ML19256F151
| ML19256F151 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/15/1979 |
| From: | Dunn C DUQUESNE LIGHT CO. |
| To: | Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19256F147 | List: |
| References | |
| NUDOCS 7911210543 | |
| Download: ML19256F151 (4) | |
Text
o 4
W (412) 456-6000 435 Suth Avenue burgh. Pa.
October 15, 1979 United States Nuclear Regulatory Commission Attention:
Mr. Robert T.' Carlson, Chief Reactor Construction and Engineering Support Branch Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspectier Depert Me, 79-08
Dear Mr. Carlson:
In response to your letter of September 20, 1979 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report.
The noted violations included (1) an apparent improper calibration of equipment, and (2) a violation of heat treat temperature without proper evaluation and resolution.
If you have any questions concerning this response, please contact my office.
Very truly yours,
/.
C. N. Dunn Vice President, Operations Attachment 15//
538 791121 0
DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 79-08 Letter Dated September 20, 1979 DEFICIENCY A Description Of Deficiency 10 CFR 50, Appendix B, Criterion XII, states, in part, that: Measures sh'all be established to assure that tools, gages, instruments and other measuring and testing devices used in activities affecting quality are properly controlled and adjusted at specified periods...
BVPS FSAR Amendment 6, Paragraph A.2.2.12, states, in part, that:
All measuring and testing devices shall be calibrated against certified equipment having known valid relationships to nationally recognized standards (e.g., the U. S. National Bureau of Standards).
The Duauesne Light Company NSQC Manual, Section 12.1, Revision 2, Paragraph 5.8 to 5 11, states, in part, that:
Reference and transfer standards used for calibrating measuring and test devices shall be traceable to National Bureau of Standards.
If other standards are used, the basis of standard shall be documented.
Contrary to the above, on July 26, 1979, (6) electrical heat treat controllers had calibration records of absolute values of 500* to 1800 which were traced to a thermocouple potentiometer catalog and serial number with no evidence that the calibrations were made against certified measurements that have known valid relationship to NBS Standards.
Discussion Of Deficiency The vendor's recorder test certificate is available for the subject heat treat controllers. This certificate references the thermocouple potentiometer used to calibrate the controllers.
The test laboratory report issued to the vendor which provides direct traceability of the calibration of the thermocouple potentiometer to standards maintained by the National Bureau of Standards has been located and is available for review.
Although NBS traceable calibration records are available for the subject heat treat controllers, Duquesne Light Company does not believe that these manually operated controllers require calibration due to their function and that the heat treat recorders are calibrated to measurements having known valid relationship to NBS standards.
Corrective Action The applicabic calibration records providing traceability are available for review.
l3//
539
/
~
Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-08 Page 2 Action Taken To Prevent Recurrence Personnel have been reminded of the importance in maintaining complete and retrievable records.
Date On Which Full Compliance Will Be Achieved The Station is in full compliance at thic time.
DEFICIENCY B Description Of Deficiency 10 CFR 50, Appendix B, Criterion XV, states, in part, that:
" Measures shall be established to control material parts, or components, which do not conform to requirements,... Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
BVPS FSAR Amendment 6, Paragraph A.2.2.16, states, in part, that:
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
The Duquesne Light Company NSQC Manual, Section 15.2, Revision 1, Paragraph 5.1.,
states, in part, that: When a material, procedural, or workmanship deficiency is identified, it shall be documented through the use of a NSQC General Inspection Report, Hold Tag, or a Nonconformance or Corrective Action Report (NCAR) in accordance with the applicable NSQC Program Procedures.
Contrary to the above, on July 26, 1979, a N5QC General Quality Control Inspection Report was written, which reported a violation of heat treat temperature for a weld in the RC-E-1A line of the feedwater system.
The report stated that a temperature of 1160*F for 15 to 20 minutes before the temperature was brought into the required range of 1125 + 25 7.
A review of this matter by the inspector revealed that the rejectable item had not been documented, evaluated or transmitted by the use of a Nonconformance Report to appropriate levels of management for proper resolution.
Corrective Action A Nonconformance..and Corrective Action Report (NCAR 182) was issued to document the violation of the post weld heat treatment procedure. The NCAR was dispositioned and the post weld stress relief as performed was determined to be accep.'able.
13/7 540
~
Beaver Valley Power Station, Unit No. 1 Reply To Notice Of Violation Inspection No. 79-08 Page 3 Action Taken To Prevent Recurrence In order to prevent recurrence of this problem, specific directives for the surveillance of post weld stress relief operations are being added to the Nuclear Services Quality Control Weld Inspection Procedure.
Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
13//
$41