ML20040H004
| ML20040H004 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/28/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20040G997 | List: |
| References | |
| NUDOCS 8202160720 | |
| Download: ML20040H004 (5) | |
Text
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' THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P o. box 5000 m CLEVELAND. Ohio 44101 e TELEPHONE (216) 622-9800 m fLLUMINATING BLDG B
55 PUBLIC SOUARE Serving The Best Location in the Nation D;lwyn R. Davidson WCE PRESIDENT January 28, 1982 SYSTEM ENGINEERING AND CONSTRUCTION Mr. C. E. Norelius, Director Division of Engineering and Technical 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. Norelius:
This letter is to acknowledge receipt of Inspection Report Number 50-440/81-16; 50-441/81-1f, attached to your letter dated January 5,1982.
This report identifies areas examined by Mr. I. T. Yin during his inspection conducted November 17-20, Decamber 10-11 and 15, 1981.
Attached to this letter is our response to the three (3) Severity Level V Violations described in the Appendix, Notice of Violation, dated January 5, 1982. 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 thirty 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, j
IW 71 i
)
Dalwy Davidson Vice President Systems Engineering and Construction DRD:pab Attachment C
cc:
Mr. M. L. Gildner - NRC, Site Mr. R. L. Spessard, 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 Washington, D.C.
20555 8202160720 820200 PDR ADOCK 05000440 FEB 3 G32 G
RESPONSE TO ENFORCEMENT ITEMS Below is our respons, to Appendix, Notice of Violation, of United States Nuclear Regulatory Commission I.E. Report 50-440/81-16; 50-441/81-16.
I. Noncompliance 440/81-16-01; 441/81-16-01 A.
Severity Level V Violation 10CFR50, Appendix B, Criterion III states, in part: " Measures shall be established to assure that... design basis...for those structures, systems, and components...are_ correctly translated into specifications, drawings, procedures, and instructions.
These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled."
Perry Nuclear Power Plant, Units 1 and 2 PSAR Chapter 17, Paragraph 17.1.3.1 states, in part, that, " Design control is performed by participating design groups to assure that the design of safety class structures, systems, and components will provide for their safe and reliable performance... The participant's procedures will cover specific design control methods and certain provisions to ensure that control will be applied to... selection and review for suitability of application of materials, parts, equipment, and processes... revision of design, including field changes, so that the changes comply with the original design control requirements."
Contrary to the above, the emergency service water pump restraint clearance was not in accordance with the GAI generic restraint design requirement. Carbon steel bolts and studs were installed in water without protective coatings. There was also a lack of inspection criteria to ensure full thread engagement at the sleeve nuts, and bolt torquing requirements to prevent loosening due to system vibration.
B.
Response
1.
Corrective Action Taken:
A new clearance requirement of 3/16" maximum total gap along a.
a diameter will be issued via an ECN and an inspection will be made to assure compliance with this requirement.
Shims will be added as required to reduce excessive gaps.
b.
The carbon steel bolts will be replaced by galvanized bolts and a nut locking device employed to prevent loosening. All other safety-related submerged items will be reviewed to verify that adequate corrosion protection measures have been specified. At the time the fix is implemented, the thread engagement of the sleeve nuts will be checked to verify that minimum embedment requirements are met.
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RESPONSE TO ENFORCEMENT ITEMS IE REPORT 50-440/81-16; 50-441/81-16 PAGE 2 2.
Corrective Action to Prevent Recurrence:
a.
GAI field engineers have been instructed that they are to assure that information received from safety-related equipment vendors has been approved and verified by the vendor's engineering element, prior to utilizing that information in response to questions from the field, b.
For other submerged items, the design has been reviewed to ensure adequate corrosion protection has been specified.
3.
Date of Full Compliance:
The area will be pumped clear of water by August 1,1982, and it is presently expected that the measures outlined in 1 a&b above will be completed by September 1, 1982.
II. Noncompliance 440/81-16-02; 441/81-16-02 A.
Severity Level V Violation 10CFR50, Appendix B, Criterion X states, in part:
"A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity."
Perry Nuclear Power Plant, Units 1 and 2 PSAR Chapter 17, Paragraph 17.1.10.1 states, in part, that, "A program for inspection has been established by CEI to assure that all safety class equipment and structures meet required quality standards...
The CEI program delegates responsibility for inspection to appropriate participating organizations and requires that the criteria set forth in 10CFR50, Appendix B, be met."
Contrary to the above, relative to the inspection of restraints in-stalled on the emergency service water pumps, there was no detailed inspection checklists and/or measurement records. A subsequent field engineering inspection indicated that the restraint clearance did not meet the acceptance values established in the QC inspection procedure.
B.
Response
1.
Corrective Action Taken:
All installed safety-related restraints will be reinspected using the checklist from the new three-part inspection program.
RES.PONSE TO ENFORCEMENT ITEMS IE REPORT 50-440/81-16; 50-441/81-16 PAGE 3 2.
Corrective Action to Prevent Recurrence:
A three-part inspection program has been developed by Pullman Power Products (PPP) in close cooperation with the Project Organization. This program, which utilizes checklists and documented locations of hangers and pipes, has been reviewed and approved by the Owner.
Implementation of tha program will follow a series of training sessions for PPP personnel.
3.
Date of Full Compliance:
February 2,1982 III. Noncompliance 440/81-16-03; 441/81-16-03 A.
Severity Level V Violation 10CFR50, Appendix B, Criterion VI states, in part, "Veasures shall be established to control the issuance of documents....ncluding the changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed...and approved...by authorized personnel and are distributed to and used at the location where the prescribed activity is performed."
Perry Nuclear Power Plant, Units 1 and 2 PSAR Chapter 17, Paragraph 17.1.6.1 states, in part, that, " Procedures shall be utilized to control those documents which specify, describe or evidence activities affecting the quality of the PNPP. These procedures shall be in accordance with the CEI Nuclear Quality Assurance Program and 10CFR50, Appendix B, and will identify persons who review for adequacy and approve documents for use.
Document distribution shall be spec '
d and controlled. Control Methods will include periodic issuance d revision status lists to prevent use of obsolete information. Cnanges or revisions to documents will be processed by the same method as the original issue or by an approved alternate method."
Contrary to the above, the Piping Engineering Department Perry Project Instruction, Section C - Support Design, and the design allowables developed for Hilti bolts uued by the site small bore piping group, had not been issued, reviewed, and approved in accordance with approved document control procedures.
B.
Response
1.
Corrective Action Taken:
GAI Piping Engineering Department PNPP Instruction, Section C has been replaced with a controlled document addressing support design. The instruction book inspected by the NRC has been reviewed to verify that all information that may have been used for support design is valid. Additionally, a sample of the supports designed prior to the NRC inspection will be reviewed to assure that the criteria used for the selection of Hilti bolts were valid.
RESPONSE TO ENFORCEMENT ITEMS IE REPORT 50-440/81-16; 50-441/81-16 PAGE 4 4
2.
Corrective Action to Prevent Recurrence:
An audit will be conducted of small bore piping design in February 1982.
Subsequently, this area will be audited on an annual basis.
3.
Date of Full Compliance:
February 15, 1982 i
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