ML20081C067

Responds to NRC Re Violations Noted in IE Insp Repts 50-440/83-37 & 50-441/83-35.Corrective Actions: Training & Reevaluation of Candidate Performed Per Lk Comstock Procedure 4.14

ML20081C067
Person / Time
Site:	Perry
Issue date:	02/24/1984
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20081C057	List: ML20081C067
References
NUDOCS 8403120126
Download: ML20081C067 (7)

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! y P.O. box 5000 - CLEVELAND. OHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSQUARE Serving The Best Location in the Nation February 24, 1984 VICE PRESIDENT NUCLE A R Mr. W. S. Little, Chief Engineering Branch 2 Division of Engineering U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441

Dear Mr. Little:

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

83-37; 50-441/83-35 attached to your letter dated January 27, 1984. This report identifies areas examined by Messrs. K. Naidu, Z. Falevits and E. Christnot during their inspection conducted November 30 through December 15, 1983, at the Petry Nuclear Power Plant.

Attached to this letter is our response to the Notice [ of Violation dated January 27, 1984. This response is in accordance with the provisions of Secticn 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.

Our 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, M. R. Edelman

' lice President Nuclear Group MRE:pab Attachment ec: Mr. M. L. G11dner USNRC Site Mr. R. C. Knop, Chief Projects Branch 1 Division of Project and Resident Programs U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road .,

Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Comnission c/o Document Management Branch Washington, D.C. 20555 8403120126 pDR ADOCK 05000440 840306 VEB 2'? gg4 G PDR

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~ RESPONSE TO ENFORCEMENT ITEMS Delow is our responce to the Notice of Violation appended to United States Nuclear Regulatory- Commission I.E. Report 50-440/83-37; 50-441/83-35.

I. Noncompliance 440/83-37-02; 441/83-35-02 A. Severity-Level IV Violation 10CFR50, Appendix B, Criterion V, as implemented by CEI Corporate Nuclear Quality Assurance Program Mantial, Section 0500, requires that

activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.

Contrary . to the above, the following eFempled were identified:

a. LKC procedure 4.1.4 does not spectfy the steps to be taken to re-exanine a candidate who failed his Level Il qualification examination.

One candidate had been re-examined and qualified without the neccesary procedural requiremente.

b. During a walkdown of safety-related raceway and conduit installations, three cases were identified which violated the design separation criteria specified in drawing D-214-004, Revision K, titled "Cinduit and Tray , Separation Criteria".

B. Response This noncompliance consists of two parts which are answered separately o , w'below.

.v 1.' Relative to personnel qualifications:

a. Admission or Denial of the A11cged Violation

- We cot 10ur with the inspector's observation that "LKC procedure 4.1.4- does not specifically identify the steps to be taken to re-examine a candidate who failed his Level II qualification jexamination". However, with regard to the Notice of Violation statement, "One candidate had been re-examined and qualified without the necessary procedural requirements", further explanation is of fered.

Reason

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' -m, LKC prodedure 4.1.4 has requirements which must be met and

' succestfully completed to be qualified / certified as a Quality Control' 1nspector Level I, II, or III. The intent of the

, procedure is to define the requi'rements to certify personnel.

If the candidata does not meet the requirements, he does not receive certification by L. K. Comstock or concurrence by the t Project Organization.

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, ' RESRONSE TO ENFORCEMENT ITEMS PAGE 2 Initially, the referenced candidate did not meet one of the requirements. Project Organization oral questioning during a Practical Examination revealed a deficiency in the candidate's utilization of the work procedure. After subsequent tralring, a re-evaluation of the candida ta was conducted by both L. K.

Comsteck and the Project Organization. The results of the re-evaluation revealed acceptable proficiency in the use of the procedure and fulfillment of requirements for certification.

Corrective Steps Taken and Results Achieved Prior to the NRC inspection, training and re-evaluation of the candidate had been performed in accordance with LKC procedure 4.1.4. The candidate demonstrated acceptable proficiency in the use of the LKC procedure and was thereby certified.

Corrective Steps Taken to Avoid Further Violations The L. K. Comstock inspector qualification and certification procedure has been revised. The revision specifically addresses the steps to be taken to re-examine a candidate. Additional training and a three-day minimum waiting period prior to receiving re-examination have been Instituted if a candidate does not satisfactorily complete the practical examination.

Date of Full Compliance Full compliance was achieved on February 3,1984.

2. Felative to conduit and tray separation criteria:

b. Admission or Denial of the Alleged Violation We concur with the inspector's observation that two cases of safety-related raceway, as cited in Inspection Report 440/83-37; 441/83-37 Item 6.b. (3) and (4), violated the design separation criteria. In the third case, item 6.b.(5) cable trays are not in violation because drawings indicate that barriers are to be Installed at a later date. However, nonsafety cable in the referenced safety-related tray did violate separation requirements.

Reason The safety-related trays were installed, inspected, and accepted. Subsequently, nonsafety-related cable / tray were installed in violation of the separation criteria relative to the safety-related tray.

. " RESP,0NSE TO ENFORCEMENT ITEMS PAGE 3 Corrective Steps Taken -and Results Achieved h Violations of separation criteria for trays 617A and 695A were documented on Nonconf ormance Report number LKC 2639 durirg this NRC inspection. The nonsafety flexible conduits IR33B94X and 1R33R1351X were reworked to alleviate the violation.

I Cables exiting nonsafety tray 964X were documented on Deficiency

[ Report 2472 during this inspection. The nonsafety cables were reworked to alleviate the violation.

l The development of the program for barrier installation, as I specified on the raceway installatioa drawings, was discussed l during the Construction Appraisal Team Inspection conducted l at PNPP during 1983. The technical and installation require-ments for barriers were under development by Project Engineering prior to the Construction Appraisal Team Inspection.

In response' to that concern, all previous raceway inspection

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( records were stamped to indicate that barrier installation

'has not yet been verified. Procedure revisions were made also to ensure that future raceway records accurately reflect the status of the raceway. inspection. These actions were completed September 16, 1983.

Corrective Steps Taken to Avoid Further Violations Action Request 796 has been issued to L. K. Comstock directing that the raceway installation pr,ogram be reviewed to identify

, what actions will be taken to alleviate ;imilar violations.

t In response,sthe contractor has proposed to institute a final

'walkdown by areas to identify acparation viclations

. This is currently unde r evaluation. Additionally, the contractor has re-emphasized to all LKC supervisors that separation criteria must be maintained during all installations or the installation mu<at be stopped until engineering resolution to the problem is achieved. _

Idtthermore, Project Organization is catablishing an ongoing program in which the Construction Quality Section will inspect for separa, tion violations of raceways.

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'Da*.e of Full Compliance

,, . Nonconformance Report 1KC 2639 is being closed February 24, 1984. Deficiency Report 2472 was closed December 27, 1983.

The. Construction Quality Section inspection program described s "j above will be initiated on March 2 1984.,

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.- . RESPONSE TO ENFORCEMENT ITEMS PAGE 42 II. ' Noncompliance 440/83-37-03; 441/83-35 A. Severity Level V Vio1'ation r

10CFR50, Appendix B, Criterion III, as implemented by CEI Corporate Nuclear Quality Assurance Program Manual, Section 0300, requires that a J CEI. performs a design coordination function consisting of selected reviews and design control monitoring program, that these procedures shall assure design activities are conducted in a planned and systematic

- . manner, that Perry Safety Analysis Report requirements have been appropriately addressed in design documents and that design require-J 'ments can be controlled and inspected and/or tested to specified

. acceptance criteria.

- - Contrary to the above, CEI f ailed to assure that Gilbert Associates, Inc. (GAI). reviewed and verified that the schematic and wiring diagrams relating to Class 1E/Nonclass 1E isolation devices in relay panels 1H51-P870, - 1H51-P871 and 1H51-PS72 were adequate in that numerous inconsistencies' were identified.

B. - Response

.. 1. Admissicn or Denial of the Alleged Violation Ve concur with the inspectors observation of inconsistencies existing between the elementary wiring diagrams and the inter-connection wiring diagrams for relay panels 1H51-P870, 1H51-P871 and 1H51-P872.

2. Reason A' revision to 'the respective elementary wiring diagrams occurred without 7the appropriate revision of the interconnection. wiring

- diagrams.

3._ . Corrective Steps Taken and Results Achieved

-Engineering Change Notice 6220-33-1240,' Revision A, was issued to correct'the interconnection wiring diagrams to identify the '

relays-as 1K22, K23, and,K24.

w i 4 '. -Corrective Steps Taken to Avoid Further Violations A Project Internal Audit on drawing / design control is being performed at the Gilbert Associates Reading, Pennsylvania of fice during.the week of February 20, 1984, to further pursue this matter. Any ; problems noted will be addressed within our correc-tive action program.

5. Date of Full Compliance Engineering Change- No tice 6220-33-1240, Revision A, was issued on February 14,,1984.

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RESPONSE TO ENFORCEMENT ITEMS o,

PAGE 5 III. Noncompliance 440/83-37-04; 441/83-35-04 A. Severity Level V Violation 10CFR50, Appendix B, Criterion V, as implemented by CEI Corporate Nuclear Quality Assurance Program Manual, Section 0500, requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances.

Contrary to the above, CEI Project Administration Procedure 0302 is inadequate in that it does not require the GAI engineer to initiate nonconformance reports when potentially defective components or procured items supplied by GE are identified. Several examples were identified where CEI had initiated nonconformance reports af ter corrective action had been completed.

B. Response

1. Admission or Denial of the Alleged Violation We concur with the finding that implementation of Project Adminis-tration Procedure (PA) 0302 did not ensure timely initiation of Nonconformance Reports (NRs) in all cases, for potentially defec-tive components identified on Field Disposition Instructionr.

(FDIs) or Field Deviation Disposition Requests (FDDRs) issued by the General Electric Company (GE) .

2. Reasons PA 0302, entitled " Project Control Interf ace - GE Field Disposi-tion Instructions / Field Deviation Disposition Requests", required the Responsible Nuclear Construction Engineering Section (NCES)

Engineer, not the CAI Engineer, to review FDIs/FDDR,s for non-conforming conditions.

The delays in issuing NRs cited in the report occurred because a Responsible NCES Engineer was not fully cognizant of the requirements stated in PA 0302,

3. Corrective Steps Taken and Results Achieved Project Organization revised procedure PA 0302 and Nuclear Design and Procurement Procedure 3-0305 to clearly define the Nuclear Construction Engineering Section review of FDIs/FDDRs. The revision also requires the NCES Engineer to stamp, sign, date and record the NR number, if applicable, on the FDI/FDDR to document the review.

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. RESPONSE TO ENFORCEMENT ITEMS PAGE 6 All Project Organization Work Elements and all contractors presently performing FDI/FDDR work were directed to inform the Responsible NCES Engineer of all uncompleted FDIs/FDDRs issued for implementation prier to February 15, 1984, The Responsible NCES Engineer will review the identified FDIs/FDDRs to ensure that any nonconforming materials or components are documented on NRs.

A review of closed FDIs/FDDRs has been determined not to be necessary. Completion of the FDI/FDDR assures that any actions needed to correct nonconforming conditions were completed and verified by QA/QC personnel. The FDI/FDDR, as a design input document, ensures any changes made are incorporated into the applicable design.

4. ' Corrective Steps Taken to Avoid Further Violations The individual Responsible NCES Engineers responsible for review of FDI/FDDRs prior to their issuance have been instructed in the requirements of the reviced procedures.

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. Implementation of the revisions to the Project Organization procedures 'and the ongoing review by the Responsible NCES Engineers of FDI/FDDRs. currently issued should prevent recurrence of this violation.

5. Date of Full Compliance The revisions to procedures PA 0302 and 3-0305 were issued February 15, 1984, and training for the individual Responsible NCES Engineers was completed by February 24, 1984.

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