ML20098F927
| ML20098F927 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/02/1984 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Bloch P, Bright G, Kline J Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-234 OL, NUDOCS 8410030553 | |
| Download: ML20098F927 (44) | |
Text
l y9/>l .
REMEDCORRESPONDENCE SHAw, PITTMAN, PoTTsD @NOWBRIDGE A PARTNERSMiP OF PROFESSIONAL CORPORATeONS 1800 M STREET. .
WA S H I N GTO N, C. 3 TELEcOP:Em iaOai .za-.O . .aa-i October F
- '**^*'^****'
0 TG SEP BRANCH **"* E **"
TELEPHONE J AY E. SILBERO, RC. e.Das .aa-sO63 Peter B. Bloch, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 The Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2)
Docket Nos. 50-440 and 50-441 &
Gentlemen:
During a conference call on September 28, 1984, the Chairman asked for further information concerning a Notice of Violation dated August 14, 1984. The Notice accompanied NRC Inspection Report Nos. 50-440/84-07(DRS); 50-441/84-07(DRS).
The Chairman inquired whether the Staff had reached a conclusion whether Violations 1.b and 1.c were accidental or willful.
For the Board's information, there is attached the entire Inspection Report together with Applicants' September-13, 1984 Reply to the Notice of Violation. As shown in Applicants' reply, neither Violation can be considered to be of major significance. The discrepancies in dates which are the subject of Violation 1.b were inadvertant errors (1982 instead of 1981; November 22 instead of November 23). The issue on hold point dates (Violation 1.c) was based on the inspector's questioning of a procedure which called for certain documents to be dated upon completion of secondary review, rather than on the date of installation. As set-forth in the September 13 reply, the procedure has now been revised to remove the inspector's ]
Concern. ;
8410030553 841002 )
G h
c a
7-S SHAW, PITTMAN, PoTTs & TROWBRIDGE A panthtgesseep OF pHOFEMONAL CompomattONS Further indication of the level of significance of the two violations is that Region III believed that the cumulative seriousness of those two -- plus two others -- rated only a single Severity Level V (Supplement II) violation. While Applicants take any: violation seriously, it is nevertheless worth noting that a Severity Level V (Supplement II) violation is defined as one having " minor safety or environmental significance." 10 C.F.R. Part 2, App. C. The NRC's inspector was quoted in the attached newspaper article as stating, "There really was nothing of consequence."
As for the wi31 fulness of the violations, Applicants would point out that Region III has within its arsenal of enforcement powers the ability to characterize violations as " falsification of records," " deliberate falsifications" and " falsifications."
See 10 C.F.R. Part 2, App. C, Severity Levels I, II and III (Supplement VII). Applicants agree with Region III's implicit determination not to categorize Violations 1.b and 1.c in those terms. Region III's choice of Severity Level would be inconsistent with a deliberate misdating of the documents.
Verytrulyyourg, JAY' . SI BERG Coui s1 or Applicants JES: lam Attachment cc: To Attached Service List b
h4 .. .Val$ . ~ . - .,i '.V)d. . .^ #
m ,..
,.. a nse . T* 7 ?.7Q~ W.'[ '..; UNITED . STATES"g.'.- . . . ~
.g*
.4
- f. ~'f*, * , NUCLEAR REZULATORY COMMISSION ? [ ,'
- V E C cEi~ ton 111
( *; ~j 7ss noostvELT no Ao ' .-
., OLEN ELLYN. ILUNOIS 60137
. AUG 141984 '84 OCT -3 All :04 Docket No. 50-440 LFFlcE c- n ui.,t ;;.c Docket No. 50-441 00CKETihG & SEi<W.i BRANCH The Cleveland Electric Illumin ting Company ATTN: Mr. Murray R. Edelman Vice President
- Nuclear Group Post Office Box 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 the 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 records, ubservations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in' non-comoliance 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 pa'rt 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 and 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.
A
w- , ., ,,;.c ,
i
- k. i. -
1 The Cleveland Elsctric Illuminating 2 AUG 141334 Company The responses directed by this letter (and the accompanying Notice) are not' subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
We will gladly disc.uss any questions you have concerning this inspection.
- Sincerely, W. S. Little, Chief k 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/encis:
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 e
4 1
I 1
7
. Appendix 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 ident.ified:
- 1. 10 CFR 50, Appendix B, Criterion X, as implemented by CEI Corporate Nuclear Quality Assurance Prograni Manual, Section 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 on 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 crimping 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 verify 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 Corporate 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
+ .
l
. Appendix. 2 l 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 can be controlled and inspected and/or tested to specified acceptance criteria.
. 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 arrors and inconsistencies were identified.
This is a Severity Level IV violation (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 -
taken 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.
AUG 141984 gj Dated W.S.Little',Chiefg',g-Engineering uranch s . . . , . , - . . . _ . , - - - . . , _ . . . - . . - ,
~
U. S. NUCLEAR REGULATORY COP 911SSION REGION III .
Reports No. 50-440/84-07(DRS); 50-441/84-07(DRS)
Docket Nos. 50-440/50-441 License No.. CPPR-148; CPPR-149 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plants, Units 1 and 2 Inspection At: Perry Site, Perry, OH Inspection Conducted: April 9-12, June 4-7, 1984 Mb -
Inspectors: A. R. Naidu f [/4[IV Date
[
E. Christnot Date Z. Falevits M b i i Date l'.,
Tar.1 }D2 9 T 8//+f84 Date cif
^
A. Gautam .
Date' GL.aete.rafee;-
Approved By: C. C. Williams, Chief Plant Systems Section h/f!Of Date
~
-. - -. _- , - - - , ----w
o Inspection Summary Inspection on April 9-12, and June 4-7, 1984 (Report No. 50-440/84-07(DRS);
~
50-441/84-07(DRG))
Areas Inspected: Licensee action on 50.55(e) items; noncompliances; unresolved items; review of corrective action taken on nonconformance reports initiated in the electrical construction activities; installation of instrument-ation and review of their records; receipt inspection of safety-related limit switches for mainsteam stop valves and pressure switches for mainsteam control valves; independent design verification of instrumentation loops; separation of class 1E cables and qualification of safety-related equipment. The inspection involved 168 onsite inspection hours by five NRC inspectors.
Results: Of the nine areas inspected two items of noncompliance with mul-tiple examples were identified (inadequate design review - Paragraph (8.b)(8.d)(8.f);
inadequate inspection recor.ds - Paragraph (4.a)(4.b)(5)(11.b.(4)(h)).
e 4
9 l
2 :
l l
I 1
l
DETAILS
- 1. Persons Contacted ,
Cleveland Electric Illuminating Company (CEI)
- C. M. Schuster, QA Manager
- P. O. Martin, General Supervising Engineer
- R. G. Solt, Quality Engineer
- E. C. Christiansen, Electrical Engineer
- B. P. Walrath, General Supervising Engineer
- K. C. Kaplan, Senior Engineering Technician -
- E. Riley, General Supervisor
- G. Parker, Unit Supervisor
- D. E. Duff, QC Inspector
- V. K. Higaki, Unit Supervisor
- K. J. Cimmone111, Quality Engineer
- J. L. Lesnick, Quality Engineer
D. R. Green, Senior Project Engineer J. H. Bellack, General Supervising Engineer K. H. Matheny, Senior Engineer G. R. Leidich, General Supervising Engineer L. K. Comstock Company (LKC)
R. Bower, QA Manager C. Hart, Assistant QC Manager L. Pfenningworth, QC Supervisor R. Whithead, QC Inspector Johnson Controls Incorporated JCI J. A. Buschnell, Project Manager S. Young, QA Manager G. Christiansen, QC Inspector D. P. Baynes QA Auditor D. Lynch, Purchasing D. Gupta, Assistant Manager, Engineering J. Beddow, Project Engineer E. E. Gasti, Manager, Engineering M. W. Jefferis, Quality Control Inspector Gilbert Associates Incorporated (GAI)
A. Killian, Field Engineer, I&C General Electric Company (GE)
J. J. Larsen, Resident Site Manager -
J. Bucka, QAE E&I Representative 3 l l
1
- Denotes the persons who attended the exit meeting on June 7,1984. In addition to the above, other licensee and contractor personnel were contacted during this inspection. .
- 2. Licensee Action On 50.55(e) Items (Closed) Overtorquing of electrical cable tray splice plate bolts (DAR 68) (Reports 440/81-13-EE; 441/81-13-EE). This item is considered closed based on the review documented under closure of noncompliance 440/81-19-03; 441/81-19-03 in this report.
- 3. Licensee Action on Previously Identified Items
- a. (Closed) Noncompliance (440/81-19-03; 441/81-19-03): Inadequate program to inspect cable tray splice bolts. The subject inspection report cited three examples of inadequate inspection programs. One of the three examples related to inadequate inspection of improperly seated cable tray splice bolts. Licensee's action included reinspec-tion of at least 1000 cable tray splice connections and cable tray tests on worst case configuration.
(1) Bee-Line, the manufacturer of cable tray splice plates, performed destructive tests on cable. trays to provide assurance of the adequacy of cable tray splice connections. The tests evaluated the following as-installed inadequacies identified in the field:
(a) Bolt head dimensions were observed to be reduced by grinding to provide clearance during installation.
(b) Some bolts were supplied with " incomplete roll" of the bolt head.
(c) The possible installation of A307 type bolts rathe- than the higher grade 5 bolts.
(2) The test specimen had a worst case configuration with 25% of the bolts attaching the splice bolts deleted.
The test results indicated no adverse results with the use of or possible installation of " defective" bolts in small quantities.
The test concluded that the present installation would not degrade the strength of the cable tray below the level required for the Perry site.
(3) Approximately 1000 cable tray splice joints were reinspected.
The NRC inspector selectively reviewed the results of the rein-
! spection reports and determined that the observations documented therein were not significant.
This example of noncompliance is considered closed. One more example concerning the installation of the electrical containment vessel penetrations remains open pending review. -
4 ,
l 1
- b. - (0 pen) Unresolved Item (440/83-37-05; 441/83-35-05): (R:III-83-A-0122): An alleger identified as individual "A" contacted the NRC l with some concerns. A few days later on November 23, 1983, his l
- concerns were documented in the Plain Dealer newspaper. On-November 27, 1983,- the alleger met with CEI personnel in the ,
presence of the NRC site resident inspector and expressed his con-cerns. Refer to Paragraph 11.a for details.
- c. (Closed) Unresolved Item (440/83-37-06; 441/83-35-06): (R:III-83-A-0093): This item resulted from the followup on allegations by Individual "B" described in Report No. 440/83-37 and 441/83-35 and relates to inadequate inspection reports on rework activities in the main control room. This item is escalated to an item of n6ncom- '
pliance (440/84-07-01a/441/84-07-01a(DRS)) and is discussed in para-
- graph 11.b.(4).(h) of this report.
! 4. Review of Nonconformance Reports The inspector reviewed several nonconformance report (NCRs) initiated in the area of electrical installation activities to determine whether the corrective action taken was adequate. Of approximately (10) NCRs reviewed, -
l the following were observed to have discrepancies:
) a. NCR 2375 initiated on September 26, 1983, identified some unacceptable terminations on circuits 1821F7538, IM51F7B, and 1B2F767B. Recommended i
corrective action was to replace the lugs with new ones. The step taken to prevent recurrence was to retrain the craft. Corrective
{ action was verified on November 23, 1983. Training records indicate l that the craftsmen were retrained on November 9, 1983. Individual j crimping inspection reports (CIR) were included. In two CIRs, the
{
Level II reviewer's signature was dated November 22, 1983 which preceeded the inspector's signature, dated November 23, 1983. The l
calibration due date of the criinping tool used, was also in error.
The NRC inspector discussed the details of the inspection results with the concem ed individuals in the LKC organization and determined that the signatures and dates were in error and that the actual inspection
, results were not. The NRC inspector informed the licensee that reviews of inspection reports were not being performed adequately as reflected in the discrepant dates. The inspector informed the licensee that this is an example of noncompliance contrary to the requirements of l 10 CFR 50 Appendix B Criterion X (440/84-07-Olb; 441/84-07-Olb(DRS)).
! b. LKC 2568/PO 33-2424, Revision 0, dated November 17, 1983, identified cables violating the minimum bend radius. Corrective action recommended retraining the cables, and adjusting the supports to eliminate the
, bend radius violation. Cables were to be meggered to ascertain dam-age. If the megger tests were unacceptable, the NCR was to be returned for further disposition. The CEI Construction Quality :
4 Section (CQS) stamped the NCR (Owner QA " Hold" point-Released). !
/
The licensee explained that this stamp was intended to implement a
! requirement in Paragraph 1.04.b of the specification SP-709-4549-00 7
to review an NCT. prior to closure. CEI imposed a mandato'ry " hold" 5
-~m., e ~--,,,,-,,w,,,,,,,,--,..-,,,,,,---,,n,,
w-n,.--,,-,wn_-m,,~w ,,m-,,.wm_,,n,,,,,,,,4,,w-sme-w--,-g,,-v,-ww-.r,w,,,,-mnwn.,,v,,w,w-,e-e,
r~~:'
k .
point for CQS on the closure of all interface Nonconformance Reports.
The CEI CQS inspector signed the LKC QC inspection reports, which l included the Insulation Resistance / Continuity Test Reports for various cables and the (IR/CRE) Inspection Reports and cable' tray installation i checklists, several' days after the actual individual LAC QC inspections were performed. One IR/CTR on cable 1023R1168 had two inspection dates on it, namely 1/5/83 and 1/4/84. Some inspection dates were not legible.
The CEI/CQS inspector signed this report on 1/24/84 as acceptable.
Paragraph 3.3.9 of LKC procedure 4.11.1 states, " Interface NRs re-ceived by LKC for corrective action shall be completed in accordance with the prescribed disposition of the NR with the final verification r and closeout of CQC. Note: (CQS Hold point) CQS must be notified prior to closure of all interface Nonconformance Reports."
The inspector informed the licensee that the dates of CQS " hold" ,
point signatures on the inspection report did not reflect that CQS witnessed the reinspection on the day the reinspection was performed.
Other discrepancies in the dates of the LKC QC inspector's signoffs were not detected and corrected by the CQS inspector who reviewed -
the inspection reports. The intent of Paragraph 3.3.9 of LKC Proce-dure 4.11.1 was not properly implemented. The NRC inspector informed the licensee that this was another example of an item of noncompliance contrary to 10 CFR 50 Appendix B Criterion X identified in the pre-vious paragraph (440/84-07-01c; 441/84-07-01c(DRS)).
- c. NCR 2569 also contains misleading discrepancies in dates and does not reflect that inspections were performed in a timely manner. The NRC inspector stressed that inspection reports should be self-supporting and should not need additional documents to confirm that actual inspections were performed on one date and the actual closure was signed on a different date.
- 5. Review of Receipt Inspection of Components The inspector reviewed the receipt inspection process for pressure and limit switches which are mounted on the control valves and stop valves of the main steam lines.
The inspector selected reactor protection input pressure switches IC71-N005A thru D which actuate when the control valve is less than 90% open, and limit switches IC71-N006A thru H which actuate when the stop valve is less than 90% open.
Interconnection Wiring Diagram D-209-040 Sh. 1-4 indicates that IC71-N006A-H are Namco type EA-170-5111 limit switches. Receipt Inspection Report (RIR) dated February 22, 1984 and G. E. Project Quality Certificate dated February 14, 1984 indicated that 8 switches were received on site on February 24, 1984, that they have been manufactured under a controlled QA program and are in conformance with the procurement quality requirements.
No adverse findings were identified.
6 i
Review of RIR for IC71-N005A-D dated March 16, 1978, indicated that four pressure switches were received and due to a fire in the warehouse had to be replaced with new switches. The new switches were sent out on November 6,1980, along with G. E. Domestic Memo of Shipment, dated November 6, 1980. Neithe'r the G. E. Product Quality Certificate (G.E.
PQC) dated November 4, 1980, nor the CEI RIR dated November 18, 1980, identified the serial numbers of the switches; only the MPL number was identified.
Failure to verify the serial number is contrary to Paragraph 1.2.2.B of CEI procedure NQI-0711 which requires that receipt inspections verify that the supplier has positively identified all parts / materials by vendor's number and corresponding CEI stock number code, MPL, serial number, and/or engineering BM number as applicable. The inspector informed the licensee that the receipt inspector failed to verify that the vendor documents met all the applicable requirements delineated in the procedure NQI-0711 as reflected in the RIR and the G. E. PQC, and that a failure to perform and document inspections adequately is another example of an item of noncompliance contrary to the requirements of 10 CFR 50 Appendix B, Criterion X (440/84-07-01d(DRS)). .
- 6. Observation of Instrumentation Work and Work Activities Unit 1 (52053B)
The inspector observed the installation of instrument sensing lines for the reactor pressure vessel (pressure and level) located inside the reactor building (RB). The applicable specification is SP-90-4559-00(SP90).
Gilbert Associates Incorporated (GAI) performed the design work for the instrument line supports and hangers inside the RB. Johnson Controls Incorporated (JCI), the instrumentation installation contractor, fab-ricates and installs the hangers to support the sensing lines. Each support / hanger was designed for a specific location, designated with a unique number and assigned specific drawing numbers. Work performed on the installation is assembled in Installation / Fabrication (1/F) packages. The inspector observed the work performed for the following lines and examined the following I/F packages:
1H22 - P004 Lines Al and A2 1H22 - P005 Lines Al and A2 1H22 - P026 Lines Al and A2 1H22 - P027 Lines Al and A2 B21 - N12/ Azimuth 195*
The inspector determined the following:
- i 1
l
- a. The slope of the installed sensing lines as well as the installation of line supports met the applicable drawing requirements.
- b. All components were adequately identified.
- c. Instrument lines were routed in accordance with the drawings and appeared to be adequately separated. .
7
- d. QC inspections were performed on the welds, installation of hangers /
supports and were documented in the I/F packages.
- e. Reviewed activities,in the JCI fabrication s'op h and the storage and handling of safety-related material were found apparently in accord-ance with procedures.
No items of noncompliance were identified in the above area.
- 7. Review of Instrumentation Installation Records Unit 1 (52055B)
- a. The inspector reviewed the following records:
(1) Five (I/F) packages for sensing line supports / hangers, as mentioned in Paragraph 6.
(2) Welder qualification records for two JCI welders.
(3) Two JCI procurement order packages including receipt inspections for support tube steel and support plate steel. The inspector determined that the material was purchased from JCI approved vendors.
(4) Qualification records for one JCI Level II receiving inspector.
- b. The inspector reviewed the following records available at JCI on the installation of the instrument panels supplied by General Electric, the NSS supplier.
(1) The installation of the main steam isolation valve leakage control panel was in accordance with Document No. 1H22-P073. The rack is installed at elevation 599'-0 in the Auxiliary Building.
(2) Drawing 18 requires 1/2" diameter 13 Universal Nation Co.,
2" long Nelson Studs to be welded to the embedded steel plate.
The panel is placed on these bolts and the nuts are tightened.
A lock nut has been provided.
(3) Field Material Requisition (FMR) 0899 dated July 6, 1981 indicates that 18 pieces of 1/2" x 2" ASTMA-108 Grade 1010-1020 Nelson Studs were requisitioned along with other material.
(4) Daily Production Qualification and Inspection Report, dated July 7, 1981 indicates that the Nelson Stud Welding procedure QAS-1007/2 was qualified to weld 2 Nelson Studs with the TRW NS-30 type welding machine. The machine was set for 800 amps and 75 seconds. Two Nelson Studs were bend tested and determined acceptable. After installing 18 Nelson Studs, one nut was torque tested to 37 ft lbs and determined acceptable.
(5) Installation / Fabrication Planner (I/F) for the rack #1 indicates the various steps followed during the installation af the rack l
8
i
=
and the various inspections performed. The drawing indicates that the 18 holddown nuts (ASME SA 194 Grade 2H) were torqued to 37 ft lbs and a lock nut was tightened..
(6) Noncomformance' Report NR JCI 627 Revision 1 dated February 2,~1984 indicates that SA 307 Grade 8 nuts were replaced with SA-194 Grade 2H nuts to meet the specification requirements.
- c. The inspector reviewed the following records relative to the RCIC rack (drawing No. 1H22-P017P).
(1) The installation of the reactor core isolation cooling (RCIC) e
- Section B, Division'1 rack was in accordance with IIP drawing 1H22-P017P. The rack is installed at elevation 568' in the auxiliary building.
! (2) The records indicated that additional shim plates type A-36 were welded to the embedded steel (installed by the civil contractor).
Nelson Studs were welded to the shim plates. The racks were set on the Nelson Studs and SA192 Grade 2H type nuts were used .
to holddown the racks. All other records were similar to those in the above paragraph and were considered acceptable.
- d. The inspector reviewed the records related to the procurement of the
- flow restricting orifices installed in the instrument lines. These I were as follows:
JCI placed purchase order (PO) X87961 with'the Mutual Manufacturing
- & Supply Company (MMSC), Cincinnati, Ohio for 200 pieces of restrict-
- ing orifice, 3/4" socket weld (SW), 3000 lbs., SA-479, Type 304. The
- PO stipulated that the material met the requirements of ASME Section IIA, 1974 Edition through Winter of 1975 Addenda and ASME Section IIA 1974 Edition through Winte" 1975 Addenda Subsection NC. Addi-tional quality requirements were attached to the P0. JCI Receipt Inspection Report (RIR), dated May 27, 1981 indicates the receipt of
. 60 pieces of ASME-SA 479, Type 304, 3/4", 3000 lb socket weld fittings without any shipping damage. RIR dated June 5, 1981 acknowledged the receipt of the remaining 140 pieces. CAMCo Fitting Company (manufacturer) certified that the fittings would withstand a hydrostatic test of one and one-half times the fittings maximum permissible working pressure without bulging, cracking or leaking.
l MMSC issued certificates of compliance that the fittings with heat number EEC met all the applicable requirements. MMSC holds the ASME
' Quality Systems Certificate #QSC 279, expiring on April 29, 1983.
CAMCo provided a material certificate which included the chemical analysis, results of tensile tests and heat treatment.
- e. The inspector reviewed the records related to the weld rod traceable to the Heat Number 431E3931. 500 lbs of 1/8" diameter, E-7018 type weld rod from Lot 21924 was purchased to meet the requirements of AWS A 5.1-69 and ASME Section II, Part c, SFA 5.1 (1974 Edition) with
- Winter 1975 Addenda. Teledyne-McKay supplied the weld rod and provided i
9 i
.- .- -- , , . .- ,. ,,.- . - - - , _ _ ,-- -- - ___ , --,n- - , . . - . ~ - . - . , - . .
.. . .w. .
J
. the chemical analysis and results of the mechanical test performed on a specimen weld produced from weld rod with.this heat number.
Results included Charpy V-Notch impact tests at -20*F, filler weld usability test,. radiographic test and actual' concentricity.
No items of noncompliance were identified in the above area.
S. Independent Design Verification of Installed Process Instrumentation Loops
- a. The inspector reviewed a residual heat removal (RHR) system instrument loop selected at random. The schematic for RHR "C" flow is shown on G.E. Dwg. 828ES34CA, Sh. 9, Rev. 13. The inspector reviewed the following documents associated with the selected loop, and verified the installation by performing a field walk down of installed equipment associated with the following records:
(1) Pull card for cable circuit No.1E12R-10B dated November 5,1980.
(2) Pull card for cable' circuit No. 1E12R-138 dated January 15, 1981.
(3) Conduit layout drawing No. D-215-658, Rev. W.
(4) Conduit layout drawing No. D-215-212, Rev. A.A.
(5) Interconnection wiring diagram No. D-209-055, Sh. 9. Rev. B. -
(6) Interconnection wiring diagram No. D-209-055, Sh. 12, Rev. A.
(7) Interconnection wiring diagram No. D-209-100, Sh. 87, Rev. G.
- b. The inspector identified the following discrepancies between drawings and as-built equipment:
(1) Circuit No. 1E12-R13B on the wiring diagram (item (5) above) indicated cable routed to rack 1H22-P021 while it was actually routed to rack 1H22-P055 as required.
(2) GAI drawing B-208-055 Sh A10, Rev. J, indicated that this drawing had been updated to G.E. Dwg. 828E354CA, Rev. 13. However, the NRC inspector's review of G.E. 828E354CA, Rev.13 indicated that the GAI drawing had omitted the designation of device SRU38 and
. termination points on terminal block DD at panel H13-P642.
(3) Two different wires on panel H13-P642 TBDD-52 & 53 indicated the same wire code (E12A1015C).
(4) Lifted lead to device SRU2B on panel H13-P642 indicated that the loop was being calibrated since September of 1983. This record is incorrect.
(5) One of the wire markers was erroneous in Item a(6) above. On TBCC point I wire marker as installed is E12A1557R, but should '
be E12A1557A.
No other deficiencies were identified during field walk down and drawing review for this instrument loop. The racks and cables inspected appeared to be installed in accordance with the applicable drawings. Items 8.b.(1),
(2), (3), (4), and (5) above, are additional examples of the noncompliance summarized 19 paragraph 8.f. (440/84-07-03a(DRS)).
l 1
10 l 4
, ~ , _ . ~ . . , ,__ ~ m,--,__,,__,.,_.__,._~,.,m._,__.mm_..,_,_,_,,,.m-,..,,.~,,_,.,,.,,,.,,_..-,,,,.%.,---.,-,m~,---..
i
- c. The inspector selected the RHR System Steam Supply Pressure Instru-ment Loop Schematic for Valve 1E12-F051A shown on GAI Drawing 8-208-055, Sh. All, Rev. H. The inspector performed a field walk down to ascertain whether the installation met the requirements of the following relate'd documents,:
(1) GAI elementary diagram B-200-055, Sh. All, Rev. H.
(2) GAI interconnection wiring diagram D-209-055, Sh. 10 Rev. C.
(3) GAI interconnection wiring diagram D-209-055, Sh. 9. Rev. B.
(4) GAI interconnection wiring diagram D-209-100, sh. 113, rev. E.
(5) GAI conduit layout drawing D-215-211, rev. Y.
(6) GAI conduit layout drawing D-215-655, rev. U.
(7) GAI conduit layout drawing D-215-221, rev. V.
(8) GAI conduit layout drawing D-215-652, rev. Q.
(9) Pull cord for cable circuit No. 1E12R-4A, dated January 4, 1981.
(10) Pull cord for calbe circuit No. 1E12R-54A, dated June 26, 1981.
- d. The inspector identified the following discrepancies between drawing and as built equipment:
(1) In item (2) above, circuit 1R25-B62A on drawing was found _
as 1R25B5664A on equipment.
(2) Circuit 1R61-A846A was identified as 1R61A1218A on the equipment.
(3) TBBB-16 wire designation on drawing as E12A1123C was marked as E12A1123A on the equipment.
(4) TBBB-3 indicated shielded wire while equipment did not have shielded wire.
(5) TBCC-7,8 indicated cable on IC71-R7XA to be terminated, while .
equipment had cable' de-terminated.
Items d.(3), (4), and (5) are additional examples of the noncompliance identified at the end of Paragraph 8 (440/84-07-03b(DRS)).
No other adverse items were identified during field walk down and drawing review of this instrument loop. The rscks and cables inspected appeared to be installed in accordance with the applicable drawings.
The licensee indicated that ECN-18882-33-3129 dated February 22, 1984 was written to resolve items (1) & (2) above,
- e. The inspector reviewed process radiation monitoring systems elemen-l tary diagram drawing B-208-054, Sh. A02, Rev. F, which indicated that the fuse protecting off gas pre-treatment and post-treatment recorders 1017-R604 & 1D17-R601 respectively, and emergency service water recorder 1017-R602, was removed on a previous G.E. revision. GAI l engineers indicated that they are not required to review G.E. design 1 changes before they transfer them to GA1 design drawings. The only review performed is on interface circuits between G.E. and GAI design.
The inspector requested the G.E. field office to indicate the reason j for removing the protective fuse to the recorders; G.E. review in-
! dicated that the fuses should not have been removed and they initiated FDDR-Kl.1-3258 dated June 5,1984 to add the fuse back into the circuit.
~
11
\
l l
i
- f. The inspector reviewed the standby liquid control systems elementary l 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 (0514) circuits in MCB for "SLCS injection loop "A" manual valve position closed or system manually out of service" contained actuating contact from injection valve IC41-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 1C41-F036 was shown in loop A circuit as N.O. .
contact when per development it should have been 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 IC41-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.
4 (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 crawings 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 l
12 ,
1
- l
. area. The audit confirmed the inspectors' concern and the li-consee subsequently initiated Action Request (AR) 0043 dated June 6, 1984 to implement steps to assure appropriate maintenance of current desi.gn drawings.
The inspectors discussed the above findings with the licensee's staff. The licensee informed the inspectors that GDS Associates, Inc., an independent design reviewer, had been contracted by the licensee to review all safety related design drawings relating to G.E. and GAI. GDS Associates had com-plated 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 findings outlined in paragraph 8.b.(1),(2),
(3), (4), (5); 8.d.(3), (4) & (5); 8.f.(2), (3), (4) & (5) indicated a failure to establish adequate design control measures to prevent numerous discrepancies among design documents. This is considered an apparent example of noncompliance contrary to the requirements of 10 CFR 50, Appendix B, 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 showing barriers to be installed at a later date. See Table 1 for details. No apparent deficiencies were found.
Clast IE 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))
13
1
. TABLE I I Raceways Having l l l l l Separation Conflicts i Area /E1. I Drawing l _ Justification l 1 1 I l l l X1167 l l l Cable l l l l X1136 l Separation i A1680 l Spreading l D214-141 Rev. E l Barriers shown l l X1137 I + 8" + l A1688 i Room I l on drawing l ,
l X1138 l l A1681 1 E1. 638 l l l l I I I l l 1 l l l l X1168 l l l Cable l l l l X1146 l Separation i B1824 l Spreading l l Barriers shown l l X1147 l +9"+ l B1825 i Room l D214-141 Rev. E l on drawing l l X1148 l l 81820 l E1. 638 l l l l X1169 l l B1830 l l l l l l l l l l Separation l Cable l l Barriers shown l l X964 l + 6k" + l A618 l Chase l D214-143 Rev. N l on drawing i l l E1. 638 l l l 1 l l l l l 81830 l Cable l l l l 't l Spreading l D214-141 Rev. E l Barriers shown l I Separation 1" l Rocm l D214-143 Rev. N l on drawing l l 4 l El. 638 l l l l X1146 l l l l 1 I I I l l l Cable l l NCR LKC-2305 l l A654 & A636, IR33R906D l Chase l l 08/30/83 l l l E1. 638 l l l 14
- 10. Review of Class IE Qualification of Equipment ;
The inspector reviewed equipment from three suppliers, Rockbestos, Cutler-
. Hammer and General Electr.ic for Class 1E qualification of supplied equip-ment. -
One item was reviewed for each supplier. The following exceptions were found:
- a. During review of the qualification of Rockbestos reel SKA-109 2C#14, it was observed that there was no evidence of a dielectirc test being performed on the cable prior to cabling. This is a requirement per '
spec. SP-560-4549-00, Rev. XX and ICEA S-68-524, Rev. 9 The licensee reported that this test report exists at the supplier location and that it will be made available for NRC review.
During review of the qualification of Cutler Hammer MCC 1R24 50018, it was observed that test reports and Procedures 58900 & 5842, re-quired per Spec. 557-4549-00, Sec. 2.08.2, had not been submitted by the supplier. In lieu of this the licensee presented an inprocess inspection report as evidence of testing. The licensee was advised that IEEE 323, Sec. 8 and 10 CFR 50, Appendix B, Criterion XVII requires a test report to contain data that demonstrates the qualifi-cation of the equipment. The licensee reported that these test reports will be retrieved from Cutler Hammer for NRC review.
Pending review of test reports from Rotkbestos and Cutler-Hammer, this is an unresolved item. (440/84-07-05(DRS))
- b. The inspector reviewed the Class 1E qualification of General Electri.c Rosemount 1152 pressure transmitters. The licensee reported that dut to prior contractual agreements, all G.E. supplied aquipment and qualification documentation was maintained at the G.E. San Jose Office in California. Due to limitations of frequency and scope, the licensee's audits of G.E. in San Jose could not provide evidence of Class IE qualification of these instruments. Due to a lack of documentary evidence the inspector could not determine if the Rosemount transmitters were qualified to Class 1E requirements or if G.E. had monitored Rosemount during manufacture of these items. Pend-ing further review of this matter, this remains an unresolved item.
(440/84-07-06; 441/84-07-06(DRS))
- 11. Review of Allegations The inspectors reviewed and examined the allegations received from various individuals as identified in previous NRC inspection reports as follows:
15
.i Individual A (R:III-83-A-0122)
(Details Par. 11.a in this report) .
Individual B *R:III-83-A-D093)
Paragraph 9b in report 440/83-37(DRS); 441/83-35(DRS); 440/84-05(DRS; 441/84-05(DRS)
(Details Par. 11.b in this report)
- Individual C (R
- III-83-A-0121)
Paragraph 9c in report 440/83-37(DRS); 441/83-35(DRS) 4 Individual D (R:III-83-A-0108) j Paragraph 9d in report 440/83-37(DRS); 441/83-35(DRS)
Individual E (R:III-83-A-0048)
Individual F (R:III-83-A-0062)
Paragraph 9f in report 440/83-37(DRS); 441/83-35(DRS) ~
(Details Par. 11.f in this report)
{ The allegations and results of investigation are discussed in the following
! paragraphs as referenced above.
J 1 a. Individual A (R:III-83-A-0122) Contacted the NRC with some concerns.
! A few days later, on November 23, 1983, his concerns were documented in the Plain Dealer Newspaper. On November 27, 1983 the alleger met
) with CEI personnel in the presence of the NRC site resident inspector 4
and expressed his concerns. Pending review of the CEI's corrective
- - action an these allegations, this item was identified as an Unresolved
- Item 440/83-37-05; 441/83-35-05.
CEI documented the alleger's concerns and the NRC inspector verified j the licensee's investigation / corrective action as follows:
(1) Allegation: The alleger identified a specific instance where a
- cable tray was filled with debris, including electrical wiring and welding material.
1 Licensee's Corrective Action: LKC NRs 2419 and 2570 were written i
to clean cable tray 622 in Reactor Building #1'at elevation ;
634'6". The debris was removed and the tray was reinspected for
} damage. No adverse finding 5 were identified.
+
l
Conclusion:
The allegation was substantiated and corrective action j taken by the licensee appears to be adequate.
i f
I L
3 16
. . , - , , , . - - - _ ~ ~ ~ _ . , , , ,-..,,,,.,,,.._,,y_- ._-.w-_. .,_,,_,..,yy,,.,.-,,--,,..-m_ . . , . . , . . , _ .em,. .. - , , . .
, (2) Allegation: Conduit installations by the craftsmen are not meeting the acceptance criteria. The alleger had brought this to the )
attention of LKC management in May, 198,2.
{
Licensee's Corrective Action: The LKC Corporate QA organization performed an audit and initiated Corrective Action Request (CAR) 008 on May 10, 1982. LKC hired a full time training coordinator. ,
Subsequently, on April 25, 1983 LKC QC initiated CAR 011 to '
the LKC Project Manager informing him that conduit installation did not meet the acceptance criteria. CEI Lead electrical construction engineer in a letter (PY/50-33-18112) dated June 13, 1983 informed LKC that due to field installed non-class IE raceways and accumulations of installation tolerances, the actual design of class IE divisional raceways may inoeed violate the established separation criteria. He informed LXC that the Conduit Design Group has been instructed to review the specified detailed drawings more closely. Based on this letter CAR 011 was closed.
Conclusion:
The allegation was substantiated and corrective action .
taken by the licensee appears to be adequate in that the existing conditions were corrected and the program governing these activi-ties was improved.
(3) Allegation: The alleger identified examples where he was asked to write Inspection Reports (irs) instead of Nonconformance Reports (NCRs).
NRC Action The inspector reviewed the documents identif.ied by the alleger and determined that in all instances, irs were appropriate, as follows:
(a) NCR LKC 2434 dated October 12, 1983 identifies examples of inadequate information on a drawing and reference.s a Field Variance Authorization (FVA). This NR was rejected on the basis.that there was no conflict with the FVA which would invalidate and/or question the field instal 1ation and QC
~
inspection requirements.
, (b) NCR LKC 2264 dated October 11, 1983 identifies a conduit installed to Engineering Change Notice (ECN) 2454. This NCR was rejected because QC inspected the installation to Revision A of the ECN instead of Revision B. IR dated December 13, 1983 was correctly issued instead of the NCR.
(c) NCR LKC 2412 dated October 7, 1983 identifies some problems ;
with design drawings. The NCR was rejected because they l were not hardware problems. IR 8210 was correctly initiated '
on December 8, 1983 to clarify drawing correlations.
17
m ~_-ma .- -- . - _ . m . - . _ . - _ . -
4 x .. . _ . .. - __
.1 l
(d) Review of Inspection Reports (irs) 5537, 6767, 5639 and 5784 indicated that various discrepancies, ainor in nature, were identified and corrected. IR,5784 has not been officially closed out. '
l
Conclusion:
The allegation is not substantiated.
(4) Allegation: The alleger complained of harassment from production and stated that quality control concerns were ignored if they slowed production. He suggested that interviews with other LKC '
inspectors be used to assure that this situation does not exist.
Licensee's Corrective Action: The licensee has conducted inter-views with other LKC inspectors. Additionally, the licensee interviews'every QC inspector who leaves the Perry site. The i licensee stated that they are unaware of LKC production personnel intimidating QC inspectors. ,
Conclusion:
The NRC inspector concluded that this allegation is not substantiated based on the results of the licensee's efforts -
and the NRC inspectors' discussions with other LKC personnel.
Based on the above activities by the licensee and results of the NRC i
investigation, portions of individual A"s concerns have been adequately addressed. NRC will continue its evaluation of these issues in subse-quent reports. This item remains unresolved. (440/83-37-05; 441/83-35-05) "
r b.
Individual B (R:III-83-A-0093) contacted the NRC with his. concerns.
Subsequently, he contacted the press. CEI officials interviewed him and documented his concerns. The NRC inspectors identified one item l
- of noncompliance (440/83-37-04; 441/83-35-04) after. reviewing the
- inspection repo'ts and nonconforming reports generated by Individual B.
j The item of noncompliance identifies inadequate procedural requirements '
for initiating a nonconformance report on equipment supplied by General Electric, the nuclear steam supplier. NRC inspection reports (IR) 440/84-05(DRS) and 441/84-05(DRS) document the NRC inspection i performed on Individual B's concerns. The licensee's review of work performed on the Main Control Room panel, also known as the Power Generation Control Console was not complete. The following informa-tion summarizes the results documented in the above inspection 1
reports and the results of this inspection. ,
l . (1) Allegation 1: Individual B alleged that L. K. Comstock craft performed work to implement field disposition instructions (FDI) l without the benefit of work procedures. He further alleged that j inspections may not be completed and test equipment used may not j be traceable. He furnished a list of FDIs. The NRC inspector reviewed the allegation and concluded (440/84-05(DRS); 441/84-05 (DRS)) that individual B's concerns were valid but were approxi-
- mately two years old. During this period, work procedures and
- inspection requirements were revised and upgraded. Furthermore, i even though the work was completed, the licensee had not reviewed i and accepted the documentation.
18
__. a,-____- _ _ _ _ _ . _ - _ . _ _ . _ . _ . _ _ . _ _ _ _ _ . _ _ . _
4 1
(2) Allegation 2: Individual B stated that he wrote a meno to the LKC QC Manager on December 17, 1981 listing outstanding engineer-ing change notices (ECNs). He was concerned that the work may not be complete and the inspections. performed on ECNs may not.
have been adequately documented. The NRC reviewed this concern
concerns were approximately two years old. During this period, work procedures and inspection requirements were revised and upgraded. Even though the work was completed and the document-packages have been considered complete, the licensee has not yet received and accepted the document packages.
4 i
(3) Allegation 3: Individual B provided a list of adverse findings.
The NRC inspector reviewed these adverse findings and determined that these adverse findings are documented in various LKC in-
- spection reports and have since been corrected, verified and accepted. Details of this review are discussed in Inspection Report No. 440/84-05(DRS); 441/84-05(DRS).
(4) Investigation: During the current . inspection, NRC inspectors reviewed additional Field Disposition Instructions (FDIs) and Field Deviation Disposition Requests (FDDRs) initiated by i
General Electric Company (GE) for the modification of the Power Generation Control Center (PGCC). This review is a continua-i tion of the review documented in NRC Report 440/84-05(DRS);
441/84-05(DRS), and Unresolved Item 440/83-37-06; 441/83-35-05 is escalated to an item on noncompliance 440/84-07-01; 441/84-07-01 as discussed in subparagraph (h) below.
1 The inspectors selected a number of FDIs and FDDRs related to Unit I which were alleged,to have been performed without the
] benefit of approved procedures. The inspector reviewed the j FDIs and FDDRs for adequacy of implementation and to dete.mine j whether the inspection reports (IR). reflect the verification of i the completed work. The following documents were reviewed:
(a) FDI-WNEL, Rev. O issued on March 31, 1981, required that ship-short items be properly installed in the field; this i FDI was returned to G. E. for lack of applicable documents and was reissued on February 1, 1982 with all required documents. Work Request 233E was written to implement this l FDI, and KLI-711, Rev. O dated March 15, 1982, was issued to correct cable number errors on Rev. O of the FDI.
Inspection reports on visual and continuity tests indicated i that results were satisfactory. G. E. site office trans-
! mittal letter indicated that the work performed was reviewed l
and approved by G. E. and the item was closed.
l (b) FDI-WNDY, Rev. O dated February 19, 1980, was issued to
! assure that items that were shipped short from the manu-l facturer were properly identified and installed in the
- field (cables, duct covers) on panel H13-U735. ' LKC QC 19
I~ .
' inspection reports IR1510, 1003, 1004, 1005, and 6285 document the inspections performed to verify work on this FDI. They indicate that visual and continuity tests were performed,per LKC Procedure 4.3.30 and QA requirements, and that no unacceptable findings were identified. FDDR' XLI-638, Rev. O was written to correct errors in routing of cable N41-023 in the FDI.
(c) FDI-WNGQ, Rev. O dated July 28, 1980, required replacement I,
of old trip units B21-N673C, G, L and R with new ones.
- IR1409 indicated that the work performed was visually ,
inspected and determined to be satisfactory. l
\
i (d) FDI-WNGW, Rev. O dated July 28, 1980, required that old legend plates be replaced with new ones. IR1047 indicated -
that a. visual inspection was performed and found acceptable.
(e) FDI-WNCK, Rev. O dated January 4, 1980 and Rev. I dated April 23, 1980, required changes in termination and connection to match 7916 cable data base in termination cabinet H13-P712. irs 6602. 5830, 5872, and 5873 indicated -
that visual inspections and continuity checks were per-formed an.d determined acceptable.
(f) FDI-WNCO, Rev. O dated January 4,1980, recuired changes in termination and connection modules to match 7916 cable data base in termination cabinet H13-P717. Part of the work was performed by LKC, and IR 1037 indicated that visual continuity tests were satisfactory. The rest of the work was completed by G.E. using traveler No. TI-97-148.
The FDI had been used as the procedure for installation.
Compliance and verification indicated that inspections were
, performed and accepted. Also', visual and point-to point continuity checks were performed and signed off by QC.
(g) FDI-WNJF, Rev. O dated July 30, 1980, required that term.in-ation and connection modules be installed and tested visu-ally and point-to point continuity checks made. IR 1052 indicated that installation had been completed; however, continuity checks were not performed on the connectio'n modules and will be performed when pins are installed per a new FDI in the future. Discussions with G.E. personnel indicated that a FDI will be written when the assigned '
cable is installed.
(h) FDI-WN8E, Rev. O, dated January 4,1980, required that old termination modules be replaced with new ones and that specified jumpers be added. The checklist for Insulation Resistance and Continuity Test Report lists the module TM 057 on the top, but does not ir.dicate in the continuity check column whether any pins failed the continuity test.
The LKC QC inspector, however, signed the test' report.
20
i This test report, which was included in a package, was reviewed and accepted by G.E. even though it was incomplete. ,
The NRC inspectors informed the licensee that the inspection report was incomplete and did not reflect inspection activi-ties or results of the inspection. The NRC inspectors also informed the licensee that this was an additional example of noncompliance contrary to 10 CFR 50 Apper. dix B, Criterion X (440/84-07-01a(DRS); 441/84-07-01a(DRS)).
(i) FDI-WNJN, Rev. O dated August 28, 1980, required wiring changes to panel H13-P680. IR 1563 indicated that visual inspection and continuity checks were performed and found i acceptable. Errors found on this FDI were corrected'by FDDR KLI-697, Rev. O, dated February 18, 1982.
(j) FDI-WNGZ, Rev. O dated July 30, 1980, required modifications to some panels. IR 1104 indicated that visual and contin-uity inspections were performed and found acceptable. t (k) The inspectors reviewed the following FDIs and FDDRs -
related to Unit 1: FDIs, WRBP, WRBN, WRED, WRHE, WRBD, 2 WRDS and WREP; FDRRs KL2, 559, 556, 546, 537, 551, 554, 565, 532,.544, 526. All FDRs with the exception of KL2
[
concerned routing of cables in the control room. The '
inspector reviewed three nonconformance reports and determined that they were adequately dispositioned. The LKC QC inspection reports reference the applicable LKC QC
- . procedure for verifying work completed on FDDRs. The inspector determined that the G.E. FDI served as a proce-dure for accomplishing the work. The NRC inspector observed.LKC QC inspectors performing reverifications on FDIs which were considered complete.
Conclusion:
The allegation that the procedures were inadequate could not be substantiated because the inspection reports (IR) written while implementing the FDIs snd FDDRs contained refer-ences to various applicable LKC procedures such as Procedure 4.3.18, LKC/GE-24, LKC/GE25, which relate to continuity checks and' implementation of FDI and FDDR requirements. G. E. had used the FDI itself as the procedure for implementing it. The
- NRC inspectors determined that the inspection reports did not specifically state activities inspected and scope of acceptance.
, This matter has been identified as an item of runcompliance in Paragraph h above.
(5) Allegation 4: Individual B stated that two cables with no black ID tags entered Compartment YE in Motor Control Center 1R24-5018 and were not supported in any way.
The NRC inspectors' reviewed compartments YH & YE and identified g two #6 black wires which had been prewired by the vendor from i
21
~
, power distribution transformer EFB-1-A2 (1R25-5033) at compart-ment YH, to disconnect switch in compartment YE. Since these are vendor wired, no black ID tags are required by the licensee's program. Cables were tie wrapped and supported in both compart-ments. While the allegation was substantiated, the absence of the tags is appropriate and acceptable.
Conclusion:
This allegation was not substantiated.
(6) Allegation S: Individual B stated that a wire leaves the cable
. at 90 degrees on Cable 1R61A-843a to compartment HH.
The NRC inspector visually inspected Cable 1R61A-843a and determined that this deficiency does not exist, and the allega-tion was not substantiated.
Conclusion:
This allegation was not substantiated.
(7) Allegations 6 and 7: Individual 8 stated that in Compartments K, N, F and G of MCC 1R24-5018, various cables violated the ,
training radius.
The inspector visually inspected all cables in above compart-ments and in 24 additional compartments, and could not identify any cable training violations. One loose terr.ination was identified; the licensee indicated that an NR would be written to correct the deficiency.
The inspector reviewed NR 0QC394, dated December 5, 1983, which documents that four cables in the above MCC had training radius violations. This was corrected and signed as acceptable by the QC inspector.
The inspector also reviewed IR 3845 dated October 4, 1982,
- which identified nine cables in MCC 1R24-5018 that were not properly supported. Corrective action was.taken to support these cables properly and QC inspection was performed and found acceptable.
CEI Quality Section "OQC" performed an overall inspection of 1R24-5018. All items were accepted with the exception of those documented on NR #0QC394. ,
Conclusion:
This allegation was substantiated. However, all items identified by individual B appear to have been taken from incomplete inspection reports on which corrective action w:s being
.taken. All of his concerns have been corrected in the normal course of corrective action. The NRC inspectors looked at other Motor Control Centers and determined that there were no similar problems and that the Itcensee/ contractor inspection program was effective in this specific area. ,
22
4
. (8) Allegation 8:
Individual B furnished the names of five individuals who he stated "were never tested for knowledge of a full power termination, during the testing of individuals not one was tested for full power termination involving Raychem kits."
During this inspection, the NRC inspector reviewed the training and certification records of the five individuals mentioned.
Four of the five were certified as Level II termination inspectors.
One of the five did not pass the practical exam and therefore ~
was never certified.
The inspector reviewed the written test given to the above individuals which contained twenty questions. Six of the twenty were power cable termination questions; one of the twenty speci-fically related to Raychem heat shrink terminations. All training for terminations was performed in accordance with LKC Procedure 4.3.6 which includes power terminations and Raychem kit installations.
All five passed the written exam with a grade higher than 80%, -
which is the minimum passing grade. Four passed the practical exam and were certified in April, May, and June of 1983.
The inspector noted that Individual B conducted some of the training sessions for the above individuals, and that a newly certified individual would train his co-worker. Consequently some of the five individuals mentioned would conduct training sessions for each other.
It appears that the training requirements, including on-the-job training, as recommended by ANSI N45.2.6 " Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel," were met prior to these inspectors beitig certified.
Conclusion:
This allegation was not substantiated.
- c. Individual F (R:III-83-A-0062). Individual F was an ex-employee of Johnson Controls (JCI).
Items 1, 2 and 3 of the allegation were discussed in inspection report 440/83-37; 441/83-35. The following paragraphs summarize items 1 and 2 and document the results of investigating items 1, 3, 4, and 5 during this inspection.
(1) Individual F alleged that JCI had inadequate procedures. Examples are procedures: QAS-1001 (visual weld inspection), IF/ Planner inspection control, Hilti-Bolt, welding and QAS-1601 (noncon-formance). This item was identified as unresolved in report 440/83-37-06a; 441/83-35-06a.
During this inspection, the NRC inspector reviewed the above procedures. These procedures have been revised since 1983, and appear to be adequate. Selective review of the implementation of these procedures indicate no unacceptable findings.
! 23
l l
This item remains unresolved (440/83-37-06a(DRS); 441/83-35-06a l (DRS)).
(2) Individual F alleged work package trave'llers were left unattended.
The inspector determined that unattended travellers do not violate any NRC regulations.
1 (3) Individual F alleged that JCI had poor work procedures. During this inspection, the NRC inspectors reviewed the implementation of several work procedures and identified no unacceptable findings.
This item cannot be substantiated.
(4) Individual F allege'd that the pipe support standard issued from document control is not stamped " release for construction"; how-ever, JCI QC inspectors inspect.to this document.
The inspector discussed this concern with cognizant members of the JCI management and determined that in the past there had been verbal directives from supervisors to override Gilbert 818 drawings. The NRC inspector determined that during 1983 drawings were not stamped " release for construction." -
These drawings contained tolerances that JCI QC inspection personnel used to perform inspections. Considerable delays were experienced in the issue of drawings requiring this stamp.
Since late 1982, the drawings were stamped. During the review of the preparation, review and issue of drawings for the in-stallation of instrument sensing lines and .their supports, the NRC inspector determined that an on location design group was established to design the routing of instrument sensing lines and their supports. Designers would look at the location of the sensing lines and consider the physical obstructions sur-rcunding the lines due to work performed by other disciplines such as large bore piping and their supports. The designers would then go back to their trailer and design the routing of the sensing lines and their supports. However, when the final drawings were issued to'JCI for installation, JCI personnel determined that the design could not be implemented either due to interference or due to the description of welds. In most cases, an Engineering Change Notice (ECN) was issued to revise the design. The NRC inspectors collected a number of such '
drawings and discussed the contents of these with the licensee.
The licensee agreed to evaluate the examples to determine the adequacy of the design review process for the on location design and drafting. This portion of the allegation was sub- {
i i
stantiated, however, the practice described is acceptable.
( Pending review of the results of the licensee's evaluation, l
this item is considered unresolved. (440/84-07-02(DRS);
l 441/84-07-02(DRS))
1 1
(5) Individual F alleged that an "N" stamped 3/8" valve was found in the trash area. A nonconfermance report was written with a dis- l position to down grade the valve to non-safety.
24 l
l 1
_ _ _ _ - _ . = _ = . . = _ - :.- -
Discussions with various JCI personnel indicated that in May 1983, a "N" stamped valve was inadvertently left lying on the floor and that the cleaning craft placed it in the trash can.
This valve was recovered, JCI NCR 2340 was-initiated on May 2, 1983, and " Hold Tag" 746 was applied to the valve as required' '
by Paragraph 5.9 and 5.11 of JCI procedure QAS-1402. The dis-position was to scrap the valve. It was further stated that similar occurrences will be tracked via trend analysis as required by JCI procedure QAS-1701.
This portion of the allegation was substantiated, however, the incident was adequately controlled.
Based on the above results of the investigation into alleger F's concerns, except as noted, these items are closed. The remainder of Individual F's allegations will be reviewed during subsequent inspec-tions. .
- 12. Unresolved Items U'nresolved items are matters about which more information is required in -
order to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items disclosed during this inspection are dis-closed in paragraphs 10.a. 10.b. and 11.c.(4).
- 13. Open Items l Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licer ' e e or both. Open items disclosed during the inspection are discussed in Paragraph 9.
- 14. Exit Interview The inspector met with the licensee representatives (denoted in Persons Contacted) at the conclusion of the inspection on June 7, 1984. The inspectors summarized the purpose and findings of the inspection, which were acknowledged by the licensee.
25
(.
- s .
g* . - - -
A , e 5,
as _
_ .m.m.
mme q
, w =r a r H o o'o n o. a o 5 e. - - .
D o9 o e o IN -
.y, 3es .
, ,, <g
- p ,
l
}3 y
, , j- .
..Tog o
c o Q t - C g 9 4 -
P I d b
,io i
- t e c
g _t _ g L-
- i
. J., ,! 4 de ,$ .$ ? "aof b .,3d -
. b __ s _ ~ H. a-5_1 -
L n env O g ~dj w t.J. c u,
g 4J o(*~ __
iq f gg 1.tl 1 < 5, - a, la 7- ,
l G UMWbf5 5$$O _
$ l 2;.
- Tu !
k.C s ~. I- J. I
~* 1
- I,) ' i I I. i l 1 l
(
-Y., hl ,\
- *5 1
h, 4 l
=
s qi %,.
a V
o
,3
. .o
) , ,
h a I L
.< so :: ~
i g -c _ _
e ;
/
- b. e,
, I .g , -
1- -
l "U I t)__$ M g' '". "[ -
O 7 1- 4 * - 't' 2 -
- , i c -
t .
l 3)c d E - - -
1 L u _
q _ - --
, f _ _ -
l 04 -
c - -
g g ca - -
.cg$1 ; -
i --
g.y.
uv G5 f()
Q x e _ - __
es _
Y c o --
i o5 _ _ _ __
t i
-0 y
_ f, -
_ f
' :s.w'- yL . }3 _s - _ --
V -
- .mm.mu-g :,
.u.m..s gq m m.mq . m
,s, __ :, ,,
e o
l._f 8 -T p_ E - - _ __
. x d w-Ji -
u- -
e3 e' J
- i. ! _ _ , -_. --
4 * -_ .
.*0 - - _- --
s,2=
T~
s _n._t.
. r_ . g,_ p -
]3, , >>__ <1 _
a oa 55 % __s 4 __ __ --
__ 4 EJ J )g w __ "., 5. *- r 4 - 'C -
_ e
__ y
_ _ 4
-J -
- 4. .. ,_.__ , W _ t I_J _ =Y - -. t _
I- . 1 .
. i i
a, ,. . _ _ -
TC $i*
C5 b2 dd2, oc o, H,, eeo'c c ,,u.oa. ' .J o Y' LC - -
1 E. A ,,
f , 4 .ya _
c' 1
4' .
g 3,t - -
a 0
5 1
g .
_ - g -
R '$
f ,
- R.
.j
,q e. .: R_ - 3- ,
- c. tc ' s 1 c -
4
- ;p
- e v .,Z d # # #a
.4J N -
.N }4 ,
. 4.8 ,o, - e S .w L a in v O g .*f ci
- 6 -- - --
e e g. g _ b 9* io
, c --
8 5 <W a H a,o_E 2 2 2 M -
- 2 '
- I
- U I IJ
- G.
. B.c .!
-
- 1
. l
-t's.,gq
.%_ rg- ,
? s, '4 w i
- w 9 -
f -
$ t 5 -
q) %. . - -
i
--e C
a, ,p 5' -
., ?t o
=
= $':_
1 e
- b. e,
- 1 -
- - 1 1
1 I h
_$ ""'.\ [ _
O-~~7 c
1-Z d ). .
t 2 -
i I
i i
i
.- e
$c d E c
1 L -
4 -
ti e -
l 0d -
c -
d t ,T - -- -
G o
yp Q. ve - - -- --
d cy o
'# 4 c
~~
o5 1 ._
_ s - - --
yJ -g ,
(xH_;aw l,.en -
.a m(v
. p --
i . _ - N
- g. D,a d _
- ^
br]= -_
- 48 e
r ca - - -- ,
gL _ _ _ -_ ,;
y
=
1 t 346 t, _
- g_x c _ _
3 m
cl e ._
s %g _ _ - - --
$u_4 .a*
x _
4 _ - - . --
4 * - -
W y- * --
-7 7m1 __
L O is J.' -$ . m -
s I>-- > 1 = S o 4' 1 ss_ , G" z 4: o _ __ --
EO 3
~
r _
,c 'C - -- ~
-- *+
, 4.
o,2. . w,5 s Z J (0 _ a.,
A -
Z~. ..
.l ' ,il .
- l 1 1 -
, , . I 1 1 4
' g2, I 1 1 a.e
- - , , I 1 1
- t. 44A
- I 1 1 1
EiQRc.sooFPLb i 1 1
. ;t 1 : 4 2 : ;
t, l 1 1 .
3, y w 4t
. l 1 1 _
. +
t i ee t
r.
ss I
1 1
1 1
1 1 1 e \. 1 s 3 ce h. *., .
h c c, r.
l n n9 1 e
.- s a e.
nil .
l l J.,ll d u S.. o op t l m
1 l
) ev t. o m I r
1 rm l .
i .t. s%:r's - (:.bao2g 7J 's Mo N t -
r 1 % - 1 - l v.
J '
p sses 'o e. c n sr
- o. n\
h si /OTSoAilcbLb l
r c dr u :y : gi e e*c t Ee v i
Rih 1 1
1 1
I1 Il Il -
1
. u .
u~
n 1
C l
l e: 'r..
T:,
y!
l t; jv l f
- _W " f ,
? 'y l
1
'" RI ' ?, j D..
1 1
w 1
i 1
e N.t o g
. I 1 II k G s I 1 s e - 'b I 1 pk. I 1
. I 1 d
1 I
wae _
_ " I 1 l
- U I
R a. _ i m v.,
. l
] " dr'l l E'r a. l n -
1 1
i -
h.
1 ll 1 1 I
cL I 1 1 I 1 l 1l
. C m I 1 l 1l Y e I d
. l l 1I ll ll W
. ll I l l e
l hA o I I .
s.
a si l
l 1
1 l1 L
1i 1l ll ll wC l g . 's l 1 l 1l '
ll u% plt. f s l 1 ll 1l ll 3
I n l A l 1 l1 ' 1l ll soe.
- ll 1l l
n 1 1 l1 c I o sr 1 1 l1 1l ll ra I A 1 1 l1 1l ll e f .,., ll PrI - I A'f,T.OT4 4 1 Y.
~
1 1 1
l1 l1 ll ll ll l
~
l 1 l1 '
1l II 1 ll l l l 1l e .
- k1 1 l l l 1l ~
e s *
- e
%",11 nt- a I I
I n
I l
l 1
6 a 4 0
I 1
1 l
l l
l l
l 1l 1l 1l
- - c. -e a n l
II l t R. FT I
I r
}"
l' 1 1
r r
h s 1
1 l
l l
1 1
1 ll l
ll l
1l l1 I
- ' Y. 1 l1 b 5 C 1 l 1 - ll 1l
'% 1l A ,, , 1 l 1 1 l I1 e
. % l1 ll hI J
D 1
1 l 1 l 1 1i 1l 1 i 1l myy iJ J
a I m
n u
1 he 1 l 1 1 l MM nt I n
1 1
1 1
l l ll 1l ll 1l g-I ,
hu uev n
- a . 1l II I r u. l r 1 l 1 l 1 ll
/.
4 1i m 3I%
1 1l I -
re 8 b.f 1 l
'l r. E [ M ll I1 r,
1I 1l
!1!1 , 1 4 ;lilJl;! i ilL ,liIl !;ilili 4 ;l!'
%pk: t pe g c Lc.
3 T o.c.hinQ dem <
[u s.,g 1 >E ma.e, - .
so ss(e) .
F nomp tinres.tv.am tt 14em W. %"ee
~ Person aho .tu aaie Gt# cah /\EO's tk- '
bcr yy , , , ,, ,
- - raenb".C A Wern .
t order = ii uc.nsee -- R
' - 1IIIIIIIIIIIIIII e _ _ _
Int.'s : r. '
/
ra i
7 . . 'A YEi5 E s.cg gtcp,y t.cg S;yn tie m\SA=8 T%s* eo 5
- v. s,eN ,
Mm uc.n bs.s.
- sQ Event. .)A. R.,- +. .ia. To lIIIIIIIIl1 @^ ab " oo.n-F11IIII, to CF R 20 F-
[IIIII] Q*a '/is eyydnne ,InivMamb , '/wa Fb t ?J : P g,u u,, 3"P'jg- *bson kss,*,gne,L %h,, LQ's bevioMons - : >b L,
T' 143nea ptiacces-s'euedkg
' IIIIIIIIIIIIIIII ra fIIII13
- 4rran6=IIIIIII y.. ,
te9ds*bt;% *.6
.g v. . , .
3 r1c.h D as'c.r'spMon ~
- IllillIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII 4.:
~3"nSp aAb -
'h' i" f.fi3. Illl1111 1IIIIi1
- ^ ~
1 off _ _
l r.,,..s l n I
i
- ,v:r.,, lll1II11IIIIIIII 4
"fm ,
g ,
v.
i.
u ..> - '
1 dw:::c .. Il 11 LI I l l l l l l 11,
- * */as -
9 (rl__ _ _
1 '
e, _ $
-- __'I I
9 000XETED P.O. Box 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMikEiiNE BLDG. '- 55 PUBLIC sOUARE Serving The Best Location in the Nation
'84 00T -3 All :04 MURRAY R. EDELMAN 0FFICE 0' ildL +1 E' N yjCE e ,R September 13, 00rKETthG & SERViN 1984 BRANCH Mr. W. S. Little, Chief Engineering Branch Division of Reactor Safety USNRC, Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Re: Ferry Nuclear' Power Plant Docket Nos. 50-440; 50-441
Dear Mr. Little:
This letter is to acknowledge receipt of Inspection Report Number -
50-440/84-07; 50-441/84-07 attached to your letter dated August 14, 1984.
This report identifies areas examined by Messrs. K. R. Naidu, Z. Falevits, A. Gautam, K. Tani and E. Christnot during their inspection conducted April 9-12 and June 4-7, 1984, at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated August 14, 1984 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.
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,
[
Murray R. Edelman Vice President Naclear Group MRE:nb DW165/G/1 Attachment ec: Mr. J. A. Grobe Mr. R. F. Warnick, Chief USNRC Site Projects Branch I )
i Division of Reactor Projects l USNRC USNRC, Region III l c/o Document Management Branch 799 Roosevelt Road Washington, DC 20555 Glen Ellyn, IL 60137
, ~ , , ,
g; bt '
RESPONSE TO ENFORCEMENT-ITEMS Below is our response to the Notice of Violation appended to United States Regulatory Commission I.E. Report 50-440/84-07; 50-441/84-07.
JI.-Noncomo11ance 440/84-07-01; 441/84-07-01 A. Severity Level V Violation 10CFR50, Appendix B, Criterion X, as implemented by CEI Corporate >
. Nuclear Quality Assurance Program Manual, Section.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 on 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 245B.
- 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 crimping tools used to crimp the ,
termination lugs.
- c. Inspection Reports verifying corrective action on LKC Noncon-formance Reports 2368 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 verify whether th hold point was honored.
- d. General Electric Prod .- Quality Certificates (PQC) certifying 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 FQC to establish traceability.
B. Response , .
The following responses correspond to each of the subitems a through d that are listed above:
- 1. Corrective Action Taken and Results Achieved
- a. The inspection reports which the inspector reviewed had been generated prior to October 1983. In-process Audit 990 was performed to review the documentation generated after that date. Results of the audit were favorable and greater clarity has been provided since October 1983.
This audit was performed in response to the NRC recommendation
~ -
p
'v as stated in the cover letter to I.E. Inspection Report 440/84-07; 441/84-07.
A review of the inspection reports generated prior to October 1983 has also been completed and a comprehensive list of reports which may lack clarity has been compiled.
Because each of these documents reflects only a portion of the history of an installation, they may appear unclear if the document is not reviewed in context with the balance of the re ord package. Currently, a review with the balance of the record package is being conducted to determine the adequacy of these inspection reports.
- b. There were two discrepancies that appeared within the -
documentation attached to Nonconformance Report LKC 2375. -
The first discrepancy "as that the inspection checklist -
was gener.ted .... 2gnad by an inspector on November 23, 1983, but the revi, ewer's signature and date was November 22, 1983.
It was explained that this occurred during a period when the reviewer was working extended hours and inadvertently signed the previous day's date.
The second discrepancy was that the calibration date for a tool was incorrectly recorded as September 14, 1983, instead of September 14, 1982.
Both of these discrepancies have been corrected.
- c. The CEI Hold Point stamp was placed on documents only after the document was considered complete. Documents were not consfdered complete until a secondary review was performed by an L. K. Comstock supervisor or lead inspector.
This review may occur several days or more after the actual date on which the inspection was performed.
Since this p:actice was a concern to the Region III Inspectors, che Electrical Unit's Surveillance Inspection Plan SIP 33 has been revised. The Plan new states that the documents are to be stamped and signed at the time of the installation. All unit personnel have been apprised of the change of procedure.
- d. The basis for this finding was presented in Section 5 of .
Inspection Report 50-440/84-07; 50-441/84-07, in which the inspector discussed his review of the receipt inspection process for pressure and limit switches mounted on control valves and stop valves of the main steam lines. As a result of our review of the inspector's concerns the following responses are provided:
- 1. Relative to NAMCO Limit switches, Master Parts List Numbers (MPL) 1C71-N006A-H, these items were not G
v required to be individually serialized by procurement requirements. NAMCO, therefore, identified the switches with their date code and the Master Parts List number only. Adequate traceability of the C71 limit switches is maintained by the Master Parts List number which is referenced in the applicable Material Receipt package.
- 2. Relative to the pressure switches MPL C71-N005A-D, as referenced on Receiving Inspection Report (RIR) for Material Recelot Number 14201, it was determined that no serial numbers were present on these pressure switches. Further investigation identified that the supplier, General Electric, had furnished pressure -
switches of an incorrect part number. Field Devi- -
ation Dispositica Request KL1-3208 was initiated on April 16, 1984 to return these switches to GE and to authorize shipment of the correct pressure switches to the site. No additional action regardin; the lack of serial numbers on C71-N005A-D was performed as -
these switches are being returned to GE. Upon receipt of the correct switches, receiving inspection will be performed as required and the new Material Receipt package will provide adequate traceability of the - -has.
- 2. Corrective Act- __ en to Prevent Recurrence
- a. The inspector's concerns have been discussed with the contractor and the In process Audit 990 has been performed verifying that this condition has been corrected since October 1983.
The current program requires a series of documentation reviews, one of which is a comprehensive review of completed
' work packages by the Contractor prior to turnover to the owner. Subsequent to the turnover another-required comprehensive review of cc >1eted work packages is performed by the Project Organizat ,a prior to acceptance of the work. It is important t- note that the records which the inspector reviewed had not yet received the contractor's
. turnover review.
- b. The document reviews performed in series serve to identify these discrepancies on a case by case basis.
- c. The CQS Electrical Surveillance Inspection Plan SIP 33 has been revised to apply the CEI Hold Point stamp on the contractor's documentation immediately after completion of the construction activity. CQS Electrical Unit personnel have been informed of this change of procedure. ~
- d. A memo was circulated to receiving inspection personnel on April 23, 1984, to reinforce understanding of the 1
1 l
l l
l I
_ l V
requirements in NQ1-0711 relative to ensuring that documentation in the Material Receipt Package provides a unique method of traceability for items received, as appropriate.
- 3. Date of Full Compliance All the above actions have been completed with the exception of the review of the inspection reports which may lack clarity referenced in 1.at The assessment of these inspection reports will be completed by November 15, 1984.
II. Noncomn11ance 440/84-07-03 .
A. Severity Level IV Violation 1 -
10CFR50, Appendix B, Criterion III, as implemented by CBI Corporate 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 shall assure that design activities are conducted in a planned.and systematic manner; that the Perry Safety Analysis Report requirements have been appropriately addressed in design documents; and that design requirements can be controlled and inspected and/or tested to specified acceptance criteria.
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.
B. Resconse
- 1. Corrective Action Taken and Results Achieved
' The basis for this finding was presented in Section 8 of Inspection Report 50-440/84-07; 50-441/84-07. A. review was conducted of the individual items referenced in the final paragraph of Section 8 on page 13. An evaluation of each follows:
Inspection Report paragraph ref. Evaluation o
8'(l) Drawing error was a cross-reference note to provide additional drawings clarification.
Cable routing and termination are correct in panel lH22-P055. The prescribed cable routing is identified on approved construc-tion cards (i.e., pull slips). Drawing D-209-055, Sheet 9 will be revised to correct this cross-reference.
. I a
This is a minor discrepancy that does not affect construction nor compromise system design.
8b(2) The elementary drawing B-208-055 Sheet 10, Revision J, is incorrect. The designation for SRU3B was not shown on this drawing revision. The missing designation is minor and does not reflect a lack of design coordination between General Electric and Gilbert Engineering.
An Engineering Change Notice (ECN) will be developed to replace this designation and -
terminal board point assignments on TB-DD. -
8b(3) Elementary diagram B-208-055 Sheet 10, Revision J is incorrect in designating two wires with the same wire markers. The drawing will be revised through the issuance of an Engineering Change Notice.
8b(4) This item concerns the status of lifted leads to a device and is not associated with Gilbert Engineering's design control.
Device SRU2B does not have any lifted lead tags dated September 1983 as stated in the NRC Inspection Report.
Device SRU33 was found to have lifted lead tags dated Septembet 1983. The lifted lead log indicates these tags as still being active. Leads are lifted in support of a functional check and a loop calibration for the E12 system.
No design or programmatic problems could be identified with respect to this item.
8b(5) There was no discrepancy with drawing D-209-055 Sheet 12, Revision A, as stated in the Inspection Report. The wire markers were incorrect and have been identified on Nonconformance Report CQC-3493.
No design discrepancy could be identified with respect to this item.
8d(3) The vendor wire marker designation in the field is correct as it currently exists.
The vendor used the B-208 elementary drawings to designate internal wire mark identification. During the transfer of V
information-from the B-208 to the D-209 wiring diagrams, transfer of this one wire designation was inadvertently omitted.
Earlier this year, Project Internal Audit 84-27 was conducted at Gilbert Engineering offices in Reading, Pennsylvania to review the interface between the two respective engineering groups working on the B-208 and D-209 drawings. Results of the audit were positive,and reficcted that a controlled interface is established. Based upon this assessment, an occurrence of this type of error is isolated and not considered -
indicative of a systematic problem. -.
Drawing D-209-055, Sheet 10, will be -
revised to correct the wire marker desig-nation.
8d(4) Engineering Change Notice 12734-33-2405 issued July 20, 1983 against drawing D-209-055, Sheet 10, Revision C, indicates a floating shield at TB-BB-3 in panel
, 1H22-P018. A shielded twisted pair cable was installed. In accordance with the installation procedure,.the shield jacket was cut back and taped. This configuration conforms to design requirements.
There is no design or installation discrep-ancy with this item.
8d(5) The reference to circuit 1C71R7XA in the Inspection Report was incorrect. The circuit identification number should have been 1C61R7XA. This circuit was determina-ted at the time of the inspection due to work being performed to correct a noncon ,
forming condition. The work was being performed -in accordance with the engineering disposition provided on Nonconformance Report P033-931.
There is no design or program violation associated with this item. '
8f(2) This item, had also been previously identified during the Safety System Functional Capability review performed by GDS Associates.
The initial response from General Electric was received in January 1984. j l
Subsequently, General Electric provided j 1
, - . . , , . . . .a . = ;" - t
. ,4_.,. _ . , ..,vg . -- ,
- s-i further response on this~ item in August
-1984. Their response stated that during
.the last; revision of the Standby Liquid l Control elementary it was decided.that the valve position lights, in conjunction with the administrative controls, were sufficient to indicate C41-F036 position.
. This item, therefore, has been identified
,and was being addressed.
8f(3) The switch development shown on B-208-030, Sheet 1. depicts switches in the "stop" position.which is their normal operating --
- position. Contacts 1-2 of S1A and S13 -
should therefore be normally closed as shown. ' -
No design error could be identified with s
l' respect to this item.
^
8f(4). Based upon the observations in the Inspection Report, an Engineering Change Notice for this drawing is being issued to correct the identified discrepancy.
8f(5) Engineering Change Notice 21080-33-3436 was-
'being processed at the time of the inspec-tion. At completion of its processing the ECN was posted on the appropriate drawing.
The ECN does address the technical concerns of the Inspection.
No design concerns or errors could be identified with respect to this item.
Corrective Actions Taken to Prevent Recurrence -
All Engineering groups are being apprised of the concerns raised from this inspection. The thoroughness of design reviews will be re-emphasized.
Date of Full Ccmpliance All engineering actions described in the above' response to 440/84-07-03 will be completed by September 26, 1984.
9
- DW165/G/9/dlh T
7-I +k--
$ g g 9- 7 g y v 1= = T $#-e-e( y ww --rw--g- w w-g-w g y - - -g*- e p y V
'. C.s t. f"t* Cf!* , e %'.s.C.rM* f* '. 6 .C.l* f* B t . :* , q;
- THE PLAIN Q?. ALE.R. rR'OAY. AUrMT 84. 1984 - --
4 Perry cited
,p i q -
~
- LOT b TChirLOT r
i G 9 0
^ '
a lae_,
iU-*e' V( )
b o!
.m.
. By James Lawless to pay more attention to detail,"
Cleveland EIcetric Illuminating l Co. has been cited for two viola- Naidu nothing said. "There really was of consequence."
tions of federal construction stan-
. dards at its 86 billion Perry NRC was conductjng both a rou- ,
I nuclear power plant, but a federal tine review of numerous systems I inspector sal.: the violations do at Perry and investigating several
' not amount io much.
allegations. raised by former
, workers at Perry. One of the alle- '
"We found some problem areas, 8attons, which Nh'Idu said was
', but for a plant of this magnitude, confirmed, involved an electrical i that is not significant," said cable tray which was reported Kamal R. Naidu, a Nuclear Regu , filled with garbage. .
- latory Commission inspector from
. Chicago., .
- Naidu said, "It was filled with "We are concerned that your garbage but we find that all the f
' inspection reports contain various time. It is a convenient place to !
discrepancies such as erroneous , store stuff,like lunch buckets and
! dates of review and other inaccu. equipment. Some people even , '
rate information," an NRC report sleep in them." .
- said,"We point out that these are Naidu said many of the allega.
. permanent records and as such tions raised by former workers
. should not contain significant dis- were'several' years old and as a
'crepaneles in luformation and result have already been cor-
^
[ dates." rected throu~g h the normal review CEI was cited'for a level four Process in nuclear construe'.lon.
l and a level five violation of NRC CEI spokesman J.' Lee Bailey
- regulations, the two least severe refused to answer any questions levels in NRC's ranking systems. on the report or to arrange an The violations concerned either interview with a CEI executive
- procedural problems in inspec- familiar with the report. .
, tions or errors in paperwork. . .
Insteadihe offered a written .
In the more serious violation, statement:."The Perry Prpject
,CEI was criticized for not making has never had a problem area. . [
sure that a contractor had classified more severe than 1.evel P f reviewed'and verified safety 4. .
j related diagrams. The report said "These two areas of concern l
. , numerous design errors and "are being corrected. Our full - l l Inconsistencies wereidentified. response will be made to the NRC y "Most of the problems seemed witMn 30 days as required bylaw.
' to be just human error but ve Perry has had only four such find-wanted to tell the licensee (CEI) Ings(violations)this year."
.-. - - .. . _ _