ML20154N453

Insp Rept 50-440/85-84 on 851203-860110.No Violation or Deviation Noted.Major Areas Inspected:Followup on Allegations RIII-85-A-0171,RIII-85-A-0206 & RIII-83-0089 Re Coatings & Instruments Air Lines & Tubing

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: ML20154N445 ML20154N453
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 ) d

F W N 7 6

Date

Approved By:

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J. W. Muffett, Chie

W 3 /5!86

Plant Systems Section Date

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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

PDR 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).

3. J,Closedl,A11ega_

C d tion _RIII-85-A-0171:

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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

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

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Carboline 191HB. Surface temperature limits for the application of

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,

! 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

welds.

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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g. 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.

4. [C1osed)

s Allega_ticn_(_AM_S_

o No._ RIII_-85-A-206)

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.

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NRC Review

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 ,

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 ,

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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