ML20078A472

Affidavit of Gr Leidich in Response to ASLB 830818 Memorandum & Order Re Comstock Task Force

ML20078A472
Person / Time
Site:	Perry
Issue date:	09/19/1983
From:	Leidich G CLEVELAND ELECTRIC ILLUMINATING CO.
To:
Shared Package
ML20078A470	List: ML20078A467 ML20078A472 ML20078A484
References
NUDOCS 8309230282
Download: ML20078A472 (37)

Text

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AFFIDAVIT OF GARY R. LEIDICH l

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8309230282 830919 PDR ADOCK 05000440 G PDR l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of , )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

AFFIDAVIT OF GARY R. LEIDICH County of Lake )

) ss:

State of Ohio )

Gary R. Leidich, being duly sworn, deposes and says as follows:

1. I, Gary R. Leidich, am Senior Engineer, Nuclear Con-struction and Engineering Section, The Cleveland Electric Illuminating Company. My business address is 10 Center Road, Perry, Ohio 44081. My professional qualifications and experience are set forth in Applicants' Testimony (Edelman/Leidich Testimo-I ny), following Tr. 1031, at 3-5. I have personal knowledge of the matters set forth herein and believe them to be true and correct.

2. I have reviewed the Board's Memorandum and Order (Motion to Reopen), dated August 18, 1983 (Memorandum and Order), and am

addressing in this Affidavit concerne identified by the Board at pages 3-8 of the Memorandum and Order. The Board's concerns relate to findings discussed in a Comstock task force letter, dated August 6, 1982, which was attached to the July 13, 1983 Motion to Reopen the Record on Issue #3, filed by Ohio Citizens for Responsible Energy (OCRE). The letter cited by OCRE discussed preliminary task force findings that showed instances in which inspectors had completed inspection documents in areas outside the inspectors' certifications. I discussed the task force findings, and responsive actions thereto, in an Affidavit dated August 4, 1983 (August 4 Affidavit), attached to Applicants' Answer to OCRE Motion to Reopen the Record on Issue #3, dated August 4, 1983.

The Board has requested supplementary information concerning the certification issue. The following information is provided in re-sponse to the 'oard's questions.

3. The requirements for qualification and certification of Comstock inspectors are contained in the PNPP quality assurance attachment specification (SP-709) to the PNPP electrical installa-tion specification (SP-33). SP-709 incorporates by reference American National Standards Institute (ANSI) N45.2.6-1973, enti-tied " Qualification of Inspection, Examination and Test Personnel for the Construction Phase of Nuclear Power Plants." ANSI N45.2.6 sets forth guidelines for the qualification and certification of inspectors, based on factors such as education, training and expe-rience. The standard indicates that in considering these factors,

employers may also take into account other factors such as satisfactory completion of proficiency testing. ANSI N45.2.6 provides for three certification levels. Level I inspectors may only perform inspections and are not permitted to evaluate, approve, or accept inspection results. Level II inspectors are permitted to inspect as well as evaluate, approve and accept in-spection results. Level III inspectors have the same authority as Level II inspectors and may, in addition, approve and accept in-spection procedures.

4. Consistent with SP-709 and ANSI N45.2.6, Comstock developed a certification program for its inspection personnel prior to initiation of safety-related electrical work. Project Organization QA personnel reviewed Comstock's program prior to its implementation, to assure compliance with SP-709 and ANSI N45.2.6.

Under Comstock's program, inspectors are certified to task-specific areas. (The level designations discussed above apply to each task area). At the time of the task force review, Comstock's inspectors were certified as level I, II or III inspectors in one or more of the following areas: receipt, equip-

! ment, installation, calibration, tray / conduit (raceway) installa-tion, cable pulling, electrical terminations, hilti bol; installa-tion, core drilling, civil, visual welding, stud welding, liquid penetrant testing, and magnetic particle testing. In order to be certified in a particular task area, inspectors must first be pro-ficient in the procedures applicable to that area.

5. In accordance with SP-709, since the beginning of Comsto'ck's program Project Organization QA personnel have reviewed all Comstock certifications. Inspectors have not been permitted to begin work at a new certification level, or in a new task area, without Project Organization approval. On several occasions, the Project Organization has withheld certification approval when our evaluation determined that qualifications were not satisfactory.

6. In addition to these reviews, CEI and Comstock have overviewed Comstock's implementation of its certification program through periodic audits and field surveillance. CEI's field sur-veillance resulted, on at least two occasions, in the decerti-fication of Comstock inspectors, when it was determined that they were not satisfactorily carrying out their inspection responsibilities.1/ In addition, seven CEI audits between 1978 and 1982 identified isolated instances of certification discre-pancies similar to those found by the task force. However, nei-ther the audits, nor the final task force findings, identified a serious problem with certifications. As discussed below, the cer-tification discrepancies identified by the task force were insig-nificant in number and kind, and involved no safety deficiencies.

The task force findings thus confirmed the adequacy of Comstock's l

and CEI's QA/QC program with respect to certifications. This 1/ The work inspected by these decertified inspectors was fully evaluated and, where necessary, reinspections were performed.

[ -explains why we did not emphasize certification issues during our i

testimony. See Memorandum and Order at 4-5.2/

7. In March 1982, at the direction of CEI's lead electrical l

quality engineer, Comstock conducted Audit CQA-27, which was a comprehensive internal audit of Comstock's QA program. I made reference to this audit at the hearing. See Tr. 1534. Among other things, the audit observed a small number of random cer-

tification discrepancies, and raised questions concerning the com-pleteness of inspection documentation. CQA-27 concluded that further assessment of QA records and procedures was required. CEI i- reviewed the results of the audit. Comstock's principal correc-

, tive action in response to this finding was to establish a task force under the direction of Comstock's Corporate QA Manager.

This was the task _ force referenced in the August 6, 1982 letter '

i attached to OCRE's July 31, 1983 Motion. The task force had a i

broad charter to perform a comprehensive review of Comstock QA' documentation completed as of the time of the task force review.3/

8. The task force performed its review from April-December, 1982. Its findings were set forth in a series of internal letters and memoranda issued on a periodic basis during that period. The i

2/ The certification discrepancies discussed herein are unrelated to CEI's testimony concerning Comstock's periodic difficulties in obtaining appropriate numbers of inspection per-

, sonnel. See Memorandum and Order at 4, 7.

- j3 s/ Inspector certification was one of many QA/QC areas reviewed by the task force and covered in their findings.

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documentation review was divided into six construction areas:

civil, hangers, penetrations, equipment, circuits (including ter-minations), and raceway. The task force consisted of four individuals from the Comstock QA organization, and three indepen-dent QA consultants retained by Comstock. The seven task force members worked on the review on a full time basis until the review was completed in December 1982. The task force review covered ap-proximately 5,900 documentation packages containing approximately 30,000 records. See NRC Inspection Report No. 50-440/83-06; 50-441/83-06, dated March 16, 1983 (83-06 Report; Board Exhibit 4, ff. Tr. 1619), at 2-3.

9. At the time the task force was formed, Comstock informed CEI of the nature and broad scope of the effort to be accom-plished. CEI viewed the task force as an aggressive corrective action by Comstock in response to documentation findings from the NRC's 1981-82 investigation and Comstock's CQA-27 Audit. CEI was aware that the task force was documenting its findings, and, con-sistent with CEI's QA program, CEI's review of the task force findings was to take place on completion of the task force review.

Meanwhile, CEI was closely overviewing Comstock's performance throughout 1982. See, e.g., Tr. 1534-41 (Leidich).

10. CEI issued a CAR (#82-21) in August, 1982 identifying, among other things, some of the same certification discrepancies as those identified by the task force. Among other things, CAR 82-21 identified an absence of level II co-signatures on

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inspection documents (one of the certification. findings discussed in the August 6, 1982 task force letter). As I testified in re-sponse to questions about CAR 82-21 from Mr. Abramson and the Board, one of the corrective actions in response to the CAR was that "all of the inspectors were notified by their supervision --

and this is one of the particular findings -- level II inspectors must review all inspection-releted documents." Tr. 1338. See 115. For the Board's informatioa, I am attaching a copy of CAR 82-21.

11. In,yesponse to CAR 82-21, Comstock reemphasized to CEI that Comstock's task force would fully document and evaluate all certification discrepancies (the CAR at page 2 makes explicit ref-erence to the task force), and would take the necessary corrective action,. including reinspection of hardware where required. I

' discussed the corrective action plan to CAR 82-21 at Tr. 1336.

Because the task force review was still in process when the CAR was issued, and since the reviews conducted up to that time had not revealed hardware problems, CEI did not direct Comstock to

file a Nonconformance Report. However, CEI did agree with the NRC that corrective action documents should have been written by

,- Comstock to track task force items as of February 1983, by which time Comstock had reviewed the final findings of the task force.

4 For this reason, we did not contest the 83-06 Notice of Violation (Board Exhibit 4, ff. Tr. 1619). See August 4 Affidavit, 19; Tr.

1611-19. A' copy of CEI's formal response to the 83-06 Notice of Violat' ion is attached.

12. As indicated in CEI's response to Inspection Report No.

83-06, Comstock's findings had been documented on documentation package checklists. In addition to Comstock's recording the docu-mented findings on NRs, CEI placed the task force findings on Project Organization Surveillance Inspection Reports (SIRS) to en-sure proper resolution of the findings. CEI also.placed a-Project Organization QA representative in Comstock's organization on a full time basis to perform continuous monitoring of Comstock in-spection reports and documentation packages, including those af-fected by the task force findings. I discussed this individual's QA role at Tr. 1541-42, 1556-57.

13. The final certification findings identified by the task force involved equipment (cable reels, control room panels, motor control centers, switchgear, and termination cabinets) and pene-trations.4/ The final task force findings, covering certification and other areas, were formally transmitted to CEI on February 12, 1983.5/

i 4/ The reference in the August 6 letter to megger/ continuity tests, included in the Board's citation at page 5 of the Memoran-i dum and Order, did not involve certification discrepancies -- this is evident from the discussion under items 2A and 2B of the letter.

5/ Project Organization QA personnel discussed task force find-ings (including certifications and other issues) with Comstock personnel on a periodic basis between April 1982 and February 1983.

14. The task force review covered the majority of Comstock's-inspection records from 1978-1982. I would emphasize that the task force review was conducted in advance of the final turnover document reviews conducted by both Comstock and Project Organiza-tion. See Tr. 1540-41. These reviews would have detected discrepancies of the type identified by the task force. The final certification finding involved only 190 out of the approximately 30,000 records reviewed by the task force, and 15 out of approxi-mately 110 inspectors employed by Comstock during the 1978-1982 time period.s/ As explained below, the task force found only a limited number of instances in which the 15 inspectors had 1

conducted inspections that were not in strict accordance with cer-tification requirements. The vast majority of the inspections performed by these 15 jnspectors were properly within their cer-tifications.

15. Of the 190 affected inspection records, approximately 35 l of the records indicated failures to document level II inspector acceptance of inspection results (i.e., missing level II I

co-signatures). This problem, including some of the same specific cases cited in the August 6, 1982 task force letter, had been s/ The August 6, 1982 task force letter stated that "Approxi-mately six (6) people were certified out of 22 people who were signing off various Inspection documents and were not certified to do so at that particular time." The finding was based on only a partial record review. Based on subsequent review, the task force concluded that the certification discrepancies involved 15 l inspectors.

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identified by CEI in conjunction with CEI's audit leading to the issuance of CAR 82-21, dated August 31, 1982. fee 1110-11.

16. The remaining certification discrepancies covered by the task force finding involved instances of inspectors completing checklist items for tasks outside the inspectors' task cer-tifications. However, in these cases, the inspection personnel were performing inspections that were common to two or more cer-tification area checklists. The technical knowledge for these 1

common inspections was the same or similar, even though they were in different task-specific areas. For example, inspectors cer-tified to inspect torquing operations for raceway bolts inspected torquing operations for penetration bolts. The knowledge and pro-ficiency required to perform these two inspections was the same.

Because inspectors were completing these common inspections on i

checklists for areas in which they were not certified, cer-tification discrepancies were noted by the task force. CAR 83-02, identified at 110 of the August 4 Affidavit, was CEI's formal re-sponse to this finding. I referred to this CAR at Tr. 1541. For i

the Board's information, a copy of CAR 83-02 is attached. In re-l sponse to the CAR, Comstock has discontinued the practice of inspectors signing common checklist items outside their cer-l

! tifications. Despite Comstock's and CEI's confidence in the pro-ficiency of the inspectors involved in the task force finding, en-

gineering reviews were conducted, and reinspections were l

performed. As indicated below,-the reinspections did not uncover safety deficiencies.

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17. As indicated in the August 4 Affidavit, 110, Comstock issued Nonconformance Reports LKC 1795 and LKC 1797 to-document all Comstock inspector certification discrepancies covered by the task force finding. The NRs describe certification discrepancies 1

covering, in total, 248 pieces of equipment, and 35 penetrations.

The NRs were reviewed by both Comstock and Project Organization engineering and QA personnel. Based on the reviews, Comstock and CEI jointly concluded that reinspections should be conducted with respect to 239 out of the 248 pieces of equipment, and six out of the 35 penetrations.

18. The engineering reviews concluded that the. remaining items, including 29 penetrations and nine pieces of equipment, did j not require reinspection. The 29 penetrations, which were installed and not readily accessible to reinspection, were thor-oughly evaluated by Comstock and Project Organization engineers.

These reviews indicated that the certification discrepancies in-volved common checklist items for uncomplicated types of inspec-tions such as torquing, cleanliness, and cosmetic damage. It was determined that the inspectors who signed these items were profi-cient in the inspection procedures involved. See 116. For this reason, and based on Comstock's and Project Organization's reviews

of the types of inspections involved, it was concluded that reinspection of the penetrations was not required. Although

reinspections are not being performed, final acceptance testing of

the penetrations will be performed to provide additional assurance of the adequacy of the penetrations. The remaining nine equipment discrepancies. involved various examples of items not requiring

r reinspections, e.g., items which had previously received

engineering review and acceptance subsequent to inspections, and items for which inspections were never required.

19. The reinspection program has been completed with the

-exception of two penetrations. These two penetrations are cur-rently disassembled and will be reinspected after reassembly. ,

'These reinspections, which are uncomplicated, involve the align-ment of holes prior to bolting. We expect the reinspections to take less than four hours.

20. The reinspections,2/ which met or exceeded the original inspection requirements, have included visual inspection for

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cleanliness and storage, adequate protection for cable reels, I torquing, location,.and alignment. All reinspections have been accomplished without difficulty in obtaining access to previously inspected items. Although several cases involving minor cosmetic-damage (e.g., scratches, chipped paint) were identified due to ambient' construction activity, no hardware deficiencies or safety problems were identified.

To. accomplish the reinspections, Comstock used two level 21.

II inspectors working for four months, and one level II and one level III inspector working for one month. Throughout the

! reinspection effort, Project Organization QA personnel have closel'1 monitored Comstock's QC staffing levels to assure that the reinspection effort has not reduced Comstock's ability to maintain 1

2/ All discrepancies involving in-process inspection were covered-by the reinspection program. See Memorandum and Order at 8.

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effective first line inspection of current construction activities. In addition to CEI's surveillance and inspection.

Comstock has submitted a biweekly report to CEI quantifying the status of all their outstanding inspections, including those covered under the reinspection program.

22. Pursuant to DAR #118, dated February-28, 1983-(see August 4 Affidavit, 110), Project Organization engineering and QA personnel reviewed the final task force certification findings in their entirety, as well as the QA/QC and engineering reviews and reinspection program discussed above. Based on the extremely low percentage of certification discrepancies (i.e., discrepancies on only 190 out of 30,000 inspection records), the type of cer-tification discrepancies identified, and the adequacy, status, and preliminary findings of the reinspection program, CEI concluded that the certification discrepancies did not raise safety issues.

Thus, CEI concluded that the certification discrepancies were not reportable, and the DAR was closed on March 2, 1983.

23. In sum, the task force certification review and CEI's and Comstock's responses to the task force review have confirmed the adequacy of Comstock's and CEI's QA/QC programs with respect to certifications. The task force was an aggressive corrective action by Comstock involving a massive documentation search. The reinspection program was equally thorough. The task force find-ings involved no serious certification discrepancies, either in terms of numbers or types of discrepancies, and no safety problems were identified by Comstock or CEI during the reinspection pro-gram. Although Comstock did not draft formal QA/QC documents

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until February 1983, Comstock was none'theless documenting all discrepancies found during the task force review. CII was aware of the task force review, was monitoring the review consistent with its QA/QC program, and was independently performing QA/QC \

reviews of areas covered by the task force. CEI has reviewed all instances of certification discrepancies and has found nothing to suggest that the discrepancias were attributable to " wrongdoing."

See Memorandum and order at 7. CEI's overview of Comstock has in-dependently verified the adequacy of Comstock's certifications and ,

the safety of the plant.

kh k GargR.Leidich Subscrib and sworn to before me ,

this day of September, 1983.

W 1_ sfj & ssi -

v NOTARY PUBLIC ,

My Commission Expires:

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m. s.s Parry Nuclear Pm;r Plant SEP 211392

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Appendix B Responsible MC Audit Number .

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/r' 99 Criteria No. , 1, 7 Organization .L.K.C .0 3 3 .

Initiated Bg A. Alonso/D. Bruver Initials AA0/DAa Issue Date .0.813.118.2.

Govemis,g Requirement: SP-709-_4540-00:'l_05.17: 1:05.2; LKComstock Procedure 4.1.4 s

Obiervation: (1) Tnaneerinn rep ree ar'k = i on ad hv nnnn=14fiad nar=nnn 1 (2) Inspection reports are incomplete and without'the requi' red QC signatures.

7 3) No program exists for cualifvit.g inspectors in Insulation Resistance and Continuity Testine. Insnection renorts nre-beine signed by insnectors with inconsistent aualifications.

(4) Of the packages examined. a 54% reiection was observed. e_

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"' 2 5 f co, Per:etially Reportable Per 10CFR21 or 50.55 e Yes E No: DAR No. . PAron - .

vnf Upgraded to CAR G Yes No .

Reviewed for Significance By:

Recommendation: (1) LKC shall train all inspectors on the importance of the inspector signaturc on a report. what the significaace of that signature is. and the imoortance of completely filling out reports. (2) LKC shall implement a orogram for cualifying inspectors in IR&C testing. (3) LKC shc11 immediatelv implement a program to correct existing deficiencies in inspection documentation. (CONTINUED - SEE A'ITACHED) - ...

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Response Due Date . O . 9 Nf2 ." 8M'-

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c. ' Acknowledged By: % P_- C) M # "A Cruse: Inadequate written training. - -

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u . .u t Response ( include corrective action and steps to prevent recurrence) 7 m /nc han undereone a mannive reernini program concerning all areas of documentation. In order to satisfy this C.A.R. the follovi items should be considered. (1) Insoectors were notified in writting (See attachment 1) tha a resoonsible Level II must review all inspection related documents. (2) All Inspectors in

) .the area of cable pull. terminations, and eauipment installation were tested to assure l workit.g knowledge (See attachement 2) of continuity and meggering. Test scores range from 90% to 100%. LKC Procedure 4.3.18 vill be revised to include a statement reflecting the fact that cable null. termination and eauipment installation Inspectors will be trained to thene reouf rements. All future Inspectors certified in these areas vi'll be tested to assur Completion Date . O. li 0,3,8.3 Continued on page 3 of 7.

Response Prepared By: Larry G. Seese . Response Date .O,9;1,4l8,2, Response Evaluation: j2cAOG u;. Abcc0 ATE A4b Acct:OTER LEc gab TAtm*J M4 M FFYiATLY Actiord M:m12 T7-WJ G2 (2. (M.4 i% trg;w f4 o2 Sat TV do O-(11 <T / T-2E NAOilE MN Iha 4 'CO O no htAtG h . /*

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Accept R 'ect CAUSE CODE ddu [:i Ev luation By: -

N44 . N 02 Evaluation Date: .I i M 8 f ,

Verified By: // .

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RECOMMENDATION (continued) o

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, Some of these problems have been identified by the Records Task Force.

, The response to this CAR shall include the corrective action plan in response to items identified by this audit and by the Task Force.

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PAGE 3 C.A.R. 82-21 ,

RESPONSE: " CONTINUED " .-

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knowledge in this subject. (3) All past documents are being reviewed for technical cdequacy and required corrections or updates are being performed. (4) A memo has been issued to all Inspectors (See Attachment 3) covering timely responses of Inspection documents.

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1. Define Continuity Test: k M tn/e17 .r h DF ;~fotrhrou w ' 14 fcNoJC 70/C 15 A domptSTL rim ss A 4 Ad TM let ie s eYnnkL Q d.est ta r* k e m fajo h smo. .

2. Define Megger Test: ka JAssJc A rion AEf / STANCE 7457 tJ50 M L V DLA toes Jn A r 4 il'S hkd4 / /fMf0 t/etTM 4- E. QA . kl unir e A Cacti Untefit. -ffJ 7.

3. Medium voltage electrical penetration power conductors shall be tested at 500 VDC (min) and shall have a minimum resistance of ggeta between the conductor and ground.

4 Low voltage electrical penetration power and control conductors shall have a minimum resistance of fog 4 A between the conductor and ground.

5. List three pieces of equipment that can be used to conduct a continuity test.

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L. K. Comstock Engineering Company, Inc.

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CLEVELANo. oHlo 44101 - TELEPHONE (tie) 822 98C0 ILLUWNATING. s' o3 - 55 PUBLIC$ouARE P.o. sox S000

• Sening The Best Location in the Nation MURRAY R. EDELMAN April 15, 1983 wei mmstomer aucuan Mr. R. L. Spessard, Director Division of Enginaaring U.S. Nuclear Regulatory Commission, Region III 799 Roosavait Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441

• Responsa to I.E. Report Daar Mr. Spessard:

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

83-06; 50-441/83-06, attached to your letter dated March 16, 1983. This R., Naidu and report identifies areas examined by Messrs. P. A. Barrett, K. -

P. R. Pelka during their inspection conducted February 8-11, 1983.

Attached to this letter is our response to the three Violations described in the rafaranced Notice of Violation, dated March 16, 1983. This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practica", ~ ' * *

~

Part 2, Title 10, code of Federal Regulations.

Our response has been submitted to you within thirty days of the date of the Notica of Violation as you required. If there are additional questions, please do not hesitate to call.

Very truly yours, 7/7 'su -

M. R. Edelman Vice President Nuclear Croup MRE:pab Attachment cc: ' Mr. M. L. Cildner USNRC, Site Mr. C. E. Nore11us, Director Division of Projects and Resident Prograus

• U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Commission c/o Document Management 3 ranch -

Washington, D.C. 20555 ,

i RESPONSE TO ENTORCDfENT ITIMS l

I Below is our response to Appendix A. Notice of Violation, of United States l Nuclear Regulatory Commission I.E. Report 50-440/83-06; 50-441/83-06. 1

> Noncompliance I. (440/83-06-01: 441/83-06-01)  :

\

A. Severity Level IV Violation l

10CFR50, Appendix 3, Criterion II states, in part, "The quality assurance program shall provide control over activities.affecting the quality of the l identified structures, systems, and components, to an extent consistent with their importance to safety."

. CEI Corporate Nuclear Quality Assuranc,e Program, section ,0200, Revision 4 paragraph 1.1 states in part, "The progran provides for secomplishing activities affecting safety under suitably controlled conditions and in accordance with the program elements of procedures, instructions, speci-fications, and drawings." I Contrary to the above, the L. K. Comstock QA Program failed to provide control over deficiencias identified by an internal LKC doc' umentation task .

force, in that these deficiencies were addressed in uncontrolled review checklists and interusi LKC letters.

t E. Response

• . o.

1. Corrective Actions Taken and Results Achieved L. K. Comstock has written a QC Inspection Report for each of the concerns identified during the LKC Task Force document review. This will provide for status tracking of each concern until it is fully addressed and closed out.

As identified above, the LKC Task Force generated checklists for each .

document package as they performed their review to detail their comments.

These checklists have been procedurally addressed within the LKC QA -

program to ensure that each specific item is tracked and resolved prior to turnover.

Along with the contractor's actions, the Cleveland Electric Illuminating Co. (CEI) has developed a Special Project Plan in accordance with the requirements of our " Project Administration Procedures," that defines

- the actions necessary to resolve the task force issue.

As a part of this program, all of the " task force" concerna have been addressed on Project Organisation Surveillance Inspection Reports .

l (SIR's). This duplicates the LKC tracking of these items. The SIR's i are assigned to individuals within the Construction Quality Section.

l This enables CEI to monitor, provide follow-up, and ensure resolution 1 of each item.

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FIS'POSEIoEirUitm5fdrh ~

PAGE 2

2. Corrective Action Taken to Avoid Further Noncompliance In light of this NRC concern, the PNPP Nuclear Quality Assurance

~

Department Manager re-emphasized to L. K. Comstock by written memo-randum that all quality issues shall be processed in strict accordance with the Project approved LKC QA program. On a Projr.ct level, this message vos additionally directed to all site contractors performing safety-related activities at Perry. In addition the s NQAD Construction Quality section performed a review of all safety-related contractor's internal correspondence files to insure that quality issues were being processed in strict accordance with their QA programs. This review netted positive results.

In order to provide continuous monitoring of L. K. Comstock, a Project Organization QA representative has been assigned to L. K. Comstock on a full time basis. This individual will monitor all LKC inspection '

reports and provide a continuing review of documentation packages that are in process to ensure that the Task Force items are being properly [

addressed.

3. Data When Full Compliance Will Be Achieved

.The concerns and individual checklist items noted by the LKC task force have been addressed on QA program documents. Therefore, full compliance has been achieved.

' ~~**

Noncompliance II. (440/83-06-06: 441/83-06-06)

A. Severity Level V Violation 10CFR50, Appendix B, Criterion III, states in part, "The design contrcl measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews...parformed 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 of selected reviews and design control monitoring program. . . . These procedures shall assure. ..

" 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 eriteria."

' Contrary to the above, CEI failed to assure that Gilbert Associates Inc.

(GAI) adequately reviewed and verified that the requirements of Westinghouse Electrie Corporation drawing E-40048 for medium voltage penetrations and electrical specification SP-33 were adequately translated into the isometric drawings 1R-72-3 and 1R-72-4 prepared by Pullman Power Products. Specifically, '

drawings 1R-72-3 and 1R-72-4 were approved by GAI, without the consumable insert specified on drawing E-4004g and the backing ring specified in paragraph 5:08.1.4C of specification SP-33. Consequently, the medium voltage penetrations were welded in Unit 1 without the benefit of either a consumable insert or a backing ring. Furthermore, there was no assurance that this discrepancy would have been corrected during the installation of '

medium voltage penetrations in Unit 2.

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PAGE 3 4 . .

B. Response

1. Corrective Action Taken and Results Achieved L. K. Comstock issued Stop Work Notice i11 on the installation of the medium voltage penetrations. The discrepant velding conditions that exist on the Unit 1 medium voltage penetrations have been documented on Nonconformance Report LKC 1769 The nenconformance report has since been dispositioned, accepted, and verified.

2. Corrective Action Taken To Avoid Further Noncompliance The Construction Quality Section issued Observation Action Request

• #605 to Gilbert Associates for inadequately reviewing the Pullman

- Power Products isometrie drawings for the medium voltage penetrations.

• As a result, the Unit 2 penetration drawings will be revised to reflect tha specification requirements and GAI personnel have been alerted to assure that drawings are reviewed to the specification governing the work.

To ensure compliance, an owner hold point has been established on the welding of the Unit 2 medium voltage penetrations. . .

3. Date When Full Complianes Will Be Achieved Drawing revisions will be completed by May 20, 1983, and full compliance - -*

will then be achieved.

Noncompliance III. (440/83-06-03: 441/83_-06-03)

A. Severity Level IV Violation 10CyR50, Appendix 3, Criterion I 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 documented instructions, procedures, and drawings for accomplishing the activity."

CEI Corporate Nuclear Quality Assurance Program, Section 1000, Revision 3, paragraph 1.1 states in part, "A program for inspection shall be established by CEI to ensure that all safety-related components, systems, structures, and activities affactin~s those itsas meet the required quality standards."

' Contrary to the above, a program for the inspection of inyrocess fillet veld activities performed by L. K. Comstock Company had not been established or executed to verify conformance with standard AWS-DI.1 1975, Section 6.

B. Response

1. Corrective Action Taken and Resuits Achieved The immediate corrective action taken by L. K. Comstock was to issue Stop Work Notice #10 on all welding performed by LKC.

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FAGE 4 As a result, a program for the in-process fillet veld activities has '

now been established by the contractor. This was accomplished through a revision to their veld inspection procedure 4.8.18, paragraph 3.7.

To address the procedure deficiency concerning previous in-process inspections, the contractor initiated Nonconformance Report LKC 1788,

2. Corrective Action Taken to Avoid Further Noncompliance To prevent recurrence, training was conducted to the revised LKC Wald Inspection Procedure. The procedure currently reflects the in-process veld inspection as required by AWS D1.1-1975.

3. Data When Tull Compliance Will Be Achieved ,

• - . J Full compliance has been achieved.

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R E rf IV E D wo.2sio Perry Nuclear Power Plant '- 1 8

9 .s 12, g , (y . ,r1 3 1983 ACTION REQUEST f{.

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'd- AR , .5 6 7 , l Fila No. ,3,0l 1,1 0,312, Nih,bfkkhf!bhh[hhbb"'

Appendix 8 Responsible OBS Number OOO ,1 O. LKC

, , . Criteria No. Organization 3, 3, initiatzd By: 8#U U Govtrning Requirement:

- 8"

( Initials .

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SP 4549-00 RevisionIVdated4/12/82andassociatedspecification Issue Date ,Q2l 28 83, i changes required on 2/20/03 Attachment Sp-709-4549-oo:

1. j Section 1:05.2.1 which states in part: The lines of authority. (continued next sheet:

Observation: During a review of the equipment referenced in Nonconfomance Report I LKC 1797, it was determined that certified inspectors were performing parts of inspection i checklists. Although the checklists required a Level II of a specific certification to s sign and indicate final completion of the entire inspection checklist, portions of the l checklist were completed by "other inspectors" that in most cases were certified in other I crets.

' The "other inspectors" were qualified to perform these checklist items through othe]

certifications. This is not programmatically addressed and aDpears to have been the cause of confusion during the LKC Task Force review of documentation / records.

Potentially Reportable Per 10CFR21 or 50.55 e O Yes G No: DAR No. , , ,

Upgr:ded to CAR U Yes O No 1)

MMY '

f Recommendation: Define what inspector certification (sReviewed e for Significance By*M u inspection checklist items. 2)

Define the meaning of tile interim and final inspector signatures on the inspection checklists. 3) Procedurally address these two definitions.

4) Ensure that previous cases of this condition are identified and verify that all involved inspectors were certified or generate nonconformances or provide re-inspections.

Rgponse Due Date ,03/ 0,l/, 83,

// A /?

Inadequate procedural address. Acknowledged By: # C. /h J-/-nT Cause:

Response (include corrective action and steps to prevent recurrence)1_ A oc In=nection Matrix has been M,=4gned and in currenciv beine researched to ascertain which individual checklist nf nn, diccinlina enn he comnieted by a certified insoector of another discipline.

items Once enmn1.eed. reviaved and accented this Matrix vill be procedurally addressed within LKC Prncedure 4.1.4. 2. A checklist is designed to accomplish a procedurally addressed in=neccinn function. The checksheet is a listing of items that lead to a completed inspection function. Certified inspectors of other disciplines may complete specific items nf annehar diccinlinen checklist as described in the checklist matrix. This 4e== u411 individual

h. inicialed and dated on the ch ecklis t (Continued on third sheet)

! Completion Date . 0,3 ,3 ,1,8 .3 , Prepared by Larry G. Seese Response Prepared By:- -

Response Date O.310,/ l b Response Evaluation: Seco .i 444 m A . 4 % = . M 6 M.A., au. A/=2W 4--

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d.a.h 2A n 3/s1) AS.

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Evaluatkon: b Accept O Reject CAUSE CODE d Ev:Iuation By: YV N' I~ Evaluation Date: . O.317 // I 8. 3 ,

Verified By:

d Verification Date: , , l . I ,

Remarks:

ACTION REQUEST -

AR # 587 Governing Reouirement: (Continued) organizational structure, functional responsib311 ties, and duties shall be clearly established and delineated in writing." (uaGer score added for e=phasis)

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2. Section 1:05.10.3.d which states: "The personnel who are qualified to perform the inspections and tests, and to whom they report." -

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4 CORRECTIVE ACTION REQUEST #83-02 Sheet 3 of 3 ACTION REQUEST #587 item and will be defined as an interim inspection. The final inspector will be the certified inspector within the given discipline of the checklist who will evaluate each checklist item and by his signature assure that all items are complete.

These definitions will be incorporated within Procedure 4.1.4.

3.

LKCE Task Force Concerns have been procedurally addressed within LKC Procedure 4.11.1.

be addressed on an IR or NR as required.These items will be completely rev Reinspections will be performed if necessary.

4 Items I and 2 will be incorporated in LKC Procedure 4.1.4.

all inspectors will be trained to this revision. This will prevent Once procedurally addressed, recurrance.

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P.o. Box 97 m PERRY, OHIO 44081 m TEL EPHoN E (216) 259-3737 a ADoRESS.10 CENTER Ro AD Serving The Best location in the Nat{on PERRY NUCLEAR POWER PL. ANT March 24, 1983 PY-S/ CON 5964QA L. K. Comstock P. O. Box 324 Perry, Ohio 44081 Attention: Mr. Richard Bower RE: CAR # 83-02

Dear Mr. Bower:

I have evaluated the corrective action response provided for CAR # 83-02 and consider the response acceptable. However, until such time that 1) Project Organization has reviewed and approved the referenced matrix and 2) it can be demonstrated that the balance of the corrective action has been implemented, the following restriction shall be enforced.

In the strictest accordance with the L. K. Comstock QA Program, only those inspectors certified Level II and authorized for final sign-off completed checklists shall be permitted to complete items within the checklists.

Portions of .those checklists shall not be delegated to "others" uncertified for completion of the final sign off of the specific checklist.

If there are any questions do not hesitate to contact me.

Very truly yours,

=

f Vernon K. Higaki l Responsible Quality Engineer Construction Quality Section VKH:fl -

cc: J. Kerr J. Furness l E. Riley l CAR # 83-02 File PAQS l 300.204.2 1 303.033.2.1 D.Graneto

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. COMSTOCK

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N (.-; - PERRY NUCLEAR POWER PLANT Y

P.O Box 324 Perry CH 44081 seace 1904 (216) 259 3755 Comstoc< Engineering,lnc.

A CoMStoCK GROUP COMPANY Cleveland Electric Illuminating Company June 10, 1983 P.O. Box 97 Perry, Ohio 44081 AITENTION: VERNON HIGAKI QAE CONTROL NUMBER: Q 83-6-622

SUBJECT:

CAR 83-02

Dear Mr. Higaki,

L.K. Comstock Quality Control is requesting to change our response to CR 83-02 as follows:

1.) The QC inspection matrix as referenced in the orginal response will not be used or placed in LKC Procedure 4.1.4. LKCE Current inspection practices are, inspection reports and line items on the report will be signed only by inspector who are certified in the given area of certi-fication. Therefore, there will be no need to revise LKC Procedure 4.1.4 to include a QC inspection matrix.

2.) Disposition to LKC NR #1797 is currently being worked to by LKCE QC Personnel. Inspections of which a certified inspector performed part of a inspection checklist for a given area of certification which he was not certified in, even though he was certified to perform this same or similar type inspection in a area of certification for which he was certified in and being re-inspected or evaluated for area inspection if required by a certified inspector in that given area of certification.

3.) Delete Item #4 of the orginal response.

Sincerely, L

R.L. Bower

"*88#

CC: T. Woodman J. Kerr J. Furness E. Yockey g E C _IVED C. Hart JUN 1 3 1933 RLB/gh CQ5fELEC./EC STVN6TA

• CHICAGO

• NEW YORK e PITTSBURGH e SAN FRANCISCO

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e.o..eox 97 e rtaav, csio 44:ai a T El.CPHoNE 1:16) Et9 37 37 e ado RC CS-10 C EN T E R Ro AD Serving The Best location in the Nation PERRY NUCLEAR POV!ER PLANT June 21, 1983 PY-S/ con 6439 QA L. K. Comstock P. O. Box 324 Perry, Ohio 44081 Attention: Mr. R. Bower Re: CAR # 83-02 .

Dear Mr. Bower:

The revised response, dated June 10,1983, to CAR # 83-o2 has been reviewed and considered acceptable. Further, the CAR is considered verified and therefore closed out in total.

The reinspections to resolve Nonconformance Report # LKC 1797 will provide cdequate assurance that all previous inspections are satisfactorily addressed.

Very truly yours, Y w $.Y h Vernon K. Higaki Responsible quality Fr.gineer Constr etion Quality Section

$$$k James Furness Lead quality Engineer Construction quality Section JF:VKH:fl ec: E. Riley E. Sterle J. Kerr .

T. Stear R. Parker D. Graneto SO/DCC Construction Engineering 300.204.2 and 303.o33.2.5 ,

DAR # 118 File CAR # 83-o2 File

• BACK-UP DoCUIGNTATION To CIOSE CAF583-o'2

. o Construction (uality Section verified that the forms listed below are in compliance with the revised response to CAR //83-02 dated June lo,1983 Form 21 - Insulation Resistance Continuity Test Report Equipment Nu .ber - oP 9 Coo 2B OP49 Coo 2A Form 27 - Class lE Rotating Equipment Insulation Checklist Equipment Number - OP49 Coo 2B OP49 Coo 2A Form 32 - Class lE Equipment Installation Checklist Equipment Number - 2C61 Fool OR24So37 Form 39A - Material Receiving Report, Purchased by Utility Equipment Number - oP49 Coo 2B Form 39C - Cable Receiving Inspection Report .

Manufacturer's Reel Number (MR)- 24538 24539 Form 70 - Magnetic Particle Inspection Report Equipment Number - OR24So37 Form 82 - Conduit Installation Checklist Conduit Number - 1C54C32X lE51C157B

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Form 97 - Maintenance Verification Record Equipment Number - OR24So37 Form 99 - Hilti Kwik Bolt Installation Checklist Conduit Number - lE31T42B Form lo5A - Cable Pull Inspection Checklist Circuit Nu=ber - 1P45F5A Form lo5B - Prepull Walkdown Checklist Circuit Number - 1P45F5A Form 107 - Equipment Weld Documentation Record Equipment Number - OR24So37 Form 118 - Inspection Report Specific Inspection Report Numbers 4842 6248 6309 5484 6265 6310 5852 6301 6313 6068 6302 -

6314 6143 6303 6315 6168 6304 6317 61 % 6305 6318 6220 6306 6324

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