ML20112E316

Responds to NRC Re Violations Noted in Insp Rept 50-440/84-22.Corrective Actions:Nonconformance Procedures & Review Procedures Revised & Personnel Responsible for Disposition & Review of Nonconformance Repts Clarified

ML20112E316
Person / Time
Site:	Perry
Issue date:	01/24/1985
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8503260493
Download: ML20112E316 (8)

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, T li E C L E V E L A N D E L E C T R ! C I L L U TA I N A T ! N G C 0 ili P A N Y P.O. Box 5000 - CLEVELAND. OHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSoVARE Serving The Best Location in the Nation g yg g g January 24, 1985 VICE PRESIDENT NUCLEAR Mr. R. F. Warnick, Chief Reactor Project Branch 1 Division of Reactor Project's U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illitois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50-440; 50-441

Dear Mr. Warnick:

This letter is to acknowledge receipt of Inspection Report 50-440/84-22 attached to your letter dated December 28, 1984. This report identifies areas examined by Messrs. J. A. Grobe, D. E. Keating and J. M. Jacobson during their inspection conducted September 11 through November 19, 1984, at the Perry Nuclear Power Plant.

Attached to this letter is our response to the Notice of Violation dated December 28, 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 f~

Vice President Nuclear Group MRE:pab Attachment cc: Mr. J. A. Grobe Mr. W. S. Little, Chief USNRC Site, SBB50 Engineering Branch Division of Reactor Safety Mr. D. E. Keating U.S. Nuclear Regulatory Commission USNRC Site, SBB50 799 Roosevelt Road Glen Ellyn, Illinois 60137 U.S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 ldAN 28 GS5 8503260493 850124 PDR ADOCK 05000440 Je. b I Ig G PDR

RESPONSE TO ENFORCEMENT ITEM Below is our response to the Notice of Violation appended to United States Nuclear Regulatory Commission I.E. Report No. 50-440/84-22 (DRP):

I. Noncompliance 440/84-22-04 A.- Severity Level IV Violation 10CFR50, Appendix B, criterion IVI, as implemented through the

-'applicant's Corporate Nuclear Quality Assurance Manual, Section 1600, Revision 5, requires that corrective action to preclude repetition of significant conditions adverse to quality shall be taken.

Contrary to the above, the following three nonconformance reports (NRs) were issued and closed out addressing the deficient condition of installed structural steel without taking' timely corrective actions to-preclude recurrence following the identification of each of these nonconforming conditions:

a. NR No. CQC-2439, issued on April 1, 1982, documented thi

-indeterminatestatusofallboltedstructuralsteelconoc,gtions with A325 high strength bolts in four rooms on the 574'103 elevation of the Unit 1 Auxiliary Building. The bolting of 237 connections was tested with a torque wrench resulting in 5) s connections being rejected and rebolted (22 percent failuth).

b. NR No. P085-3782, issued on August 29, 1984, documented the unauthorized loosening of two bolted structural steel conrections

. . in the Unit 1 Reactor Building at the 677'4-1/2" elevatior.

! These connections were rebolted.

j c. NR No. CQC-2433, issued March 19, 1982, documented the L unauthorized removal of two hardened hex nuts and washers connecting a plate to the east' steam tunnel wall in the Unit 1 Reactor Building at the 620'6" elevation. The hex nuts and washers were replaced.

B. Response

1. Corrective Action Taken and the Results Achieved We concur with the inspector's observation that corrective actions to preclude recurrence were.not taken immediately l' following the identification of two of the above nonconforming conditions; however, at the time these and certain other k .. nonconformances were identified, the causes were determined to be unauthorized actions by unknown parties. Each nonconformance was reviewed and determined not to be significant within the intent

-of 10CFR50.55(e) or 10CFR21. CEI Corporate Nuclear Quality t

RESPONSE TO ENFORCEMENT ITEM-JANUARY 24~

, 1985 PAGE 2-Assurance Program 1600, states, in part, that the cause of conditions adverse to quality shall be determined and appropriate

-action taken to preclude repetition, and that significant conditions within the intent of 10CFR50.55(e) or 10CFR21 are reported to appropriate management levels.

The Nonconformance Reports (NRs) cited by the Inspector were evaluated for corrective action to preclude recurrence but since the responsible parties could not be determined, appropriate action was taken only to correct each deficiency as it was identified. In December 1982, when subsequent evaluation of recurring nonconformances indicated a need for more definite corrective action to prevent recurrence, corrective action was initiated through Observation Action Request (AR) 556, dated December 14, 1982. This corrective action to preclude recurrence included notification of all site contractors of the problem and their expected compliance to prevent further deficiencies.

Additional findings in late 1984 were cause for AR PO 0131-080 to be issued on September 6, 1984, to address unauthorized removal of structural bolts. All site contractors and appropriate Project Organization personnel were notified at that time of the problem and the necessary corrective action. Our evaluation of project response to AR PO 0131-080 found that disturbed structural connections were being found, documented and dispositioned during normal Construction Quality Section surveillance and contractors' inspections.

In response to this I.E. finding, Action Requests PO 0131-115, PO 0131-116, and PO 0131-117 were issued to the Construction Quality Section, Nuclear Construction and Engineering Section and the Operations Quality Section, respectively. In response to these ARs, selected NRs issued between November 1983 and November 1984 were reviewed to ensure that corrective action to preclude recurrence was appropriate. The results of this review indicate that, for the majority of cases, appropriate corrective action was taken. Cases where not applicable was deemed an inappropriate response have been evaluated. No adverse programmatic trend or significant unreported impact on hardware has been determined to exist.

2. Corrective Action Taken to Avoid Further NonconD11ance To ensure a more thorough evaluation of the cause of nonconformance and timely corrective action, CEI nonconformance procedures and nonconformance review procedures were revised November 2, 1984, via Procedure Revision Notise, to require a

1 RESPONSE TO ENFORCEMENT ITEM JANUARY 24, 1985 PAGE 3 written explanation if Not Applicable (NA) is to be applied to the Steps to Prevent Recurrence section on Nonconformance Reports. Personnel responsible for the disposition, review, and approval of Nonconformance Report corrective action have been trained to the requirements of project procedures and revisions thereto.

3. Date When Full Compliance Will Be Achieved Full compliance has been achieved.

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RESPONSE TO ENFORCEMENT ITEM JANUARY 24, 1985

' PAGE 4-II. Noncompliance 440/84-22-03 A. Severity Level IV Violation 10CFR50, Appendix B,. Criterion II, as implemented through the licensee's Corporate Nuclear Quality Assurance Program, Section 1100, Revision 4,-requires that a testing program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Regulatory Guide 1.68, Revision 2, Section C.1,-committed to by the licensee in Final Safety Analysis Report (FSAR), Section 1.8, provides six criteria to be used in selecting plant features to be tested. FSAR Section 14 describes the test program for PNPP. In FSAR Section 14.2.1.1.b, the applicant reiterated the same six criteria stating that those criteria would be used to selset which plant features are preoperationally tested vice acceptance tested (a lower level of testing than preoperatienal tests).

Contrary to the above described test program, the following systems that meet one or more of the six selection criteria were not included in the preoperational test program " Software Status Report" as

-requiring preoperational testing:

a. Containment Atmosphere Monitoring System (D23).

b. Motor Control Centers and 120, 240, and 480 Volt Distribution (124 and R25).

c. Seismic Instrument System (D51).

d. Feedwater Leakage Control System (N27B).

B. Response e

1. Corrective Action Taken The Containment Atmosphere Monitoring System (D23), Class IE 480 VAC Load Centers and Class lE 480/120 VAC Distribution Systems 4

(R24/25) and Feedwater Leakage Control System (N273) have been added to the Software Status Report as Preoperational Test Procedures. The Seismic Instrument System (D51) is being carried on the Software Status Report as an Acceptance Test procedure based on the following:

. .The Seismic Instrument System performs recording, monitoring, and alarm functions only.

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RESPONSE TO ENFORCEMENT ITEM JANUARY 2A; 1985 FAGE 5

. The system is not required for safe shutdown and cooldown of the plant.

. The system is being tested during the preoperational testing phase as an Acceptance Test which is described in FSAR Section 14.2.12.3 of Amendment 15. (NOTE: This Amendment was submitted af ter I.E. Report No. 440/84-22 was received.)

2) Si: ens Taken to Avoid Further Noncompliance The Test Procedure Review Committee (TPRC) will periodically review the Software Status Report ',.>r test procedure correctness as determined by the TPRC Chairma... In addition, the report is regularly distributed to Nuclear Test Section supervision for use and evaluation.

3) Date When Full Compliance Will Be Achieved ThieSoftwareStatusReportiscurrentlyincompliancewith respect to this violation.

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RESPONSE TO ENFORCEMENT ITEM ,

JANUARY 24, 1985 l PAGE 6 III. Noncompliance 440/84-22-01

- A. Severity Level V Violation 10CFR50, Appendix B, Criterion V, as implemented through the applicant's Corporate Nuclear Quality Assurance Program, Section 500, Revision 6, requires that activities affecting quality shall be accomplished in accordance with appropriate procedures and instructions.

Contrary to the above, the installation of jurisdictional tags and dots and informational dots on thirteen safety-related 480 volt motor control center compartments was not accomplished in accordance with Project Administrative Procedures 1103 and 1104 and Test Program Instructions 6 and 9.

B. Response Backaround Jurisdictional status of equipment is required to be indicated in accordance with Project Administration Procedures 1103 and 1104 and Test Program Instruction 9. Test Program Instruction 6 addresses application of red dots for informational purposes on annuncistors.

There were fourteen (14) tagging discrepancies indicated in the body of the I.E. report. Thirteen (13) of these discrepancies involved inappropriate application of blue and red dots and one (1) involved both a blue and green tag on the same component.

1. Corrective Action Taken The components identified within the violation plus the balance of switchgear and motor control centers were inspected and any tagging or dot application discrepancies corrected. This was completed during 1984.

2. Steps Taken to Avoid Further Noncomoliance Test Program Instruction 9 was enhanced to address application of blue dots. This clarification stipulates use of blue dots only where size or. configuration is not appropriate for use of tags.

In addition, Nuclear Test Section supervisors and leads were directed by their General Supervising Engineer to instruct the System Test Engineers to ensure their system tagging was periodically reviewed and in accordance with Test Program Instruction 9.

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RESPONSE TO ENFORCEMENT ITEM JANUARY 24, 1985 PAGE 7

3. Date When Full ConD1iance Will Be Achieved The revision of. Test Program Instruction 9 to address blue dots will be effective by 1/31/85. All other corrective action has been completed.

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