ML20154N453
| ML20154N453 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/05/1986 |
| From: | Muffett J, Neisler J, Witt F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20154N449 | List: |
| References | |
| 50-440-85-84, NUDOCS 8603170327 | |
| Download: ML20154N453 (13) | |
See also: IR 05000440/1985084
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-440/85084(DRS)
Docket No. 50-440
License No. CPPR-148
Licensee: Cleveland Electric Illuminating
Company
Post Office Box 5000
Cleveland, OH 44101
Facility Name: Perry Nuclear Power Plants, Unit 1
Inspection At: Perry Site, Perry, OH
Inspection Conducted: December 3, 1985 through January 10, 1986
Inspectors:
J. H. Neisler
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Approved By:
J. W. Muffett, Chie
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Plant Systems Section
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Inspection Summary
Inspection on December 3, 1985 through January 10, 1986 (Repurt
No. 50-440/85084(DRS))
Areas Inspected:
Followup inspection on allegations:
RIII-85-A-0171,
RIII-85-A-0206 and RIII-83-A-0089. The inspection involved a total of
58 inspector-hours by one Region III inspector and eight hours by one NRR
reviewer.
Results: No violations or deviations were identified.
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8603170327 860311
ADOCK 05000440
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DETAILS
1.
Persons Contacted
Principle Licensee Employees
- C, Shuster, Manager Quality Assurance
E. Riley, General Supervisor, Construction Quality Section
- M. Kritzer, Unit Supervisor, CQS Civil
- S. Tulk, Unit Supervisor, CQS Electrical
- E. Parker, Unit Supervisor, CQS Pipe /I&C
- V. Higaki, Unit Supervisor, 0QS
- T. Boss, Supervisor QAD
- R. Reifsnyder, Quality Engineer CQS
- K. Cimorelli, Lead Quality Engineer, Electrical
- R. Matthys, Lead Quality Engineer, Piping /I&C
B. Ferrell, Licensing Eiigineer, NED
- T. Heatherly, Compliance Engineer, PPTD
The inspector also contacted other quality, craft, engineering and
contractor personnel during the inspection.
- Denotes those persons attending the exit interview.
2.
Previcus Inspection Items
(Closed) Open Item (440/85034-01): Coatings test to resolve questionable
application to be performed at Oak Ridge National Laboratory. This item
will be tracked as Unresolved Item (440/85084-01).
J,Closedl,A11ega_ tion _RIII-85-A-0171:
3.
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The NRC received anonymous allegations relative to deficiencies in coating
application at Perry on October 16, 1985 and subsequently on two other
occasions. The NRC provided the technical details on five of these
allegations 6. a letter to the licensee on November 4,1965. The licensee
responded to the technical content of these allegations on December 13,
1985. The NRC reviewed the results of the licensee's inspection of the
five allegations and did a selected independent review of numbers 2, 3,
4 and 5 to collaborate the licensee's findings. The NRC's review of these
allegations is independent of the licensee's review. The NRC also reviewed
those aspects of the allegations that were not submitted to the licensee
for their review. The technical aspects of the allegations which follow
are considered to be closed,
a.
Allegation
White Carboline HB paint was applied to power tool cleaned surfaces
without first applying a prime coat.
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NRC Review
The paint referred to by the alleger is Carboline 191HB coating.
The NRC staff determined by review of applicable docunentation that
Carboline 191HB was applied directly to bare steel for repair of
damaged paint areas between 0ctober 13, 1983, and April 15, 1985.
The application of 191HB to bare steel was authorized by
ECN 7433-64-44, Revision F, based on a Carboline letter dated
July 21, 1980, that described the application of 191HB direct to
SP-10 cleaned steel areas as an alternate procedure for coating
repair. The licensee's Construction Quality Section (CQS) issued
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Stop Work Notice 85-01 on April 16, 1985, prohibiting the use of
191HB coating on bare steel and issued nonconformance report
CQC 3784 on April 23, 1985, to resolve the stop work notice. Both
the stop work notice and the nonconformance report were issued as
a result of a CQS finding that proper documentation was not
available to prove the coatin0 application met design basis accident
requirenents in the drywell . The licensee prepared samples of
Carboline 191HB coating on bare steel and submitted the samples to
Oak Ridge National Laboratory (0RNL) for testing to resolve the
nonconformance report. This item is unresolved pending the NRC
review of the licensee analysis of the results of the ORNL coating
sample test (440/85084-01). The licensee issued ECN 26607-64-78
Revision A to prohibit the use of 191HB coating on bare steel to
satisfy the conditions of Stop Work Notice 85-01.
Conclusion _
Although this allegation was substantiated, the licensee's QA program
has identified this problem and had initiated corrective action on
this problem some six months prior to being identified by the alleger.
b.
Allegation
QC inspectors checked liner temperatures with terrp sticks and that
readings were off scale high (greater than 150*F). Application
of coatings was permitted by QC in violation of engineering and
procedural requirements that the temperature be 80 F or less on
containment dome.
NRC Review
The NRC inspector reviewed QC inspection reports indicating surface
temperatures measured on the containtrent dome for coatings applica-
tion. The measurements were made with a contact themometer, not a
temp stick.
The maximum temperature recorded was 116*F. According
to the QC inspection report, coating application began four and
three-quarters hcurs later when the surface temperature was 92*F.
The coatings used for this application were Carbonzinc No.11 and
Carboline 191HB. Surface temperature limits for the application of
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these coatings listed in Metalweld coating procedure WI 210 were:
Carbozine No.11, 40*F minimum,110 F maximum; and Carboline 191HB,
50 F minimum, 110 F maximum. QC records indicate that coatings
application were not performed when temperatures were outside these
limits.
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Conclusion
Based on the review of coatings application records and the coatings
procedures, this allegation was not substantiated.
c.
Allegation
Painters have used tungsten carbide tipped drill bits (pencil
grinders) on their buffing and grinding tools to prepare weld
surfaces for coating application thereby removing excessive weld
metal from coated items such as snubber brackets, pipe supports,
pipes, etc. The alleger did not identify specific locations where
the use of tungsten carbide tipped drill bits occurred.
NRC Review
The inspector reviewed documentation of the licensee's inspection
of the coatings contractor storage areas and tool cribs, and
applications' tool boxes. No tungsten carbide tipped bits were
fcund.
Interviews with quality control personnel indicated that
deburring tools are used to remove sharp edges on structural steel.
Use of these devices is permitted by the Steel Structures Painting
Council and contractor procedures. None of the personnel
interviewed was aware of the use of these tools on welds, supports
or pipes in a manner that could lead to excessive metal removal. A
general visual inspection of brackets, supports and pipes revealed
no excessive base or weld metal that had been removed by use of
these tools.
Conclusion
Based on the inspector's review of available documentation,
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interviews with personnel, and the lack of specific information as
to where the tungsten carbide drill bits were used this allegation
was not substantiated.
d.
Allegation
Paint cracks on welds on crane box beam were due to cracks in
NRC Review
Cracked welds on the polar crare box girder (beam) were previously
reviewed as Allegation No. RIII-85-A-0125 and are as documented in
Inspection Report No.440/85078. Paint was removed from the areas
of alleged cracked welds and the welds were nondestructively
examined using the magnetic partical examination methed. No crack
indications were observed in the box girder welds.
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Conclusion
Based on previous NRC inspection of allegations related to cracked
welds on the polar crane this allegation was not substantiated.
e.
Allegation
Coating defects on spray header of 689 elevation.
NRC Review
The inspector reviewed nonconfomance report CQCS-111, dated
November 1, 1985. The nonconformance report identified the
coating defects. All the spray headers were inspected and
defects corrected. The NRC visually inspected the repaired area
(calculated by the licensee to be about 0.75 square foot), the
other headers, and the containment wall in the vicinity of the
headers. No defects were observed.
Conclusion
Based on the licensee's identification and correction of the defects
in the spray header coating prior to the allegation and the NRC's
inspection in this area this allegation was not substantiated. The
licensee had previously identified and corrected coating defects on
the spray header. The allegation was received subsequent to the
licensee's correction of the deficiencies.
The NRC inspection of
the area subsequent to the licensee's correction of the deficiencies
showed that the allegation could not be substantiated.
f.
Allegation
Paint is peeling and rust is visible on the fuel handling bridge
platform.
NRC Review
The inspector examined the platform and observed areas of rust on
the painted surfaces. The rust had previously been identified by
the licensee on nonconformance report MW 1230-2/3 dated September 11,
1985. The nonconformance report disposition was to rework the paint
on the platform.
Rework activities including sandblasting and
painting was observed by the inspector during the inspection.
Conclusion
Since the licensee had previously identified rust on the fuel
handling bridge platform and had initiated adequate corrective
treasures as indicated by the above nonconfomance report, this
allegation did not identify an unknown nonconfonnance.
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Allegation
The alleger stated that the shop steward would arrange for the
hiring of unqualified people. The person applying for the position
would attempt to qualify by painting a test panel and the shcp
steward would touch up the panels after the applicant was finished
but before the panels were inspected for qualification. This
activity was alleged to have occurred from January to March 1980.
NRC Review
The inspector ascertained that the painting contractor, Metalweld
Incorporated, did not arrive onsite until August 1980 and would not
have been qualifying personnel onsite during January to March 1980.
Since Metalweld was not onsite during January to March 1980, the
inspector elected to review applicator qualifications for January
through March 1981 and 1985. During January through March 1981
seven persons passed the qualification test and approxinately 200
persons were certified as passing in the January through March 1985
period. The qualification tests were witnessed by a quality control
inspector and results were evaluated in both wet and dry coating
conditions.
In addition to contractor quality control witnessing
the performance of the quality tests, licensee quality assurance
personnel perfonn periodic surveillances of the testing and review
all test results.
The inspector reviewed Metalweld Procedure WP-007A, Revision 1 dated
August 21, 1980, " Method for Qualifying Journeyman Applicators (Test
Panel)." This procedure requires all journeyman applicators who
apply coatings under the requirements of ANSI N101.4 to be qualified
in accordance with this procedure prior to that individual's
applying production coatings. At Perry, there are no prequalified
applicators.
Conclusion
This allegation was not substantiated. Since the contractor was not
at Perry during the time frame identified by the alleger other time
periods were chosen for review. The inspector's review of qualification
test results revealed the tests were witnessed by quality control
while the coating was being applied to the panel and inspected wet.
Therefore, the shop steward would not have had an opportunity to touch
up the samples. Since all painters are considered to be unqualified
until tested, whether or not the shop steward arranged for certain
persons to be hired has no safety significance.
[C1osed) Allega_ticn_(_AM_S_ No._ RIII_-85-A-206)
4.
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The NRC received the following allegatior>s relative to instrument air
lines and tubing via an anonyrrous telephcne call on December-18,1985.
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a.
Allegation
Incorrect drawings were issued for initial field work and the
numerous design changes and rework have caused the as-built drawings
to be incorrect and not accurately reflect the field conditions.
NRC Review
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Region III inspectors perfonned walkdown inspections on instrument
pipe and tubing to compare the as-built field conditions with the
as-built drawings during inspections documented in Inspection Reports
50-440/85028 and 50-440/85038.
Instrument tubing was inspected and
documented in Inspection Reports 50-440/84007.
Ir.stallation records
including drawings were inspected and documented in Inspection Report
50-440/84018. No violations of licensee commitments were identified
during any of the above inspections. The inspector examined
documentation of the licensee field verification and as-built drawing
review of instrumentation systems. At final turnover all identified
deficiencies had been corrected.
_C_oncl us ion
Based on r.urerous NRC inspections this allegation was not
substantiated in that deficiencies had been identified and
appropriate corrective actions initiated,
b.
Allegation
The alleger rrentioned inaccuracies in instrument line seismic
support spacing criteria.
NRC Review
Improper use of seismic support spacing criteria was reported to
the NRC pursuant to 10 CFR 50.55(e) and was tracked by Region III
as 10 CFR 50.55(e) report 440/85017-EE. The licensee's corrective
action was inspected and closed in Region III Inspection Report
No. 50-440/85072. During inspection No. 50-440/85072, the inspector
verified that the atchitect/ engineer had performed a seismic
support spacing design review, reviewed 100 percent of the support
installation and fabrication packages, issued guidelines in the form
of ECN 13239 to clarify the support spacing criteria and provided
retraining for personnel involved in seismic support spacing reviews.
Conclusion
Based on the licensee's reporting the deficiency and the NRC review
and acceptance of the licensee's corrective action prior to receipt
of the allegation this allegation was not substantiated.
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c.
Allegation
The slope of instrument lines was not.irtgompliance with design
requirements.
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NRC Review
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Instrument line slope deficiencies were addressed in NRC Region III
Inspection Report No. 50-440/85028 conducted May 13-17, 1985, and
identified as Open Item 440/85028-02. The open item was closed in
Inspection Report No. 50-440/85062. The licensee documentation
indicated that they issued Corrective Action Requests to address
these deficiencies during September 1984.
In addition, the licensee
established a slope verification program to identify and document
instrument line slope deficiencies. Nonconformance reports were
issued to identify and effect corrective action for each slope
deficiency. The inspector verified that the slope deficiencies
were being corrected as systems were preoperationally tested.
Conclusion
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Based upon the NRC's and the licensee's identification and the
corrective actions being.;,erformed previous to the receipt of the
allegation, this allegation was not substantiated.
d.
Allegation
The total instrun.ent air system was full of contaminants and water
as the system had been flooded fcr more than six months.- Deviation
Analysis Report No. 268 was written on the condition; however, that
report was being kept low key and deemed not reportable to the NRC.
NRC Review
The Deviation Analysis Report (DAR) Number documenting moisture in
the safety-related instrurrent air system was DAR-259, not DAR-268
the DAR was reported to the NRC as a construction deficiency
pursuant to 10 CFR 50.55(e) and is being tracked by Region III as
item 440/85023.
Instruirent air dryers had been turned off, for an
unknown period time, during preoperational testing causing moisture
levels within the air system to rise above design levels. The air
system was cleaned according to specifications and procedures were
implemented to assure that the air dryers are kept in operation.
Conclusion
Based on the licensee's previous identification of this deficiency,
proper reporting and the NRC inspector's verification of the
licensee's actions, this allegation was not substantiated.
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e.
Allegation
Approximately 500 nonconformance reports were written for
nonconforming instrument line slope conditions. Corrective action
reports, trend analyses and corrective actions have not been done on
this condition. This too was not reported to the NRC.
NRC Review
The NRC inspector reviewed the 1982 trend analysis report of the
instrument line slope nonconformances.
Nonconformance reports and
corrective actions regarding line slope were addressed by the NRC in
Inspection Reports 50-440/85028 and 50-440/85062. A walkdown
inspection was performed prior to turnover, the designer and the
installer established an instrument line slope verification program
to assure proper slope prior to system turnover to plant operations.
The inspector verified the nonconformances were trended by CQS,
corrective actions were effected and that appropriate inspections
were performed to verify that the slope nonconformances were
corrected.
The item was not considered to be reportable pursuant
to 10 CFR 50.55(e) when reviewed by the licensee.
Conclusion
Based on the NRC inspectors' review of trend analysis reports,
nonconformances, corrective actions and the licensee's slope
verification programs, this allegation was not substantiated.
5.
Closed) Allegation (RIII-83-A-0089)
The NRC office of investigations informed Region III of the results of
interviews relative to previous allegations regarding the L. K. Comstock
document review task force. The allegations and the results of the NRC's
inspection of the allegations are discussed below:
a.
Allegation
Document check lists used by the task force that identified errors
in work packages were subsequently removed from the packages.
NRC Review
Subsequent to the task force review, and prior to turnover, each
document package was reviewed by L. K. Comstock QC document
reviewers. Additionally, the licensee construction quality section
performed a 100 percent review of the Comstock document packages at
turnover. The NRC inspector reviewed 86 work packages that had been
assembled before the task force review during this inspection.
In
addition, the inspector had reviewed document packages during a
previous inspection in November 1985.
Each package with task force
concerns contained a task force document review checklist listing
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the concerns and a checklist of steps taken to resolve the task
force concerns.
In the document packages that contained no
identified task force concerns, the QC document reviewers had
included a master checklist of all task force concerns. The document
package was reviewed against the master checklist to ensure that all
task force concerns and the required sign-offs had been considered
during the turnover review. The document packages reviewed by the
NRC inspector had identified and resolved the task force concerns.
During the inspector's review of the document packages no packages
were identified where task force review checklists had been removed,
nor did the inspector identify a case where removal of the task
force checklist would have had a negative impact on the quality
assurance document program.
Conclusion
Based on the inspectors review of a sampling of L. K. Comstock
document packages, checklists and procedures, thic allegation was
not substantiated.
b.
Allegation
"NRC did not address task force concerns of improper and no QC
documentation covering conduit pulls." The alleger did not identify
a specific task force concern relative to conduit pulls.
NRC Review
The NRC inspector reviewed the task force transmittals of concerns
from the task force contractor, Energy Consultants Incorporated,
to L. K. Comstock. No conduit pull documentation concerns were
identified in the transmittals. However, the task rorce did
identify concerns relative to swabbing of conduit after cables
are pulled through; including the size of conduit on inspection
documents; and inspection criteria for inspection of conduit
bushings. The NRC inspector verified by review of QC inspection
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reports and licensee surveillance reports that these conduit
concerns had been addressed and corrective actions completed.
During the review of document packages, the inspector ascertained
that those cable pulls through conduit had been inspected according
to procedure. Each cable pull package indicated that the conduit
had been inspected, pull tensions calculated and the cable pull
witnessed by QC according to the appropriate procedure.
Conclusion
Based on the inspector's review of documentation attesting to the
adequacy of the corrective action relative to identified conduit
concerns, task force concern transmittals and cable pull document
packages, this allegation was not substantiated.
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c.
Allegation
How does one become a Level III in an inspection discipline in
which he/she has not met the minimum experience or educational
requirements for,
i.e., overall Level III of the L. K. Comstock QC
Manager?
NRC Review
The L. K. Comstock QC Manager identified by the alleger is no longer
employed at Perry. The NRC inspector's review of those portions of
the QC managers personnel file that remained onsite indicated that
he did not have "Overall Level III qualification." Review of the QC
manager's resume of experience indicated that he had been certified
as a Level III by two previous employers at nuclear construction
sites. His qualifications (in 1983) listed in the resume included
nine years nuclear quality experience, f;ur years related experience
in aircraft maintenance / inspection and five years related experience
in parts / components for a scheduled airline.
Education included
high school and technical training courses. NRC regulations and
ANSI standards list no qualification requirements for construction
QC managers; however, based on records available at the time of
the inspection, the NRC inspector concluded that the QC managers
experience and education was adequate for ANSI N45.2-6-1978
Level III certification in those areas in which he was certified
Level III.
Conclusion
Since the QC manager did not have an overall Level III certification
and his experience and education meets ANSI N45.2-6-1978 requirements
for those areas in which he was certified, this allegation was not
substantiated.
d.
Allegation
NRC did not address AR-260. A11egers comment on NRC Inspection
Report 440/83008.
NRC Review
The audit report identified by the alleger was not AR-260 but AFR-260.
The AR designation indicates the audit was performed by licensee
quality assurance organization, AFR designates L. K. Comstock audit
finding report.
No AR-260 was issued by the licensee in this area.
The NRC inspector reviewed AFR-260 during this inspection. The
audit finding report was issued to. document inspection of repairs on
switchgear 1/2R225006/7. During receipt inspection, weld cracks had
been identified in the frames of the switchgear and nonconformance
report NR-142 initiated to document the cracks and to effect
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corrective action. QC review of AR-260 documentation determined
that two crack repairs in Unit 2 switchgear were not signed off.
AFR-260 Revision 1 was initiated to document the repair and
inspection of the two cracks. During the document package review,
the reviewer observed that LKC form 118 should have been used to
document the inspection instead of the AFR. The repairs were
reinspected on Inspection Report 4876, LKC form 118, in 1983, and
the deficiencies corrected. Based on the above, the inspector
documentation of the inspections and repairs on this switchgear was
adequate and that disposition of the nonconformance report was
proper.
Conclusion
The alleger's statement that NRC inspectors did not address AFR-260
in Inspection Report 440/83008 is correct. However, the NRC
inspector's review of AFR-260 and it's supporting documentation
revealed that deficiencies in the AFR had been adequately identi'ied
and corrected in accordance with the quality assurance program.
Based on the above this allegation is not substantiated as having
a negative impact on the quality assurance program or nuclear
safety-related issues.
d.
Allegation
NRC did not address AR-276. Alleger comment on Inspection Report
440/83008.
NRC Review
Audit Report No. 276 performed by the licensee's construction quality
section, identified nonconforming electrical cable tray support welds.
The licensee issued nonconformance report CQA-048 to track the
corrective action of deficiencies identified in AR-276. Action
Request AR-001 was issued instructing L. K. Comstock to reinspect
and repair the nonconforming welds, to document the inspection of
the welds on inspection reports, document nonconforming welds on
nonconformance reports and to hold and document training sessions
for Comstock QC welding inspectors on weld acceptance criteria.
Inspection procedures were clarified and revised to include weld
acceptance criteria. Checklists were developed specifically for
electrical hanger turnover inspection prior to turnover of hangers
beginning in August 1984. The NRC inspector verified that the above
actions had been accomplished and that the audit report had been
properly closed by the audit team leader and the CQS unit supervisor.
Conclusion
Based on the inspector's review of documentation providins evidence
that hanger weld inspection deficiencies had been properly corrected,
this allegation was not substantiated.
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6.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations or
deviations. An unresolved item is discussed in Paragraph 3.a.
7.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection and summarizad the scope and findings
of the inspection. The licensee acknowledged the inspector's comments.
The inspector also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspector during the inspection. The licensee did not identify any such
documents / processes as proprietary.
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