ML20030B979
| ML20030B979 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/14/1981 |
| From: | Wilt D WEGMAN, HESSLER & VANDENBURG |
| To: | Churchill B AFFILIATION NOT ASSIGNED, CHURCHILL, B.W. |
| References | |
| ISSUANCES-OL, NUDOCS 8108250279 | |
| Download: ML20030B979 (4) | |
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WEGM AN. IIESSLER & VANDERBUHG b
A LEG AL PROFESSION AL ASSOCI ATION ATTO R N EYS AT LAW I i..,. _
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July 14, 1981 q.\\
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-2 Bruce W. Churchill, Esq.
Attorney at Law k 8ss, bOI A [
1800 M Street, N.W.
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Dear Bruce:
m This letter is in response to your letter dated June 11, 1981.
Since our efforts are entirely a voluntary effort, we simply do not have the facilities to produce photocopies such as perhaps your office does.
This is the reason that it was necessary for the inspection reports to be sent in two packages.
We are trying to spread the ccst of our efforts around several interested individuals who are willing to help but cannot bear the entire expense.
You should have the following inspection reports in your files as these are the inspection reports that have been filed with the Atomic Safety & Licensing Board.
If for any reason you do not have a specified inspection report, then, of course, I apologize, and will send copies to you as soon as I can.
We try to do the best that we can.
I am submitting the following inspection reports:
1.
An inspection report dated February 8, 1978, concerning an inspection conducted on January 24 through 26 of 1978 and February 2 ana 3 of 1978; 2.
An inspection report dated March 31, 1978, covering an inspection that occurred on February 9, 1978, February 17 and 18, 1978, and February 28 through March 2, 1978; 3.
An inspection report dated April 28, 1978, covering an inspection on March 15 through 17, 1978; 4.
An inspection report dated June 20, 1978, covering an inspection that occurred on May 2 and 3, 1978; 5.
An inspection report dated July 7, 1978, covering an l
inspection that occurred on June 7 through 9, 1978; 40 h
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PDR ADOCK 05000440 C
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Bruce W. Churchill, Esq.
4 July 14, 1981 Page 2 6.
An inspection report dated July 13, 1978, covering an inspection that occurred in Jant ry and February of 1978; 7.
An inspection report dated August 3, 1978, 7overing an inspection that occurred on June 19 through 22, and June 2E through 30, 1978; 8.
An inspection report dated August 16, 1978, covering an inspection that occurred on June 6 through 9, 1978; 9.
An inspection report dated October 3, 1978, covering an inspection that occurred on August 22 to 24, 1978; 10.
An inspection report that appears to be dated December 19, 1978, covering an inspection that occurred on October 25 to 27, 1978; 11.
An inspection report dated January 24, 1979, covering an inspection that occurred from November 28 to December 1, 1978; 12.
An inspection report dated May 15, 1979, covering an inspection that occurred on April 18 to 20, 1979; 13.
An inspection report June 19, 1979, covering an inspection that occurred on May 22 to 24, 1979; 14.
An inspection report dated August 1, 1979, covering an inspection that occurred on July 10 to 12, 1979; 15.
An inspection report dated October 4, 1979, covering an
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inspection that occurred on September 10 to 12, 1979; 16.
An inspection report dated February 26, 1980, covering an inspection that occurred on January 23 to 25, 1980; 17.
An inspection report dated May 21, 1980, covering an inspection that occurred on April 21 to 24, 1980; 18.
An inspection report dated May 21, 1980, covering an inspection that occurred on May 5 to 7, 1980; 19.
An inspection report dated June 4, 1980, covering an inspection that occurred on May 6 to 9, 1980; 20.
An inspection report dated June 26, 1980, covering an inspection that occurred on June 10 to 12, 1980; i
21.
An inspection report dated October 21, 1980, covering an
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inspection that occurred on September-7 to 19, 1980;
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Bruce W. Churchill, Esq.
July 14, 1981 l
Page 3 22.
An inspection report dated November 19, 1980, covering an inspection that occurred from October 1 to 31, 1980; 23.
An immediate action letter dated January 28, 1981, covering an inspection that occurred on January 23, 1981; 24.
An inspection report dated February 27, 1981, covering an inspection that occurred on January 21 to 23, 1981; I
25.
An inspection report dated March 3, 1981, covering an inspection that occurred on January 21 to 23, 1981.
Finally, as additonal evidence in support of contention 49, I am enclosing a copy of an inspection report dated May 21, 1981, covering an inspection that occurred from April 1 through April 30, I
1981.
As stated above, should you be missing an above identified report, please let me and I will see that you get a copy of it.
Should you have any questions, feel free to call me.
Very truly yours, j
WEGMAN, HESSLER & VANDERBURG l
Daniel D. Wilt DDW*md Enclosures l
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD J-d,
l' IN THE MATTER OF:
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/g CLEVELAND ELECTRIC ILLUMINATING CO.,
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Docket Nos. 50-440-OL and 50-441-01 j,,
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SERVI CE LIST NI o
The preceding letter and enclosures have been sent to the following:
Peter B. Bloch, Chairman, Atomic Safety & Licensing Board, U.S.
Nuclear Regulatory Commission, Washington, D.C.
20555 Dr. Jerry R. Kline, Atomic Safety & Licensing Board, U.S. Nuclear Regulatory Commissior., Washington, D.C.
20555 Mr. Frederick J. Sbon, Atomic Safety & Licensing Board, U.S.
Nuclear Regulatory Commission, Washington, D.C.
20555 I
Atomic Safety & Licensing Board Panel, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Panel, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555 Docketing & Service Section, Office of the Secretary, U.S.
Nuclear Regulatory Commission, Washington, D.C.
20555 Charles A. Barth, Esq., Office of the Executive Legal Director,
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U.S. Nuclear Regulatory Commission, Washington, D.C.
20555 Mr. Jeff Alexander, 929 Wilmington Avenue, Dayton, OH 45420 Bruce Churchill, Esq., 1800 M Street, N.W., Washington, D.C.
20036 Terry Lodge, Esq., 915 Spitzer Building, Toledo, OH 43604 Mr. Todd J. Kenney, 228 S. College Street, Apartment ( A, Bowling Green, OH 43402 Donald T. Ezrone, Esq., Assistant Prosecuting Attorney, Lake County Administration Center, 105 Center Street, Painesville, OH 44077
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[cteauh UNITED STATES y *, y, i NUCLEAR REGULATORY COMMISSION
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799 ROOSEVELT ROAD GLEN ELLYN,ILLINots 60137 g
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May 21,1981
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6 Docket No. 50-440 Docket No. 50-441 The Cleveland Electric Illuminating g
ATTN: Dalwyn R. Davidson g g},, y Company J_
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Vice President-System
'C' Engineering & Construction
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Post Office Box 5000 Cleveland, OH 44101 Gentlemen:
This refers to the routine safety inspection conducted by Mr. J. Hughes of this office on April 1 thru 30, 1981, of activities at the Perry Nuclear Plant Project, Units 1 and 2, authorized by NRC Construction Permits No.
CPPR-148 and No. CPPR-149 and to the discussion of our findings with Messrs.
M. R. Edelman and G. W. Groscup and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and inter-views with personnel.
During this inspection, certain of your activities appeared to be in noncom-A pliance with NRC requirements, as specified in the enclosed Appendix A.
written response, submitted under oath or affirmation, is required.
In accordance with 10 CFR 2.790 of the commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room. If the enclosures contain any informa-l l
tion that you or your contractors believe to be exe=pt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your intention to file a request for withholding; and (b) subnit witFin twenty-ffve (25) days from the date of this letter a written application to th'; office to withhold such Section 2.790(b)(1) requires that any such application must be information.
accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed I
in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incor-If we do I
porated as far as possible into a separate part of the affidavit.
not hear frem you in this regard within the specified periods noted above, f
a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.
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The Cleveland Electric May 21, 1981 Illuminating Company We will gladly discuss any questions you have concerning this inspection.
Sincerely, W
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. F. Heishman, Acting Director Division of Resident and Project Inspection
Enclosures:
Appendix A Notice of Violation IE Inspection Report No. 50-440/81-08 and No. 50-441/81-08 l
cc w/encis:
l Central Files Reproduction Unit NRC 20b PDR Local PDR NSIC TIC Harold W. Kohn, Power Siting Commission Mr. Daniel D. Wilt. Attorney Helen W. Evans, State of Ohio I
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Appendix A
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Cleveland Electric Illuminating Co=pany Dceket No. 50-440 As a result of the inspection conducted on April 1-30, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the fol-lowing violation was identified:
10 CFR 50, Appendix B, Criterion V (Procedures), states in part that, "Acti-vities affecting quality shall be prescribed by documented instructions.
and shall be accomplished in accordance with these procedures CEI Corporate QA program, Section 0500 requires that procedures and instructions of consultants, agents, contractors and vendors for those activities affecting quality shall be delineated by instructions and procedures.
Contrary to the above, General Electric (GE) failed to follow the abcVe pro-cedurc by allowing the reactor vessel internals to be installed in inclement weather conditions (rain).
GE specification No. 22A4671, Rev. 1 states in part'" cover of vessel shall be provided over the top of vessel, this cover shall not be opened or removed for installation of internal parts unless weather forecasts indicate reasonable assurance that rain or stoms are not imminent and that there will be time to replace the cover."
This is a severity Level V violation (Supplement II.E).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) cor-rective action taken and the results achieved; (2) corrective action to~be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this responu shall be submitted under oath or affir-mation.
D IIAY f f not R.' F. Heishman, Acting Director Date
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report Nos:
50-440/61-08; 50-441/81-08 Docket Nos:
50-440; 50-441 License Nos.:
CPPR-148; CPPR-149 j
Licensee:
Cleveland Electric Illuminating Company P. C. Box 5000 l
Cleveland, OH 44101 l
Facility Name:
Perry Nuclear Power Plant, Units 1 and 2 Inspection At:
Perry Site, Perry, OH l
Inspection Conducted:
A il 1-30, 1981 Inspector:
Hu s'
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Approved By:
R. F. Wfrnick, Chief f/fd((/
Reactor Projects Section 2B Inspection " Sum =ary Inspection on April 1-30, 1981 (Report No. 50-440/81-08: 50-441/81-08)
Areas Inspected:
Routine inspection by the IE Regional Resident Inspector of safety related construction activities, including followup on previously identified unresolved items (Units 1 and 2); followup on 50.55(e) report of fuel handling pool penetrations (Units 1 and 2); plant tours (independent inspection); observation of welding on electrical penetrations (Unit 1);
observation of installation of reactor vessel internals (Unit 1); and ob-servation of structure steel activities (Units 1 and 2).
This inspection involved 195 inspector-hours onsite by one NRC inspector including 33 inspector-hours onsite during off-shifts.
Results:
In the areas inspected, one apparent violation was identified (failure to follow specifications for installation of reactor vessel inter-1 nals - Paragraph 6 b.).
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DETAILS 1.
Persons Contacted a.
- M. Edelman, Manager, Nuclear QA Department
- G. Groscup, Manager, Nuclear Engineering Department J. Kline, General Supervising Engineer, Construction P. Martin, General Supervising Engineer, PQS G. Leidich, CQS QA Supervisor K. Combs, CQS Engineering Aide S. Tulk, CQS Lead Electrical Quality Engineer T. Thompson, CQS Electrical Quality Engineer E. Christiansen, Nuclear Electrical Engineer
- J. Bellack, General Supervisor Engineer, Administration & Special Products b.
Other Contractors Personnel J. Gilstrap, CQS, Mechanical Quality Engineer (GAI)
J. Anulies, Site QA Manager (PBI)
C. Burnett, Engineer Quality Manager (Kelley Steel)
C. Hart, QA/QC Manager (LKC)
J. Bucka, QA Engineering (GE NEBG)
The inspector also contacted and interviewed other licensee and contractor personnel during this reporting period.
- Denotes those attending at least one of the exit meetings.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (440/81-02-01; 441/81-02-01):
CEI, unable to pro-duce seismic qualification data addressing the use of spade lugs for termi-nation and connections in General Electric (GE) supplied termination cabinets (PGCC) in the control room.
The RI reviewed GE letter dated March 30, 1981 to the licensee, subject " Qualification of Panels with Lock on Fork Spade Lugs".
GE stated that a survey of seismic qualifications records has shown that spade lugs were used on Limerick Panel H12-P603 and successfully com-pleted seismic qualification testing.
The inspector did not review the seismic report DRF #H12-10.
The RI observed several spade lugs located in the termination cabinets and determined that they were the same as GE's I
spade lug drawirg number 225A4895, revision 8.
The RI has no further questions on this matter and this item is closed.
l 3.
Licensee Action on Other Items - Units 1 and 52 (0 pen) 10CFR50.55(e) Report,
Subject:
" Deficiency concerning the degradation of the G-41 System, fuel handling pool penetration piping." The RI observed i
the replacement of the fuel pool penetration nu=ber 8 by Newport News In-dustrial Corporation (NNIC) in accordance with nonconforming report (NR)
- 53-204, revision 6.
The inspector witnessed the fit-up of the replacement L
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backing ring, replacement liner, and leak chase. Welding was performed in accordance with NNIC Weld instruction 946-N-WOO 1.
The RI witnessed Pullman Power Products (PPP) in-process repair of penetration number 12.
The inspector determined the following:
work was conducted in 2;cordance with PPP welding procedures; proper welding materials were used; field process sheet was current; and liquid penetrant inspection was conducted in accordance with PPP procedure IX-PT-1.
4.
Functional or Program Areas Inspected - Units 1 and 2 (Independent Inspection)
One or more plant areas were toured several times during this reporting period to obcerve general con'struction practices.
During the week of April 7-10 of this reporting period, the RI observed Region III electrical inspector's activities on Units 1 and 2.
Summary and findings are contained in IE Inspection Report 81-07.
I Three tours were made on off shift.
No items of noncompliance or deviations were identified.
5.
Observaticn of Electrical Penetrations Work and Work Activities - Unit 1 The inspector observed in-process work activities including welding of safety related electrical penetrations located in the containment.
I The inspector observed the in-process fit-up and welding of a.
electrical penetration equipment numbers 1R725012, 1R72S013 and 1R725007 in accordance with PPP welding procedure WPS-IT-12A, Westinghouse drawing no. E-40047, ISO-1R72-12, revision A.
b.
It was determined that (1) work was conducted in accordance with welding procedures and drawings; (2) proper welding materials were j
used; (3) the work area was free of weld rod stubs; and (4) physical appearance was acceptable.
No items of noncompliance or deviations were identified.
l 6.
Observation of Installation of Reactor Internals - Unit i During this reporting period the inspector observed the installation of the reactor internals.
a.
On April 10, 1981 the inspector witnessed the installation of the shroud assembly (Il-B13-01) in accordance with General Electric (GE) layout drawing no. E-015-044, drawing no. B-370-0, revision 3 and traveler no. T1-B13-01.
Prior to the installation of the shroud assembly, the reactor vessel was vacuum cleaned. However, when the o
vacuum cleaner was turned off, the hose was still inside the vessel and dirt, dust and small foreign particles fell back down into the vessel.
The inspector is unable to determine at this time if the reactor vessel is still in a Class "B" cleanliness condition in accordance with GE specification 21A2045, revision 2.
This item is considered an unresolved item.
(440/81-08-01),
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b.
On April 12, 1981 the installation of the steam dryer / separator (1B1,3-D005 ) into the reactor vessel was being conducted during ad-verse weather conditions.
GE specification 22A4671 paragraph 3.10.1 states in part "A protective cover shall be built over the top of the vessel.
This cover shall not be removed for installation of internal parts unless the weather forecasts indicate reasonable assurance that rain or stoms are not imminent and that there will be time to replace the cover." The inspector questioned the licensee on this subject.
The licensee notified the inspector that nonconfoming reports (NR)
GE38-194 and GE38-199 were issued on this matter.
Also, the Nuclear Quality Assurance Department issued an Action Request ( AR) #297.
During an inspection of the internals on April 16, 1981, the RI and GE QC personnel found that the internals had water (approximately I gallon) still standing on them.
This cor ;ition represents an item of noncompliance as identified in Appendix A.(440/81-08-02) 7.
Observation of Structure Steel Work and Work Activities - Units 1 and 2 The inspector observed work activities including welding, receipt in-spection and storage of structure steel.
a.
The inspector observed receipt inspection of safety related structure steel and detemined that procedural requirements had been met and that inspections verify acceptability in accordance with Pittsburg Bridge Iron (PBI) specification no. 85 and Quality Assurance Program, Section 10.
b.
Tour of the storage area was made by the inspector to detemine that control, marking, protection and segregation were in accordance with PBI Quality Assurance Program, Section 13.
c.
The inspector observed partially completed and completed columns YS, Y6, Y7 and Y10 located at the 578 ft, elevation in reactor buildings.
The inspector detemined that installation was in accordance with the lay-out drawings D-561-036 and D-561-038.
Welding was being per-fomed by qualified welders and PBI welding procedure specification SMA-14 for joint design, weld rod issue slip was correct in accordance with PBI Quality Assurance Program, Section 9, Paragraph F.3.
The inspector detemined that the fit-up/ alignment was within the toler-ances of the drawings.
NOTE: During the inspector's observation of the welding activities, the inspector asked the welders (4) how they determined the pre-heat temperature (2250 F.).
The welders stated that they were issued temp-sticks by the Qualfty Control Section, but were unable to produce them due to various reasons.
Prior to the inspector leaving the work area, PBI QC section reissued I'
new temp-sticks to each welder / fitter. PBI also issued a Corrective Action Motice (CAN)
No. 4-81-1 to construction immediately.
A training session was held the same day instruc-ting welders / fitters to use temp-sticks for pre-heat welding.
d.
The inspector reviewed PBI ultrasonic examir.ation test reports nos.
t UT-34-77-81-47U, UT-34-77-81-48U, UT-34-77-81-48SB and UT-34-77-81-4 9U for the aforementioned column welds.
Test reports appear to be in accordance with PBI procedure for ultrasonic examination, UT-NIC-059 revision 4.
No items of noncompliance or deviations were identified.
Unresolved Items Unresolved items are matters about which more information is required in order to detenmine whether they are acceptable items, items of noncompliance, or de-viations. Unresolved items disclosed during this inspection are discussed in Paragraph 6.a.
Exit Meetings The inspector met with licensee reptasentatives (denoted in Persons Contacted) on April 3, 10, 17 and 24, 1981.
The inspector summarized the scope and findings of the inspections performed.
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