ML20080B729
| ML20080B729 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/22/1984 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20080B721 | List: |
| References | |
| NUDOCS 8402070250 | |
| Download: ML20080B729 (25) | |
Text
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4 P O. Box 5000 - CLEVELAND, oHlo 44101 - TELEPHONE (216) 622-9300 - lLLUMINATING BLOG - 55 PUBLIC SQtIARE Serving The Best Location in the Nation MURRAY R. EDEUAAN January 22, 1984 VICE NESIDENT NUCM A P Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regula tory Commission 799 Roosevelt Road Glen Ellyn, I111nois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to Construction Appraisal Team I.E. Report
Dear Mr. Keppler:
, y This letter is to acknot. ledge receipt of the Notice of Violation attached to Mr. More11us' le tter dated December 23, 1983. This Notice resulted from the review conducted by your office of Construction Appraisal Team IE Report 50-440/83-31; 50-441/83-30 which discusses their review of activities at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated Decem13r 23, 1983.
This response is in accordance with the provisions of Section 2.201 Of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Information concerning the four construction program areas to be strengthened was previously forwarded to you in my letter dated December 23, 1983.
This response has been submitted to you within thirty days of the date of the Notice of Violation as you required. If there are additional questions, please do not hesitate to call.
Very truly yours, bL M. R. Ede.an s
Vice President Nuclear Group MRE:pab Attachment cc:
Mr. M. L. Gildner Mr. R. L. Spessard, Director USNRC, Site Division of Engineering U.S. Nuclear Regulatory Commission, Mr. Richard C. DeYoung, Director Region III Office of Inspection and Enforcement 799 Roosevelt Road U.S. Nuclear Regulatory Commission Glen Ellyn, Illinois 60137 Washington, D.C.
20555 U.S. Nuclear Regulatory Commission f
Mr. C. E. Norelius, Director c/o Document Management Branch Divialon of Project and Resident Programs Washington, D.C.
20555 U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 8402070250 840203 g () \\
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RESPONSE TO ENFORCEMENT ITDIS Below is our response to the Notice of Violation appended to United States Nuclear Regulatory Commission I.E. Report 50-441/83-31; 50-441/83-30.
I.
Noncompliance 50-440/83-31-(01); 50-441/83-30-(01)
A.
Severity Level IV Viola tion 10CFR50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures, or drawings."
a.
PNPP FSAR Section 8.3.1.4.1.4, states in part, "... cable trays of different divisions have a minimum horizontal separation of three feet when there is no physical barrier betwaen trays. Where hori-zontal separation of three feet is unattainable, the trays will be separated by fire resistant materials...In cases where trays must be stacked one above another, a minimun separation of five feet is maintained. Where vertical separation cannot be maintained, the trays will be separated by fire resistant materials."
Contrary to the above, the Inspectors observed cable tray segments which did not maintain the required separation between divisions.
The inspectors observed that the inspection checklist, line item 11, separation criteria acceptable, had been initialed by the QC inspector, b.
PNPP FSAR Section 8.3.1.4.1.1, states in part, "... electrical equipment and wiring for Class 1E electrical systems are segregated into separate independent divisions...such that no single credible event is capable of disabling suf ficient equipment to prevent reactor shutdown... division separation requirements apply to equipment and wiring systems concerned."
Contrary to the above, in the PGCC ductway of the Unit 2 Control Room, the inspectors observed that many cable separation violations existed.
Cables of one division were installed in physical contact with those of another division. Additionally, the inspectors found no formal procedures for installation and inspection of barriers.
B.
Response
1.
Item 1.a.
a.
Corrective Action Taken and Results Achieved The Contractor's inspectors were Indicating on checklist line item 11 that separation criteria were acceptable based upon field verification that separation of the raceway was in accordance with the installation drawing. The Installation drawings indicated that barriers were to be installed af ter the cables had been pulled.
l Barrier installation is considered to be a separate construction activity and requires its own inspection program.
Inspection /
installatloa criteria for the barrier installation were under development by Project Engineering prior to this inspection.
Observation Action Request 692 was issued to the Contractor to reiterate the concern about accuracy of the inspection records.
The corrective actions included the stamping of all raceway inspection records with a qualifying statement to indicate that barrier installation has not yet been verified.
Procedural revisions were also made to ensure that future records would accurately reflect the status of the raceway inspection. All these actions were completed by September 16, 1983.
This was verified by Construction Quality Section and the Action Request was closed, b.
Corrective Action To Avoid Further Noncompliance Implementation of the procedural revisions made in response to Action Request 692 will ensure that future inspection records accurately reflect the status of raceway inspection.
c.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
2.
Item 1.5.
a.
Corrective Action Taken And Results Achieved l
Cable separation violations exist in the Unit 2 Control Room due to the absence of floor duct covers. The duct covers were to be shipped installed in the ductways; however, Project Engineering chose to install the duct covers at a later date to aid in the Installation of cables in the ductways. Upon placement of the duct covers in their designed locations, separation violations will not exist.
Quality Control personnel presence is required by procedure throughout the entire installetion of duct covers in the Power Generation Control Complex.
Acceptance / rejection criteria are provided in several separate d ocument s.
It was not foreseen that duct cover installation may require unique considerations and specific procedural address.
Observation Action Request 720 was issued to the Contractor addressing concerns raised during the NRC inspection. Noncon-f f ormance Report P033-2243 was issued in conjunction with AR 720 on the duct cover Installation which took place during the NRC inspection.
The Licensee has placed a mandatory hold point on future Installa-tion of floor duct covers in the PGCC.
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b.
Corrective Action To Avold Further Noncompliance The Contractor's Procedure 4.3.30 shall be reviewed and revised as necessary to include additional directions for the installation of the floor duct covers.
This includes appropriate inspection criteria. The revision will be based upon an evaluation by the Licensee's Engineering element.
Training shall be provided to both the Contractor's construction crew and inspectors regarding the requirements of a hold point and specifically their applicability to duct cover Installation.
Action Request 720 shall remain open until an acceptable procedure revision has been developed and approved by the Licensee.
c.
Date When Full Compliance Will Be Achieved The Engineering evaluation of the existing procedure and the resulting revision will be completed by February 29, 1984..
II.
Noncompliance 50-440/83-31-(02); 50-441/83-30-(02)
A.
Severity Level V Violation 10CFR50, Appendix B, Criterion VI, states in part, " Measures shall be established to control issuance of documents, such as instructions, y
procedures, and drawings, including changes thereto, which prescribe all activities affecting quality."
PNPP CNQAP, Section 0600, Paragraph 1.1, states in part, " Procedures shall be established and utilized to control those documents which specify, describe or evidence activities affecting the quality of the Perry Nuclear Power Plant."
Contrary to the above, raceway sketches used to perform Installation of conduit and conduit supports in the Unit I containment drywell area lacked appropriate procedural control for items such as issuance, revision, retrieval and approval.
Inspection records generated for in-process inspections performed in accordance with these sketches did not contain the applicable sketch revisions.
B.
Response
1.
Corrective Action Taken And Results Achieved In-Process Audit 868 was initiated in July 1983 and concluded on August 11, 1983 Both the Conduit Detail Group and the Contractor were cited as a result of this audit for the conditions disclosed above. Resolution of these concerns was in progress at the tLme of the Construction Appraisal Team inspection.
The Observation Action Request 683 issued to the Conduit Detalling Group as a result of this audit has been closed.
This was based upon completion of procedural revisions to address design change concrol and issuance and control of sketches.
In response to Audit Action Request 868-02, the Contractor has committed to research his inspection records and note the applicable sketch revision number for the completed inspections. Additionally, the Contractor has developed procedure revisions to clarify responsi-bility and control of raceway sketches.
The revised procedure defines the interface of the contractor with respect to the Conduit Detalling Group.
2.
Corrective Action To Avold Further Noncompliance The procedural revisions required as part of the corrective action measures in response to the findings from Audit 868 will provide a method to control the conduit sketches. - _ _ - - _ _
3.
Date When Full Compliance Will Be Achieved Procedure revisions for both the Conduit Detailing Group and the Contractor were comple ted as of December 1,1983. An audit of the Contractor to ensure adherence to the revised procedure will be completed by January 30, 1984. Research of Contractor documentation to ensure past records include the applicable sketch revisions will be completed by March 9,1984.
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III. Noncompliance 50-440/81-31-(03); 50-441/83-30-(03)
A.
Severity Level IV Violation 10CFR50, Appendix B, Criterion X, states in part, "A program for Inspection of activities af fecting 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 accomp1.f shing the activity."
PNPP CNQAP, Section 1000, Paragraph 1.1, states in part, "A program for inspection shall be established by CEI to ensure that all safety-related components, sys tems, structures, and activities affecting those items meet required quality standards."
Contrary to the above, seismic pipe supports / restraints have, in some cases, not been ccnstructed and inspected in accordance with design requirements. In addition, the licensee's as-built verification program for safety-related valves, valve operators and pipe supports / restraints have, in some cases, failed to identify discrepancies between installed items and design drawings.
B.
Response
1.
Corrective Action Taken And Results Achieved Each unacceptable condition Identified by the Construction Appraisal Team was documented as required by the applicable nonconformance procedure.
All resultant Nonconformance Reports and Deficiency Reports (nonsafety) have now been dispositioned in accordance with the governing requirements.
The Seismic Clearance Violations will be dispositioned by January 31, 1984.
Prior to close-out of subject Nonconformance Reports, retraining of the Pullman Power Products' (PPP) inspection personnel involved in accepting nonconforming supports / restraints will be conducted.
Additionally, Construction Quality Section inspection personnel have instituted a mandatory hold point on all PPP Phase II hanger inspec-tions to ensure that the completed hanger is acceptable. This hold point will remain in ef fect until an acceptable level of confidence is achieved.
2.
Corrective Action To Avold Further Noncompliance Project Organization issued Observation Action Request 726 to identify that the current PPP as-built procedure lacked definite detail regarding l
Individuals' responsib111tles.
It also noted that although the existing procedure requires each contractor as-built crew to consist of field engineering and QC Inspectors, an es.iluation of the as-built program Indicated a lack of contractor QC involvement.
In response, PPP will revise the controlling procedure. At the present time, l
contractor QC sign-of f is required for each as-buil t being prepared by PPP.
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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 Audit 935 of the preparation and review of PPP as-builts. The audit resulted in the issuance of three Action Requests against PPP and one against Project Organi-zation. Additional audits of other contractor as-built programs will be conducted as programs are finalized.
- 3) Project Organization has initlated an Instruction, 35-0303, which identifies responsibilities and criteria for reviewing contractor prepared as-built drawings.
- 4) Engineering Change Notice (ECN) 7501-44-732, Rev. D, was issued to PPP to further clarify and detall the requirements for submittal of as-built inf o rma t ion.
- 5) Engineering Change Notice 17391-44-5724 was issued to PPP to require verification of valve orientation and directional flow at fit-up.
3.
Date When Full Compliance Will Be Achieved Upon receipt of the above mentioned ECNs, Pullman Power Products will complete revisions to the applicable procedures to detail and more clearly define individual duties.
It is anticipated that all thelt necessary procedure revisions will be completed by March 9,1984, i
The Project Organization Instruction 35-0303 will also be issued by this date.
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q' IV; Noncompliance 50-440/83-31-(04); 50-441/83-30-(04)
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Severity -Level V Violation
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10CFR50, Appendix B, Criterion XVI, states-In part, " Measures shall be
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d established to assure that conditions adverse to quality, such as failures, malfunctions, defieleacles, deviations, defective material and equipment, l
and nonconformances are promptly identified and corrected."
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'i PNPP CNQAP, Section 1600,' Paragraph 1.1, states in part, " Measures shallf be established which ensure that conditions adverse to quality, such as' f ailures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconfermances be promptly identified and corrected."
Contrary to the above, the licensee's heating, ventilating, and air conditioning (HVAC) contractor's corrective action programs failed to promptly identify, evaluate and' correct recurring deficiencies in installed and QC accepted RVAC duct supports.
In addition, the licensee identified purchased equipment that does not meet FSAR commitments and did not initiate timely corrective action to resolve those identified problems.
s B.
Response
This noncompliance consists of two parts which are answered separately below.
1.
Relative to the HVAC contractor's corrective action program:
(f a) Corrective Action Taken And Results Achieved
,In response to the NRC Inspectors concern, Observation Action Request 702 was written by the Construction Quality Section to I
ensure that the contractor would initiate nonconformance reports
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Y to identify unacceptable welds and perform a complete reinspection of, welds that had been accepted by their inspector in question.
Robert 'Irsay Company (RICO) has completed their reinspection of i i vork previously inspected and accepted by the Individual in-questEcn. All areas were reinspected 100% except 620' Control y
Complex. At this Iceation, the detcil on Dra.1ng's D-936-764 and
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(,3 765 calling for the welding of gusset plates to existing building wide flange beams was reinspected in 14% of the installations (5 of 36 supports).
This sample reinspection revealed no discrepancies and was determined to be adequate verification of the accept-ability; of the welding and initial inspections.
Overall, 55 Nonconformance Reports covering 189 hangers (45 NRs on 73 hangers prio,r_ito this NRC inspection and 10 NRs on 116 hangers af ter this
.NRC insp'ection) were written.
Currently 7 NRs are still open.
RICO expects to complete rework / repair by February 29, 1984.
Additionally, in response to Observation Action Request 702, the
-contractor has attested to the fact that noncompliances have been y
~,H innd will be documented in accordance with the applicable procedure.
The contractor has also retrained QC personnel on use of fillet gauges to determine proper weld profile and fillet sizes.
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b) Corrective Action To Avold Further Noncompliance The inspector in question is no longer associated with RICO.
Several steps have been taken to identify and properly address recurring deficiencies. To provide assurance that the condition cited above was an isolated occurrence, Audit 942 was conducted December 20, 1983, to evaluate RICO's Corrective Action Progran.
Results indicated the program to be adequate and effective. No Action Requests were issued.
In addition to the ongoing 100% review of Construction Quality Section Surveillance / Inspection reports, the Construction Quality Section Quality Engineer is now performing a monthly detailed trend analysis of contractor Nonconforcance Reports.
c) Date When Full Compliance Will Be Achieved Full compliance including weld reinspection, training of QC inspectors and procedure review has been completed. Actual rework / repair per Nonconformance Reports issued will be completed by February 29, 1984.
2.
Relative to equipment which did not meet FSAR commitments:
a) Corrective Action Taken And Results Achieved The following is provide.d for each equipment item identified in the Construction Appraisal Team report:
- 1) Valve E51-F063: Gilbert Associates is currently evaluating the disparity identified. Changes required based upon this evaluation will be made to the appropriate documents in accordance with our procedures.
It is presently anticipated that all required actions will be completed by April 30, 1984.
- 2) Valve E51-F022: FSAR change request 84 was initiated. This change request was approved for incorporation in an FSAR amendment on January 17, 1984.
- 3) Pump E12-C002: FSAR change request 51 was initiated. This change request was approved for incorporation in an FSAR amendment en January 5, 1984.
- 4) RCIC Turbine E51-C002:
Confirmation has been received from General Electric that serial number observed in the field conforms to procurement requirements.
- 5) Valve actuator Installation - 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 p erfo rmed.
The survey identified over 100 valves containing potential problems with valve actuator model numbers. On
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i July 29, 1982, CEI instructed Gilbert Associates Incorporated (GAI) to investigate this problen in letter PY-CEI/GAI 5305.
i GAI responded to this letter on October 1,1982, in PY-GAI/CEI 13050 stating they would contact BorgaWarner to l
resolve problems associated with actuator model numbers.
BorgaWarner responded to the GAI inquiry on February 18, 1983, stating that they "will revise and resubmit the drawings to agree with the stress reports. At the same time, the valve operators used on motor-operated valves will be reviewed I
and revised as necessary." Subsequently, drawings were revised and transmitted to the Project Organization. A comparison of model numbers in the specification versus the model numbers in the qualification documents has been com-pleted.
From this comparison, specifications will be revised as necessary by March 15, 1984.
Additionally, CEI has instructed GAI to address the Construction i
Appraisal Team inspector's concerns regarding their Manufacturing Surveillance Plan program. As a result, GAI has issued a letter to all inspectors cautioning them "to make sure that information contained on assembly drawings and reflected in the equipment specifications are consistent." By verifying consistency of these documents, we can avoid a repetition of this situation.
I b) Corrective Action To Avoid Further Noncompliance Project Administration Procedure PA 1603 has been initiated to provide the mechanism to prepare changes to the FSAR based on review of ongoing changes to design generated during construction, testing, and operational activities of the plant. PA 1603 will be issued effective by February 10, 1984.
u c) Date When Full Compliance Will Be Achieved i
f Full compliance will be achieved by April 30, 1984.
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V.
Noncompliance 50-440/83-31-(05); 50-441/83-30-(05)
A.
Severity Level IV Violation 10CFR50, Appendix B, Criterion LM, states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by quallfled personnel using qua11 fled procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.
PNPP CNQAM, Section 0900, Paragraph 1.2, states in part, "CEI procurement documents shall require contractors and vendors to establish measures that ensure control of special processes.
Procurement specifications shall require that special processes will be accomplished under controlled conditions and...that appropriate provisions in the following codes, s tandards, recommended guides, and engineering requirements are met...
ASME and/or AWS codes."
Contrary to the above:
Welding inspections performed for AWS welds in structural steel and a.
HVAC applications were found to be deficient with respect to specific requirements stated in the AWS D1.1 Structural Welding Code, b.
Fabrication requirements for field installed branch connection weld-o-lets, and measures to control the welding of stainless steel socket welds, were found to be deficient with respect to specific ASME Boller and Pressure Vessel Code requirements.
Several examples were observed in the area of welder qualification by c.
radiography where radiographs did not conform to appropriate quality standards.
B.
Response
1.
Item a.
Relative to the portion of this item which concerns structural steel erection, the following actions were taken:
a) Corrective Action Taken And Results Achieved Our contractor, PBI Industries (PBI), initiated Corrective Action Notice (CAN) 8-83-1 to their subcontractor Kelley Steel and Nonconformance Report (NR) PBI-981. The eight welds cited in the Construction Appraisal Team report were repaired per the Fon-conformance Report.
The previous inspections of their inspector in question were re-examined as required by CAN 8-83-1 and reworked as required. The NR and CAN were subsequently disposi-tioned and closed. -
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b) Corrective Action To Avoid Further Noncompliance The inspector in question is no longer associated with PBI.
The Kelley Steel Quality Manager advised all inspectors of the necessity to follow all codes and specifications and informed them of the consequences, c) Date When Full Cynp11ance Will Be Achieved Full compliance to program requirements was achieved on September 20, 1983.
Relative to the portion of this item which concerns HVAC applications, the following actions were taken:
a) Corrective Action Taken And Results Achieved In response to the NRC inspectors concern, Observation Action Request 702 was written by the Construction Quality Section (CQS) to ensure that the contractor would initiate nonconformance reports to identify unacceptable welds and perform a complete reinspection of welds that had been accepted by their inspector in question.
Robert Irsay Company has completed their reinspection of work previously inspected and accepted by the individual in question. All areas were reinspected 100% except 620' Control Complex. At this location, the detall on Drawings D-936-764 and 765 calling for the welding of gusset plates to existing building wide flange beams was reinspected in 14% of the installations (5 of 36 supports).
This sample reinspection revealed no discrepancies and was determined to be adequate verification of the acceptability of the welding and initial inspections.
Overall, 55 Nonconformance Reports covering 189 hangers (45 NRs on 73 hangers prior to this NRC inspection and 10 NRs on 116 hangers af ter this NRC inspection) were written. Currently 7 NRs are still open. RICO expects to complete rework / repair by February 29, 1984.
b) Corrective Action To Avoid Further Noncompliance The inspector in question is no longer associated with RICO.
In response to Observation Action Request 702, the Contractor has also retrained QC personnel on use of fillet gauges to determine proper weld profile and fillet sizes.
Other measures being taken to identify and properly address recurring deficiencies include an ongoing 100% review of CQS Surveillance / Inspection reports and performance of a monthly detailed trend analysis of RICO Nonconformance Reports, both performed by the CQS Quality Engineer..
c) Date When Full Compliance Will Be Achieved Full compliance including weld reinspection, training of QC Inspectors has been completed. Actual rework / repair per Non-conformance Reports issued will be completed by February 29, 1984.
2.
Item b.
a) Corrective Action Taken And Results Achlered Rela tive to the fabrication problem, Nonconformance Report's CQC 2916 and CQC 2917 were issued to identify the two occurrences of Insuf ficient reinforcing fillet weld on the field welded branch connections identified by the Construction Appraisal Team inspector. These NRs have been dispositioned by Project Engi-neering in accordance with the requirements of ASME Section III.
In addition, CQS and a representative of the Construction Appraisal Team inspected other existing branch connections during the course of the appraisal and found no other instances of insuf fi-cient reinforcement.
As a result, this has been determined to be an isolated occurrence.
Relative to the measures to control the welding of stainless steel socket welds, the Project Organization has reviewed the heat input as defined in Pullman Power Products (PPP) Procedure WPS-29 in relation to ASME Code requirements and has determined that it is in full compliance with the code.
In addition, pre-11minary destructive testing of actual samples indicates that the actual application of the WPS on our piping samples resulted in no detrimental ef fect on the weld or base material.
Pho tomicro-graphs are available for review.
A more formal Engineering study using selected materials welded under controlled conditions is being performed at this time to provide additional assurance that the subject socket welds meet ASME code requirements, b) Corrective Action To Avoid Further Noncompliance PPP revised their General Welding Standards procedure to address section NX-4244 of ASME Section III concerning reinf orcement of branch connection welds.
Corrective action measures to control the welding of stainless steel sockets will be based on the results of Engineering's tests and evaluation.
c) Date When Full Compliance Will Be Achieved Relative to field welded branch connections, full compliance will be achieved upon PPP's Jeneral Welding Standards procedure revision acceptance by Project Organization. Procedure acceptance is anticipated by January 31, 1984. _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _
Relative to stainless steel socket welding, full compliance will be achieved upon review and acceptance of results of the Engineering s tudies. Study completion is anticipated by February 17, 1984.
3.
Item c.
The finding in this section deals with two contractors, General Electric (GE A&ES0) and Pullman Power Products (PPP). Each will be addressed separately.
Relative to General Electric A&ESO:
a) Corrective Action Taken And Results Achieved As a result of this concern, Project Organization issued Observa-tion Action Request's 714, 715, 716, 717 ana 721 to GE A&ESO.
In turn, GE A&ESO issued Nonconformance Report GE 38-731 and Corrective Action Request 004 against their own organization. A sensitivity comparison of radiographic techniques has been performed. A documented review has concluded that welders with questionable qualification radiographs have not performed any production welding in the area of question and will be requallfled if required to.
As appropriate, radiograph reader sheets and reports have been corrected to reflect correct techniques.
In addition, an evaluation was performed of welds made by welders whose quall-fication reports indicated incorrect thickness test coupons.
Documentation was reviewed which verified that the welders had not performed welding on items beyond their actual qualified thickness, b) Corrective Action To Avoid Further Noncompliance Retraining sessions have been given to GE A&ESO Quality Control /
Nondestructive Examination personnel involved with radiographs.
A letter was issued to radiograph personnel clarifying penetrameter usage. Welder qualification coupon thickness will be verified by the Welding Supervisor and/or GE QC inspector prior to welder certification. Techniques have been revised to provide for adequate station markers during radiography.
c) Date When Full Compliance Will Bo Achieved Full compliance was achieved as of December 22, 1983.
Relative to Pullman Power Products:
a) Corrective Action Taken And Results Achieved In response to this concern, Project Organization issued Observation AR 713 to Pullman Power Preducts concerning wrong side placement of penetrameters and lack of reader or technique sheets. _ - _ _ _ _ _ _ _ _ _ _ _ -. _ _ _.
b) Corrective Action To Avoid Further Noncompliance Pullman Power Products has revised Procedure IX-RT-5 to require the use of " Radiographic Inspection Reports" during interpretation of welder coupons. Additionally, the procedure revision clarifles proper penetrameter placement.
Comment resolution is now in process.
All PPP radiographic examination personnel will be trained to the procedure revision upon its acceptance.
c) Date When Full Compliance W111 Be Achieved Full compliance vill be achieved by January 31, 1984.
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VI.
Noncompliance 50-440/83-31-(06); 50-441/83-30-(06)
A.
Severity Level V Violation 10CFR50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promp tly identified and corrected."
PNPP CNQAP, Section 1600, Paragraph 1.1, states in part, " Measures shall be established which ensure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances be promptly identified and corrected."
Contrary to the above, engineering disposition of seismic clearance violations have, in some cases, not been performed in a manner which would ensure structural integrity.
Examples include lack of considera-tion in some analyses for deficient hardware conditions and for lateral movement of fire protection piping near Class 1E cable trays, improperly dispositioned seismic clearance violations, and several telated calculation deficiencies.
B.
Response
1.
Corrective Action Taken And Results Achieved a) Relative to Seismic Clearance Violation (SCV) calculations, Observation Action Request 752 was issued te Engineering. Of the SCVs discussed in the Construction Appraisal Team inspection r epo r t, no cases were identified in which a significant analysis error existed. Due to the wide margin of conservatism applied by Engineering in their computations, it has been ascertained that a complete review of all computations done to date for errors is not warranted.
Engineering will review a sampling of SCV compu-tations to determine if further review is warranted.
It should he noted that the Generic Design Input for all the SCV computations requires that AISC - Specification of the Design Fabrication and Erection of Structural Steel for Buildings -
November 1, 1978, and AWS D1.1 - Structural Welding Code 1972, with 1973 and 1974 revisions be followed. These are the basic requirements for the computations and will continue to be so.
In addition, various vendors' catalogs have been used to determine allowable capacities for hardware.
Engineering is currently conducting tests on various types of hardware used throughout the plant to determine actual ultimate capacities of the hardware to compare with the manuf acturer's catalog capacities and to establish safe working loads for this hardware used on the Perry Site. __
l The Engineering response to Observation Action Request 752 also addressed consideration of lateral movement of fire protection piping among safety cable tray. A review of all computation will be made to ensure adequate numerical analysis are available to substantiate the Engineering justifications.
For those areas where existing numerical analysis is not deemed suf ficient, a
field evaluation will be performed and, if necessary, revisions to the computations will be made and new supports added as necessary, b) Relative to incorrect dispositioning of SCVs, observation Action Request 706 was issued to Engineering.
A total review of all SCVs written identified twenty-nine (29) similar conditions in which SCVs requiring additional repair were incorrectly dispoal-tioned. These SCVs were subsequently reopened with the correct disposition.
2.
Corrective Action To Avoid Further Noncompliance a) Engineering is presently in the process of developing standard design input criteria for engineering calculations (as recommended in AR No. 752) which would greatly reduce the possibilities of errors, inconsistencies, and omissions in future SCV calculations.
b) It has been determined that the practice of dispositioning SCVs "use-as-is" based on additional supports being added at a future date was a policy which was in ef fect for a relatively short period of time and has since been corrected.
The SCV Engineers have since been instructed by the Lead Engineer as to the proper practice of dispositioning SCVs.
This should preclude premature closure of SCVs prior to the necessary repair work being performed.
3.
Date When Full Compliance Will Be Achieved a) Full compliance will be achieved by April 30, 1984.
b) Full compliance to program requirementa was achieved on September 22, 1983. - - - - - _ _ _ _ _ _ _ _ _ _
d VII. Noncompliance 50-440/83-31-(07); 50-441/83-30-(07)
A.
Severity Level V Violation 4
10CFR50, Appendix B, Criterion VIII, states in part, " Measures shall be established' for the identification and control of materials, parts, and components, including partially fabricated assemblies. These measures shall assure that identification of the item is maintained..."
PNPP CNQAP, Section 0800, Paragraph 1.1, states in part, " Measures shall i
be established to provide for the identification and control of saf ety-
'related materials, parts, and components, including consumables, off-the-shelf items, and nonsafety-related Ltems which affect the function of j
safe ty-related equipment."
Contrary to the above, the storage, issuance, application and Installation of fasteners and some components were not adequately controlled.
Examples i
include lack of material identification markings on parts of some ASME Class I hangers, and some cases in which marked materials were not traceable to verification documentation.
B.
Response
l This noncompliance consists of two parts which are answered separately below:
1.
Relative to the portion of this item which concerns material identi-fication of Class I hangers, the following actions were taken:
a) Corrective Action Taken And Results Achieved l
This problem was originally identified during Project Organization Audit Number #768.
Project Organization had requested General Electric for reverification and recording of material identification for the Main Steam and Recirculation Hangers. Nonconf o rmance Report's GE-38-0522 and GE-38-0523 were issued by GE.
Subsequently, l
Nonconformance Report GE-38-0708 was issued to complete the recording and/or verification of material marking.
This activity has been complete. Material markings which could not be verified as consistent with manufacturer's markings have been identified on Nonconformance Report GE-38-0797.
For this nonconformance, i
further evaluaticn/ testing is in progress, b) Corrective Action To Avoid Further Noncompliance GE receiving inspections will include verification of the Identity of all pieces of an assembly or items shipped loose of an assembly.
c) Date When Full Compliance Will Be Achieved Full compliance will be achieved upon receipt of the material analysis for several items of a hanger apsembly and the disposi-tion verification of the Nonconformance Reports NR-GE-38-0708 and l
NR-GE-38-0797.
Estimated completion date is January 31, 1984. - - -. - -... -,
t 2.
Relative to the portion of this noncompliance which concerns trace-ability of marked caterials, electrical and mechanical concerns discussed in the Construction Appraisal Team Report in Section VI-B-1-b(3) will be discussed separately.
For electrical items, the following actions were taken:
a) Corrective Action Taken And Results Achieved Bolts in Bin (Example a)
As discussed in the inspection report, storage of the bolts is somewhat questionable. There was documentation available, however, to verify that the bolts were ASTM grade B7.
The B7 bolts meet or exceed the characteristics of A-325 bolts and when used as a substitute, would not compromise the quality of the installation.
Bolts for Battery Racks (Example b)
The qualification test report for the R42 battery racks provided calculations to justify the use of grade 2 as well as grade 5 bolts.
The bolts utilized on the battery racks were appropriately marked as either grade 2 or 5.
The use of the grade 2 bolts was documented on Nonconformance Report OQC-0307. The Nonconformance Report directs the Nuclear Test Section to " remove all grade 2 bolts and replace with SAE grade 5 bolts of the same size".
Bolts for 4kV Switchgear Cabinet (Exanple c)
The grade 2 bolts associated with the Unit 1 and Unit 2 R22 switchgear are documented on Nonconformance Reports 0QC-0325 and OQC-0324 respectively. Conversations with the vendor revealed that the Interf rame bolts presently installed in the switchgear are acceptable. Switchgear bolts will be "use-as-is" in their present configuration based upon the vendor's letter.
Bolts for Class 1E Motor Control Center (Example e)
The \\" round head bolts associated with the R24 Motor Control Centers are documented on Nonconformance Reports 0QC-0318, OQC-0319, 0QC-0320, and 0QC-0321. Conversation with the vendor indicates that 2 flat washers are required when bolting sections of Motor Control Centers together. Additionally, the vendor's manual Indicates that the bolts are to be installed with the bolt head on the cable channel side of the panel.
b) Corrective Action Taken To Avoid Further Noncompliance
- 1) To ascertain the adequacy of the electrical contractor's control of stored items, an audit of their storage f ac111tles will be performed by Construction Quality Section. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
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- 2) The Gilbert Assoclates Inc. Quality Assurance Department Division PNPP Program Manager has been requested to review the situations listed in the NRC report and identify any additional steps that could be taken to minimize future occurrences of the types of problems identified in the NRC report.
c) Date When Full Compliance Will Be Achieved Nonconformance Report's OQC-0307, 0324, and 0325 have been verified closed and accepted.
Nonconformance Report's 0QC-0318, 0319, 0320, and 0321 have been dispositioned and will be closed by February 29, 1984.
The action required of Gilbert Associates Inc., and the audit of the electrical contractor storage f acilities will be completed by February 29, 1984.
3.
For mechanical items, the following actions were taken:
a) Corrective Action Taken And Results Achieved Bolts for Flanged Joints of Diesel Starting Air Line IR44509 (Example d)
The Construction Quality Section reinspected the bolts in question and found that they were temporary bolts installed by the diesel manufacturer.
The correct bolts will be installed at final installation by Pullman Power Products per Procedure IX-5.
Fasteners for Standard Component Supports (Example f)
The Construction Quality Section conducted Audit 892 to determine whether Pullman Power Products was adequately implementing program requirements for material control and traceability.
Audit Action Request 892-01 was issued identifying a problem with material control.
Problems were not encountered with material traceability.
Resolution of this Action Request is lu process, b) Corrective Action To Avoid Further Noncompliance Construction Quality Section has implemented a program of planned, systematic surveillances of Pullman Power Products procedural requirements.
By reviewing the contractor's program, the contractor's adherence to each procedural requirement will be continuously monitored and assessed.
Scheduling and planning of the surveillances is reviewed quarterly and f requency is based upon current field activity and PPP procedure requirements. - - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
o c) Date When Full Compliance Will Be Achieved Full compliance will be achieved upon close-out of Audit Action Request 892-01, presently expected by February 15, 1984.
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C VIII. Noncompliance 50-440/83-31-(08); 50-441/83-30-(08)
A.
Severity Level V Violation 10CFR50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are prompt 1_y identified and corrected.
PNPP CNQAP, Section 1600, Paragraph 1.1, states in part, " Measures sF111 be established which ensure that conditions adverse to quality, such as f ailures, malfunctions, deficiencies, deviations, defective material and
~
equipment, and nonconformances be promptly identified and corrected."
Contrary to the above, nonconformances were closed prior to completion of the required corrective actions. Examples include premature close-out of two NRs involving reverification of material identification for parts of fourteen hangers, close-out of a nonconformance report requiring an FSAR change before the change was submitted, improper voiding of a nonconformance report involving soils testing because of misinterpretation of specification requirements, and close-out of a nonconformance report requiring training of concrete placement personnel before the training was given.
B.
Response
1.
Corrective Action Taken And Results Achieved During the Cons truction Appraisal Team inspection, over 300 Non-conformance Reports were reviewed.
As only four examples of close-out prior to implementation of all corrective action steps were noted, we feel these are Isolated incidents.
For the purpose of this reply, therefore, they will be treated separately, a) In regard to the close-out of two Nonconformance Reports involving verification of material identification, Nonconformance Report's GE-38-522 and GE-38-523 were closed on July 14, 1983, and July 12, 1983, respectively. The dispositions for these Monconformance Reports contained nultiple corrective action steps and underwent numerous revisions, each of which related back to the previous revision. This condition created confusion for 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 Nonconformance Report to complete the recording of the material markings that were omitted during the disposition verification of GE-38-522 and GE-38-523.
Nonconformance Report GE-38-0708 was issued on September 6, 1983, and requires completlen of material identification and recording of material workings for the Main Steam Reactor Recirculation hangers...
c 4
2 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 January 22, 1982. This Nonconformance Report required that an FSAR amendment be issued to identify those cases where Code Case N-242 was utilized. Engineering l
issued a memo on September 14, 1981, to the Nuclear Licensing and 1
Fuel Management Section (Licensing) identifying a list of items qualified using the Code Case and requesting an amendment to the Safety Analysis Report. The Nonconformance Report was subsequently closed out based upon this memo.
However, the Quality Engineer was not made aware of the fact that Licensing had requested additional information from General Electric prior to Initiating the FSAR amendment. The information from General Electric is still pending.
Nonconformance Report TAS 073 was initiated to document and track the. premature close-out of Nonconformance Peport CQA136.
c) In regard to the improper volding of Nonconformance Report QCA-100 (Blount Brothers) Involving soils testing, the Construction Quality Section initiated Nonconformance Report CQC 2919 to obtain Engineering evaluation when this condition was identified.
This Nonconformance Report was subsequently dispositioned use-as-is because there was only a small deviation (3 pcf) from the required minimum of 120 pcf and the results of the in-place density tests exceeded compaction requirements.
In addition, a review of all Blourt Brothers (SP-18/82) Nonconformance Reports was performed to detenmine whether similar conditions existed.
The results of the review Indicate this to be an isolated case.
d) In regard to the matter of a Nonconformance Report being closed j
out prior to completing training of concrete placement crews, Nonconformance Report DICK-216 was inadvertently closed out on Sep tember 14, 1983. When it was realized that the Nonconformance Report was closed prior to training being perf ormed, training was conducted on September 21, 1983. However, the training records l
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 l
one week later.
4 Action Request 718 was issued to the contractor on October 7, 1983.
The Action Request retterated 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
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2.
Corrective Action To Avoid Further Noncompliances 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 addition, the Program Revision Notice will instruct personnel revising the disposition of a Nonconformance Report to include all i
steps in the latest revision and avoid referencing previous revisions.
3.
Date When Full Compliance Will Be Achieved The Program Revision Notice will be issued by February 15, 1984.
Since resolution of individual deficiencies has been documented in accordance with program requirements, full compliance will be achieved by February 15, 1984. _
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