ML20072J613
| ML20072J613 | |
| Person / Time | |
|---|---|
| Site: | Perry |
| Issue date: | 06/27/1983 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8306300169 | |
| Download: ML20072J613 (3) | |
Text
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P.o. Box 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLOG.
- 55 PUBLICSOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN June 27, 1983 VICE MtESIDENT NUCMAR Mr. James G. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Comnission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 Mono-Sol Brand 7-0015-3 CQS Polyvinyl Alcohol Film, Water Soluble Purge Dam Material, Manufactured by Chris Craft Industries [RDC 18(80)]
Dear Mr. Keppler:
This letter serves to clarify a portion of our final report pursuant to 10CFR50.55(e) dated August 3,1981, concerning use of Mono-Sol brand 7-0015-3 CQS Polyvinyl Alcohol Film, Water Soluble Purge Dam Material manufactured by Chris Craf t Industries.
The Description of the Deficiency and the Analysis of Safety Implication remains unchanged.
Under the portion titled Corrective Action Taken and Methods for Removal, we identified the following areas as subject to the purge dam removal program because insoluble mono-sol material could af fect the safe operation in safety-related systems:
a.
All lines which could eventually lead to the reactor vessels.
I b.
All lines which supply sealing water or sealing steam.
l The Suppression Pools and all lines leading to the pools.
l c.
d.
The Condensete Storage Tanks and all lines leading to the tanks.
Augmented Quality Assurance Program portions of Fire Protection and Off-e.
Gas Systems.
The purge dam removal program consisted of engineering analysis of each system in the defined areas to determine the extent and degree of cleaning technique required.
Augmentation of the existing Flush program was determined to be required for cleanup.
Ib[I 8306300169 830627 PDR ADOCK 05000440 Ji]N 2 ' G83 S
-Mr. Jrmen G. K pplar Juna 27, 1983 Our engineering personnel completed the review of the systems identified.
With assistance from EPRI..other industry consultants, and actual results obtained from mock-up tests of cleaning methods to insure adequacy, they established the following criteria:
- 1. - Lines with direct access to the reactor. require cleaning.
2.
Cleaning upstream of strainers, condensate filters, demineralizers, or any other device-that will filter out Mono-Sol is not required. During flushing activities, the Nuclear Test Section monitors the strainers for pressure drops and removes 'and cleans as necessary.
3.
Cleaning of lines to the suppression pool is not required because the pool itself is to be inspected, drained and cleaned of all material flushed there prior to fuel load. The lines to and from the direct contact heater and also to and from the condensate storage tank are to be treated in the same manner as the suppression pool. The discharge lines from the pool have been dispositioned in accordance with 1. and 2. above, except that where the lines can be cleaned through system recirculation (closed-loop circulation through the system), this method will be used.
4.
Instrument lines are to be checked to identify obstruction only and blown down as necessary by the Nuclear Test Saction.
Status and records are to be maintained by the Nuclear Test Section.
5.-
Chemical cleaning methods are not to be utilized.
Af ter completion of this review, we concluded that our _ August 3,1981, response to Mr. Keppler was correct, but neaded refinement of Items c.,
d., and e.
At this time, no action need be taken on the supply lines referenced in Items c. and d.
There are no lines coming off the bottom of the pools or tanks. As stated in 3. above, strainers shall be utilized on lines leading l
from the tanks and pools. The applicable portions of systems shall be flushed prior to loading nuclear fuel.
Upon Operational Quality Control Unit inspection of the pools and tanks, debris observed will be assessed at that time and evaluated by responsible engineering personnel to determine additional actions.
Under item (e) of our letter to Mr. Keppler, the Fire Protection portion has been deleted since strainers are used in this system as described in Item 2.
above. The commitment to clean the Off-Cas System remains correct.
Nonconformance report (NR) PPP-912, now closed, was written to identify all weld areas for Units 1 and 2 requiring cleaning, and to document the cleaning program needed to supplement the Flush Program based upon the criteria stated above. The NR was closed out in advance of the original commitment dates, which were identified as prior to the Reactor Pressure Vessel In-Flush in the l
August 3, 1981, letter. At that time the In-Flush was tentatively scheduled j
for December 11, 1983, for Unit I and December 1, 1986, for Unit 2.
i t
('.
Mr. James G.'KIpplzr Junt 27, 1983 Remaining activities will be performed during the Flush Program which will follow the Project Organization schedules.
Please call if there are additional questions.
Sincerely, Murray R. Edelman Vice President Nucleo Group MRE: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 Records Center, SEE-IN Institute of Nuclear Powr.r Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339