ML20030E009
| ML20030E009 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/26/1981 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20030E004 | List: |
| References | |
| NUDOCS 8109170281 | |
| Download: ML20030E009 (3) | |
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P o, Box 5000 e CLEVELANO, OHlo 44101 m TELEPHONE (216) 622-9800 e ILLUMINATING DLDG e 55 PUBL8C SoVAAE
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Dalwyn R. Davidson NSH$ E G\\NEERNG AND CONSTRUCTION August 26, 1981 Mr. C. E. Nore11us, Acting Director Division of Engineering and Technical Inspection U. S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Gisa Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Response to I. E u.eport
Dear Mr. Nore11us:
This letter is to acknowledge receipt of Inspection Report Number 50-440/81-09; 50-441/81-09, attached to your letter dated July 24, 1981, which was received on July 27, 1981.
This report identifies areas examined by Mr. K. D. Ward during his inspection conducted June 4 and July 14, 1981, and describes one (1) Severity Level V Violation in Appendix A, Notice of Violation.
As discussed by Messr. R. Rinderman and H. Walls of the Cleveland Electric Illuminating Company with Mr. D. Danielson of your office on August 21, 1981, we have determined that it is necessary to request an extension for submittal of our response to this item of noncompliance.
Mr. Danielson agreed to the extension but requested that an interim respor.se be flied stating corrective action taken to date and measures planned to resolve the problem, including the planned submittal date for our response pursuant to the provisions of 10CFR2. 201.
Accotdingly, attached to this letter you will find our interim response 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, V2 D. R. Davidson Vice President Systems Engineering and Construction DRD:pab Attachment cc:
NRC - Site 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 U. S. Nuclear Regulatory Commission c/o Document Management Branch
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RESPONSE TO ENFORCEHENT ITEMS Below is our interim response to Appendix A,. Notice of Violation, of United States Nuclear Regulatory Commission I. E. Report 50-440/81-09; 50-441/81-09.
I.
Noncompliance 440/81-09-01; 441/81-09-01 A.
Severity Level V Violation 10 CFR 50, Appendix B, Criterion IX states in part that, "Heasures shall be established to assure that special processes, including...
nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
The Perry Nuclear Power Plant, Units 1 and 2, PSAR Section 17.1.9.2, stated in part that "CEI requires contractors to establish and document measures that will assure that special processes will be accomplished...in accordance with the applicable codes..."
American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section V, 1974 Edition, Winter 1975 Addenda, Article 2, Paragraph T-2624 requires that the shim thickness shall be selected so the total thickness being radiographed under the penetrameter is essentially the same as the total weld thickness.
Contrary to the above, for several radiographs the shim thickness was not selected so the total thickness being radiographed under the penetrameter was essentially the same as the total weld thickness.
B.
Interim Response 1.
The following actions have been taken to prevent recurrence:
a)
Pullman Power Products (PPP) has been informed officially ther all radiographs produced in the shop and at the Site shall contain the required proper size shim.
b)
Gilbert Associates (GAI), our Architect / Engineer recalled all their field representatives and resident inspectors and held a training seminar, which included the interpreta-tion of radiographs and Code requirements.
c)
GAI has been directed to increase their radiographic test surveillance at the PPP shop in Williamsport, Pennsylvania, from 25 percent to 50 percent coverage until further notice. Project Organization surveillance coverage of PPP radiography at the Perry Site has been determined to be adequate.
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Interim Ragponte to Enforcem2nt Item Noncomp'Ifance 440/81-09-01; 441/81-09-01 Page 2 2.
To resolve this problem,' the PNPP Project Organization has committed to perform a 100 percent review of all.PPP shop radiographs. Acceptable density has been found during the initial phase of this review. Upon completion of 35 percent of the planned review, through an agreement with the Chief Inspector, State of Ohio, Boiler and Pressure Vessel Section and the Vice Chairman of the National Board of Boiler and Pressure Vessel Inspectors, they will again be requested to concur with our assessment of the_ corrective action being taken relative to the severity of the concern.
It is presently anticipated that this portion of the review will be completed during October 1981, and that our final response will be mailed by October 30, 1981.
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