ML19320C282
| ML19320C282 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/11/1980 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| References | |
| NUDOCS 8007160598 | |
| Download: ML19320C282 (3) | |
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P.o. Box 5000 m CLEVELANo. ohio 44101 e TELEPHONE (216) 622-9800 e ILLUMINATING BLoG. e 55 PUBLIC$oVARE Daiwyn R. Davidson viCE PRES 10ENT SYSTEu ENGINEER;NG AND CONSTRUCT:oN July 11, 1980 Mr. James G. Keppler Director of Region III Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE: Perry NucAear Power Plant Docket Nos. 50--440; 50-441 Interim Report on Use of Mono-Sol brand, 7-0015-3 CWS Polyvinyl Alcohol Film, Water Soluble Purge Dam Material, Manufactured by Chris Craft Industries
Dear Mr. Keppler:
This retter serves as an Interim Report as required by 10CFR50.55(e) concerning use of Mono-Sol brand, 7-0015-3 CWS Polyvinyl Alcohol Film, Water Soluble Purge Dam Material, manufactured by Chris Craft Industries. This was first reported by W. J. Kacer of the Cleveland Electric Illuminating Company to J. Konklin of your office on June 12, 1980.
This report includes a description of the deficiency, an analysis of the safety implications, and the corrective action taken to date.
Description of Deficiency:
The PNPP piping contractor (Pullman Power Products) has been using a purge dam material classified as water soluble by the manufacturer Chris Craft Industries. The material is identified as Mono-Sol, 7-0015-3 CVS Polyvinyl Alcohol Film. Under certain environmental conditions (subjected to heat, approximately 400*F), this material is transformed into a substance which will not dissolve in water.
Piping systems in which this material was used have been subjected to heat above 400*F in the areas of purge dam placement by post weld heat treating, application of diamond / ring heat patterns for bending pipe, and placing purge dass too close to the veld area.
Investi-gation has determined this protice to be generic to both carbon and stainless steel piping of all sizes in bc'th safety and non-safety systems.
It was also determined that the piping contractor did not have a procedure addressing i
the type of material used or cont tols for issuing and placing the purge dams.
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/!O 8007160598
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Mr. James G. Kepplar July 11, 1980 Analysis of the Safety Implications:
Certain piping systems will not be subjected to water flush or hydrostatic testing prior to plant operations. System designs do not provide access for installation of temporary strainers at all equipment such as heat exchangers and flow orifices. Undissolved purge dam material could restrict flow of fluids and prevent proper seating of valves during plant operation.
Corrective Action Taken to Date:
A " Corrective Action Request" (CAR 0496) was issued to Pullman Power Products addressing the lack of procedural address. The CAR has been responded to, evaluated, verified and was closed out on June 9, 1980.
Pullman Power Products initiated and implemented Project Procedure IX-29, dated June 2,1980, for " Control of Purge Dams".
The PNPP Project Organization directed the contractor to discontinue use and remove from site all remaining 7-0015-3 CWS, Polyvinyl Alcohol Film per letter PY-SO/044/045-2873, dated May 30, 1980.
Samples of the material before and af ter heat transformation have been sent jto. CEI's laboratory and three independer.t laboratories to determine a solvent which will dissolve the material without damaging the pipe.
The Nuclear Engineering Department is preparing a list of systems which will not be subjected to water flush or hydrostatic testing. This information will be forwarded to the piping contractor.
The piping contractor is being directed by PNPP Project Organization to identify by weld number all locations where the referenced purge dam material was used.
Nuclear Engineering and Nuclear Test Sections have prepared a list of methods to be used both singularly and in combination to remove and verify removal of undissolved purge dam material. This list includes flushing, poly-pig cleaning, hydrolaser cleaning, chemi..al cleaning, and visual inspection.
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Mr. Jamas G, Kspplcr July 11, 1980 At the present time, CEI is still in the process of identifying locations of deficient' material in the piping systems and having chemical analysis performed to identify a solvent capable ~ of dissolving the purge dam material without damaging the pipe. This evaluation should be complete by September 1,1980.
After that, a plan to remove and verify removal can be established, and a final report will be submitted by December 15, 1980.
Very truly yours, 4
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Dalwy R. Davidson Vice resident System Engineering and Construction ksz cc:
Mr. Victor Stello, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 U.S. Nticlear Regulatory Co= mission c/o Docu=ent Management Branch Washington, D.C.
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