ML20084F861
| ML20084F861 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/25/1984 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| RDC-90(84), NUDOCS 8405040339 | |
| Download: ML20084F861 (4) | |
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P o. DoX 5000 - CLEVELAND. oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG.
- 55 PUBLICSoVARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRE 510ENT NUC LE A R Mr. James G. Keppler Regional Administrator, Region III office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 ASME Class 1 Supports [RDC 90(84)]
Dear Mr. Keppler:
This letter serves as our final report pursuant to 10CFR50.55(e) concerning material purchased and designated for installation on ASME III Class 2 and Class 3 supports / hangers which was subsequently installed in Class 1 supports /
hangers.
Initial notification that this problem was being evaluated by The Cleveland Electric Illuminating Company (CEI) was made to Mr. P. R. Pelke of your of fice on January 12, 1984, by Mr. E. Riley of CEI.
Our interim report on this subject was filed February 10, 1984.
This report contains a description of the deficiency, an analysis of the safety implication, and the corrective action being taken.
Description of Deficiency One hundred sixteen (116) ASME Clasu 1 supports installed by Pullman Power Products (PPP) under the SP44-4549-00 contract were identified as having material in their construction which is qualified for use in ASME Class 2 or 3 supports. This occurred because a change was made in procurement requirements which was not identified by the piping installation contractor at receipt inspection nor reflected in his material control procedures.
Analysis of Safety Implication All material used was, as a minimum, acceptable for ASME Class 2 and 3 construc-tion. There is no evidence that the identified deficiencies compromise the design / functional integrity of the supports; nevertheless, the problem does represent a failure in the Contractor's quality program in that the necessary requirements of NA-3700 were not met.
Therefore, for all 116 affected supports, the material in question is being replaced.
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h Mr. Jcmes G. Kepplar April 25, 1984 Corrective Action A complete review of all Class 1 supports was performed by the Contractor with results indicating that 116 installed / fabricated supports did not have proper material certification. Nonconformance Reports were generated by the Contractor for items that were determined to be in violation of quality requirements.
Additionally, PPP Corrective Action Request 006 was generated to document the programmatic deficiencies. Corrective Action resulting from CAR 006 included revision of two PPP procedures (IV-34 Site Purchasing and X-5 Field Receiving Inspection). Revision of the procedures clarified procurement requirements.
and provided for more detailed receipt inspection. Both revised procedures have been accepted by the Project Organization. A Class 1 material identification and control log was also established listing all acceptable material. Only material listed in the log is issued to construction for installation in Class 1 supports. This is verified and documented by PPP QA/QC personnel during review of the material requisitions.
Implementation of this system has prevented problems of this nature from recurring. Completion of all work required to close the Nonconformance Reports is presently scheduled for January 4,1985.
If there are additional questions, please do not hesitate to call.
Very truly yours,
't%&' h M. .. ' Edelman Vice President' Nuclear Group MRE:pab cc:
Mr. M. L. Gildner USNRC, 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 Ins titute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339
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P o Box 5000 - CLEVELAND oHlo 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLIC SQUARE Serving The Best Location in the Nation MURR Y R. EDELMAN VICE PRESIDENT NUC LE AR Mr. James C. Keppler Regional Administrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 RE:
Perry Nuclear Power Plant Docket Nos. 50-440; 50-441 ASME Class 1 Supports [RDC 90(84)]
Dear Mr. 'Keppler:
This letter serves as our final report pursuant to 10CFR50.55(e) concerning material purchased and designated for installation on ASME III Class'2 and Class 3 supports / hangers which was subsequently installed in Class I supports /
hangers.
Initial notification that this problem was being evaluated by The Cleveland Electric Illuminating Company (CEI) vas made to Mr. P. R. Pelke of your of fice on January 12, 1984, by Mr. E. Riley of CEI.
Our interim report on this subject was filed February 10, 1984.
This report contains a description of the deficiency, an analysis of the safety implication, and the corrective action being taken.
Description of Deficiency One hundred sixteen (116) ASME Class I supports installed by Pullman Power Products (PPP) under the SP44-4549-00 contract were identified as having material in their construction which is qualified for use in ASME Class 2 or 3 supports. This occurred because a change was made in procurement requirements which was not identified by the piping installation contractor at receipt inspection nor reflected in his material control procedures.
Analysis of Safety Implication All material used was, as a minimum, acceptable for ASME Class 2 and 3 construc-tion. There is no evidence that the identified deficiencies compromise the design / functional integrity of the supports; nevertheless, the problem does represent a failure in the Contractor's quality program in that the necessary requirements of NA-3700 were not met.
Therefore, for all 116 affected supports, the material in question is being replaced.
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Mr. James C. Kappler April 25, 1984 Corrective Action A complete review of all Class I supports was performed by the Contractor with results indicating that 116 installed / fabricated supports did not.have proper material certification. Nonconformance Reports were generated by. the Contractor for items that were determined to be in violation of quality requirements.
Additionally, PPP Corrective Action Request 006 was generated to document the programmatic deficiencies. Corrective Action resul' ting from CAR 006 included revision of two PPP procedures (IV-34 Site Purchasing and X-5 Field Receiving Inspection).
Revision of the procedures clarified procurement requirements and provided for more detailed receipt inspection. Both revised procedures have been accepted by the Project Organization. A Class 1 material identification and control log was also established listing all acceptable material. Only material listed in the log is issued to construction for installation in Class 1 supporta. This is verified and documented by PPP QA/QC personnel during review of the material requisitions.
Implementation of this system has prevented problems of this nature from recurring. Completion of all work required to close the Nonconformance Reports is presently scheduled for January 4,1985.
If there are additional questions, please do not hesitate to call.
Very truly yours, M. R. Edelman Vice President Nuclear Group cc:
Mr. M. L. Gildner USNRC, 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 Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 i
.