection for the Unit 1 penetrations. Training to the revised procedure has been cocpleted'and documented.
Penetration inspection records have been reviewed by the Proj ect Organization Engineering Group. The records are inccmplete and the contractor is in the process of completing the records.
This item will be resolved by December 15, 1982.
Unit 2 penetrations are being ins talled to revised Procedure 4.3.10 2)
L. K. Comstock Procedure 4.3.4 has been revised to clarify the equipment installation inspectton criteria.
Additionally, g
innZitIms have been established to verify a equate installation i
inspections of the 4160 volt /480 volt switchgear, the 430 volt motor control centers (MCC) and 480 volt unit subs *tations (including the sequence of assembly such as shimming, torquing of bolts, fitup and welding).
The status of the reverification programs related to in-process inspection are as follows:
l Switchgear Installation - All items complete except for switchgear weld rework verificat'on.
Unit Substation Installation - All items complete except f
f er lead center veld rework verifiestion.
"o::: Central Centme Insta1Ls:Len - All itets complete i
exc-;
evaluation and dispos' tion cf slot welds for shims.
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Any subsequent equipment installation will be performed in accordance with the revised procedure, This item will be resolved by January 14,11&a -
y b.
L. K. Comstock Nonconformance Report 1070 was gsnerated to document the specific cable' trays in question.
After reinspec_-
tion, these trays were evaluated to be acceptable.
Comstock Proceduce 4.3.3 was evaluated in order to determine L.
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whether or not procedure revision was necessary. As part of the evaluation, a review of Nonconformance Reports was done to o
. determine if any Class lE cables had been previously damaged due to sharp edges.
Twenty-two (22) L. K. Coms tock Nonc onformance Reports written in 1981 on cable anc wire were reviewed and none were related to sharp edges or burrs on cable tray.
Thus, based on the fact tha t no negatLvc trend could be identified in this it was determined that a proced' ice revisien was not required.
- area, This item is considered to be' resolved.
An inspection program was developed to reverify on a sample c.
basis the adequacy of ins tallation of the bolts.
The reinspection has been completed, and the original NR (C0C 2344)
- revised? The NR dispositica documents the accep tability. cf the ins tallation.
CQC 2344 has been closed.
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Inspections are performed in accordance t.th revised L. K. Coms tock Procedure 4.3.1.
This item is considered to be resolved.
Nonce pliance 440/31,19-10; 441/81-19-10 VI.
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A.
Severity Level IV Violation 10CFR50, Appendix B, Criterion XIII, states, in part, " Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equiptent in accordance with work and inspection instructions to prevent damage or deterioration."
CEI Construction Quality Assurance Pecceduce No. 2-1301 in a.
Paragraph 1.2.3, states in part, " Monitor housekeeping on a continual basis while performing storage and maintenance insp?'_-
tions.
Terward any leviation noted on an Action Request, to P roj ec t safety Sup'ervisor."
Contrary :o the abcre, the inspec tors ob se rved tha t the protec-tEve cevers on the Reactor Core lation Cooling and Residual Eent o.e ca; instrw :n: panels nad de tecierated and the s:ccage and a;n:enance inspection had -'
- dsn
- L' Led this cendition prior :: : e ':RC inspect ~on.
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b.
CEI Specification Nc, SP-33-4549, Procurement Specification for.
Electrical Installations, paragraph no. 2:16.1, states in part, "The contractor shall keep the precises clean at all times during the progress of the work and shall remove dirt and
-rubbish as 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 caterials, on the scaffolding in the Unit 1 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 December 7, i
1981.
On December 10, 1981, Region III personnel reinspected this same area and found a fire had occurred.
Inte rviews, revealed that the licensee did ne: know when the fire started or when it was extinguished.
There was no damage to safety-related equipmen: as a result of the fire.
3.
Response
a.
Audit 614 was performed ay the '_ ice.see and two (2) f indings WEre issucC aget.dt ~Jc6 Son Centrols, Inc. (JCI).
The panel discussed above was addressed in or.e of the findings.
Panels under JCI jurisdiction were inspec:ed and naintenance documen-tation reviewed.
All deficiencies were corrected by January 28, 1982.
Project Administration Procedu're PAP 3206 nas been re-reviewed and detectined to adequately address program requicecents for housekeeping. These areas will he centinaed to be monitored per this procedure.
]
This item ic considered to be resolved.
S b.
Action Request 369 was issued against the Nuclear Construct' ion Section (SCS).
In respense to the AR, the Reactor Building Composite crew was concitted to checking and cleaning the area on a daily basis.
Project Administration Procedure ?A? 0206 has been re-reviewed and deteccined to adequately address program requirements for housekeeping.
Incr' eased surveillance and an improved checklist have bean ins:i:nted by the Cons true: ion Quality Section.
This ite is corsidered to be resc1ved.
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VII. Nonco pliance 440/61-19-11; 441/81-19-11 (Page 79)
A.
Severity Level V Violation 10CFR50, Appendix B, Criterion XV, states, in part, " Measures shall be established 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 af fected organiza tions.
Nonconforming items shall be reviewed and accep ted, rejected....in accordance with docume,nted 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, s:cuctures or systems which are not in compliance to the requiremeats o.f specif.tcations, codes, drawings, and de tailed Lns tallatlon 'or manu-facturing progra= cequirements."
L. K. Ccas tock Proceduce No. 4.ll.1, Scnconformance Items and
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Corrective Action, paragraph 5.5.1, s tates in part,
,..Nonconf o rming Items are either segregated, marked, or icentified with a Hold Tag (Attachment No. 7), to indicate their status and prevent inadve r tent use or installation."
Contrary to the above, 4.16 KV switchgear with hold down welds known
-;o be nonconforming Sy the licensee were not identifled and controlled with. Hold Tags.
S.
Resoonse Tags were subsequently placed by Project' 3rganizatten (initially respons Lble for the tag) on svitchgear to identify the nonconformance 5
in the field. Also, the utillzatlon of hold tags has been clarified with the deuelopment of Quality Tagging Procedure (PAP 1404) which more clearly describes the quality tagging requirements.
s Proper taggi.;g per Project Administration Proceduce 1404 will ensure the organization (s) affected are aware of the codhitton.
that Training to the new proceduce has been completed and documented, l
This item is ccasidered to be resolved.
440/31-19-11; 441/S1-19-11 (Page 70) f VIII. ':encompliance A.
Severity T.evel IV Viola tion 10CFR50. Appendix
, Criterion V, s tates ir part, '.' Ac t ivi t tes af fecti.g cuality shall be prescribed %;. decumented ins truct lens, l
precedures, and drazings of a type c;;repriate to the ctrcums tances...
and sSc.ll be accomplished in accords ce zit:- these Las t ruc t ions,
procedures..."
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a.
CET, Electrical Ins talla tion Specificati:a SP-33-4549-00 requires a one inch cinimum separation between conduits containing Class 1E circuits and conduits containing Non-Class 1E circuits.
Contrary to the above:
1)
InstaIled Class lE conduit'lR331024A and Non-Class IE conduit 1021R36X, did not meet the one inch separation requirecent.
- 2) Class IE conduit 1R33R516A was separatgd by 1/2 of an inch fro: Non-Class lE conduit 1R52'o'91X located a t eleva tion 568' t
in the Auxiliary Building above the RCIC instrument panel s
1H2'-P017.
b.
CEI Electrical Ins talla tion Specification SP-33-4549-00 requires a minimun horizonta?. and verties1 separation of six inches bet ecn ccnduits of dif ferent de.isions in cable spreading roo=s.
Contrary to the above:
,1)
Division 3 conduit 1R33Al29C was installed separated by 2-1,'2 inches feca Division 2 conduits ?R33R919B and ICllB3B at eleva tion 639' in the cable spreading room.
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2)
Division 2 conduits 1R33R.7383, 1R33R786B and 1R33R926B were ins: tiled separatad by 1-1/2 to 3-1/2 inches from Division 3 conduits 1R33C2509C and 1R33C2071C at elevation 638' in the cab'_e spreading room.
3)
Division 2 conduits 1R33R92GB and 1R33C3033B were se'parated by 3-1/2 inches fcca Division 3 ccnduits 1R33R2071C, IR33C2809C, 1R33:29:4C, and 1R33Al29C lccated at elevation 636' in the g
cable spreading room.
4)
Division 2 conduit 1R33T3293 was separated by 1-1/2 inches fro: Division 3 conduit 1R33T330C located at elevation 638' in :he cable spreading room.
l
- 5) Division 2 conduit 1R33T3293 was separated by 2-1/4 inches l
fre Division 3 conduit 1R33C291C located at elevation 638'-
in the cable spreading roo=.
l c.
CEI Ele ctrical Ins talla tion Specif ication SP-33-4549-00 requires I
that the minicua separation cay be reduced to one inch for conduits of redundant divisions men routed through wall and floor : ane t ra tions.
the$b:ve, Divis; " '. conduit 1R33C1095A was separated Centeste :e b: 3/- :f ar inch frer Division 3 conduit IR33R334C through a fleer renetrat;on at e'.evation 3:6' in Room 1 of the Auxiliary
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B.
Response
s.
Separation criteria violations where Class 1E and Non-Class lE conduit did not meet the one (1) inch separation requirement, were documented on L. K. Comstock Ndhgonformance Reports 1193 and 1323.
J Inspectors will continue to use the electrical installation
' specification SP-33,4549-00 for' separation criteria along with required D-215 drawings and to document nonconforming conditions 3
as required.
e Construc: ion Quality Engineering Audit 717 was perfocmed to 4
evaluate LKC compliance with separatieu triteria. As a result, 3
retraining was conducted for LKC QA Inspectors and craf t to assure understanding of separation requirements including -the
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identification of violations.
This ite-is considered to be resolved.
1 b.
These ite=s were evaluated by the Project Organization and i
determined to be in ace'ordance with the Specification.
j Section 3:08.10.1 of SP33 requires 6" minimum separation between divisions, but is prefaced by "unless othetwise indicated on engineer-approved drawings..."
The Jnstallation observed is in accordance with the applicable conduit layout drawings.
For general plant areas, SP33 includes a paragraph allowing for a reduction to 1" separation if shown on the layout drawing.
To clarify this requirement, ECN 8426-33-IS99 was issued.
In addition, L. K. Coms tock P7ocecure *.a.1 was revised to reflect this specific criteria.
S These items are considered to be resolved.
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NR LKC 1329 was written to document this violation.
Ihis NR has
-be,en closed out and verified.
_lcons truction. Quality Engineering Audit 71,7,was performed to
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evalu,a'te' ~LKC compliance with separation criteria.
As a result, retraining was conducted for LKC QA Inspectors and craf t to assure understanding of separation requirements' including the
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identification of violations.
This ite is considered tc be resolved.
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':enecep li ance 4-:!31-19-05; 141/SI-19-0S Severi:y '_e cal 7 Viola t ten
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10C??.30, ap;endix S, Crt erion XVI, sta:es in part, " Measures shall be es tablished :c assure tha: condit inns adverse to quality, such as...nnne,.f :::an:es are prn:p tly ide ::;fied and corrected."
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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 condition and to preclude continuation or recurrence...The NQAD shall verify compliance to corrective action measures through audit, surveillance.and inspection of project organizations and other QA evaluation and control techniques such as nonconformance trend analyses."
Contrary to the above, eight L. K. Comstock N[nconformance Reports written during the period August 14 - November 20, 1981, indicated the reason for the nonconformances was inadequate attention to installation 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.
3.
Response
As described in Construction Quality Section Procedure 2-1602, the need for a formal trend analysis is determined during the course of nonconformance reviews and the Quality Engineer had determined that en the basis of the magnitude and scope of the electrical' installation (overall), there was not significant repetition to warrant performance of a trend analysis.
Subsequent to the concern expressed by the Nuclear Regulatory Commission, the contractor generated an internal CAR regarding workmanship problems.
Extensive training programs were developed and implemented to address these probleas. The effectiveness of this hcs been confirmed by Construction Quality Engineering Audit 723 on raceway installation.
The continued implementation of the L. K. Comstock inspection p rogram, with an overviev b-f Construction Quality Engineeri g 5
including daily surveillances and in-process audits, will maintain our philosophy of resolving concerns as the work is being performed.
This ites is considered to be r,esolved.
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ATTAC!! MENT B RESPONSE TO UNRESOLVED ITEMS The following information is provided to assist with resolution of the con-dicions set forth for future review:
Unresolved Item 440/81-19-02; 441/81-19-02 The eequirement for end caps on conduits waa-re-evaluated by Engineering.
To resolve the identifled inconsistency, ECN 9075-33-2006 has been issued to clarify the requirement for the need:,t'o in's tall and caps for. above ground i
conduit runs.
i Unresolved Item 440/81-19-04; 441/81-19-04 L.K.ComstockProcedureNo.4.3.10,_Inskall,atLonofElectricalPenetratiogg, has been revised to provide specific ' accept / reject criteria for containment J vesse'. electrical pene tration-essemblies, ~ including a detailed checklist where each ite has a separate Contractor QC signof f line. Revision 6_gf the Wes ting heuse Lnstruction nanual contains specific criteria for accaptance, which will be used for the Unit 2 ins tallatlon.
A plan was developed to confirm the adequacy of the Unit 1 ins tallation.
As indicated in the response to Nonec=pliance 440/81-19-03; 441/81-19-03, the j
penetration documentation review will be completed by December 15, 1982.
Unresolved Item 440/81-19-05; 441/81-19-05 A_gail._spection for hole verification on electrLeal pene tration numbers 1R72-5 01 "., 1E72-S017, 1R72-5027, and 1R'2-5028 wae performed and the alignment of Jne b:lt holes was verificd to be encrect.
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UnreqolvedItem 440/81-19-06; 441/81-19-06 Field Questions 12159, 12173, 12230, 12249 and 12295 concerning ins tallation of Unit 1 'w'estinghouse penetrations have been revised to include an Engineering evaluation of the acceptance of the Unit 1 penetrations. As indicated in the respense to Noncompliance 440/81-19-03; 441/81-19-03, the penetration documentation reviee will be completed by December 15, 1982.
Unresolved Item 440/81-19-07; 441/81-19-07 SE ^Q:-2290 has been dispositioned by the Engineer and reviewed by the Quality Eng
.eer.
In part, the Engineer's disposition stated that the 80* to 140*F
- e perature limit app'.ies to all' anblent temperatures inside the MCCs excep t
- - f.e surf ace of the heater strips.
In additLon, the Engineer performed a s.:a'. L.spection cf :he ::CCs at that t Lme and de te cci,ned that no damage was fr-
- c :.e ".CCs by the past ove rh ea t ing.
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In addition, in March of 1982, the FSMR was revised to disconnect the heaters and use itght bulbs for heat. No additional tempecature problems have been experienced.
4, Unresolved Item 440/81-19-09; 441/81-19-09 To strengthen their Audit Program, L. K Comstock has extensively revised their Procedure 4.14.1, " Internal Audit Procedure," and initiated A new LkC Procedure 4.14.2, "The Qualification, Certification, and Training of Auditors."
Inplementation of these procedures was the subject, in part, of Construc: ion quality Audi: 722 and good progress has been nade in resolution of this concern.
A Ruality 2ngineer has been added to the corporata staff And is cuccently assigned :o the Perry site on a full-time basis.
Incesolved Item 440/81-19-12; 441/81-19-12 1). The use of a common support for Class 1E and Non-Class 1E conduits has been evaluated by the Design Cngineer and determined to be acceptable.
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- 2) The acceptability cf the RPS circuit in the Turbine Building is addressed 3
in the 7 3 AR, Sec t'. an 7.2.1.2(g).
Clarification of this requirement was transmt::ed to L. K. Comstock by ECN 8928-33-1986.
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Unresolved I:em 440/31-19-13; 441/81-19-13 S?33, Sectica 5:08.9.2, states, "... minimum separation of 14 inches, excep t as i
o therwise indicated on cable tray layout drawings..."
Drawings applicable to the identified concerns were reviewed to assure that
- he insta11atien'is in accordance with the drawings and that barriers, to be installed later, are shown on the drawings as required by IEEE Std. 384 Unresolved Item 440/81-19-14; 441/81-19-14 ECN I701-33-1932 'was issued to clarify Paragraph 5:08.13.6, and L. K. Co.r>tock Procedure 4.3.3 was revised to address the criteria for inspection and subsequent nctifica:Lon to Engineering of cable fill in safety-related installations.
Unresolved ::em 440/S1-19-15; 441/81-19-15 Revisions to Site and Contractor turnover procedures have been issued to address this concern.
Unreselved ::em 440/51-19-17; 441/81 19-17
!ne ::n: ac:ces inspection report da:ed 12-30-31 was incorrectly written in
- hat i: not only addressed the wrong section of SP33, but also failed to
- . sider :.at 5?33 does not apply to owner furnished equipment.
A second insne::ir reper: was issued which reflected the actual acceptable condition.
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Unresolved Item 440/81-19-18; 441/81-19-18 An evaluation was A plan developed to address this concern is now closed out.
perforced by the Architect-Engineer and the limited usage of such materials was analyzed to be acceptable.
The installation is in accordance eith industry standards as referenced in the Final Safety Analysis Report.
Unresolyed Itec 440/81-19-20; 441/81-19-20 This concern was analyzed by the Architect-Engineer. Af ter an evaluation of fault currents and relay settings, the AE determined that a 5 kV breaker tissle was not a credible esent for Percy and that the commitments in Section's 3.5.3 an S.3.1.4.1.1 of the FSAR have been net.
Unresolved Iten 440/81-19-21; 441/81-19-21 Cerrective Action Reques: 32-09 was written to document this concern.
In the Architect-Engineer re-evaluated traceability of' materials for resp:nse,
?erry construction contracts.
The re-evalua tion concludes that the current prograns, subj ect to satisf actory implementation, are acceptable.
Unresolved Item 440/31-19-22; 441/81-19-22 The henger was cut out and scrapped per the NRC Inspectors recommended correc-tive action.
Training sessions have been performed for the applicable Johnson Centrols, Inc., personnel, and the drawing has been ravised.
Unresclved Itec 440/31-19-24; 441/81-19-24 The : recall assessment of the contractors' Quality Assu'rance Programs has been cc:pleted as described in the May 6, 1982, letter from D. R. Davidson to Mr. K2ppier.
That assesscent resulted la the determination that the concerns iden'tified by the NRC and analyzed by the licensee do not represent a signift-QA program breakdown for either L. K. Comstock (LKC) or the Project cant O rganiz a t ion.
t Corrective Action steps were being implemented on a priority basis.
Some delays in implementation had occurred attributable to the Owners philosophy of surveillance which af fords the contractor the opportunity to correct his problems.
Tc d2:e, L. K. Constock, in conjunction with the Project Organization, has take-the following actions:
fey personnel changes were made in LKC corporate and LKC site staffs.
AddL:;cnal.anpower was hired for LKC Corporate and LKC site staffs and f:r ::ns: rue:Lnn ^uality Engineering.
h3 backleg ' f '. : Audit Finding,eports and Cons truction Quality Ac tion P- 'e : e.d ':encsnf e ctance Reper:s has been reduced substantially.
Fe-aca.ast;mn ani u-date of IEC nrocedures is approximatel: 00% complete.
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- grar and hardware cana;ns at a very high level.
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