ML19274E435
| ML19274E435 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/01/1979 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19274E433 | List: |
| References | |
| NUDOCS 7903260102 | |
| Download: ML19274E435 (5) | |
Text
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T H E C L E V E L A N D E L E C T R I C I L L U M I N AT I N G C 0 fC F /J: t ILLUMINAn;4G tLDC. o PUBUC SQUARE e CLEVELAND, OHtO 44101 e TELEPHONE (216) 623 1350 m MAIL ADDRESS: P.O. BOX 6000 Dalwyn R. Davidson VICE PRESIDENT SYSTEu ENGINEERING AC CONSTRUCTION March 1, 1979 Mr. Gaston Fiore111 Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Fiore111:
This letter is to acknowledge receipt of your Inspection Report Number 50-MO/78-15;50-W1/78-14,attachedtoMr.Heishmtm'sletterdated January 24, 1979, which I received on January 29, 1979 This report identifies areas exerined by Messrs. J. E. Konklin, K. R. Naidu, and W. A. Hansen during the inspection conducted November 28 through December 1, 1978.
Attached to this letter is our response to the three (3) items of non-e-tpliance described in Appendix A, Notice of Violation. This response is in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Shou ~.d there be any questions, please don't hesitate to call.
Very truly yours, D. R. Davidson Vice President System Engineering and Construction ksz Attachment i
7903260102.
.AR 0 21979
RESPGISE TO ENFORCDEIT ITEMS 9
Listed below are the responses to the noncompliances identified in Appendix A, enclosed with United States Nuclear Regulatory Coc=ission Notice of Violation,/78-15; 50-Wl/78-14.
IE Report No. 50- W O I.
A.
Infraction 10CFR 50, Appendix B, Criterion VII states, in part, " Measures shal.1 be established to assure that purchased materials, equircent and services, whether purchased directly or through contractors and subcontractors, confom to the procurement documents." Paragraph 17.1.7 of the Quality Assurance Program documented in the Perry Nuclear Power Plant (PNFP)
PSAR states, in part, " Appropriate measures will be included to evaluate procurement cources, monitor the actidties of vendors and contractors, and confim that purchased material confoms to procurement documents..."
Contrary to the above, measures established by CEI did not assure that stainless steel liner plates beits installed in the Spent Fuel Storage Pool were inspected to Section 4.30 of the AWS D1.1-75 Code, as required by paragraph 2:07:2 of Specification SP-665 The NRC inspector identified several Nelson Stud attachments which had been repaired by stick welding and had not been bend tested as required by the code. Also, several welds attaching angle-iron stiffeners to the stainless steel veir wall liner plates were observed by the inspector to be less than the specified size.
CEI's failure to assure that purchased materials (embedmente and structural steel) confom to requirements was cited (against Criterion IX) once previously as an item of noncompliance in IE Inspection Reports No. 50-40/78-02andNo.50-W1/78-01.
B.
Response
Newport News Industrial Corporation required their sub-vendor J. T.
1.
a.
Ryerson to perfom 100% reinspection of the Fuel Pool Liner Plate stud welds on both installed plates and those in storage. Approx-imately 750 welds were verified with about 60 questionable veldments being identified. Evaluation has been ocupleted on all but three (3) studs which must be weld repaired due to undercut. Newport News Industrial Corporation has written NR 53-32 to document and correct the three remaining weldments, b.
The weir wall angle iron stiffeners will be reinspected prior to further construction activities making the veldments inaccessible.
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RESPONSE TO ENFORCDENT ITEMS
- Page 2 2.
As a result of identified weld deficiencies and the failure to perfom the 15 bend test on studs repaired by fillet velding, manufacturing surveinance activities of NNIC and its vendors have been increased. Project manufacturing assurance specialists engaged in surveinance of Newport News and its vendors have been instructed to pay partiedar attention to the AWS inspection requirements in their attendance at final inspections of safety-related ite=s on which welding has been perfomed.
3.
a.
Stud weld repairs will be complete by March 15, 1979 b.
The angle iron stiffeners will be reinspected and repaired, as needed, before further construction or no later than May 1, 1979 II.
A.
Infraction 10CFR50, Appendix B, Criterion IX statas, in part, " Measures shall be established to assure that special processes, including welding...non-destructive testing, are controlled and accomplished...using qualified procedures in accordance with applicable codes, standards, specifications, criteria..."
Paragraph 17 1 9 of the Quality Assurance Program in the PNFP PSAR states, in part, "Special processes to be used during the manufacture and instal-lation shall be established and controlled in accordance with approved procedures. Welding,... nondestructive examination and other processes which require unusual care or close control shall be perfomed in accord-ance with appropriate written procedures."
Contrary to the above, on the evening of Nove=ber 28, 1978, the NRC inspectors observed that adequate measures had not been established to 0
verify and document that the preheat temperature was above 70 F for containment liner plate welding, as required by the relevant specification, SP-17. Furthemore, the inspectors detemined that a program was not established to ascertain whether the welding machines met the requirements of paragraph 31.2 of the AWS D1.1-75 Code or to document that the NNI inspectors verified that the requirements of paragraph 6.3.2 of AWS D1.1-75 Code were met. Specification SP-17 requires confomance to AWS D1.1-75 B.
Response
1.
a.
Newport Nevs' Quality Control Inspectors have been Elven additional training on the requirT:lents for, and methods of, monitoring preheat and interpass temperaturec during welding operations with special attention given to interrupted operations. Censtruction supervicors have been directed te use strfp heaters for all large weld =ents on members. Small or li=ited access areas will still use localized beating for preheat but with extra monitoring by the velders and supervisors to insure proper preheat is maintained.
. RESPONSE TO ENFORCDENT ITD4S l
Page 3 b.
Newport News' Welding Engineering has issued a memo to NNIC Quality Assurance that establishes the technical basis and quali-fications for the machines in use by NNIC at FNPP.
2.
NNIC QA and Weld Engineering will prepare an instruction to provide for the monitoring of welding operations. The instruction and program will cover both the verifying of physical parameters such as root gap, preheat and interpass temperature and final dirtensions as well as the particular attributes of welding, such as voltage, amperage and travel speed. This will insure that a continuing program is in place to monitor veld machine and welder perfomance. The program will also provide for random surveillance of preheat control in addition to the mandatory inspections required by the welding program which are documented on the Weld History Record.
3.
The immediate corrective action is complete. The welding sur-veillance instruction will be written, reviewed and approved by April 16, 1979 III.
A.
Deficiency 10CFR50, Appendix B, Criterien XVII states, in part, that " Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include...the results of reviews, inspections, tests,...'Ibe records shall also include closely related data such as qualifications of personnel."
Paragraph 17.1.17 of the Quelity Assurance Program documented in the PNPP PSAR states, in part, " Approved procedures shall establish and control the QA records program of each participant responsible for quality."
Contrary to the above, the NRC inspector identified several discrepancies in the Pressure Test Reports related to the Units 1 and 2 Reactor Vessel Pedestal embedment leak chase system.
B.
Response
1.
On January 3, 1979, the Construction Quality Engineering Element rescinded approval of NNI Procedure h65-N-TOO5, titled " Pressure Test for the Containment Vessel Base Liner and Leak Chase System",
Revision A.
7ne recision of the procedure approval stopped any flirther pressure testing until such time as the procedure is re-vised to clarify the requirements for proper documentation and record keeping for pressure testing.
- RESPONSE TO ENTORCEMENT ITEMS l
Page 4 NNIC has been directed to review the pressure test reports (ITR's) ccupleted to date and provide an explanation of personnel qualifi-cations that win document that the tests were conducted by an appropriately qualified inspector. NNIC will complete this review by March 1, 1979 2
'Ibe revised procedure win be reviewed by the Construction Quality Engineering element to ensure that the procedure adequately addresses personnel qualification and data reporting to avoid further confusion as to the identity of the individual who conducted the tests.
3.
Fun ecupliance vin be achieved by March 31, 1979