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#REDIRECT [[PY-CEI-NRR-1049, Responds to Notice of Violation & Proposed Imposition of Civil Penalty Dtd 890711.Corrective Actions:All Limitorque Terminal Blocks Not Marathon 300 Replaced.Penalty in Amount of $37,500 Paid]]
| number = ML20246B118
| issue date = 08/10/1989
| title = Responds to Notice of Violation & Proposed Imposition of Civil Penalty Dtd 890711.Corrective Actions:All Limitorque Terminal Blocks Not Marathon 300 Replaced.Penalty in Amount of $37,500 Paid
| author name = Kaplan A
| author affiliation = CLEVELAND ELECTRIC ILLUMINATING CO.
| addressee name =
| addressee affiliation = NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000440
| license number =
| contact person =
| document report number = EA-87-206, PY-CEI-NRR-1049, NUDOCS 8908230256
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 7
}}
 
=Text=
{{#Wiki_filter:-          _
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY
                                                                                      ~
P.O. BOX 97 5 PERRY, OHIO 44001 5 TELEPHONE  (216) 259 3737  8      ADDRESS-10 CENTER ROAD FROM CLEVELAND: 241-1650 Serving The Best location in the Nation  j Al Kaplan                                                            PERRY NUCLEAR POWER PLANT                  '
VICE PRESIDENT 94UCLEAR GROUP l
August 10, 1989 L                                                        PY-CE1/NRR-1049 L 1
l p
V l-l            Director, Office of Enforcement l            U.S. Nuclear Regulatory Commission ATTN:    Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Reply to a Notice of Violation l            Gentlemen:
Attachment 1 provides the Cleveland Electric Illuminating Company's (CEI) l _.          reply to the Notice of Violation pursuant to 10CFR2.201 as required by the NRC l'            Notice of Violation and Proposed Imposition ot Civil Penalty dated July 11, 1989.
Also enclosed is a check made payable to the Treasurer of the United States for payment of the civil penalty. Please feel free to contact us should you have any additional questions.
Very trul          ur ,
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Al Kaplan Vice PreLident Nuclear Group Attachment AK:njc                                                                                                j cc: Regional Administrator, Region III Sr. Resident Inspector T. Colburn                                                                                      ,
fif 8908230256 6908.1O                                                                                      'fl  i
.    ._f              K0500fO                                                                          yCf((f f,5 J
 
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                                    ,                                                              Attachm:nt l                                                                                                  PY-CEI/NRR-1049 L Page 1 of 6 Reply to a Notice of Violation Restatement of Violation During an NRC inspection conducted during the period March 20 through April 19, 1989, a violation of NRC requirements was identified.      In accordance with the " General Statement of Policy and procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13, 1988) (Enforcement Policy), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (ACT), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and the associated civil penalty are set forth talow:
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires that measures be established to assure that conditions adverse to quality, such as nonconformances, are identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The corrective action taken shall be documented and reported to appropriate levels of management.
A Notice of Violation and Proposed Imposition of Civil Penalty (hotice) (EA 87-206) was issued on February 11, 1988 which, in part, identified the following significant conditions adverse to quality:
: 1. Unqualified terminal blocks installed in Limitorque valve motor operators.
: 2. Target Rock solenoid operated valves with covers not installed in the environmentally qualified test configuration.
: 3. Limitorque valve motor operators with "T" drains improperly located to assure proper moisture drainage.
Contrary to the above, the licensee failed to assure that the above significant conditions adverse to quality were promptly identified and corrected in that further examples of-these problems were identified that had not been corrected as a result of actions taken in response to the Notice.
This is a Severity Level III violation (Supplement I).
  ---..____                                                                                                              i
 
. ,w Attachment PY-CEI/NRR-1049 L Page 2 of 6 Admission or Denial of the Alleged Violation The Cleveland Electric Illuminating Company (CEI) admits that the violation occurred as stated.
Reasons for (pe Violation As previously discussed with ,nembers of the NRC staff during the inspection and at the enforcement conference on May 11, 1989, the reason for the violation was a lack of sufficient detail and follow through with inspections /
checklists, and reliance upon inaccurate data in correcting the problems identified in the NRC Inspection Report 87-013. Each of the three examples is discussed in more detail below:
Unqualified terminal blocks in Limitorque valve motor operators The July, 1987 NRC Environmental Qualification (EO) Audit determined that the only terminal blocks the NRC considered qualified by the Perry documentation files for use in Limitorque motor operators were Marathon 300s.                                                                                                      Later after discussions with the NRC this was expanded to also include General Electric (GE) model EB-5 terminal blocks. In response to this issue, CEI restated the position that certain other models were also considered qualified by CEI, but that all terminal blocks other than the Marathon 300 and GE EB-5 vould be replaced by Marathon 300s.
During the March 1989 NRC EO Inspection an EB-25 terminal block was discovered in a Limitorque motor operator where ve thought an EB-5 terminal block existed. Shortly after the inspection a KULKA 622 terminal block was found in a Limitorque motor operator where we thought a Marathon 300 terminal block vas installed.
In response to the 1987 inspection instead of performing a field inspection to determine what terminal blocks existed in the Limitorque valve motor operators, a list of terminal blocks was generated by the E0 element personnel reviewing data from a Limitorque rework program done in 1983 and 1984.
However, the data used was from earlier phases of the rework program which did not give true indication of the terminal blocks which existed in the plant.
The 1983/84 rework program was done as a result of a large number of industry problems with Limitorque valves. The program at Perry was divided into three separate phases.
Phase 1 of the program was a field inspection of all Limitorques in the program to identify the existing configuration of the Limitorques including the terminal blocks installed.
Phase 2 of the program took the results from the Phase 1 inspections and developed a valve specific list of what to modify / change out for each valve.
The final phase then removed the valve operators from the plant and reworked the operators in the maintenance shop per the procedures developed in Phase 2, and then reinstalled the valve operators back into the field.
 
L L
L Attechm:nt PY-CEI/NRR-1049 L Page 3 of 6 As stated above, when formulating the Limitorque valve operator terminal block l
list as part of the follovup to the 1987 EO Audit, that data was taken from Phase 1 and 2 which provided erroneous information. Using this incorrect input data, it was determined that there vere eleven Limitorque motor operators which had to be inspected due either to missing data points,        or an indication of other than Marathon 300, GE EB-5 or Raychem splices. This resulted in two terminal blocks being changed to Marathon 300 blocks. In hindsight, although the other nine blocks were qualified, ve should have questioned the validity of the generated lists at that time since four of the terminal blocks found were different than indicated by the list. Ilovever, discrepancies were not evaluated as significant, and no further inspections were felt necessary in response to the 1987 NRC E0 Report Limitorque terminal block issue. These items cauced inaccurate information to be transmitted to the NRC and prevented CEI f. a taking proper corrective actions at that time.
Subsequent to the 1987 NRC EO Inspection we decided to establish a detailed inspection of Limitorque motor operators, due to continued industry issues being raised. Specification 2701 was written and approved in December 1988.
The inspections using the specification had begun prior to the March 1989 NRC EO Inspection.
Af ter finding the discrepancies in March 1989, we concluded that the corrective actions taken after the 1987 EQ Inspection vere not comprehensive enough to correct the deficiency.
Additionally, although not the root cause of the violation, several contributing factors also led to incorrect terminal blocks. These factors vere discussed in more detail at 'he enforcement conference and included:
: 1) failure to specifically address vendor information for KULKA terminal blocks 2) inadequate training of rework program personnel for the identification of terminal block types; and 3) inadequate control of terminal blocks in phase III of the rework program.
Target rock solenoid operated valves with covers not installed in the environmentally qualified test configuration During the 1987 NRC EQ Inspection, solenoid cover bolts were found missing en Target Rock solenoid valve covers. At that time we completed two separate actions. First, an analysis was performed to evaluate the environmental qualification effect of having up to three of the eight covers bolts missing.
This evaluation justified continued operation with this condition. Secondly, a 100% field inspection was performed of all Target Rock. solenoids covers.
Any bolts found missing during this inspection were replaced.
During the March 1989 inspection the NRC identified a Target Rock solenoid with two loose fasteners.      Since the evaluation discussed above encompassed this condition operability was not a question. However, it was apparent that the corrective actions taken following the 1987 EQ Inspections did not verify tightness.
Ve have determined that there vere two areas that led to the loose cover bolts. First it as determined that the vendor had never supplied us with any torque instructi c.s for the bolts. Discussions with Target Rock identified detailed torque instructions for reassembly of the covers.
 
Attachm:nt PY-CEI/NRR-1049 L                                                    1 Page 4 of 6 Secondly, during the 100% field inspection, the guidance given to the inspectors was to visually inspect for bolts, without giving any guidance to check for bolt tightness. Since the inspectors were not required to check for tightness, this was not performed.
Limitorque valve motor operators with    "T" drains improperly located to assure proper moisture drainage.                                                                                                        l l
During the 1987 E0 inspection a discrepancy was determined to exist in that                                                      i "T" drains on Limitorque motor operated valves were not properly located on                                                      d the low points of the Limitorque motor operator due to valve orientation.
The corrective action for this discrepancy was to perform a 100% field                                                            I inspection of Limitorque motor operators in a harsh environment to verify proper "T"    drain location, and to install  "T" drains if not properly installed. However, the maintenance personnel who performed the inspections were not provided with detailed training nor required to document their inspections, or findings. As such we can not determine whether all 166 Limitorque motor operators were actually inspected, nor the as found status of the valves at that time. It now appears that all of the Limitorque motor operators were not inspected. As part of the corrective action for finding the wrong terminal blocks in Limitorque motor operators, a detailed inspection of all 166 Limitorque motor operators was performed. This inspection identified thirteen Limitorque motor operaters without    "T" orains that were required to have them.
Corrective Actions That Have Been Taken and the Results Achieved The corrective actions which have been taken for each of the items is discussed below:
Unqualified terminal blocks installed in Limitorque valve motor operators When the KULKA 622 te minal block was discovered the following action occurred:
: 1. The valve was declared inoperable since ve had no qualification data on the terminal block at that time.
: 2. . A decision was made to inspect all 1E Limitorque motor operators located in a E0 harsh environment not only for term.'nal blocks, but for all Limitorque Specification 2701 EQ requirements. To perform these inspections a small group of EQ element and Quality Assurance (OA) personnel vere given specific training on Limitorque EQ requirements, including proper terminal block identification.
: 3. The inspections were done during the first refueling outage. Besides the 24 KULKA 622 terminal blocks the following terminal blocks were also discovered:
1 Curtis L 15 Buchanan 211 1 Marathon 1600 2 Harathon 6004
 
p  .g m Attachmznt
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PY-CEI/NRR-1049 L Page 5 of 6
: 4. All'Limitorque= terminal blocks'which-were not Harathon 300s were replaced with either a Marathon 300 terminal block or a qualified Raychem splice.
This action vas completed by June 28, 1989.
:  5. Evaluations were completed on all~ terminal blocks found which provided justification for determining the terminal blocks were operable during the first fuel cycle. Those justifications were submitted to the NRC on
                                ~ April 14,.1989 (PY-CEI/0IE-0246L) and June 5, 1989 (P7-CEI/01E-0351L).
: 6. The location and qualification of all other terminal blocks located in circuits for class lE devices in a harsh environment was verified by review of design / installation records, and confirmed by field walkdowns/ inspections.
: 7. The Limitorque motor operators configuration was captured on design output drawings. The data obtained from the Limitorque inspections was utilized in the development of these design output drawings. This vill prevent replacing Limitorque components such as the terminal blocks with a different.model without going through a formal design change process,
                                -and thus a formal evaluation of the change. This action was completed on August 4, 1989.
                          -As a result of the actions 'aken, all lE Limitorque motor operators located in an E0 harsh environment now have either a Marathon 300 terminal block, or a qualified Raychem splice installed.
                          .Tarcet Rock solenoid operated valves with covers not installed in the environmentally qualified test condition When the loose covered bolts were discovered the following corrective actions vere _ performed:
: 1. The vendor was contacted, and specific torquing requirements were
                                -obtained.
: 2. 100% of the Target. Rock solenoids were inspected and all bolts properly torqued. (a total of seven vere found with loose fasteners, one with a missing nut).
: 3. Repetitive tasks were written to inspect the bolts for proper torquing every refueling outage.
: 4. A review of similar applications was performed to see if specific torque requirements were identified. Vendors were contacted when specific requirements were not given and any specific torquing requirements
                                -received have'been incorporated into our specifications.
: 5. A decision was made to expand 0A surveillance during the refueling outage to cover other accessible E0 equipment. E0 element personnel aided in developing enhanced inspection checklists for these inspections.
These inspection vere performed from March 23 to June 6, 1989. This l
L          _ __ - -_
 
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Attachm:nt PY-CEI/NRR-1049 L Page 6 of 6 inspection covered 24 man-veeks of work, and included inspection of 773 components. It should be noted that this was independent of the 221 inspections performed by the E0 element themselves (the Limitorque inspections, electrical penetration, etc). These combined inspections resulted in 994 E0 components of the total 1166 being inspected during
                  .the first refueling outage. The only components not inspected were components that were incessible due to plant configuration and radiation levels. Numerous discrepancies were identified during the QA surveillance, but Engineering evaluations determined that none of the conditions found impaired the operability or safety functions of the affected components'during the first operating cycle. All discrepancies found vere corrected by June 30, 1989 or determined to be acceptable as found.
As a result of the action taken the Target Rock solenoid cover bolts have been properly torqued with a repetitive task to verify proper torquing on a refueling outage basis.      In addition, inspections verified the condition of over 85% of the plant's E0 components.
Limitorque valve motor operators with    "T" drains improperly located to assure proper moisture drainage.
As discussed above it was determined that 100% of the lE Limitorque motor operators in an E0 harsh environment would be inspected. During these detailed inspeelions thirteen Limitorque motor operators that require "T" drains were foun3 vithout "T" drains. Two actions were taken to correct this deficiency. Fir st "T" drains were installed in all 13 Limitorque motor operators. This action was completed on June 28, 1989. Secondly, evaluations vere performed which justified the operability of the 13 valves for the first fuel cycle. Thia justification was submitted to the NRC on June 23, 1989 (PY-CEI/0IE-0352L).
As a result of these corrective actions, all Limitorque motor operators in a harsh environment that require "T" drains have them properly installed.
The Corrective Actions That Vill be Taken to Avoid Further Violations Although not an action to prevent recurrence, one generic enhancement vill be to establish a program within the E0 Element to increase awareness of field conditions and to increase communications. The program vill require E0 personnel's presence in the plant on a periodic basis to observe E0-related work in progress, to review specific plant concerns, and to conduct general plant valkdowns. Communications between the E0 element, the work groups, and 0A/0C will be improved not only through increased awareness and informal communications but also through a series of joint meetings to identify perceptions, problems, and resultant solutions. This program has already been established, and is administrative in nature requiring no procedure changes.
Date When Full Compliance Vill be Achieved Full compliance was achieved with the completion of all actions to restore the E0 components to a qualified condition on June 30, 1989.}}

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