ML20134P787

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Revises 850809 Response to Violations Noted in Insp Rept 50-440/85-43.Corrective Actions:Procedure 4.7.1 Revised to Limit Use of E6013 Electrodes to Welding of Cable Tray Rungs to Cable Tray
ML20134P787
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 08/20/1985
From: Edelman M
CLEVELAND ELECTRIC ILLUMINATING CO.
To: Paperiello C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
PY-CEI-OIE-0102, PY-CEI-OIE-102, NUDOCS 8509090052
Download: ML20134P787 (4)


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THE CLEVELAND ELECTRIC ILLUMIN ATING COMP ANY P.O. BOX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - ILLUMINATING BLDG. - 55 PUBLICSOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT 0900 F NUC LE A R PY-CEI/OIE 0102 L Mr. C. J. Paperiello, Director Division of Reactor Safety, 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 Revised Response to Noncompliance 440/85043-01, Example (a)

Ref: PY-CEI/OIE 0094 L dated August 9, 1985

Dear Mr. Paperiello:

Attached to this letter you will find the replacement for our original response to Noncompliance 440/85043-01, Example (a).

Subsequent to our filing on August 9, 1985, during assembly of documentation for presentation to your reviewer, it was noted that the corrective action taken for Inspection Report 17830 did not fully support its closure. Therefore, this revised response is submitted to indicate the additional corrective actions that have been initiated.

If there are any questions, please do not hesitate to call.

Sj.ncerg y, A4  %

Murr R. Edelman Vice President Nuclear Group MRE:sab Attachments 8509090052 850820 PDR ADOCK 05000440 PDR o AUG 2 21985 i,

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, Mr. C. J. Paperiollo August 29, 1985 PY-CEI/OIE 9102 L cc. Mr. J. A. Grobe USNRC Site, SBB50

\ l l Mr. D. E. Keating USNRC Site, SBB50 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Mr. R. F. Warnick, Chief Reactor Projects Branch 1-Division of Reactor Projects U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 69137 1

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C g Attachmsnt i PY-CEI/OIE 0102 L l Page 1 of 2 Ref: PY-CEI/OIE 8094 L REVISED RESPONSE TO NONCOMPLIANCE 440/85043-01, Example (a)

STATEMENT OF NONCOMPLIANCE Example (a) states, "The welding procedures do not adequately control the selection of electrode (440/85043-01 (a) (DRS))."

Corrective Action Taken and Results Achieved Although L. K. Comstock Procedure 4.7.1 permitted the use of E6010, E7010, and E7018 electrodes for various joint configurations, the Gilbert approved installation drawings specify which type electrode (E60XX or E70XX) is to be used. All welding is performed in accor-dance with the applicable Gilbert drawing, utilizing the applicable weld procedure specification contained in L. K. Comstock Procedure 4.7.1, thus by using the Gilbert drawing and the L./K. Comstock Procedure the proper electrode would be used.

To assure that the proper selection of electrodes was achieved, L. K. Comstock generated Inspection Report 17830 to review all weld filler metal withdrawal tabs which indicate the use of other than -

E7018 electrodes. Inspection Report 17830 was closed on August 8, 1985; however during further review of the weld tab documentation it was concluded that discrepancies do exist and that full compli-ance has not yet been achieved. L. K. Comstock Inspection Report 18726 and Nonconfermance Report LKC 6355 have been initiated to provide corrective actions. The Nonconformance Report documents that some information had been omitted or was unclear on a small percentage of weld filler metal withdrawal tabs. The Nonconfor-r mance Report will provide further evaluation of these cases.

The Construction Quality Section (CQS) issued Hold Point Letter PY-S/ CON 13929 on the issuance of E6013 electrodes from the L. K. Comstock rod room. The electrode ~ type E6010 was not included on the Hold Point Letter because, although L. K. Comstock used this rod type for procedure qualification, it was never used for production welding at PNPP. Additionally, in the Construction Quality Section Surveillance Inspection Plan, the CQS inspectors performed random overviews of the contractor's program and found the use of E60 series electrodes to be in compliance with L. K.

Comstock Procedures and Gilbert Construction Drawings.

Corrective Action To Be Taken To Avoid Further Noncompliance

, L. K. Comstock Procedure 4.7.1, Revision 7-5-85, now specifically limits the use of E6013 to.the welding of cable tray rungs to the cable tray. L. K. Comstock Procedure 4.8.18, Revision 7-5-85, requires the L. K. Comstock inspector to verify filler metal size, type, heat and lot number, and Form #66 (weld filler metal j withdrawal tab) number during the fit-up hold point.

1 t- ' Attachm nt PY-CEI/OIE 0192 L Page 1 of 2 Ref: Py-CEI/OIE 9994 L t

Date When Full Compliance Will Be Achieved Full complia'nce will be achieved upon closure of L. K. Comstock Nonconformance Report LKC 6355. The completion date is projected as, August 30, 1985.

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