ML20035G804
| ML20035G804 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/12/1993 |
| From: | Jordan D SENIOR FLEXONICS, INC. |
| To: | Moerke C COMMONWEALTH EDISON CO. |
| References | |
| REF-PT21-93 NUDOCS 9304300041 | |
| Download: ML20035G804 (4) | |
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'I April 12,1993 4
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Commonwealth Edison Company
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Quad Cities Nuclear Power Station b
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22710 206th Avenue North Cordova, IL 61242 1
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Attention:
Charles A. Moerke, Site Engineering Supervisor p
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Subject:
10CFR21 Reportable Non-Compliance 6
RE:
Comr.onwealth Edison Co. P.O. No. 343180 and 325483 I-Senior Flexonics Jobs N144 and T104N j:,.
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This is to advise you that the clam shell expansion joints supplied to you on the above referenced purchase orders were not hydrostatic tested as required by ASME Section 111, Class MC,1980 Edition with Summer 1982 Addenda, Para. NE-8230, prior to the applicable data reports being certified.
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.y in the case of P.O. 343180(N144), these items were NPT stamped and an N-2 Data Report completed and certified by Senior Flexonics and our Commercial Union Authorized Nuclear inspector. Based on the requirements of NCA-8320, the NPT stamp should not have been applied and the-data report should not have been oortified without performance of the required hydrotest.
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i in the case of P.O. 325463(T104N), the same scenario applies except that these units were not NPT stamped or N-2 Data Report certified. -However, in this instance, a
" Certificate Holder's Data Repod of Third Party inspection for Non-Stamped identical Nuclear Parts" was completed and certified by_ the same parties as above. This data report basically certified to the same ortleria as a standard N-2 report does.
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Based on the above information, it is the opinion of Senior Flexonics that both of these situations would be reportable under the rules of 10CFR21,
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April 12,1993
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I' By this letter, we request your concurrence and assistance in this matter, if you do not concur pinase udvise us, in writing, of your reasons for non-concurrence and the justification for your reasoning.
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- (I' if you do concur, please advise us of the safety hazard that could be created should these iterns not function as certified. This information needs to be included in our formal report to the NRC.
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Senior Flexonics honestly feels that these items will function totally as they were designed to and does not feel that there is any impending safety concem.
,j Re cause of this situation appears to have been strictly an oversight by all parties concemed.
f Senior Flexonics believed, or wrongly assumed, that these units would be subjected to
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a system test after installation and obviously were not reading the code requirements thoroughly, otherwise, we would have realized that the stamping and certifying could not have boon completed until the hydrotest was complete. Senior Flexonics included a 6tatement on the Commonwealth Edison Co. approved drawings that the pressure test would be by "Others" and also included a statement ' Hydrostatic test will be performed by others after Installation" on the N 2 form.
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'l Obviously, there was no' intent on the part of Sonior Flexonics to circumvent Code requirements. This is a prime example of a misunderstanding of the requirement which was overlooked by all parties throughout the fabrication, certification, and installation functions.
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lt is now imperative that resolution of this mistake be expeditiously processed.
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Senior Flaxonics proposes the following actions as a possible resolution to the situation.
Senior Flexonics will fabricate two (2) bellows elements, klentical to those supplied on P.O. 343180, and subject them to the Code required hydrostatic test pressure for verification that the design is more than sufficient to withstand any pressure experienced in operation and show no evidence of leakage, meridional yleiding or squinn.
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3 These test units would be fabricated from the same heat of material as those installed and processed in exactly the same manner and sequence.
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Pago Three April 12,1993 di~
y Upon successful completion of the testing of these units, Senior Flexonios proposes that these test results be utilized as justification for acceptance of the instaHed units in Penetration X-12 at Quad Citias-Unit No.1. These are the loner bellows of that penetration.
.@I All of the above operations and processes would be performed under the witness and verification of our Authorized Nuclear Inspector and would be available for witness by Commonwealth Edison Co. personnel and other interested parties.
in the case of Commonwealth Edison Co. P.O. No. 325463, please advise which of the supplied units have been installed so we may determine what action needs to be taken in regard to the installed units.
I I have reviewed our inventory and verified that we still have material of the same heat in stock as was used to fabricate the bellows elements on 325463, so the same justification soonario could be followed.
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Your assistance in these matters will be appreciated and I apologize for the inconvenience created by these situations.
i Ji You are requested to tag any non-installed units, on either of the above P.0,*s, identifying them as *Not for installation" until these situations are resolved.
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i Your expedillous response is needed and will be greatly appreciated.
. !5 Very truly yours, I
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' ' '8 2/93
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Dick 4 rdan Director of Nuclear Contracts
' ?,Il and Quality Assuranoo
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G. Hoursett -Vice President and General Manager j
G. Perkins
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C. Wendler -ANI-Commercial Union B. Juarez
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Commonwealth Edison Co. Corres Filo Don Noe
-Commonwealth Edison Co.
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-Commonwealth Edison Co.
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10CFR21 Report File Region lil-USNRC -Hubert Miller O
USNRC-Operations Center-Washington, D.C.
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