ML20066C429
| ML20066C429 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/29/1982 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8211090503 | |
| Download: ML20066C429 (2) | |
Text
- 7
' THE CLEVELAND ELECTRIC ILLUMIN ATING COMPANY P o. BOX 5000 m CLEVELAND. OHlo 44101 e TELEPHONE (216) 622-9800 m ILLUMINATING DLDG e 55 PUBLIC SQUARE Serving The Best Location in the Nation D'lwyn R. Davidson VICE PRESiOENT SYSTEM ENGINEERING AND CONSTRUCTivN Octobpr 29, 1982 Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nucicar Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Final Report on Valve Identification and Traceability
[RDC 48(82)]
Dear Mr. Keppler:
This letter serves as a Final Report pursuant to 10CFR50.55(e) concerning identification and traceability of installed safety-related valves.
Initial notification concerning our evaluation of this problem was made on March 4, 1982, to Mr. J. E. Konk11n of your of fice by Mr. R. L. Vondrasek of The Cleveland Electric Illuminating Company (CEI). Our Interim Report on this subject, dated March 25, 1982, identified July 30, 1982, as the date for completion of our evaluation. This subsequently changed to October 31, 1982, as discussed by Mr. P. Pelke and Mr. R. L. Vondrasek during a telephone call on July 30, 1982.
This report contains a description of the deficiency, an analysis of the safety implications and the corrective action taken.
Description of Deficiency Ef fective measures had not been established or implemented to provide assurance that valves issued to our prime piping contractor were totally traceable by Master Parts List Number, Bill of Material Number, or Serial Number from fabrication documentation to final installation.
Correlation of valve serial numbers and related vendor documentation to the Master Parts List Number tags attached by Project Organization at time of issuance to the installing contractor was not performed consistently. This problem was recognized when valves which had been issued to the field were found to have been improperly tagged or in several cases to have no tag.
8211090503 821029 PDR ADOCK 05000440 NOV 3 082 S
PDR SEL7
Mr. Jcmes G. Kcpplar Octob2r 29, 1982 Analysis of Safety Implication Our evcluation of the deficiency per 10CFR50.55(e) has been completed, and we have concluded that we were not in full compliance with 10CFR50, Appendix B, Criterion VIII. While no significant safety-related valve installation problems were found, it could be postulated that had this problem gone uncorrected, unique valve identification might not have been maintained. A valve subsequently identified as potentially defective could not then have been readily located and safe operation of its system would not be assured.
Corrective Action Taken Upon identification of the deficiency, PNPP Nonconformance Reports were initiated to document the existing discrepancies. Issuance of safety-related valves to the prime installing contractor and related contractors was halted until applicable procedures for identification and traceability of components had been reviewed and necessary revisions made.
Provisions were made to adequately address the control of material irsued to the field. The prime piping installation contractor's Quality Assurance Program was revised to assure component identification and traceability to a unique document package through installation.
Issuance of valves was resumed March 18, 1982.
A complete review of all safety-related valves already installed or released for installation to the prime piping installation contractor, and interfacing contractors as required, was performed by PNPP Project Organization personnel.
This involved approximately 1,850 valves and all discrepancies identified were evaluated. Required corrections will be completed by December 17, 1982.
Finally, verification of implementation of revisions made to the prime installing contractor's procedure was performed by the Construction Quality Section.
If there are any questions, please feel free to call.
Sincerely, Dalwyn R. Davidson Vice President System Engineering and Construction DRD:pab cc:
Mr. M. L. Gildner NRC Site Office 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.
20555