ML19331C824
| ML19331C824 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/13/1980 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8008190601 | |
| Download: ML19331C824 (4) | |
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@Mj'I THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P G SCX fc00
- CLEVELAND. CMIC 4101 TELEPMCNE G1EJ E22-Geoc
- ILLUMtNATING EL::G.
- 55 PUS;,1C s0VARE
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O2!v/yn R. Davicson v CE petsioENT SystEu ENGeNEERiNG AND CoNSTmvCTioN August 13, 1980
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Gaston Fiorelli IINb DOCUMENT CONTAINS Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission P00R QUAUTY PAGES Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RI:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Re.ponse to I. E. Report
Dear Mr. Fiorelli:
~~his letter is to acknculedge receipt of your Inspection Report Nunber 50-440/
50-10, attached to your letter dated July 9,1950.
Tcis report identifies areas exanined by Mr. E. . K. I.ee during :he inspection conducted June 25 through 27, 1980.
A : ached to this letter is our response to the two (2)'itens of noncenpliance described in Appendix A, Notice of Violation.
Tnis 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.
Please call if there are any' questions.
Very truly yours, 4t D. R. O_vidson Vice President Systen Engineering and Construction ks:
At:achment cc:
J. Hughes N
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8008190GO/
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RESPONSE TO E!.?ORCEMEN* ITD!S s
Listed below are cur responses to Appendix A, Notice cf 's'iolation, cf United States Nuclear Regulatory Cc::issic: I. E. Reper: 50 440/S0-10.
I.
A.
Infraction 10CFR50, Appendix 3, Criterion IX, states tha: "'feasures shall be established to assure that special processes, including velding, heat treating, and nendestructive testing, are centrolled and acec:plished by qualified personnel using qualified precedures in accordance with applicable codes, standards, specifica: ions, criteria and other special require =ents.
Cleveland Electric Illu=inating Cc=pany PSAR Section 17, paragraph 17.1.9.1 states, in part, tha:
"Special processes to be used during the manuf acture and installation of equip ent shall be estab-lished and controlled in acccrdance vi;h app cved procedures..."
General Electric Cc:pany Installatien and Service Engineering Division (ISSE) ? ocedure No. GWP-1000, Revisic: 15, Paragraph 5.11.1.1 states
- hat, "3ead vidth shall be linited te :he lesser of three ices the dia eter of the electrode cere, er 5/3"."
Contrary to the above, on June 26, 1950, the inspec:c: established that at least a pass of the veld head vid:h cf the Eacirculation Syste: Weld No. 333-1-36,cn Tr avele: No. T1-3 3 2-0 6 was be:veen 3/4" to 1" and 1/S" diameter electrodes were uaed.
3.
Response
1.
On June 26, 1980, GE !&SE issued Nonconfor=ance Reper: Gd 38-24 which required tha: the referenced veld be reworked.
The affected veld bead in the area described was to be g:cund down and then reverked as required by approved procecures.
.nis work was cc -
i pleted, and the Nonconfor=ance Report was closed out on July 1, i
19S0.
i 2.
Corrective Action Reques: 0499 was issued :c CE I&SE (SP-38/39) as a result of this NRC observation.
In response, a special teaching and practical denenstration en velding techniques was ad=inistered to the CE Quality Con:rci Inspectors, the ?:oduction Engineers, and the velders to reinforce personnel ecgnizance of stated require ents.
This actica was de:er=ined to be acceptable, and CAR 0499 was closed cut on July 15, 1980.
3.
Full cc:pliance has been achieved.
IISPONSE TO ENTORCEMENT ITEMS I. E. REPORT 50-440/80-10 PAGE 2
-. fraction In II.
A.
10CFR50, Appendix L, Criterion X, states, in part, that...
"A progra:
for inspection of activities affec:ing quali:y shall be established and executed by or fer the organica:1on perforning the activity to verify conformance with the docu ented instructions, procedures, and drawings for accomplishing the activity..."
Cleveland Electric Illucinating Cc pany PSAR Section 17, Paragraph 17.1.10.1 states, in part, that... "A progra: for inspection has been established by CEI to assure that all safety class ecuip ent and structures meet required quality standards..."
Pullman Power Products (???) Procedure No. II-5, dated February 28, 1979, Par;sraph 8.1.4 states,... " Undercutting occurring at any po-sition en the entire length of the veld shall not exceed 1/32 inch in depth or in any case reduce the required section thickness." Pullman Power Products drawing for Pipe Support No. l?42-H123 requires that "a' elds No. AF24 and AFW5 be full pene: ration velds.
Contrary to the abcve, on June 27, 1930, the inspector es:ablished that Weld Nos. AF24 and AFW5 of the I:ergency Cicsed Cocling Syste:
Pipe Supper: No. 1?42-H123 failed :o mee: the procedure and drawing requirements in tha t (1) the velds appear to have undercuts exceeding 1/32", and (2) the velds do ne: appear :c penetrate the back side of p la te.
Further:cre, bc h velds were accepted by ??? on September 17, 1979.
3.
Response
1.
The velds identified during the inspection, Hanger 1?42-H123 FW-4 and 5, were exa:Ined by Fullman ?cuer Products and CEI inspectors.
Ecth velds were deficient because of undercut of appreximately 1/32" and undersice veld a: the veld extremities. 3c:h velds were I
found to have full penetratien.
In additi:n, FW-2 en Hanger lElt-H217 was found to have undercut of approximately 1/32".
Full an Power Products initiated noncenformance report number ???-354 docu-i en:ing the above deficiencies.
In addition, the Project Organiza:icn is performing 100% final veld inspection of ten (10) Fullman installed hangers selected at rando=.
Tce results of these inspections vill be used to determine whether the above deficiencies are isciated cases or whether they repr,esen:
generic proble: areas.
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Proj ect Organica:icn QC perf orrs regular Surveillance / Inspection of Full:an ?cver Products field welding activities.
The results of these Surveillance /!nspecticas indicate there are no generic proble=s vith Pullman ?cuer Products field welding.
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I. E. ?.EPORT 50-440/80-10 FACE 3
'r Reseense (Cent'd) j 2.
Individual training see icns are being held w :h the C.0 Inspectors to assure their understanding cf acceptable veld p:0 files and in-spection techniques.
3.
Full ec pliance wi:1 be achiaved by Augus: 29, 19EO.
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