ML20209H245
| ML20209H245 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/01/1985 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0135, PY-CEI-OIE-135, NUDOCS 8511110050 | |
| Download: ML20209H245 (4) | |
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l ii G C 0 fM P A i1 Y P,o. DoX 5000 - CLEVELAND, OHIO 44101 - TELEPHONE (216) 622-9800 - BLLUMINATING BLOG. - 55 PUBLIC SOUARE Serving The Best Location in the Nation MURRAY R. EDELMAN VICE PRESIDENT NUCLEAR November 1, 1985 PY-CEI/01E-0135 L J. J. liarrison, Chief Engineering Branch, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Verry Nuclear Fower Plant Eocket Nos. 50-440; 50-441 50-440/85016 Noncompliance Response s
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Dear Mr. Harrison:
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This letter is to acknowledge receipt of Inspection Report 50-440/85016 attached to your letter dated October 2, 1985. This report identifies areas examined by Messrs. P. D. Kaufman and J. M. Jacobson during their inspection conducted March 18 through September 16, 1985 at the Perry Nuclear Power Plant.
Attached to this letter is our response to the Notice of Violation dated October 2, 1985. 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 requested.
If"there are additional questions, please do not hesitate to call.
Very truly yours,
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'Edelman Vice President Nuclear Group
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v' Attachment 8511110050 851101 PDR ADOCK 05000440 0
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-J..J. Harrison:
- November 1, 1985
- PY-CEI/01E-0135 L' cc:
Mr.:J. A. Grobe-USNRC Site, SBB50'
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Mr. K.DConnaughton
- USNRC Site, SBB50 U.S. Nuclear. Regulatory Commission Document Control'Desic Washington,'D.C..
20555 Mr. R. F.:Warnick,. Chief.
' Rea'etor Projects Branch '-1 Division of. Reactor Projects -
U U.S. Nuclear Reg'ulatory Commission ~'
799 Roosevelt Road:
- Glen Ellyn,-lilinois-60137.
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Attachment PY-CEI/01E-0135 L 7,
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RESPONSE TO VIOLATION NO. 50-440/85016-01 Statement of Violation 10CFR 50, Appendix B, Criterion III, as implemented by CEI's Corporate Nuclear Quality Assurance Program (CNQAP) Section 0300, Revision 5, requires Engineering reviews be conducted and documented to verify plant design criteria and design adequacy.
Contrary to the above, ECN 23205-44-7687, Revision B, written against pipe support IP53-H3054, had progressed through the final as-built verification program without proper consideration of the support's attachment to two independent building structures and the differential seismic displacements of those buildings.
Response
1.
Background of Violation ECN 23205-44-7687/- issued in September 1984 added an out-of-plane bracing member to small-bore pipe support IP53-H3054 due to consideration of support self-weight seismic excitation. The brace was attached to the exterior shield wall of the Reactor Building, thus causing support
./'~'N 1P53-ll3054 to be attached to two independent building structures (Reactor
'j and Intermediate Buildings). The differential movements of the two
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independent buildings were not taken into account by the Engineer (Gilbert /Comm.>nwealth, Inc.) in the design of IP53-il3054 prior to issuance of ECN 23205-44-7687/.
2.
Corrective Action Taken and Results Achieved ECN 23205-44-7687/C to support IP53-Il3054 relocated the brace from the exterior wall of the Reactor Building to an interior Intermediate Building wall. Thus, IP53-il3054 is no longer attached to two independent building structures.
The design error involving support IPS3-il3054 is considered an isolated
' case. This position is based on the following:
a.
Previous Field Walkdowns Previous field walkdowns (Septeaber~- October, 1983) were conducted by Gilbert / Commonwealth Site Engineering personnel to review installations for situations potentially susceptible to adverse affects of differential building displacements. Only one support was found which was attached to two independent structures (Reactor Building shield wall and Intermediate Building siab). This support was redesigned to be attached solely to the Intermediate Building slab.
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' 10 Attachment
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PY-CEI/0IE-0135 L
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Corrective Action-Taken and Results Achieved (continued)
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b.
Existing-Design Criteria When'ECN 23205-44-7687/- was issued in September,-1984, design J_ criteria were in place which required consideration of differential-building displacements for piping analysis / pipe support design.
,Since. pertinent design requirements existed,.there is no reason to assume a generic problem in this area, c.-
Additional Field Walkdowns Additional field walkdowns performed since. identification of this violation have verified that this is an isolated instance.
Since the. identified design error is,an isolated case, no further
- corrective: action is required. Also, the condition was reviewed for 10 CFR-21 reportability by Gilbert / Commonwealth, Inc. and found to be "not.
-reportable."
3.
, Corrective Action Taken to Prevent Recurrence N/A - As-stat'd above, this violation is an isolated case, pertinent f
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" design requireu6nts are in. place and, as such, no' corrective action to
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p'revent. recurrence is necessary.
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Date of Full Compliance Full compliance was achieved with the issuance of ECN 23205-44-7687/C which corrected the problem for support IP53-H3054.
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