ML19339C789
| ML19339C789 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/22/1980 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19339C788 | List: |
| References | |
| NUDOCS 8011190472 | |
| Download: ML19339C789 (2) | |
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P o Box 5000 e CltvELANo oH o 44101 e TELEPHONE (216) 622 9800 e ILLUMINATING BLoG e 55 PUBLIC soVAH.
Dafwyn R. Davidson viCE PRES 10ENT SYSTEM ENGINEERING AND CONSTRUCfloN October 22, 1980 Mr. Caston Fiore111 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 Res)onse to I. E. Report
Dear Mr. Fiorelli:
This letter is to acknowledge receipt of your Inspection Report Number 50-440/
80-16, 50-441/80-15, attached to your letter dated September 18, 1980, which I received on September 22, 1980. This report identifies areas examined by Mr.
J. Hughes during the inspection conducted August 1 through 31, 1980.
Attached to this letter is our response to the item of noncompliance described in Appendix A, Notice of Violation. This response is in accordance with the provisions of Section 2.201 cf the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Should there by any questions, please don' t hesitate to call.
Very truly youre,
/bys/.Mn i
D. R. Davidson Vice President System Engineering and Construction ksz Attachment cc:
J. Hughes, NRC - Site U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C.
20555 80111,9Oyyk2 OCT' 2 7 seal
J A
RESPONSE TO ENrTRCEMENT ITES Below is our response to Appendix A, Notice of Violation, of United States Nuclear Regulatory Commiscion I.E. Report 50-WO/80-16; 50-W1/80-15.
I.
Noncompliance W O/80-16-03; W l/80-15-03 A.
Deficiency 10CFR50, Appendix B, Criterion V (Instructions, Procedures, and Drawings) and PNPP PSAR Chapter 17, Section 17.1.5, requires that activities affecting quality... shall be accomplished in accor-dance with instructions, procedures, and drawings.
CEI Corporate Project Administration Procedure 1501, Revision 1, Paragraph 1.2.3, states that "... utilizing the criteria for reporting deficiencies under 10CFR50.55(e) and 10CFR Part 21, per-fom a cursory review to determine if the deficiency may be repor-tableunder10CFR50.55(e)and/or10CFRPart21."
Contrary to the above, there is no documentary evidence that a cursory review was completed on the Ruskin Manufacturing Company, type N1BD23 fire dampers deficiency, which was reported to the NRC as a 10CFR Part 21 item in April 1980.
B.
Response
1.
Subsequent to the questions raised by the inspector, Deviation Analysis Report 035 was initiated on August 8, 1980 to document evaluation of the report made under the provisions of 10CFR21 by Ruskin Manufacturing Company concerning Vertical Spring Closure, N1BD23 Fire Dampers. The engineering analysis for these fire dampers as installed by the HVAC contractor at FNPP identifies them as being non-cafety related and notes have been added to the affected diagrams to identii'y the fact that the fire da=pers are an exception to the safety-related classifi-cation of the system.
2.
As part of our evaluation of the ramifications of a contractor reporting r 10CFR Part 21 significant deficiency, we evaluated our inter 41 procedures relative to their significa=,;e and com-pletene',4 for total project involvement. Based on this evaluation, we proposed to strengthen our procedures by the appropriate revis-ions to include quicker evaluations to deter =ine if potential items are reportable under 10CFR50.55(e). In addition, the importance of timeliness in reporting of potential significant deficiencies has been discussed in detail with our resident inspector during our pro-grammed weekly meetings with project r,armgement.
3.
Full compliance, including revis_ons to the procedures, will be achieved by December 1,1980.