ML20127A678
| 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: |
| References | |
| 50-440-85-18, 50-441-85-08, 50-441-85-8, NUDOCS 8506210217 | |
| Download: ML20127A678 (13) | |
See also: IR 05000212/2004029
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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
(fC be]'
d' j g g
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Approved By:
R. C. Knop, Chief
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
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
(Closed) Noncompliance (440/83-31-04a; 441/83-30-04a) HVAC
a.
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.
(Closed) 10 CFR 50.55(e) Reportable Item (440/84045-EE;
c.
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:
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NR ASC-048
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NR CQC-3538
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ASC0A Procedure F-12a, Revision 6, dated February 27, 1985,
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" Installation Procedure for Hilti HDI Drop-In Anchors."
Specification SP-108-4549
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ECN 3074-68-7
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ECN 5780-68-23
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ECN 16658-68-84
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ECN 26349-68-61
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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
and Drug Usage at Perry Nuclear Power Plant (PNPP).
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Sometime in July 1984, a Region III inspector read two (2) newspaper
articles in which two (2) former boilermakers who had been employed
at the Perry Nuclear Power Plant alleged that welders on the site
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
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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
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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.
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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.
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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
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sound."- However, since Boilermaker #5 was used only as a welder for
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.
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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
still performed today. The Shop Superintendent or his assistant by
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procedure, perform these tests.
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This item could not be substantiated.
Based upon these facts, this
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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
safety related.
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The inspector interviewed Mr. J. Finucan, Executive Vice President
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of Kelly Steel regarding Foreman "B."
Prior to coming to the Perry
- site, Foreman "B" had worked for Kelly Steel on the Avon project,
Eastlake project, and the Republic Steel project. These projects
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spanned a period of approximately 7 years, some aspects of which
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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
Foreman "B."- The' nature of these was such that the impression was
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' that he could, in fact, read and interpret blueprints adequately.
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This item could not be substantiated, therefore, it is considered
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closed.
Boilermaker 52 stated that two other boilermakers (not named) that he " rode
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with, smokcd marijuana and drank gin down inside the bottom of
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containment on Unit 1."
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Article 5, Item 0, of the CEI Employee Handbook, and individual
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contract labor agreements with contractors.for PNPP states that
...any employee who reports for work under the influence of
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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
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partake of their use could not be substantiated.
It also appears
that the applicant _is taking reasonable precautions to discourage
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and prevent the use of alcohol and drugs, and to apprehend
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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
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is outside the normal ptirview of the NRC, it is being left with the
applicant to pursue with the respective contractors.
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(CYosed) Allegation (NiII-85-A-0011): Alleged Contaminated
Penetration Sealant Material Being Used in Penetrations.
- dnJanuary 23, 1985, an allegation was received at the NRC site
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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
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QCP-102
Traceability Methods and Recording
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QCP-103
Danming Depth and Penetration Inspection
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QCP-104
Sample Evaluation
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QCP-204
Sample Evaluation
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QCS-101
Qualification Test for Silicone Foam Material
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QCS-102
Qualification Test for Silicone Non-Foam Mateial
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Formulation of BISCO SF-60
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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
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Lot No.
Sets Distributed
019
(A) EG074689
Complete Barrel
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019
(B)EF064769
Complete Barrel
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020
(A)EF064626
Complete Barrel
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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
sampling, and the means of documenting these activities.
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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
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formulation.through'the use of samples. These are recorded on
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form QCT-2, System Verification Log. The Component Traceability
LLog, QCT-1, generates a system by tracking the components from
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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.
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' The samples are compared by QC to control samples supplied by BISCO
_ Corporate QA Department. The control samples are tagged-with
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' nformation which identifies the sample and type of material for
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.which it is to be used as~a comparison. -The samples.are certified
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,
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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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indicate a nonconforming condition. At the request of the
applicant, BISCO did initiate " Hold" procedures on associated
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penetrations-relating to the identified material. Since this time,
BISCO has initiated several training sessions to retrain their
inspectors. They have~also revised their procedures to require
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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
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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
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Traceability Log Sheets, the System Verification Log Sheets, and
Inspection Reports covering these items.
In addition to this
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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
during this period, therefore, there was no damage to any other
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material or equipment.
Based upon the above-mentioned interviews, documentation reviews,
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.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
The inspector reviewed the documentation for the installation,
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termination, and separation requirements for both power cables and
instrument cables in the Emergency Service Pump Structure, Cable
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Spreading Room, and the Diesel Generator Building.
The inspector noted that adequate identification of cable and
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instrumentation cable trays existed, and between safety related and
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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
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running threads existed and that there were no welded conduit
joints.
It was also observed that no flattening of the conduit
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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
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--were segregated in a separate area. These four (4) had the ends -
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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Also identified were several reels of Rockbestos cable which had
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been segregated because it had been generically identified as
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non-conforming. This item has been identified by the applicant
(440/84034-EE).
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5.
Reactor Vessel Lower Head / Control Rod Drive Housings - Independent
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Inspection Effort
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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),
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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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