ML19290E052

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Responds to NRC 791228 Ltr Re Violations Noted in IE Insp Rept 50-412/79-08.Corrective Actions:Receipt Insp Plans Amended to Specify Preservative Coating on Instruments
ML19290E052
Person / Time
Site: Beaver Valley
Issue date: 01/29/1980
From: Woolever E
DUQUESNE LIGHT CO.
To: Robert Carlson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19290E050 List:
References
2DLC-3398, NUDOCS 8003040074
Download: ML19290E052 (3)


Text

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'Af (412) 471-4300 435 Sixth Avenue 2DLC-3398 Pittsburgh, Pennsylvania 15219 January 29, 1980 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Robert T. Carlson, Chief Facility Construction and Engineering Support Branch

SUBJECT:

Beaver Valley Power Station Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/79-08 Gentlemen:

This is in response to the item of infraction cited in Inspection Report No. 50-412/79-08 and listed in Appendix A (Notice of Violation) attached to your letter to Mr. E. J. Woolever dated December 28, 1979.

NRC VIOLATION 10CFR50, Appendix B, criterion XIII, states, in part, that:

" Measures shall be established to control the... storage...

and preservation of material... in ac-nedance with work and inspection instructions to prevent dcnage or deterioration."

Section 17.2.1.13A of Chapter 17 of the PSAR states, in part, that: "The Duquesne Light Company Quality Assurance Program establishes measures to control... storage... and preservation of material... in accordance with work and inspection instructions to prevent damage or deterioration."

Duquesne Light Company Receiving Inspection Plans RIP-59-2-R2 and RIP-59-R2 require that variable spring hangers be stored in accord &nce with Level C requirements. Stone and Webster Design Specification 2BVS-59, " Design and Fabrication of Power Plant Piping Supports," Revision 0, requires that threads and machined surfaces of piping supports shall be coated with a preservative. Attachment 3 to 2BVS-981 requires that fabricated piping supports be recoated, repainted or resealed as necessary during storage.

8003040 09+

Mr., Robert T. Carlson, Chie f Page 2 January 28, 1980 Contrary to the above, as of November 8, 1979:

- Variable Spring Hangers were stored in Level D type storage;

- There was no requirement in applicable procedures to verify preservation of threads prior to storage nor was there an effective program to maintain preservation during storage.

As a result, rusting of threaded portions of stored hanger assemblies had occurred.

RESPONSE

Resulting from the Infraction reported above, Nonconformance and Disposition Report #1172, dated November 8, 1979, was initiated as immediate action to identify the unacceptable condition of the referenced threaded rods. Following this immediate action, an investigation was initiated to establish the causes of the problem and corrective actions.

Our QC Receipt Inspection Plan Nos. RIP-59-R2 and 59-2-R2, which were applicable at the time of the receipt of the material, did not include an attribute for checking the application of the specified preservative. These Receipt Inspection Plans have now been amended to include the following attribute: " Verify - Threads and machined surfaces are coated with a rust inhibitor" . (RIP-59-R3, dated 11/9/79 and RIP-59-2-R3, Dated 11/8/79). Our Vendor Surveillance Group assigned to the Manur'acturer's Shop have been instructed to verify the application of the preservative prior to dispatch. In addition, the applicable Vendor's Specification 2BVS-59 has been amended to eliminate the use of an alternate preservative which was considered not fully effective for long-term storage as experienced at the site.

Specification 2BVS-981, Page 2SMR-059, has been revised defining specific requirements for the inspection and the inspection frequency, applicable to threaded rods, during storage. Equipment Storage History Cards required by our Field Construction Procedure No. 11 have been issued reflecting these requirements. These records have been retrofitted to reflect those inspection and corrective actions taken during December 1979 to rectify the existing conditions.

Mr. Robert T. Carlson, Chief Pags 3 January 28, 1980 Our investigation continued into the activities related to site painting processes as applicable to the protection of threads.

Field Construction Procedures, 800 Series, have been revised to reflect specific attention to the protection and preservation of threaded rods during these processes.

With reference to the incorrect storage level applied to Variable Spring Hangers, Specification 2BVS-981 has been amended to allow for the storage of these components outdoors with equivalent protection of Level C, equivalent protection being defined as the material being en pallets and covered securely with a waterproof covering. The rework of the material condition in accordance with the disposition of N&D #1172 and corrective action reference storage conditions are expected to be completed during the month of February 1980.

The original condition of the threaded rods has been evaluated by our Engineers and is not considered to have safety implication.

DUQUESNE LIGHT COMPANY BY * . ,, ,

Ey J . Woolever Vice President COPIES TO: Mr. V. Stello (15)

Mr. W. G. Mcdonald