ML19344A790
| ML19344A790 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/21/1980 |
| From: | Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8008220211 | |
| Download: ML19344A790 (1) | |
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UNITED STATES 8 '
k NUCLEAR REGULATORY COMMISSION IIC
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709 ROOSEVELT ROAD GLEN ELLYN ILLINOIS 60137 o
%UL' 21 S00 Docket No. 50-440 Docket No. 50-441 Cleveland Electric Illuminating Company ATTN: Dalwyn R. Davidson Vice President - System Engineering and Construction Post Office Box 5000 Cleveland, OH 44101 Gentlemen:
Thank you for your interim report dated July 11, 1980, pursuant to 10 CFR 50.55(c), regarding water-soluble purge dam material. We will review your final report on this matter upon receipt.
Your cooperation with us is appreciated.
Sincerely, G. Fiorelli, Chief Reactor Construction and Engineering Support Branch cc: Director, RCI/IE Director, AEOD Chief, OEB/MPA IE Files cc w/ltr dtd 7/11/80:
Central Files PDR Local PDR NSIC
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Harold W. Kohn, Power Siting e
Commission Mr. Daniel D. Wilt, Attorney Helen W. Evans, State of Ohio
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C L E V E L /t N P E L E C T R I C ll. L U.M I N I T i l. G L o '
2 P.o. Box 5000 m CLEVELANo, oHlo 44101 e TELEPHONE (216) 822-9000 e ILLUMINATING sLDG. e 65 PUBLIC SoVARE Serving The Best Location on the Nation vlCE PRE $iOENT SYSTE3 ENGINEERING AND CONSTRUCTION July 11, 1980 Mr. James C. Keppler Director of Region III Office of. Inspection and Enforcement U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 i
RE: Perry Nuclear 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 letter 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 CWS 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 dams too close to the veld area.
Investi-gation has determined this problem to be generic to both carbon and stainless steel piping of all sizes in both safety and non-safety systems.
It was also determined that the piping contractor did not have a procedure addressing the type of material used or controls for issuing and placing the purge dams.
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Mr. Jcris G. Kspplar July 11, 1980 J
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 after heat transformation have been sent to CEI's laboratory and three independent 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, chemical cleaning, and visual inspection.
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Mr. J =23 C. K',ppist 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, k
Ps 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. Nuclear Regulatory Commission c/o Document Management Branch Washington, D.C.
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