ML20235B922

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Transfers Responsibility for NRC Action from Region III to Div of Licensing for Resolution of Util Deviation from FSAR Commitments Re Containment Vessel Welds.Util Proposes to Deviate from ASME Code & Disposition Welds use-as-is
ML20235B922
Person / Time
Site: Perry, 05000000
Issue date: 04/01/1983
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML16342B348 List: ... further results
References
FOIA-87-121 NUDOCS 8707090245
Download: ML20235B922 (2)
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- MEMORANDUM FOR: D. H. Eisenhut, Director, Division of Licensing, NRR l

FROM: C. E. Norelius, Director, Division of Project and Resident Programs

SUBJECT:

TRANSFER OF RESPONSIEILITY - CONTAINMENT VESSEL WELDS NOT IN STRICI COMPLIANCE WITE TSAR COWITMENTS -

PERRY NUCLEAR P0b'ER PLANTS, UNITS 1 AND 2 This merorandum is written to transfer responsibility for NRC action from Region III to the Division of Licensing for the resolution of Cleveland Electric Illuminacing Company's (CEICo) deviation from FSAR co:=1tments for the Perry Nuclear Power Plant (PNPP), Units 1 and 2, containment vessel. ,

The PhTP TSAR specifies the applicable code for the steel containment is ASME Section III, Subsection NE. The FSAR further specifies that the steel containment is not ASME Code stamped; however, all other require-ments of the Code applicable to Class MC containment vessels are met.

As a result of ReEfon III inspection findings, CEICo conducted a re-review of previously accepted containment shell radiographs and detertined many of these radiographs were in fact rejectable. CEICo's disposition of certain of the questionable / rejectable veld joints is to "use-as-is".

This disposition was submitted to the State of Ohio with a request for approval to build and stamp the containment vessels to an " Ohio Special" classification. The Ststc, the National Loard and Eartford Steam Leiler Insurers concurred with this disposition.

We understand NRR is in the process of evaluating the use of concrete placed in the PhTP Reactor building annulus areas as a strenEth-bearing structure. Since this concrete is being ustd to reduce stresses and vibration in the containment shell, we feel it would be appropriate for NRR to determine the adequacy of the shell plate welding deviation con-current with their evaluation of the concrete.

- We request that NRR assess the technical and safety aspects df CEICo's proposal to deviate from ASME Code requirements and to disposition the velds "use-as-is".

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The following sumary of events and a reference to applicable _. documents (copies are included as enclosures to this memorandum) relat g to this

- matter are included to aid in your review.

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The CEICo deviation from FSAR commitments was identified durinE a j review of inadequacies in welding that were brought to the attention L of Region III. This review was conducted at the Perry site in February, l 1982, (Reference Inspection Report Nos. 50-440/82-03; 50-441/82-03).  !

During this inspection, discrepancies were identified with the accept- {

ability of containment vessel shell plate radiographs. In response i to these findings, CEICo re-reviewed all of the previously accepted radiographs and subsequently submitted a 10 CFR 50.55(e) report (Reference Letters (RDC 53 (82)) CEICo (D. R. Davidson) to Region 111 (J. G. Reppler) dated May 3,1982, August 31, 1982, and September 30, 1982. A followup inspection was conducted to examine the results of the licensee's evaluation. The Region III inspector's findings are documented in Inspection Report Nos. 50-440/83-02; 50-441/83-02. As a result of a telephone discussion with the licensee's site technical  ;

staff, additional information was provided to the Region III staff to aid us in our reyfew of this deviation (Reference handwritten memo l G. Leidich (CEICo) to R. Ward /D. Danielson (Region III) dated February f 7,1983, with attachments A through G). Region III conducted a special

, inspection at the site and reviewed the previously accepted radiographs (the lower four courses) of the veld joints in question. (Reference Inspection Report Nos. 50-440/83-09; 50-441/83-08) This inspection report includes the results of the radiographic film evaluations (accept / reject) for each of the films in question for both Units 1 and 2. The evaluations are those made by CEICo's h'DE Level III and an Authorized Inspection Agency, as well as those made by the Region III NDE 5pecialist.

The Region III staff has discussed the abovc- matter with appropriate NRR staff persennel. Region III will continue to fellow activities at the E.itt .

and vill provide information to NRR as necessary to support their evaluation and analysis. CEICo has expressed a desire to meet with the NRC technical staff to discuss the details of their evaluation. Members of the Region III j staff would be available to attend this. meeting. Our contact for coordinating l the regional effort is D. E. Danielson (FIS 35!-2610).

$$ $L C. E. Norelius, Director b Division of Project and Resident Programs i

Enclosure:

As Stated a

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MEMORANDUM FOR: Charles E. Worelius, Director Division of Project and Resident- -

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FROM:

Darrell G. Eisenhut, Director Division of Licensing

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SUBJECT:

cry NRR POSITION ON COMPONENT OPERABILITY WHEN 0A DIESEL' GENERATOR 15 INOPERABLE ig N i

REFERENCE:

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Memo from C. E. Norelius to D. G. Eisenhut, dated '

february 16, 1983;.

Subject:

" Request for Technical @

Assistance - Technical Specification Interpretation".

Your memorandum to me dated February interpretation by NRR on the subject of operability.16,1983 The requested (see inter- reference pretation was whether the loss .of emergency power to a system would render that system inoperable for the purpose of satisfying another system LCO.

Your memorandum included a specific example dealing with the core spray "

system and the high pressure coolant injection system at the Duane Arnold facility.

  • E lt. is our position that, in general, a system may be considered operable '

for the purpose of satisfying its own LC0 and that of another system if

" gon1 its. emergency power supply is inoperable. This position assumes that all the provisions of Technical Specification 3.0.5 in Enclosure 1 of my April 10, 1980 letter to All Power Reactor Licensees are also  !

i satisfied, i.e., a system may be considered operable for the purpose of satisfying its applicable LCO when its emergency power source is inoperable provided the system's corresponding normal power source is <

0;)erable, and its redundant train is also operable. These provisions have been incorporated into the Duane Arnold Technical Specifications as a clarification to the definition of Limiting Conditions for Operation.

We realize that this position may result in a plant not being capable of fully satisfying degraded mode. the single failure criterion while operating in the However, we consider such operation to be acceptable since it would be of limited duration and the probability of an system is occurring accident remote. with a concurrent f ailure of the remaining operable MC6l4 03 "

Contact:

D. Brinkman, x24707 i

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. .75 Charles E. Norelius -

APR 2 0 983 l l

In your memorandum, you specifically asked: "With the Core Spray System degraded by loss of its emergency power source, is the Core Spray System  !

to be considered operable to meet the High Pressure Coolant Injection  ;

System LC07" Duane Arnold Technical Specification 3.5.D.2 is~ applicable l to this example; it permits reactor operation to continue for up to  !

seven days providing that during such seven days all active components of the ADS subsystem, the RCIC system, and LPCI subsystem and both core spray subsystems are operable. In accordance with our position, both core spray subsystems would be considered operable, It should be noted, however, that our position is not intended to supersede the provisions of any technical specification which specifically requires the operability of diesel generators. For example, Duane Arnold Technical Specification 3.5.A.2 permits reactor operation to continue for up to seven days with one core spray subsystem inoperable provided the other core spray subsystem, the active components of the LPCI subsystem and i the diesel _ generators are operable. Therefore, if one core spray subsystem i and one diesel generator were inoperable, our position would not be applicable and continued operation would not be acceptable since Technical Specification 3.5. A.2 specifically requires the diesel generators to be op era ble.

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