ML20077S454
| ML20077S454 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Davis Besse |
| Issue date: | 01/28/1983 |
| From: | Shortt J TOLEDO EDISON CO. |
| To: | Jordan E NRC |
| Shared Package | |
| ML20077S281 | List: |
| References | |
| FOIA-83-349 A83-122A, NUDOCS 8309220093 | |
| Download: ML20077S454 (9) | |
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2 ': - ; < 1 p y,,.e, TOLEDO EDISON January 28, 1983 A83-122A
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Mr. Edward L. Jordan U.S. Nuclear Regulatory Commission East West / South Towers Building Stop #305 Washingt'on, D.C.
20555
Dear Ed:
During our discussions at the ASME meeting in St. Petersburg, you expressed interest in the use of Furmanite for maintenance work at nuclear power plants.
The attached internal correspondence Bescribes the control of Furmanite use at Davis-Besse Nuclear Power Station.
We have established' procedures by which Engineering controls the use of Furmanite utilizing a non-conformance report (NCR) Procedure. We are
- satisfied that the Furmanite maintenance procedure, when properly controlled and reviewed by competent engineering staff, is both safe and proper at nuclear power plants.
Very truly yours, 4'
J. If. Short Director Nuclear Engineering Division JHS/sas Attachment cc:
J. F. Helle e/6 i
o 8309220093 830728 PDR FOIA PETCHE83-349 PDR l
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THE TOLEDO EDISON C*MPANY EDISON PLAZA 300 MAOISON AVENUE TOLEDO., OHIO 43652
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DATE April 5, 1982 (NTH A. COMPANY MEMORANDUM FE-82-240 c o c2ia.2 File: 0294, 1459 T. D. Murray { f re rs " S W FRoM J. K. Wood SU5 JECT Furmanite Restriction Adapters Your memo (attached) dated 2/18/82 requested review o'f the disposition of the Furmanite adapters associated with valve packing leak repairs.
Facility Engineering agrees, technically, that the Furmanite fitting can be left in place af ter repacking and adjustment of the valve.
The reason that the recom-msndation was made tc remove the adapter was to alleviate personnel safety concerns regarding the potential for having the adapter inadvertently " knocked of f".
The decision as to whether or not the adapter should be left in place should be made in each case by the Station after assessing the potential hazards involved, i.e.,
valve location, pressure rating, traffic in area, etc.
If the Station decides to remove the adapter, the threaded plug inserted should be staked or welded (tack or seal) in place.
Facility Engineering can revise the disposition of NCR 94-81 to reflect the above discussion if so desired (original should be forwarded to FED by QC).
The Station is undoubtedly aware of the dollar and time costs involved in these repairs.
The Station may wish to review its preventive enintenance program in regard to valve packing to determine whether greater attention is needed in some areas to lessen the use of the Furmanite fix.
The Station is also encouraged to prepare a governing Station Maintenance Procedure on the control and use of Furmanite.
- nte disposition of adapters and associated precautions could be addressed in such a procedure.
Reference our previous memo FF.-81-352 dated November 12, 1981, regneding this item.
_JHS JKW/rdt FRM cc:
B. R. Beyer
-JFH C. T. Daft RAB C. R.
Domeck UGH J. F. Helle
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FGbrunry 18, 1982 J. K. Wood su T.
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J sLcT Welding Repair to Furmanite Restriction Adapter - NCR 94-81 I82-92A File:
MM 3.3.11 The Station appreciates your analysis that the location of the injection point for the Furmanite process is not pressure boundary.
However, we do not narce with your requirements to wcld the pipo plug in place.
The code allows for threaded joints and the packing is between the plug system presuurc.
A seal weld requires an ex,cessive paper work load on my staff and QC's staff, along with welder time.
The total estimated cost of this req uiremen t is in excess of $500 por seal weld.
The Maintenance Engineer does not feel this is cost effective.
Should another Furmanite repair be needed, another hole will have to be drilled, as scal welding the plug will prevent it f rom ever being used again.
Also, Furmanite has expressed concern that the threaded plugs could become "misules" when removing them to insert restrictors.
Our preference would be to leave the restrictors inpince, I believe that these are within bounds o l' Lhu codu due to thuir umu11 ulzu and uct au pipe plugu when shut.
Overn11, I would 11ku to seu restrictorn left in where pouaible after repacking and where this is not possible to insert plug and " stake" it so it cannot come out on it's own.
This way we could remove plug to Furmanite and we wouldn' t have to drill another hole.
Please revise your disposition.
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C. T. Daft' B. R. Beyer
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November 12, 1981 WYHA. COMPANY MEMORANDUM FE-81-352, File: 0294' Q C U c:16 2 To P. N. Carr FHoM J. K. Wood,,.<Y(l J
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LUuJECT Fu rmanite Within the last few months, the Station has had to use Furmanite to stop several steam leaks found throughout the, plant.
The use and control of Furmanite has been an ongoing concern of the Engineering and Quality Assurance Departments within Toledo Edison.
As a temporary control measure, the various parties agreed that Non-Conformance Reports would be generated for each Furmanite item to track these temporary fixes to assure they receive a pennanent solution.
This is presently being done on both "Q" and "Non-Q" applications.
In order to better control the use of Furmanite at Davis-Besse, Facility Engineer-ing - Mechanical Engineering recommends that the Station prepare a governing Station Maintenance Procedure on the control and use of Furmanite.
The following items are offered for your consideration for incorporation in the Furmanite procedure:
1)
The procedure should sep'arately address "Non-Q or Non-ASME" applications f rom "Q or ASME" applications.
2)
All uses of Furmanite should be logged as to location, type of temporary fix, date of temporary fix, type of permanent fix and date of permanent fix.
The log should be reviewed periodically by appropriate Station Management to assess trends requiring corrective action.
Copies of the log should be periodically distributed to interested parties, i.e. Facility Engineering -
Mechanical Engineering and QC.
3)
The procedure should be consistent with AD 1845.00.
Attached is a copy of a page f rom a revision to AD 1845.0G under review which covers temporary changes.
With the comments noted, this would be applicable also to the Furmanite process.
4)
No specific comments, other than offered above, are giv' n for use of Furmanite e
on non-nuclear safety related, non-ASME systems or components.
The Station,
may, however, wish to have the governing Furmanite procedure go into more detail than provided by AD 1845.00.
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FE-81-352 5)
For nuclear safety related und ASME applications the procedure should provide more detail than found in AD 1845.00.
The step-by-step procedure furnished and used by Furmanite for " Nuclear" jobs should be addressed in regards to its review and approval cycle.
It is strongly recommended that the proposed procedure by prepared and issued for review by Facility Engineering and Quality Control by year's end.
Efforts should be made in the 1982 Refueling Outage to provide permanent repair of all outstanding temporary Furmanite fixes.
The proposed procedure should then be fully approved and implemented prior to restart after the Refueling Outage in order to properly control the use of Furmanito at Davis-Besse.
hmj Attachment cc:
C. Daft C. Dqmeck J. Helle T. Murray 6
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AD1844.00 Maintenance wa.th a MWO QC shall be notified Maintenance Engineer and Facility Engineering.
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to issue a NCR to Facility Engineering for their acknowle gement an The NCR will a)so be uned as a tracking mechanism for the initiated temporary change until it is removed or a permanent change review.
i ring) written by Facility Engineering (with concurrence of Nucicar Eng nee by a FCR.
and submitted to SRB for review within fourteen days to comply with technical specification requirements.
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i is the Maintenance Engineer, Operations Engineer or Technical Eng neerThe MWO issued required,wich-r -emwf-MWhWem, l remain make the change will include instructions for removal and wil This will be open until the change is removed or authorized by a FCR. (#O /MM)O the tracking mechanicm and NCR is not required. CL
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s tgTRA COMPANY MEMORANDUM FE-81-254, Fils: 0294;/0298A 76 C. R. Domeck FHOM J. K. Wood l SU1 JECT Company Nuclear Review Board (CNRB) Action Items E. C. Novak recently issued lists of open CNRB Action Items.
Several items had been assigned to me as Plant Process Systems Engineer.
A sort on my initials listed five (5) remaining open items.
The following gives the status on each of those items.
Please let me know if I can be of any further assistance in resolving these open items.
1) 79-04-511
" Investigate reliability and operability of pressurizer PORV block valve." Memo No. FE-81-164, attached, dated July 6,1981 was forwarded to ycu for resolution.
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2) 79-09-502 " Review and closecut of outstanding items and test results of TP 600.35." Memo No. FE-81-156, attached, dated June 26, 1981 was forwarded to you for further action.
3) 79-09-509
" Report on the control and acceptability of the use of Furmanite."
This item was briefly discussed in CNRB Meeting No. 89.
In the meeting it was related that currently the practice being followed is that Facility Engineering will review and approve all requests for furmaniting, including the Furmanite prepared procedure.
Non-Conformance Report's (NCRs) will be generated for each task and become part of the MWO.
The NCR will be used
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to track these temporary fixes to assure they receive a permanent solution.
It has been proposed that a Maintenance Procedure be prepared to provide formal direction for furmaniting.
This has yet to be done.
Facility Engineering, Davis-Besse Maintenance, and 0.uality Assurance need to coopera-tively produce such a procedure.
In light of the current controls being used, a sixty (60). day procedure preparation period is proposed.
41 80-05-508 " Review application of remote valve operators, with clutches,
'for possible generic problems causing loss of ability to properly position the valve with the remote operator."
Mc=o No. FE-81-138, attached, dated June 15, 1981 was forwarded to you with information to close this item.
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