ML20079H031

Responds to NRC Re Violations Noted in IE Insp Repts 50-440/83-34 & 50-441/83-33.Corrective Actions:Polar Crane Recabled W/Certified Cable,Replacement Strongback Obtained & Moisture Separator Assembly Successfully Removed

ML20079H031
Person / Time
Site:	Perry
Issue date:	01/10/1984
From:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20079H015	List: ML20079H031
References
NUDOCS 8401230301
Download: ML20079H031 (5)

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P O. box S000 - CLEVELAND, OHO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSQUARE Serving The Best Location in the Nation MURRAY R. EDELMAN January 10, 1984 VICE PRESIDENT NUCLEAR Mr. R. C. Knop, Chief Projects Branch 1 Division of Project and Resident Programs 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. Knop:

This letter is to acknowledge receipt of Inspection Report Number 50-440/

83-34; 50-441/83-33 attached to your letter dated December 12, 1983. This report identifies areas examined by Mr. M. L. Gildner during his inspection conducted September 1 through October 31, 1983, at the Perry Nuclear Power Plant.

Attached to this letter is our response to the two Severity ',evel IV Violations described in the Notice of Violation dated December 12, 1983. 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. If there are additional questions, please do not hesitate to call.

Very truly yours, M. R. Edelman Vice President Nuclear Group MRE:pab Attachment cc: Mr. M. L. Gildner USNRC, Site Mr. R. L. Spessard, Director Division of Engineering 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 JAN161984 8401230301 840118 PDR ADOCK 05000440 PDR

RESPONSE TO ENFORCEMENT ITEMS Below is our response to the Notice of Violation appended to United States Neclear Regulatory Commission I.E. Report 50-440/83-34; 50-441/83-33.

I. Noncompliance 440/83-34-02 A. Severity Level IV Violation 10CFR50, Appendix B, Criterion XIII, states in part, " Measures shall be established to control handling...of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."

CEI Corporate Nuclear Quality Assurance Program, Section 1300, states in part, " Measures shall be established by vendors, contractors, and the Nuclear Group to control the handling, storage and shipping of saf ety-related materials and equipment. These measures shall include but not be limited to:...d. Established storage procedures which include, as applicabic, the following provisions: 1. Handling methods to avoid damage to equipment.. 7. Documentation and records data."

Contrary to the above, cdequate measures were not established for lif ting the Unit 1 Moisture Separator Assembly on September 15, 1983, f rom a temporary storage location inside the Unit I reactor pressure vessel, in that:

a. An inadequate traveler procedure was used to describe the method for determinirg the assembly's disengagement from the core shroud,

b. Records for the placement of the assembly into the vessel did rot Indicate that the assembly had been bolted down, and

c. Personnel performing the evolution were not f amiliar with the details of the bolting mechanism and relied on the adequacy of the process traveler.

B. Rpsponse

1. Admisainn or Denial of Alleged Violation We concur that adequate measures were not clearly established for the lif t of the Unit 1 Moisture Separator Assembly performed on September 15, 1983.

2. Reason for Admitted Violation We concur with the reasons stated in I.E. Report 50-440/83-34; 50-441/83-33, Paragraph 4.a. which reflect the results of a misinterpretation of the contractor's lif ting and rigging proce-dure by the contractor.

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GESPONSE TO ENFORCEMENT ITEMS PAGE 2

3. Corrective Action Taken and Results Achieved The corrective actions taken as a result of the violation were as stated in the Senior Resident Inspector's report and are reiterated herein:

The polar crane was examined using recommendations of the crane manufacturer and certain designated components have been examined by NDE specialists. No damaged components were found.

The polar crane was recabled with certified cable as a precautionary measure, even though no damage to the original cable was found.

A replacement strongback was obtained and the Moisture Separator Assembly was successfully removed from the vessel on October 5,1983. Visual and NDE examination of the components of the Moisture Separator Assembly and Core Shroud Assembly revealed no damage.

Additionally, relative to the potential damage which may have resulted from this incident [RDC 82(83)], final results of the evaluation conducted pursuant to 10CFR50.55(e) will be forwarded to the NRC as required.

4. Corrective Action Taken to Avoid Further Noncompliance On September 21, 1983, CEI amended previous acceptance of the handling and lifting procedure in correspondence PY/S0-38/39-19866. This letter changed the acceptance to conditionally acceptable noting changes needed to be implemented in the procedure. In response, the contractor has now formally revised his procedure as follows:

To ensure full QA/QC coverage, the contractor's handling and rigging procedure GEP-GR-C01, paragraph 4.1.5.1,

" Category A Classification", was revised to explicitly state that all lif ts of reactor vessel components including the drywell head are Class A lif ts.

The controlling procedure also specifically states that. . .

. . . detailed rigging sketches and travelers for handling operations shall be required.

. ..a briefing shall be held prior to the lif t covering details of lift including Installation or removal of item being lif ted.

The contractor has also made changes in his internal procedures to ensure that any safety-related travelers which are terminated prior to completion fully document the exact as-left condition. Prior to re-initiation of the above travelers, the as-found component condition will be fully verified and documented.

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RESPONSE TO ENFORCEMENT ITEMS PAGE 3

5. Date When Full Compliance Will Be Achieved Full compliance was achieved on September 26, 1983, when the contractor submitted Revision 4 of the affected procedure for CEI approval. CEI approval without comment was given on November 2, 1983. During _ the Interim period between the contractor submittal date and the CEI approval date, the contractor implemented the requirements of the conditionally accepted Revision 3 of proce-dure GEP-CR-0001.

II. Noncompliance 440/83-34-03 I

A. Severity Level IV Violation 10CFR50, Appendix B, Criterion II, states in part, " Activities l affecting quality shall be accomplished under suitably controlled conditions. Controlled conditions include the use of appropriate i

equipment..."

l L CEI Corporate Nuclear Quality Assurance Program, Section 1300, commits the licensee to Regulatory Guide 1.38 and ANSI N45.2.2-1972.

ANSI N45.2.2-1972, Paragraph 7.3.2, states, "Holsting equipment shall not be loaded beyond its rated load, as certified by the manuf acturer, except for test purposes."

Contrary' to the above, during the Moisture Separator Lif t on September 15, 1983, an inoperative polar crane load cell resulted in the polar crane exerting a lifting force which was calculated to be greater than the load rating of' the lif ting strongback and the polar crane.

The 11f ting force was only terminated by the failure of the lif ting s trongba :k.

B. Response

1. Admission or Denial of Alleged Violation We concur with the inspector's observation that the polar crane load _ cell was inoperative at the time of this lift.

2. Reason The polar crane load cell is an optional piece of equipment, the operation of which was not required by our program. It is possible that if it had been used the effects of the procedural misinterpre-tation identified in noncompliance 440/83-34-02 might have been mitigated.

3. Corrective Action Taken and Results Achieved Since that event CEI has replaced the polar crane load cell and intends to calibrate it in conjunction with the next major lif t.

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.. ' RESPONSE TO ENFORCEMENT ITEMS PAGE 4-  !

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- 4. Corrective Action Taken to Avoid Further Noncompliance

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L For all future lif ts of ' the moisture separator, . dryer, reactor  ;

insulation, reactor vessel head and drywe111 head adminiatrative -

control,shall.be established.and implemented to assure the-polar crane is not loaded beyond its rated capacity. This control shall as a minimum consist of visual examination to verify the load is free and clear.. If a visual examination can not be made the lift

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shall be conducted with an. operable load cell.

5. Date of Full Compliance

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Administrative control in addition to the contractor's hc.-dling and rigging procedure will be implemented prior to the next lift.

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