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Insp Repts 50-440/85-18 & 50-441/85-08 on 850212-0429.No Noncompliance Noted.Major Areas Inspected:Two Allegations, Applicant Action on Previous Insp Findings & Electrical Cables & Terminations
	ML20127A678
Person / Time
Site:	Perry
Issue date:	06/14/1985
From:	Knop R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20127A667	List: ML20127A663; ML20127A678;
References
	50-440-85-18, 50-441-85-08, 50-441-85-8, NUDOCS 8506210217
	Download: ML20127A678 (13)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-440/85018(DRP);E0-441/85-008(DRP)

Docket Nos. 50-440; 50-441 Licenses No. CPPR-148; CPPR-149

Licensee: Cleveland Electric Illuminating Company

Post Office Box 5000

Cleveland, OH 44101

Facility Name: Perry Nuclear Power Plant, Units 1 and 2

Inspection At: Perry Site, Perry, OH

Inspection Conducted: February 12 through April 29, 1985

Inspector: D. E. Keating

Approved By:

(fC be]'

R. C. Knop, Chief d' j g g ,

Reactor Projects Section IC Date

Inspection Suninary

Inspection on February 12 through April 29, 1985 (Reports

No. 50-440/85018(DRP); 50-441/85008(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspector of

two allegations, applicant action on previous inspection findings,

electrical cables and terminations, and independent inspection effort.

The inspection involved a total of 240 inspector-hours onsite by one NRC

inspector, including 35 inspector-hours onsite during off-shifts.

Results: Of the .four areas inspected, no items of noncompliance were

identified.

8506210217 850614

PDR

G ADOCK 05000440

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DETAILS

1. Persons Contacted

C. M. Shuster, Manager, Quality Assurance Department

E. Riley, General Supervisor, Construction Quality Section

V. K. Higaki, Unit Supervisor, Electrical, Construction Quality Section

M. R. Kritzer, Unit Supervisor, Civil / Structural, Construction Quality

Section

G. Parker, Unit Supervisor, Piping / Instrumentation, Construction Quality

Section

The inspector also contacted other applicant and contractor personnel

during this inspection.

Denotes those persons attending one or more of the exit interviews

conducted on March 26, 1985, and April 29, 1985.

2. Applicant Action on Previous Inspection Findings

a. (Closed) Noncompliance (440/83-31-04a; 441/83-30-04a) HVAC

contractor failed to promptly identify, evaluate, and correct

recurring deficiencies in installed and QC accepted HVAC duct

supports.

This item is the result of an NRC Construction Assessment Team (CAT)

finding. The commitment for the resolution of this item was that a

100% review of Construction Quality Section (CQS) surveillance and

inspection reports be performed as well as a monthly trend analysis

of Robert Irsay Company (RIC0) NRs.

The inspector reviewed 36 RIC0 NRs, several CQS surveillance

and inspection reports, and two audit reports generated by CQE

covering these documents and activities.

The inspector also selected at random, three safety-related HVAC

systems and the associated drawings for a walk-down and to verify

that repairs had been made. The inspector found them adequate.

Based upon these activities, this item is considered closed,

b. (Closed) Unresolved Item (440/84-06-02; 441/84-06-02): This

concerns the question raised by an NRC CAT inspection, IE Report

No. 50-430/83-31; 50-441/83-30, regarding possible long term

integr;ted effects on the drywell wall and Bypass Leakage Integrity

resulting from the installation of approximately six to eight

thousand expansion anchors.

The concerns raised are detailed in the above-mentioned IE report.

The applicant's response is detailed in Response 1 of Response to

Appendix A, " Executive Summary," M. R. Edelman to J. G. Keppler

letter dated December 23, 1983.

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The inspector has reviewed the initial concerns, the applicant's

initial response, a request for additional information

(8. J. Youngblood to M. R. Edelman letter dated May 30,1984),

the applicant's response (M. R. Edelman to B. J. Youngblood letter

dated September 19,1984), and NRR's Licensing Branch I review of

this material (B. J. Youngblood to M. R. Edelman letter dated

January 14,1985).

Based upon this review and NRR's conclusion, as stated in the last

document mentioned above, this item is considered closed.

c. (Closed) 10 CFR 50.55(e) Reportable Item (440/84045-EE;

441/84045-EE)(DAR-209): Incorrectly installed Hilti drop-in

anchors by fire protection contractor.

The inspector reviewed the applicant's and contractor's

documentation concerning this item. This review included the

following documents:

. CAR 84-18

. NR ASC-048

. NR CQC-3538

. ASC0A Procedure F-12a, Revision 6, dated February 27, 1985,

" Installation Procedure for Hilti HDI Drop-In Anchors."

. Specification SP-108-4549

. ECN 3074-68-7

. ECN 5780-68-23

. ECN 16658-68-84

. ECN 26349-68-61

NR CQC-3538 required a 100% reinspection of all Hilti drop-in

anchors, type HDI, which had been identified by Automatic Sprinkler

Company's NR ASC-048.

During the applicant's review of these documents and their

surveillance of ASC0A's activities, it was determined that these

were all associated with non-safety and non-seismic installations.

The inspector verified that the licensee inspection program was

acceptable.

Based on this review and a tour of selected areas, this is considered

closed.

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3. Allegation Followup

a. (Closed) Allegation (RIII-84-A-0110): Alleged Unqualified Welders I

and Drug Usage at Perry Nuclear Power Plant (PNPP). j

Sometime in July 1984, a Region III inspector read two (2) newspaper

articles in which two (2) former boilermakers who had been employed l

at the Perry Nuclear Power Plant alleged that welders on the site l

were unqualified and used marijuana and/or alcohol during regular

working hours.

After contact by the SRI for PNPP, both boilermakers contacted

Region III. The first boilermaker was contacted and stated that he

knew nothing. The second boilermaker stated that he had been employed

by Kelly Steel at the Perry site between 1979 and 1980, and again

for three weeks in 1984 by Newport News Industries.

This second boilermaker stated that a Newport general foreman,

identified as foreman "A," " pushed" him to complete his welder

qualification test. Foreman "A" required him to qualify in "only

one day" while allowing others several days to qualify.

Newport News Industries includes, as part of their welder

qualification procedure, a nine hour time limit on welder

qualification tests. Depending upon when a test was started

plus the number of starts and stops within the nine hour period,

it could appear that the test lasted longer. This was the case

regarding Boilermaker #3, who this boilermaker was referring to.

This could not be substantiated and is, therefore, considered

closed.

The inspector. reviewed the time records and welder qualification

test records of Boilermaker #2 and Boilermaker #3. The following

are the results of this review:

. Boilermaker #2 - hired by NNI on January 17, 1984, terminated

on February 10, 1984. Qualified on January 17, 1984 for three

positions - horizontal, vertical, and overhead on P1 or carbon

steel material.

. Boilermaker #3 - hired by NNI on January 16, 1984, terminated

on March 23, 1984. Qualified on January 18, 1984 to all three

positions on P1 material. Started qualification test at

3:00 P.M. on January 16, 1984, started another at 10:30 A.M. on

January 17, 1984, and finished at 9:00 A.M. on January 18, 1984.

Boilermaker #2 also stated that he " observed boilermaker #3 using a

grinder on the test plate." ASME Section III, ASW, and NNI Welder

Qualification Test procedures allow the use of either pencil

grinders with brushes or slag hammers for cleaning welds. At no

time is anything larger than a pencil grinder and wire brush allowed

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in the weld' test booths. In the shop area around the test booths.

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weld preparation edge grinding was being performed on spool pieces

and plates.

Since'the referenced codes and welding procedure allow the use of

pencil grinders, the allegation' is moot and is considered closed.

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Regarding an allegation that the man next to boilermaker #3 having

trouble in the overhead position. The inspector verified that the

man had not qualified and was not hired.

Regarding the allegation concerning other persons. throwing away

their. test plates and starting over, the inspector reviewed the

requirements of NNI's welding procedure, interviewed the Welding

Shop Superintendent, and toured the welding shop and test booths.

The test plates, or coupons, are all match-marked and ' tack welded to

the jig in the position that the weld is to be perfonned; i.e., '

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horizontal, vertical, flat, and/or overhead. . These also are marked

with the welder's initials, the date of the test, the booth number,

and the position. In addition, the Shop Superintendent or his

designee monitors the test booths and checks the progress of the *

welders. This precludes changing the coupons from the assigned

positions.

This could not be substantiated and is considered closed.

The allegation concerning Boilermaker #4 and #5' deals with their

alleged weak background in welding prior to coming to the Perry site. i

The inspector interviewed the NNI QA Superintendent and reviewed the

_ personnel and welding qualification records of both Boilermaker #4 '

and #5. The following are the results of these activities.

Regarding the allegation concerning Boilermakers #4 and #5:

Boilermaker #4 initielly failed the horizontal, vertical and

overhead positions for P1, or carbon steel, material. He was not

hired as a welder. Boilermaker #5 had worked for NNI in 1977 and

1978 time frame. 'At that time he had qualified in three positions

for P1 material. He returned in January 1984 and qualified in the

same three positions for P1 material. He was terminated in

-February 1984.

An interview with the NNI QA Superintendent revealed that

Boilermaker #5 welds "were not the prettiest around, but they were

sound."- However, since Boilermaker #5 was used only as a welder for f

temporary attachments this item is considered closed.

Boilermaker #2-also stated the tested welders instead of quality

control inspectors performed the bend tests on the test coupons. l

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Prior to 1982, all test coupons were radiographed. In 1982, when

the level of work reached a point when it was no longer economically

' justifiable to use:this technique, bend tests were performed and are

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still performed today. The Shop Superintendent or his assistant by

procedure, perform these tests.

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This item could not be substantiated. Based upon these facts, this

item is considered closed.

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Boilermaker #2 stated that.a Kelly Steel foreman _ employed at PNPP in

1979, was unqualified. The statements made concerned a Foreman "B,"

- and his ability to read blueprints, and that his_ work "had many

defects and had holes burned where holes should not be." The

boilermaker also stated that " Foreman "B" even had plates installed

backwards"; and, "...that a hole was burned into the bottom of the

' waterbox in the turbine building." It should be noted that the

waterbox is.not safety related, nor was any of Foreman "B" work

u safety related. '

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The inspector interviewed Mr. J. Finucan, Executive Vice President

of Kelly Steel regarding Foreman "B." Prior to coming to the Perry

- site, Foreman "B" had worked for Kelly Steel on the Avon project,

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Eastlake project, and the Republic Steel project. These projects

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r spanned a period of approximately 7 years, some aspects of which

4 were more complex than the Specification 40 work (Condenser and

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Waterbox Installation - Unit 1) at PNPP.

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A review of the contractor's files on Field Questions, ECNs, NRs,

etc. indicated a large number were either initiated or approved by

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Foreman "B."- The' nature of these was such that the impression was

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i ' that he could, in fact, read and interpret blueprints adequately. .

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This item could not be substantiated, therefore, it is considered

closed.

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Boilermaker 52 stated that two other boilermakers (not named) that he " rode

with, smokcd marijuana and drank gin down inside the bottom of

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containment on Unit 1."

Article 5, Item 0, of the CEI Employee Handbook, and individual ,

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contract labor agreements with contractors.for PNPP states that

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...any employee who reports for work under the influence of

- alcoholic beverages or drugs, or who drinks alcoholic beverage or

uses drugs on the jobsite, or who reports to the jobsite with

alcoholic beverage or drugs in his possession shall be subject to

. immediate tennination." This has been in effect since 1973. The

- security force periodically conducts lunch box / tool box-searches.

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Since this requirement has been in effect, several individuals have

been terminated for the possession of controlled substances and/or !

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attempting to gcin access to the plant under the influence of drugs

or alcohol. In addition to the above, in October 1984 the applicant

security force acquired a drug detection dog. Since the dog has

been in use there have been approximately 10 finds, 3 of which were

caches and 7 of which resulted in disciplinnry action and/or

termination.

The applicant also uses a breathalyzer for determining alcohol

levels in the blood. This unit is the san type used by the Ohio

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State Police.

While-the possibility of the use of drugs and alcohol on site is

recognized to exist, the specifics as to the individuals alleged to

' . ' partake of their use could not be substantiated. It also appears

that the applicant _is taking reasonable precautions to discourage

and prevent the use of alcohol and drugs, and to apprehend

i offenders.

This item could not be sub'stantiated and is considered closed,

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Boilermaker;#2falso alleged that ironworkers used the Unit 2

Suppressionfooltohidefromtheirsupervisors.

- The inspector discussed (this with the applicant. Since this item

is outside the normal ptirview of the NRC, it is being left with the

, applicant to pursue with the respective contractors.

be (CYosed) Allegation (NiII-85-A-0011): Alleged Contaminated

Penetration Sealant Material Being Used in Penetrations.

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- dnJanuary 23, 1985, an allegation was received at the NRC site

office that drums and cans of Elastomer were allowed to freeze

while they were located in the crane bay of the turbine building.

<The two SRI's and the inspector who initially received the information,

immediately went to the crane bay and identified the drums, by lot

number, that had been mentioned as being contaminated by snow and

frozen.-

In the process of inspecting the above-mentioned drums, it was

learned that on January 20, 1985, the crane bay doors had blown

open, that the wind had blown the lids off some of the cans, and

blown snow onto tSe contents of these cans. The individual relating

this information stated that he had measured the temperature of the

cans and foun'd that those marked NH were 26 F, those marked F0AM

were 24* F, and those marked ELASTOMER were 22 F.

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The NRC inspectors contacted the BISCO QC Supervisor and reviewed

portions of the following procedures:

. QCP-101 Receiving Inspection - Job Site

. QCP-102 Traceability Methods and Recording

. QCP-103 Danming Depth and Penetration Inspection

. QCP-104 Sample Evaluation

. QCP-204 Sample Evaluation

. QCS-101 Qualification Test for Silicone Foam Material

. QCS-102 Qualification Test for Silicone Non-Foam Mateial

. SP-204 Formulation of BISCO SF-60

Also reviewed were portions of BISCO Specifications covering Storage

and Shelf Life for BISCO SF-60 RTV Elastomer (Dow Corning Sylgard

170 Silicone Elastomer, Parts A and B); and BISCO SF-20 Silicone RTV

Foam (Dow Corning 3-6548 Silicone RTV Foam, Parts A and B). .Also,

the Dow Corning Cell Structure Comparison Chart and Color Comparison

Chart were reviewed. The Dow Corning specifications for Sylgard 170

A and B Silicone Elastomer were also reviewed. The Dow Corning-

Corporate Headquarters was contacted to determine the effects of low

temperatures on the elastomer and foam, and if snow constituted a

contaminant.

It was determined that the low temperatures recorded would not

present any problems as long as the procedural requirements of

slowly (overnight) warming the material to ambient temperature

were adhered to. The NRC inspector confirmed that procedural

requirements were met.

The issue of snow as a contaminant or the water resulting from snow

melting was reviewed by the NRC inspector with both the applicant

and BISCO. Snow is considered the least of the concerns as a

contaminant since it is the easiest to remove. Any water resulting

from snow melt is a small amount and since the relative density and

viscosity of the foam and elastomer are so much greater than that of

the water, that the water sits on the surface and is easily removed

if the lids to the buckets were left off. Leaving the buckets set

at ambient temperature overnight would evaporate the relatively

small amount of water present.' These scenarios are presumed to

occur after breaking down the 55 gallon drums to the 5 gallon

buckets. The five gallon buckets are the size containers used to

blend and pump the materials into the penetration.

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The~ applicant, on January 23, 1985, notified BISCO Management of a

conversation between an unidentified BISCO employee and the Site

Organization. 'In response to this contact, BISCO presented the

following data involving 3-6548 RTV Foam and Sylgard 170 Silicone

Elastomer Identified Lot Numbers:

System 3-6548 Silicone System Sylgard'170

No. < RTV Foam No. Silicone Elastomer

019 EG074689A 033 EH084824A

019 EF064769B 033 EK114806B

020 EF064626A 78-2 EH084823A

020 EF064769B 78-3 & 4 EK114805B

At the applicant's request, BISCO Quality Department initiated

" Hold" procedures regarding the above materials and associated

penetrations using the listed identified material.

A review of BISCO Quality Control documentation provided the

. quantities of the materials in question which had been distributed

throughout the plant. These are as follows:

Sylgard 170

~ System Silicone Elastomer Number of

No. Lot No. Sets Distributed

033 (A) EH084824 18

033 -(B) EK114806 18

78-2- (A)EH084823 26

78-2 (B) EK114805 26

78-3 (A) EH084823 40

78-3 (B)EK114805 40

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3-6548 Silicone

System RTV F0AM Number of

No.- Lot No. Sets Distributed

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019 (A) EG074689 Complete Barrel

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019 (B)EF064769 Complete Barrel

020 (A)EF064626 Complete Barrel

020 (B)EF064769 Complete Barrel

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.The balance of the material in question remained in Unit 1 Turbine

Bay. The BISCO procedures previously identified, specified the

. number of samples to be .taken by Quality Control, the frequency of

i sampling, and the means of documenting these activities.

Procedure QCP-101, Section 6.2, covers receipt inspection of the

materials in question on form RI-1, Site Receiving Checklist.

Procedure QCP-102 covers Traceability Methods and Recording.

- Q.C..in conjunction with Production, monitors and checks the

formulation.through'the use of samples. These are recorded on

form QCT-2, System Verification Log. The Component Traceability

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LLog, QCT-1, generates a system by tracking the components from

lots A and B for both the RTV Foam or the-Silicone Elastomer..

Procedure QCP-104 covers Sample Evaluation and specifies when to

take samples and how many to take. BISCO technicians provide a

sample quantity of mixed liquid components per procedure QCP-105.

i' ' The samples are compared by QC to control samples supplied by BISCO

- _ Corporate QA Department. The control samples are tagged-with

'i nformation which identifies the sample and type of material for

.which it is to be used as~a comparison. -The samples.are certified

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in the same manner as controlled materials; i.e., a certificate of

canpliance accompanies the sample to the job site. If the sample is

determined unacceptable by QC, the production is stopped until

released by QC.

In addition to the procedural reviews performed above, the NRC

Inspector reviewed approximately 100 nonconforming reports issued

from early 1984 through January -1985. None of these were associated

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with the particular problem at hand. Associated with this review,

interviews were conducted with applicant personnel assigned to

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following BISCO's activities. These reviews and interviews

determined that BISCO did control the activities in accordance with

their procedures. At the time of this allegation and during the

immediate ensuing period, there was not sufficient information to

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applicant, BISCO did initiate " Hold" procedures on associated

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L penetrations-relating to the identified material. Since this time,

BISCO has initiated several training sessions to retrain their '

4 inspectors. They have~also revised their procedures to require

taping of. lids' of both A and B material for RTV foam and the

silicone elastomer after it has been removed from the 55 gallon

!. . drums and placed in 5 gallon buckets.

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A total of 80 penetrations were identified as having been sealed

< with'the material in question. The Inspector reviewed the Component

Traceability Log Sheets, the System Verification Log Sheets, and

Inspection Reports covering these items. In addition to this

j- review, 16 penetrations were randomly selected and inspected and

found to be satisfactory.

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No other equipment or material was located in the Unit 1 Crane Bay

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during this period, therefore, there was no damage to any other

material or equipment.

. Based upon the above-mentioned interviews, documentation reviews,

.and inspections, this. item while substantiated, was handled

correctly and is; therefore, considered closed.

Information gleaned from this investigation by the NRC Resident

Inspector was shared with-the Fire Protection Inspectors pursuant to

their investigation of allegation RIII-83-A-0029.

"4 . Cables and Terminations

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a. The inspector reviewed the documentation for the installation,

termination, and separation requirements for both power cables and

instrument cables in the Emergency Service Pump Structure, Cable

L Spreading Room, and the Diesel Generator Building.

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The inspector noted that adequate identification of cable and

instrumentation cable trays existed, and between safety related and -

L non-safety related cable trays. Programmatic concerns regarding

cable tray separation resulting from an NRC CAT finding, have been

addressed and are.in place. The physical installation of. barriers

is an inprocess activity on an area-wide basis and is ongoing.

Since this activity is ongoing and not all areas have been

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completed, this is considered an open item (50-440/85018-01).

.This will also be coordinated with the Region III staff.

b. The inspector reviewed conduit installation documentation for the

' areas mentioned above. It was noted during a walkdown that no

running threads existed and that there were no welded conduit

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joints. It was also observed that no flattening of the conduit

existed at bend areas and that the bend radius was not less than

that specified.

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Minimum cable bending radius was maintained in cable tray dropouts

and other fittings.

- Conduit was permanently identified and clearly marked. Anchorage

appeared-to be satisfactory. The anchor bolts were identified by

the coded markings stamped and clearly visible on the ends of the

bol ts.

No conduit was observed attached to 'eny cable tray, and no

connections were observed through the bottom'or side rail of any

tray. . The systems were solidly grounded and continuous

electrically..

The inspector did observe and brought to the attention of the

applicant, several instances of cable tray overfill conditions.

' Although these were non-safety cables in non-safety systems, in

one instance a severe example of minimum bend radius violation

existed. This was also brought to the attention of the applicant.

These conditions had already been identified in area surveillance

reports. The applicant will address these issues on the basis of-

good engineering practice.

c. A walkdown of the cable reel storage. yard was conducted. It was

noted that all reels were stored on edges of reels on cribbing.

At the time of the walkdown, the electrical contractor was in the

process of replacing some of-the cribbing.

It was observed that all reels were clearly marked with

identification numbers and manufacturer's name.- It was also noted

, that the ends of the cables were properly taped. Four (4) reels

--were segregated in a separate area. These four (4) had the ends -

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exposed. NRs had been written. The contractor was waiting for

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engineering disposition for these four'(4) reels. ~

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l Also identified were several reels of Rockbestos cable which had

[ been segregated because it had been generically identified as

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non-conforming. This item has been identified by the applicant

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(440/84034-EE).

5. Reactor Vessel Lower Head / Control Rod Drive Housings - Independent

L Inspection Effort

L Based on information from the RIII Daily Report of March 20, 1985,

which identified. indications in welds that connect the control rod drive

housings to the reactor-vessel lower head at Clinton Power Station (CPS),

L the inspector reviewed nondestructive examination (NDE) documentation to

determine if any deficiencies had-been identified during fabrication of

the PNPP reactor vessel.

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The inspector learned that this vessel had not been erected at the site

but rather at the Chicago Bridge and Iron, Memphis, Tennessee plant.

The PNPP NDE Supervisor witnessed the welding of a large number of these

welds during fabrication. The method used to verify the adequacy of

these welds was one which was entirely different than that used at

Clinton.

The inspector reviewed the documentation of twelve (12) of these welds

and could identify no defects or discontinuities in these welds. This

item, therefore, will no longer be pursued.

6. Open Items

Open items are matters which have been discussed with the applicant,

which will be reviewed further, and which require some action on the part

of the NRC or the applicant or both. An open inspection item disclosed

during this inspection is discussed in Paragraph 4a.

7. Exit Interviews

The inspector met with applicant representatives denoted in Paragraph 1

throughout the inspection and at the conclusion of the inspection period

on March 2C and April 29, 1985. The inspector sunnarized the scope and

results of the inspection and discussed the likely content of this

inspection report. The applicant did not indicate that any of the

information disclosed during the inspection could be considered

proprietary in nature.

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ML20127A678

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