ML20079H217

Forwards Response to Const Appraisal Team Insp Repts 50-440/83-31 & 50-441/83-30 on 830822,0902 & 12-23.Drywell Wall Designed & Constructed to Maintain Leaktight Integrity for 40 Yrs

ML20079H217
Person / Time
Site:	Perry
Issue date:	12/23/1983
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8401230365
Download: ML20079H217 (12)

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. 4 P.O. Box 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG - 55 PUBLIC SQUARE Serving The Best Location in the Nation Decembe r 23, 1983 MURRAY R. EDELMAN VICE PRESIDENT NUCLEAR Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Koosevelt Road Glen Ellyn, Illinois 60137 P.E: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to Construction Appraisal Team I.E. Report Dear Mr. Keppler.

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

83-31; 50-441/83-30 issued to document the results of the Construction Appraisal Team Inspection. The inspection was conducted August 22 to September 2, and September 12 to 23, 1983. This letter is to inform you of the progress which the Perry Project Organization has made relative to address of the specific and general questions raised within the report.

The report identified four construction program areas to be strengthened in Appendix A, Executive Summary. While the report indicated that a response was not required at this time, attached to this letter you will find additional information to assist you during your evaluation of these items.

Our investigation of all concerns disclosed in this report is ongoing. After researching each item, our corrective action program is being invoked, if appropriate, both to remedy the problem and to track resolution status. Our future response will be based on direction from your office.

On behalf of the Perry Project Organization, I would like to express our appreciation for the thorough ef fort extended by the NRC personnel associated with the Construction Appraisal Team. The Perry Project has greatly benefited from this independent appraisal. An assessment of this nature which identifies program areas which we can strengthen allows us to improve our Program and aids us in the continuing ef fort to ensure the future safe and efficient operation of Perry.

If there are additional questions, please do not hesitate to call.

Very truly yours, 8401230365 831223 D /,

PDR ADOCK 050GO440 / N G PDR M. R. Ed Iman Vice President Nuclear Group ,

MRE:pab Attachment '

cc: Mr. M. L. Gildner U.S. Nuclear Regulatory Commission g USNRC, Site c/o Document Management Branch g Washington, D.C. 20555 d, Richard C. DeYoung, Director N Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission g Washington, D.C. 20555 g@y )

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RESPONSE TO APPENDIX A, " EXECUTIVE SUMMs. "

Additional Information is provided below to assist in the evaluation of the four Construction Program Weaknesses identified in I.E. Report 50-440/83-31; 50-441/83-30.

Statement 1 The current practice of installing concrete expansion anchor bolts in the drywell wall is a concern to the NRC CAT inspectors. The number of intended anchcr bolt Installations and the real potential for utacking of the drywell wall as a result of normal, transient, and accident loadings lead the NRC CAT to question the ability of the drywell to maintain the specified leaktightness throughout its service lifetime. The preoperational and periodic drywell bypass leakage tests are seen to be c rucial tests to assess and monitor drywell bypasa leakage from all sources.

Response 1 A. Background The drywell is a reinforced concrete structure using a 5,000 psi design strength concrete. The main reinforcement consists of No. 18 vertical rebars, spaced radially at a centric angle of 2 degrees, 30 minutes (approximately 18"), No.18 hoop rebars spaced vertically,12" center to center, and diagonal No.14 rebars inclined approximately 45 degrees to the vertical rebars and running in both directions. These rebars are provided on both faces of the cylinder and are spaced at 24 inches center to center. Around penetrations where reinforcement is terminated, an equivalent area of steel was replaced and distributed on each side of the opening. Also, although not required for strength, additional rebars were added diagonally around the penetrations in two directions on each face to control local cracking and strains. In general, for the 5 foot wall thickness, this reinforcement is not congested and no special concrete mixes or special construction procedures were required. In addition, concrete cover for the reinforcement was increased above the 1-1/2 inch ACI 318 minimum for the wall to 5-1/2 inches on the inside f ace and 4 inches on the outside face of the wall. The majority of the H11 tis being used are only being embedded 4-1/2" to minimize interferences with the rebar, which is at 5-1/2" clearance. The drilled anchors are much shallower than the numerons care-in-place embedments. Also, the load limits placed on the majority of the H11 tis have been very restrictive, approximately 250 lbs. tension and shear. Both the normal operating (135 deg. F inside drywell and 90 deg, outside) and the accident (250-330 deg. F inside drywell and 185 deg. F outside drywell) temperature gradients through the drywell tend to keep the inside of the drywell in compression, thus reducing a potential for crack initiation or propagation.

RESPONSE TO APPENDIX A STATEMENT 1

. PAGE 2 Although the GE topical report on drywell cracking, NEDO-10977, "Drywell Integrity Study: Investigation of Potential Cracking for BWR/6 Mark III Containment," dated August 1973 did not include consideration of construction defects such as construction joints or stress concentrations caused by penetrations, we feel the conclusions of the report are still valid, i.e.,

that no drywell liner is required to meet the intended leakage requirements of the drywell. Reinforcement provided in the Perry drywell is significantly more than that used in the CE topical report and will provide even greater crack control.

The drywell structural integrity test (SIT) at 30 psi, as well as the preoperational and periodic drywell bypass leakage tests, will adequately demonstrate the acceptability of the drywell to meet FSAR commitments on bypass leakage.

B. Corrective Action Upon completion of the drywell SIT, it will be demonstrated that the Ferry Proj ect is in full compliance with commitments and requirements. The Drywell Wall has been designed and constructed to nalntain its leaktight Integrity over its service lifetime (under normal, transient, and accident loading conditions) of 40 years.

RESPONSE TO APPENDIX A STATEMENT 2

. PAGE 3 Statement 2 A number of examples were identified where the QC inspection program and the "as-built" verification program for piping and pipe supports / restraints did not ensure that installed items conformed to design requirements. While many installations have progressed through the contractor's verification programs, the applicants verification program is in the early stages.

Response 2 A. Background Contractor procedural inadequacy allowed for potential submittal of incorrect as-built drawings. Additionally, Contractor Quality Control (QC) personnel were not utilized as fully as possible, thus circumventing the Identification of installed deficiencies prior to as-built drawings being submitted to the Project Organization.

B. Corrective Action Project Organization issued Action Request 726 to identify that the Pullman Power Products current as-built procedure lacked definite detail regarding individuals' responsibilities. It also noted that although the existing procedure requires each contractor as-built crew to consist of field engineering and QC inspectors, an evaluation of the as-built program indicated a lack of contractor QC involvement.

To improve the overall As-Built Program, a number of steps have been taken:

1) Project Organization has issued a Program Revision Notice to Project Administration Procedure PA-0303 to better define the QA verification of as-built drawings.

2) Project Organization conducted an audit of the Preparation and Review of Pullman Power Products As-Builts. The audit resulted in the issuence of three Action Requests against Pullman Power Products and one against Project Organization. Additional audits of other contractor As-Built Programs will be conducted as programs are finalized.

3) Project Organization has initiated an instruction, 35-0303, whJch identifies responsibilities and criteria for reviewing contractor prepared as-built drawings.

4) Engineering Change Notice (ECN) 7501-44-732, Rey, D, is being issued to Pullman Power Products to further clarify and detail the requirements for submittal of as-built Info rma tion.

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RESPONSE TO APPENDIX A

- STATEMENT 2

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5) Engineering Change Notice 17391-44-5724 la being issued to Pullman Power Products to require verification of valve orientation and directional flow at fit up.

6) . Upon receipt of the above-mentioned ECNs, Pullman Power Products will revise the applicable procedures to detall and more clearly define individual duties. It is anticipated that all their necessary proce-dure revisions will be' completed by January 31, 1984.

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t RESPONSE TO APPENDIX A p STATEMENT 3

, PAGE 3 Statement 3 The welder qualification program for two contractors needs attention to ensure welder qualifications are properly performed. Better controls to ensure welder identification should also be utilized. The NRC CAT found few hardware deficiencies in the welding area, and in general, the in-process and completed welds reviewed exhibited good workmanship. The one exception was in the small bore piping area as discussed in the details section of this report.

Response 3 A.- Background This statement consists of two parts which will be treated separately.

1) In regard to the first part which states, "The welder qualification program for two contractors needs attention to ensure welder qualifications are properly performed. Better controls to ensure welder identification should also be utilized.", it has been determined that:

a) The General Electric A&ESO Nondestructive Examination (NDE) sub-contractor was not performing welder qualification radiography in accordance with proper technique. 3 b) A Pullman Power Products procedure did not adequately address ASME Section IX requirements and the use of reader and technique sheets in the crea of welder qualification by radiographs.

2) In regard to the second part which states, "...the in-process and completed welds reviewed exhibited good workmanship. The one exception was in the small bore piping area as discussed in the details section of this report.",

a) Pullman Power Products procedures did not adequately address minimun specified fillet size for branch connections, b) The Construction Appraisal Team inspectors documented concerns involving field welded branch connections, field welding of stainless steel socket welds and potential minimum wall violations on small bore shop welds fabricated by Pullman Power Products, Williamsport, PA.

B. Corrective Action

1) Relative to welder qualification:

a) Project organization issued 5 Action Requests to CE A&ESO. In addition, GE issued Nonconformance Report GE38-731 and Corrective Action Request 004 against their own organization to ensure their subcontracted NDE service group implemented proper procedures for l comparing sensitivity of film versus source side penetrameters during welder qualification. The subcontracted NDE group immediately

RESPONSE TO APPENDIX A STATD(ENT 3

. PAGE 6 retrained personnel to assure that radiography will be performed with the penetrameter on the proper side in accordance with the procedure. The coupon thickness will be verified at time of welding by the velding supervisor and/or the CE QC inspector prior to the qualification process.

b) In response to CQS Observation Action Request 731 concerning wrong side placement of penetrameters and lack of reader or technique sheets, Pullman Power revised Procedure IX-RT-5 to require the use of " Radiographic Inspection Reports" during interpretation of welder coupons. Additionally, the procedure revision clarlfles l proper penetrameter placement. I c) All personnel employed at the PNPI' are now being issued photo identification badges by the Project Organization. The badge will include the individual's name, signature and social security number. This photo identification badge will be used as a method of welder identification prior to qualification. All test coupons will be uniquely identified during qualification welding and subsequent examination.

2) Relative to the issues raised in the report concerning small hore pipe welding:

l l a) Nonconformance Reports (NR) CQS 2916 and CQS 2917 were issued to identify the two occurrences of insuf ficient reinforcing fillet on field welded branch connections identified by the Construction

Appraisal Team Inspector. These NRs have been dispositioned by l Engineering in accordance with the requirements of ASME Section III.

l In addition, the Construction Quality Section inspected other i existing branch connections and found no Instances of Insufficient reinforcement. Pullman Power Products is revising their Geneal Welding Standard to address section NX-4244 of ASME Section III l concerning retnforcement of branch connection welds.

l b) Relative to the welding of stainless steel socket welds, Project Organitation has reviewed the heat input as defined in Pullman Power Products Procedure WPS-29 in relation to ASME Code require-ments and has determined that it is in full compliance with the Code. In addition, destructive testing of actual samples has f determined that the actual application of the WPS cn our piping samples resulted in no detrimental effect on the joint. The actual test reports and survey are available for review.

RESPONSE TO APPENDIX A STATEMENT 3

- PAGE 7 For the problems identified with the small bore piping shop welds concerning lack of compliance for weld quality and minimum wall violations, these deficiencies were documented on NR TAS 0057 which is now resolved. Upon identification of these problems, the Project Organization NDE group along with the NRC reviewed a larger sample of 69 Class 1 and Class 2 s -11 bore piping radiographs supplied by Pullman Power Products, Williansport, PA, and found all of the radiographs to be acceptable. In addition, the Gilbert Associates Incorporated Individual involved with the manuf acturing surveillance at the Pullman Power Products shop has been notifled of the problems identified during the Construction Appraisal Team Inspection and has been instructed to closely monitor future small bore piping work for these types of deficiencies.

RESPONSE TO APPENDIX A STATEMENT 4

. PAGE 8 Statement 4 A number of examples were found where corrective actions related to contractor identified problems were not taken in a timely manner and where nonconformances were closed out prior to completing all of the required corrective actions.

Examples where timely, corrective actions were not taken include undersized welds on HVAC supports, "as-built" program deficiencies, improper valve actuator installations, and reverifications for required material traceability.

Examples of improperly closed-out nonconformances include problens involving training for concrete placement crews and a failure to submit a required FSAR amendment.

Response 4 A. Background This statement consists of two parts which will be treated separately.

1) In regard to the first part which states "A number of examples were found where corrective actions related to contractor identified problems were not taken in a timely manner", we concur with the Inspector's obse rva tion. However, a number of f acts should be recognized regarding some of the examples ac we regard resolution of these items as being ongoing:

a) In regard to the example of undersized welds on HVAC supports, it should be noted, both CEI and Robert Irsay Company had Identified the problem and were taking steps to correct the deficiencies; however, both CEI and Robert Irsay Company did not properly document these deficiencies in the installed HVAC hardware as required by the QA Program. Robert Irsay Company QC Identified this problem in an internal memorandum on June 8, 1982, to the Robert Irsay Company QA Manager. A subsequent Investigation revealed the inadequate velds could be traced to inspecticns performed by one individual who was on site from May 1979 through June 1980. As a result, Robert Iraay Company instituted a reinspection program whereby they are reviewing all weld inspections by system. Those welds initially inspected by this individual are being reinspected and Nonconformance Reports (NR) are being initiated where applicable.

This reinspection began in May 1982 and was continuing at the time of this NRC inspection.

b) In regard to the example of as-built program deficiencies, it should be noted that a large percentage of as-builts reviewed during this NRC inspection were early as-builts issued prior to July 1982. Since the submittal of these early as-builts, a number of steps were taken prior to the Construction Appraisal Team inspec-tion to upgrade the Pullman Power Products as-built program.

Project Organization issued specification revisions via Engineering Change Notices (ECN) 7501-44-732 and 6782-45-303 on 8/23/82, which

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RESPONSE TO APPENDIX A STATEMENT 4

. PACE 9 clarified and detailed the requirements for submitting as-hu11ts.

They also required that Pullman Power Products generate an as-built procedure which was approved on 9/27/82. Since that time,

further revisions to the ECNs were written to upgrade the program and Pullman Power Products is in the process of revising their procedures.

3 c) In regard to the example of improper valve actuator installation, r it should be noted that numerous steps have been and are being taken to resolve this problem. In the summer of 1982, a spare parts survey of Limitorque nameplate data was performed. The s survey identified over 100 valves containing potential problems

[ with valve actuator model numbers. On July 29, 1982, CEI instructed C11bert Associates Incorporated (CAI) to Investigate this problem in letter PY-CEI/GAI 5305. CAI responded to this letter on October 1, 1982, in PY-CAI/CEI 13050 stating they would contact Borg-Warner to resolve problems associated with actuator model numbers. Borg-Warner responded to the CAI inquiry on February 18, 1983, stating

thct they "will revise and resubmit the drawings to agree with the stress reports. At the same time, the valve operators used on g motor-operated valves will be reviewed and revised as necessary."

Subsequently, drawings were revised and transmitted to the Project Organiza t ion. A comparison of model numbers in the specification

versus the model numbers in the qualification documents is scheduled i to be completed by the end of 1983. From this comparison, specifications f will be revised as necessary by March 15, 1984.

In addition to this action, CEI initiated a three-phase Limitorque program on November 26, 1982, to address nuuerous industry concerns

? over Limitorque actuators as identified in reports such as IE f Bulletins. Phase I of the program involved an inspection of every safety-related (Unit I and Common) Limitorque actuator by qualified Quality Assurance inspectors. Special Project Procedure 1001 was

[ utilized in performing this task. Phase I was initiated in g February 1983 and completed in April 1983. Phase II of the Limitorque rework program involved assembly of all of the inspec-tion data and conp11ation of procedures to perform all relubri-F cation, rework, or replacement of parts. This effort was completed r September 30, 1983. We are presently in Phase III of the program

? which is the actual rework of Limitorque operators in accordance with approved procedures.

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3 Finally, CEI has Instructed CAI to address the Construction I Appraisal Team inspector's concerns regarding their Manuf acturing

Surveillance Plan program. As a result, CAI has issued a letter to all inspectors cautioning them "to make sure that inf o rma tion contained on assembly drawings and reflected in the equipment r specifications are consistent." By verifying consistency of these

- documents, we can avoid a repetition of this situation.

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RESPONSE TO APPENDIX A STATEMENT 4

. PACE 10 d) In regard to the example of reverification for required material traceability, we would like to point out that this problem was identified during Audit Number 768, which was completed on 12/30/82.

As a result, Nonconformance Reports GE-38-522 and GE-38-0523 were issued requiring reverification and recording of material identification for parts of the hangers. This reverification and identification is continuing during final installation of the hangers under the monitoring of the Construction Quality Section.

2) In regard to the second part which states "Nonconformances were closed out prior to completing all of the required corrective actions, we concur with the inspector's observation. However, we feel these are isolated incidents in tF-+ over 300 Nonconformance Reports were reviewed by the Construction Appraisal Team inspectors and only three program violations were noted. Therefore, for the purpose of this reply, they will be treated separately, a) In regard to the matter of a Nonconformance Report being closed out prior to completing training of concrete placement crews, Nonconformance Report DICK-216 was inadvertently closed out on 9/14/83. When it was realized that the Nonconformance Report was closed prior to training being performed, training was conducted on 9/21/83. However, the training records were inadvertently attached to Nonconformance Report DICK-214 which was written against the same concrete placement. As a result, when reviewing Nonconformance Report DICK-216, it appeared that training was never performed, when in fact it was completed one week later.

Action Request 718 was issued to the contractor on October 7, 1983. The Action Request reiterated the concern about premature close-out of Nonconformance Report DICK-216. Since training was completed and there has been no further evidence of this problem on subsequent placements, no further training is required. However, the documentation has been revised and a closer review of Nonconformance Report dispositions prior to close-out will be taken.

b) In regard to the matter of a Nonconformance Report being closed out prior to submitting a required FSAR amendment, Nonconformance Report CQA136 was closed on 1/22/82. The Nonconformance Report

required that an FSAR amendment be issued to identify those cases where Code Case N-242 vas utilized. Engineering issued a meno to Licensing identifying a list of items qualified using the Code Case and requesting an amendment to the Safety Analysis Report on September 14, 1981. The Nonconformance Report was closed out based upon this memo. However, the Quality Engineer was not made aware of the fact that Licensing had requested additional informa-tion from General Electric prior to initiating the acendment. The information from General Electric is still pending.

Nonconformcnce Report TAS 073 was initiated to document and track r the premature close-out of Nonconformance Report CQA136.

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RESPONSE TO APPENDIX A STATEMENT 4

. PAGE 11 c) In regard to Nonconformance Report's GE-38-522 (P0 38-1425) and GE-38-523 (PO 38-1425) which were closed on 7/14/83 and 7/12/83, respectively, the disposition to these Nonconformance Reports contained multiple corrective action steps and underwent numercus revisions, each of which related back to the previous revision.

This condition created confusion to the Quality Engineer who inadvertently closed out the Nonconformance Report prior to one of the steps being completed.

Project Organization directed General Electric to issue a Non-conformance Report to complete the recording of the material markings that were omitted during the disposition verification of C"-38-522 and GE-38-523. Nonconformance Report GE-38-0708 was issued on 9/6/83. The Nonconformance Report requires completion of material identification and recording of material workings for the Main Steam Reactor Recirculation hangers.

B. Corrective Action To prevent further untimely close-out of corrective action documents, the Construction Quality Section will increase monitoring of the contractors' corrective action close-out by January 30, 1984. Any corrective action steps which are, in the opinion of the Lead Quality Engineer, excessively delinquent will be escalated to appropriate levels of management.

In order to prevent further close-out of Nonconformance Reports prior to completion of all corrective action, a Program Revision Notice has been initiated which cautions QA personnel to ensure all corrective action is completed prior to close-out of any Nonconformance Report. In additlen, the Program Revision Notice will instruct personnel revising the disposition of a Nonconformance Report to include all steps in the latest revision and avoid referencing previous revisions.