ML19331E404
| ML19331E404 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/30/1980 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19331E398 | List: |
| References | |
| NUDOCS 8009100112 | |
| Download: ML19331E404 (3) | |
Text
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JDahwynR.Davidson TIlE CL EVEL A N D ELECTRIC ILLU MIN ATIN G CD f/ P A NY P.o. Box $000 m CLEVELAND. oHlo 44101 e TELEPHONE (216) 622-9800 e ILLUMINATING BLDG.
e 55 PUBLICSoUARE 0
VICE PRESIDENT SYSTEM ENGINEERING A*-D CONSTRUCTION July 30, 1980 Mr. Gaston Fiorelli Reactor Construction and Engineering Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to I. E. Report
Dear Mr. Fiorelli:
This letter is to acknowledge receipt of your Inspection Report Number 50-440/
80-09, 50-441/80-09, attached to your letter dated June 26, 1980, which I received on June 30, 1980. This report identifies areas examined by Mr. J. E.
Konklin during the inspection conducted June 10 through 12, 1980.
Attached to this letter is our response to the two (2) items of noncompliance described in Appendix A, Notice of Violation. This response is in accordance with the provisions of Section 2.201 of the NRC'. " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Please don't hesitate to call if there are any questions, Very truly yours, AV?
W D. R. Davidson Vice President System Engineering and Construction ksz Attachment ec:
J. Hughes
$000
&009100k
RESPONSE TO ENFORCEHENT ITEMS
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Listed below are our responses to Appendix A, Notice of Violation, of United e
States Nuclear Regulatory Commission I. E. Report 50-440/80-09; 50-441/80-09.
I.
A.
Infraction 10CFR50, Appendix B, Criterion V, states in part that, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in acco'rdance with these... Instructions, procedures, or drawings shall include appro-priate... acceptance criteria..."
The CEI Corporate Nuclear Quality Assurance Program, Section 0500, Paragraph 1.1.1, states in part that, " Activities affecting quality shall be described by an approved instruction, procedure, or policy
... Appropriate quantitative and qualititative acceptance criteria shall be delineated to provide measures for determining the satis-factory accomplishment of important activities."
Contrary to the above, during the period June 10-12, 1980, the in-spector found that CEI did not have adequate procedural requirements, including appropriate acceptance criteria, for accomplishment and verification of the reactor vessel recirculation nozzle modification
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B.
Response
l 1.
- Following the NRC inspection, several actions were taken. Gen-eral Electric ultrasonically examined all twenty recirculation l
nozzles to obtain thickness measurements.
The value and location l
of minimum wall thickness for each nozzle was noted on the exam-ination data sheet. An Action Request was sent to General Electric San Jose requesting:
(a) the minimum design calculated wall thickness for a nozzle of maximum nominal inside dimension; and (b) the minimum design calculated wall thickness for the nozzle which, by indication configuration, proved to be the worst case identified at Perry, Units 1 and 2.
The minimum wall information provided by General Electric Company was compared to the ultrasonic thickness data obtained for each nozzle. Construction Quality Engineering and Engineering agreed that all twenty nozzles met the acceptance criteria based on the data received.
2.
The control of wall thickness was based on implementing approved procedures. Pre-machining and. post-machining measurements were taken as part of approved procedures. A 0.060-inch grinding limit was imposed on GE I&SE by GE San Jose. Beyond this limit a Field Design Deviation Request had to.be generated which con-l' trolled the depth of grinding and permanently recorded these dimensions. A Project Administration Procedure has been draf ted which will define interface control of Field Disposition In-p struction/ Field Deviation Disposition Requests between CEI and GE.
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R2sponas to Enfercement Items
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4 I. E. Rapsrt 50-440/80-09; 50-441/80-09 Page 2 Response (Cont'd.)
3.
Full compliance will be achieved by September 30, 1980, f
II.
A.
Deficiency 10CFR50, Appendix B, Criterion 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..."
The CEI Corporate Nuclear Quality Assurance Program, Section 1700, Paragraph 1.2.3, states in part that, " Sufficient records and docu-mentation shall be maintained to provide evidence of...the activity affecting quality...The following shall be considered as part of
. quality assurance records:...Results of reviews..."
Contrary to the above, on June 11, 1980, the inspector and CEI li-censing personnel were unable to find evidence that reviews had been made of those IE Bulletins and Circulars which did not require a written response to NRC.
B.
Response
1.
All IE Bulletins, Circulars, Information Notices and Preliminary Notifications of Events or Unusual Occurrences sent to PNPP are being reviewed and evaluated by a responsible project section.
As of July 2, 1980, these evaluations are being documented and i
maintained on file, both for IE Documents requiring written re-sponse to the NRC, and for those which do not.
To provide com-prehensive records, a documented review of all IE Documents received prior to July 2,1980, is being conducted.
2.
The program for review of IE Documents has been revised, and Project Administration Procedure 1601, effective July 2,1980, entitled " Evaluation of IE Documents" has been issued. Addi-tionally, Nuclear Design Instruction 35-0603 is being revised to j
clarify preparation of the required documentation, 3.
Review of previously received IE Bulletins'and Circulars will be j
completed by November 1,1980, and full compliance with Project review commitment will be achieved by June 1, 1981.
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