ML20005B528
| ML20005B528 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/15/1981 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20005B520 | List: |
| References | |
| NUDOCS 8107080334 | |
| Download: ML20005B528 (3) | |
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P o Box 5000 e CLEVELAND, oHlo 44101 e TELEPHONE (216) 622-9800 e ILLUMIN ATING BLOG e
55 PUBLIC SoVARE Dalwyn R. Davidson N
UICE PAESIDENT SYSTE M ENGINEEAtNG AND CONSTRUCTION June 15, 1981 Mr. R. F. Heishman, Acting Director Division of Resident and Project Inspection 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. Heishman:
This letter is to acknowledge receipt of Inspection Report Number 50-440/
81-08; 50-441/81-08, attached to your letter dated May 21, 1981, which I received on May 26, 1981. This report identifies areas examined by Mr. J.
Hughes during his inspection conducted April 1 through 30, 1981.
Attached to this letter is our response to the one (1) Severity Level V Violation described in Appendix A, Notice of Violation, dated May 21, 1981.
This 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.
Our response has been submitted to you within twenty-five days of the date of the Notice of Violation as you required, and the information submitted is true and correct to the best of my knowledge, information and belief.
If there are additional questions, please do not hesitate to call.
Very truly yours, 1
/
D. R. Davidson Vice President Systems Engineering and Construction DR' /k 7 eh me it cc:
Mr. J. Hughes, h1C - Site U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, D. C.
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8107080334 810626 DR ADOCK 0500044o PDR MUN 2 219@
RESPONSE TO ENFORCEMENT ITEMS d*
Below is our response to Appendix A, Notice of Violation, of United States Nuclear Regulatory Commission I, E. Report 50-440/81-08; 50-441/81-08.
I.
Noncompliance 440/81-08-02 A.
Severity Level V Violation 10CFR50, Appendix B, Criterion V (Procedures), states in part that,
" Activities affecting quality shall be prescribed by documented instructions...and shall be accomplished in accordance with these procedures..."
CEI Corporate QA Program, Section 0500 requires that procedures and instructions of consultants, agents, contractors and vendors for those activities affecting quality shall be delineated by instructions and procedures.
Contrary to the above, General Electric (GE) failed to follow the above procedure by allowing the reactor vessel internals to be installed in inclement weather conditions (rain). GE Specification No. 22A4671, Revision 1, states in part, " cover of vessel shall be provided over the top of vessel, this cover shall not be opened or removed for installation of internal parts unless weather fore-casts indicate reasonable assurance that rain or storms are not imminent and that there will be time to replace the cover."
B.
Response
1.
General Electric I6SE immediately initiated Nonconformance Reports GE 38-191 and GE 38-194 to address this violation.
The Construction Quality Engineering Unit of Nuclear Quality Assurance Department issued an Action Request the following day for violation of GE Specification No. 22A4671, and Field Deviation Disposition Request (FDDR) KL1-113 was written covering the entrance of rain water into the reactor pressure vessel.
l The top of the steam dryer IB13-D005 was cleaned, and GE/I&SE has committed to do closer inspections of equipment during Installation and keep equipment covered. A sample of water was taken from the top of the steam dryer IB13-D005, analyzed, and the results were sent to General Electric San Jose.
2.
After the removal of the reactor pressure vessel head, steam dryer, and steam separator, the components and internals will be inspected and/or cleaned to assure compliance with the cleaning and cleanliness controls procedure.
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RIIponaa to Enforcem;nt Itcra Noncompliance 440/81-08-02 y.
Page 2 Response (Cont'd.)
Whenever the vessel is opened to the weather, a cover will be maintained until equipment must pass the flange elevation.
Also, prior to cover removal, local weather forecasts will indicate at least four hours of rain free weather. Nuclear Construction supervisory personnel have reviewed the require-ment of GE Specification No. 22A4671 and are fully aware of i
their responsibilities in this area relative to steps to prevent recurrence.
3.
Full compliance will be achieved by September, 1981.
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