ML20098E668

Supplemental Filing on Issue 6 Re Automation of Standby Liquid Control Sys.Certificate of Svc Encl

ML20098E668
Person / Time
Site:	Perry
Issue date:	09/26/1984
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
References
CON-#484-121 OL, NUDOCS 8410010268
Download: ML20098E668 (2)

Text

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.dNITED STATES OF AMERICA 00CKETED-usnRC NUCLEAR REGULATORY COMMISSION Before the Atomic Safeiiv and _Licensina Beac43 pjj-()g

) i I In the Matter of

) U.e:tE :: SECGEP F

ff CLEVELAND ELECTRIC ILLUMINATING ,) i Docket bY.$3.dhdd #6 L- -COMPANY, Et A1. ) ~ 50-441

, ) (Operating License) '

(Perry Nuclear Pow'er Plant, )

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[ OCRE SUPPLEMENTAL' FILING ON ISSUE #6 '

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By this filing Intervenor Ohio Citizens for Responsible ,

Enkrgy - ("OCRE") is informing the Board of a recent NRC' Inspection Report which is relevant to Issue #6, concerning automation of the Perry-etandby liquid control system, currently before the Board. The r

intpection report, of which the' cover letter, notice of violation,

, <c.nd pertinent pages are attached, details Applicants' deficiencies in the contr61 of the design of the SLCS. Despite an independent design

. riview of SLCS drawings, deficiencies were discovered by the NRC .,

inspectors. It is thus fair to say that, contrary to Applicants' ascertions in its September 7 filing, the design of the SLCS at least an late as June 1984 was indeterminate, as a breakdown in design 4

co'nt.rol had occurred.

Respectfully submitted, w._. 79 d Susan L. Hiatt

<- OCRE Representative 8275 Munson Rd.

Mentor, OH 44060 (216) 255-3158

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.i i ColdETED USNRC t ..'.

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-CERTIFICATE OF SERVICE .* h-S .

84 SEP 28 All

• 10 This is to certi'fy,that copies of.the foregoing were served'by

-deposit-in-the U.S. Mail, first class, postage prepaid,othis,

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. service list b,elow. / ,

BRANCH

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Susan L. Hiatt, W % pas,'e$ YWj. _.

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.  : $ Peter B. Bloch, Chairman- Terry L dge, Esq.

I Atomic - Safety & Licensing Board - 618 N. Michigan St.

U.S.' Nuclear Regulatory Comm. te 10

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Washington,'D.C. 20555 8"feg g 0H 43624

~Dr. Jerry R..Kline Atomic Safety.& Licensing Board.

U.'S.:Noclear. Regulatory. Commission i

WasEington,1D.C. 20555 ,

Mr..Glenn O. Bright

. Atomic Safety &. Licensing Board U.S.~ Nuclear Regulatory Commission

-Washington, D.C. 20555 Colleen P. Woodhead, Esq.

- Office of the Executive Legal Director U.S. Nuclear Regulatory Commission .

Washington,.D.C. 20555 Jay.Silberg, E'sq.

Shaw, Pittman; Potts,.& Trowbridge 1800 M Street, NW .

. Washington, D.C. 20036 .,

Docket'ing'& Service Branch

.Offi^ce of'the Secretary

~U.S. Nuclear Regulatory Commission Washington,. D.C. 20555 Atomic. Safety.&_ Licensing. Appeal Board' Panel U.S. Nuclear Regulatory Commission

. . Washington,-D.C. 20555.  ;

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pp 1 ' 1994 Docket No. 50-440 5 I#I 9 Docket No. 50-441 ,

The Cleveland Electric Illuminating Company ATTN: Mr. Murray R. Edelman Vica President Nuclear Group Post Office 30x 5000 Cleveland, OH 44101 Gentlemen:

This refers to the routine safety inspection conducted by Messrs. K. R. Naidu, Z. Falevits, A. Gautam, K. Tani, and E. Christnot of this office on April 9-12 and June 4-7, 1984, of activities at Perry Nuclear Power Plant, Units 1 and 2, authorized by NRC Construction Permits No. CPPR-148 and No. CPPR-149 and to the-discussion of our. findings with Mr. C. Schuster and others of your staff at 'he

, conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during '

the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative recoros, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix.

A written response is required.

We are concerned that your inspection reports contain various discrepancies such as erroneous dates of review and other inaccurate information. We point out that these are permanent records and as such should not contain significant~

discrepancies in information and dates. As part of your corrective action regarding the noncompliance identified, we expect you to audit your records to ascertain whether your inspection reports contain adequate information regarding the identification of the item inspected, the results of the in-spection, and the date and identification of the initial reviewer.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure (s) will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter end submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the re-quirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosure (s),

and your response to this letter will be placed in the Public Document Room. ,

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[ .The Cleveland Electric Illuminating Company 2

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The responses directed by this letter (and the accompanying Notice) are not subject to the clearance procedures of the Office of Management and 1 Budget-as required by the Paperwork Reduction Act of 1980, PL 96-511. I

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We will gladly discuss any questions you have concerning this. inspection.

n _ Sincerely, '

W. S. Little, Chief //

Engineering Branch

Enclosures:

1. Appendix, Notice of Violation

. 2. Inspection Reports *

.No. 50-440/84-07(DRS);

No. 50-441/84-07(DRS) cc w/encls:

J. Waldron, Plant Manager

.L.-Beck, General Supervisor ,

Licensing and Fuels Management DMB/ Document Control Desk (RIDS) -

Resident Inspector, RIII Harold W. Kohn, Ohio EPA Terry J. Lodge, Esq.

James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health 4

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I N An- Accendix fijX NOTICE OF VIOLATION The Cleveland Electric Illuminating Docket No. 50-440 Company (CEI) Docket No. 50-441 As a result of the inspection conducted on April 9-12 and June 4-7, 1984, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion X, as implemented by CEI Corporate Nuclear Quality Assurance Program Manual, Sec+. ion 1000, Revision 3, requires that 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. The following examples,were contrary to the above:

a. Inspection Reports documenting inspections performed on rework done en the Power Generation Control Console are in some instances not clear and do not specify what was inspected and what was acceptable.

Examples include inspection reports on FDI-WNBE and Engineering Changes Notices 2458.

b. Inspection Reports verifying corrective action taken on LKC Nonconformance Report 2375 contained discrepancies such as the date of review being a day earlier than the date of inspection and the date of calibration of crimoing tools used to crimp the termination lugs.

c. Inspection Reports verifying corrective action on LKC Nonconformance Reports 2568 and 2569 contained misleading CEI " Hold" point stamps which were signed and dated several days after the actual inspection was performed. Such a practice renders it difficult to readily serify whether the hold point was honored,

d. General Electric Product Quality Certificates (PQC) certifying the compliance of Namco Limit Switches intended for mounting on the Control Valves for the steam turbine, were accepted during receipt inspection even though the serial numbers of the limit switches were not furnished on the PQC to establish traceability.

This is a Severity Level V violation (Supplement II).

2. 10 CFR 50, Appendix B, Criterion III, as implemented by CEI C;rporate Nuclear Quality Assurance Program Manual, Section 0300, requires that, CEI perform a design coordination function consisting of selected reviews and design control monitoring programs verifying that these procedures

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Appendix 2 4

shall assure that design activities are conducted in a planned and system-

~atic manner;:that the Perry' Safety Analysis Report requirements have been appropriately addressed-in design documents; and that design requirements lcan be controlled and-inspected and/or tested to specified acceptance criteria.

l Contrary to the_above, CEI failed to assure that Gilbert Associates, Inc.

-(GAI) adequately reviewed and. verified that safety related schematic'and

wiring diagrams relating to Standby Liquid Control, Residual Heat Removal and Process Radiation Systems were correct in that numerous design errors

'and inconsistencies were. identified, i

This is a Severity Level.IV violati0n (Supplement II).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to '

..this office within thirty days 'of the date of this Notice a written statement or explanation in reply, including for'each item of noncompliance: .(1) cor-rective action taken.and the results achieved; (2) corrective action to be.

-Ltaken to avoid further noncompliance; and (3) the date when full compliance

'will be achieved. Consideration'may be given to extending your response time

-for good cause shown.

A'JG 1 -1 1934 Dated W.S.Little',Chiefgg Engineering Branch

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f. The inspector reviewed the standby liquid control systems elementary

. diagram Drawing.B-208-030 Sh. 2, Rev. K. The following discrepancies were identified:

(1) Status lights (DS17) circuit in MCB for "1C41-C001B or F001B overload trip or loss of power" indicated actuating devices as 74 N.C. contact relays from starters of valves. Review of the drawing showing coils for initiating devices indicated that the relays are designated as 27 on S/D B-208-030, Sh. 4 & 5, rather than 74.

(2) Status lights (DS14) circuits in MCB for "SLCS injection loop "A" manual valve position closed or system manually out of service" contained actuating contact from injection valve 1C41-F036. P&I diagram D-302-691 Rev. c indicated that valve 1C41-F036 is located in the common header line inside the drywell and therefore, is common to loop A & B. Loop "B" circuit did not contain an interlock from valve 1C41-F036, and therefore, status lights for loop B will not come on as re-quired when valve is closed. Also, LS3 contact from the limit switch on valve IC41-F036 was shown in loop A circuit as N.O.

contact when per development it should have Deen shown as a N.C. contact.

(3) Circuit showing switches SIA & S1B contact 1-2 as N.C. contacts, should be shown as N.O. contacts.

(4) Limit switch development for valves 1C41-F031 Div. I & Div. II does not correlate with development shown on connection diagram D-209-030 Sh. e, Rev. F.

(5) The licensee could not locate the connection diagram for valve 1C41-F036 in the existing design drawings. No reference was found to any document showing the connections to limit switches of the valve. The licensee indicated that an ECN 21080-33-3436 dated June 1, 1984, had been written to show the connections, however, the ECN was not referenced on any of the design drawings, apparently indicating that it does not exist.

(6) Drawing B-208-030, Sheet 3, Rev. k did not indicate the 120VAC distribution panel number, feeding Division 1 power to 1C41-K600A instrument loop.

(7) While reviewing the design drawings at the GAI engineering office, the inspector identified instances where drawings were incorrectly filed, superseded drawings were still filed in the main controlled set and were not marked superseded. One drawing was issued in January 1984 but not filed till June 1984. These drawings are the design reference drawings used by design and field engineers. At the NRC inspector's request, the licensee performed an audit on the control of drawings in the electrical

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area. The audit confirmed the inspectors' concern and the li-C e censee subsequently initiated Action Request (AR) 0043 dated IEf ' June 6,1984 to implement steps to assure appropriate maintenance of current design drawings.

f'M Eh The inspectors discussed the above findings with the licensee's staff. The f.& licensee informed the inspectors that GDS Associates, Inc., an independent

'F d design reviewer, had been contracted by the licensee to review all safety 4 related design drawings relating to G.E. and GAI. GDS Associates had com-pleted their review and had only identified Items 8.f.(1) and 8.f.(6) above prior to the NRC inspection.

The licensee was informed that finding; outlined in paragraph 8.b.(1),(2),

(3), (a), (5); 8.d.(3), (4) & (5); 8.f.(2), (3), (4) & (5) indicated a failure to establish adequate design control ,reasuds to prevent numerous discrepancies among design documents. This it ccasidered an apparent example of noncompliance contrary to the requirement.s of 10 CFR 50, Appendix 0, Criterion III (440/84-07-03(DRS)).

9. Physical Separation of Class 1E Cable The inspector reviewed Class 1E cable installation for conformance to separation requirements outlined in IEEE 384-1974, Reg. Guide 1.75, Perry 1 FSAR Page 8.1-82, Spec.'SP-33-4549-00 2/11/77 and L. K. Comstock raceway and cable installation procedures.

The inspector identified five apparent cases of lack of raceway separa-tions,during walkdowns in essential areas of the plant. Each case was subsequently justified through documents shosing barriers to be installed at a later date. See Table 1 for details. No apparent deficiencies were found. -

Class 1E and balance of plant cables were reviewed for installations in common enclosures. It was observed that in the PGCC room, where adjacent General Electric Cabinets had 1E and non-1E circuits, wiring was touching the separating barriers. Paragraph 8.3.1.4.1.6(a) of the FSAR requires 1" between wiring and barriers - on both sides of barriers.

The licensee reported that an engineering analysis shall be performed to resolve this discrepancy. Pending review and resolution of this matter this item remains open. (440/84-07-04(DRS))

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