ML20086N177
| ML20086N177 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/10/1984 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| RDC-90(84), NUDOCS 8402170273 | |
| Download: ML20086N177 (2) | |
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P.O. BOX 5000 - CLEVELAND. OHIO 44101 - TELEPHONE (216) 622-9800 - lLLUMINATING BLDG. - 55 PUBLIC SOUARE Serving The Best Location in the Nation February 10, 1984 VICE PRESIDENT NUCLEAR Mr. Janes 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 interim 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 /
h ange rs.
Initial notification that this problem was being evaluated by The Cleveland Electric Illuminating Company (CEI) was made to Mr. P. R. Pelke of your office on January 12, 1984, by Mr. E. Riley of CEI.
This report contains a description of the deficiency, the corrective action and the date for filing of our final report.
Description of Deficiency One hundred thirteen (113) ASME Class 1 supports inetalled by Pullman Power Products (PPP) under the SP44-4549-00 contract have been identified as having material in their construction which is qua11 fled for use in ASME Class 2 or 3 supports only. 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.
Corrective Action Upon initial discovery of the material problem, PPP initiated internal Corrective Action Request 06.
In response, a review was conducted of material records for all Class 1 supports / hangers fabricated on site and installed by PPP. As a result, it was detemined that, for the past twelve months, stock material supplied to PPP by Power Piping Co. under SP527-4549-00 or procured by PPP under SP44-4549-00 did not have the necessary documentation (material certification) required for Class 1, Subsection NF supports / hangers.
It v9s also detemined that 113 Class I supports were affected, for which Nonconformance Reports have been issued.
8402170273 840210 FEB 131984 h}q gDRADOCK 05000440 PDR
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- Mr. James G. Kappler Februmry 10, 1984 Corrective action implemented by PPP thus far includes revision of their receipt inspection program to detail an in-depth review of documentation and material at receipt and initiction of a Class 1 Stock Material Log listing all acceptable material.
The use of the log allows for identification and control of material to permit installation of Class i supports to continue. 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.
The control log was instituted as an alternative segregation method af ter physical segregation of the material proved to be impractical due to inclement weather conditions.
Relative to the 113 nonconforming supports, the initial disposition was to completely remove and replace the non-Class 1 material. We determined, however, that the following' methods of correction might also be available:
- 1) Upgrade the material as allowed by ASME NA3767.4(f), or
- 2) Obtain preper documentation from the vendor / manufacturer if it could be determined that material was manufactured to NA3700 but sold as commercial grade.
To date, all vendors / manufacturers have been contacted and have agreed to supply additional documentation, if avaliable, to certify that no weld repair was performed for materials to be upgraded per NA3767.4(f) or certification to NA3700 where possible.
Pullman Power Products is also in the process of sending samples of each heat / lot of material in question to an independent testing lab for physical testing and chemical analysis.
If the problems associated with the material documentation cannot be corrected, the nonconforming material will be replaced with certified Class 1 material.
It is presently anticipated that information required to resolve this matter will be available by April 30, 1984, and we will then file our final report.
If there are additional questions, please do not hesitate to call.
Very truly yours, M. R. Ede n
Vice President Nuclear Group j
MRE:pab l
cc:
Mr. M. L. G11dner U.S. Nuclear Regulatory Commission USNRC, Site Of fice c/o Document Management Branch Washington, D.C.
20555 Director Office of Inspection and Enforcement Records Center, SEE-IN U.S. Nuclear Regulatory Commission Institute of Nuclear Power Operations Washington, D.C.
20555 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 I
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