ML19294A319

Response to IE Inspec Rept#50-305/78-10 During Which 2 Items of Noncompliance Were Noted:Ultra Sonic Testing Couplant Matl Used for UT Exam Was Only Couplant Matl Available & Insvc Records Were Avail

ML19294A319
Person / Time
Site:	Kewaunee
Issue date:	08/09/1978
From:	James E WISCONSIN PUBLIC SERVICE CORP.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19294A320	List: ML19294A319
References
NUDOCS 7810060020
Download: ML19294A319 (5)

Text

}

. WISCONSIN P U B LI C S E RVIC E CO RPO R ATIO N >

P.O. Box 1200, Green Bay, Wisconsin 54305 August 9, 1978 Mr. R. F. Heishman, Chief Reactor Construction & Engineerinct Support Branch U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Heishman:

Docket 50-305 Operating License DPR-43 1 & E Inspection Report No. 50-305/78-10 The referenced report presents the results of an inspection conducted by Messrs C. C. Williams and K. D. Ward at the Kewaunee Nuclear Power Plant. This report identifies two items of noncompliance, both classified as a deficiency. Our response is presented below:

Deficiency:

1. Contrary to 10 CFR Part 50, Appendix B, Criteria XVII, and the Kewaunee Plant Technical Specifications Section 6.8, Administrative Control Directive No. 9.2 (Plant QA Records); the following record deficiencies were identified:

a. The ultrasonic testing couplant material used during the test is not identified on the ultrasonic test report forms; i.e.,

Westinghouse form No. 45336 (Report Form); as is required by Article I-6100(b) of the ASFE Section XI.

Response

Article I-7000 of ASFE Section XI requires preparation of a report of the UT examinations performed during each inservice inspection in accordance with Article IWA-6000 and stipulates that "All procedureb and equipment shall be identified sufficiently to permit duplication of the examination (s) at a later date . . .".

o

. 1 1 1978 7 319d i MU

F Mr. R. F. Heishman August 9, 1978 Page 2 The ultrasonic testing couplant material used for UT examinations performed during the spring,1978, refueling outage as par,t of the Kewaunee Nuclear Power Plant inservice inspection program was supplied by Westinghouse f rom one specific batch of couplant material for exclusive use during the UT examinations. No other UT couplant material was available at the site. Certification of this UT couplant cucciial was also supplied by Westinghouse; the NRC inspector was shown a copy of this certification during his inspection.

The intent of Article I-7000 of ASME Section XI, as expressed in the footnote to this article, is to prevent repetition of information in the inservice inspection report. One-time identification or a material common to all UT inspections will satisfy the recording requirement of Article I-6110(b) of ASME Section XI for that material and satisfies the intent of Article I-7000 of ASME Section XI.

We feel that this citation is unjustified and counter-productive to our ef forts of efficiently maintaining high quality performance in the fulfillment of our license responsibilities as addressed above.

1. b. Ultrasonic test records did not show that the temperature requirements specified in ASME Section XI Paragraph I-4220, had been adequately complied with.

Response

ASME Section XI Article I-1200, Limitations on Scope, states that "The methods are limited to Class 1 and 2 ferritic vessels, 2h" and over in wall thickness.

Clad vessels are included." Therefore, ASME Section X1 Appendix I applies only to the reactor vessel, pressurizer vessel and steam generators at the Kewaunee Nuclear Power Plant. Only 14 of the 91 program items for the Cycle III-IV refueling outage inservice inspection requiring UT examination fall under this category; however, in keeping with good work practice the guidance of ASME Section XI Appendix I was followed for all UT examinations.

Paragraph I-4220 of ASME Section XI requires that the temperature of the calibration block shall be within 250F of the component temperature during UT examination syrtem calibration. The intent of this requirement is to avoid errors which might result if a large temperature difference exists between calibration and examination conditions. There is no requirement in ASME Section XI for recording the calibration block / component temperature dif ference.

Accepted practice throughout the industry has been that components at ambient temperature with the calibration block, as established by touch, do not require instrumented temperature measurement to demonstrate compliance with paragraph I-4220 of ASME Section XI. All but two of the UT examinations performed as e Nuclear part of the spring, 1978, inservice inspection program at the Kew d components Power Plant, including the 14 program items referred to above, invo e

at ambient temperature and did not require specific comparison wit

Mr. R. F. Heishman Augus t 9, 1978 Page 3 calibration block ambient temperature. For the two inspections involving components at slightly gre,ater than ambient temperatures, our technical representative, charged with overall monitoring of the ISI program, and the ISI inspectors did verify that the calibration block temperature complied with the requirement of Article I-4220 of ASME Section XI even though the requirement did not specifically apply to these components.

This citation is contrary to previously accepted code interpretation and im-plementing work practices which have long been accepted by both industry and government and is therefore invalid.

1. c. The Westinghouse (W) inspection report form No. 45336 and Westinghouse procedure No. OPS-NSD-101 required recording of the test specimens, technical specification reference identity. However, at the close of this inspection, none of 50 finalized records reviewed showed compliance to this requirement.

Response

A Westinghouse inspection report form No. 45336 is completed for each individual UT examination performed as part of the inservice inspection program according to the instructions of OPS-NSD-101, Appendix A. The information item addressed by this citation is block number 5. The instructions given in OPS-NSD-101, Appendix A for block number 5 are to " Enter Plant Technical Specification reference item number applicable to area being examined (to be entered by the data coordinator) ."

There is no specific requirement in ASME Section XI for including this information for each individual examination. This information is provided as a records keeping tool for identification of the plant specific requirement for the testing summarized on the form and serves no purpose in the actual performance of the UT examination for which the form has been completed.

The inspection of these No. 45336 forms by the NRC inspector was premature because they had not been reviewed and accepted by Wisconsin Public Service Corporation at the time of the NRC inspection. The NRC inspector did not take issue with the technical data provided on the No. 45336 report forms, therefore, we conclude that the actual UT examinations were documented in accordance with applicable requirerents.

All of the No. 45336 report forms were fully comp'eted prior to final acceptance of the licensen on May 10, 1978. We consider this citation to be of minor significance because it addresses a records keeping deficiency that was corrected in the final review of the records and contributes nothing to the technical adequacy of our inservice inspection ef forts at the Kewaunee Nuclear Power Plant.

To preclude reoccurrence of this situation we will direct Westinghouse to delete block nwnber 5 from the No. 45336 form f or future inservice inspections at the Kewaunee Nuclear Power Plant.

Mr. R. F. Heishman August 9, 1978

' Page 4 Deficiency:

2. Contrary to 10 CFR Part 50, Appendix B, Criteria IX, ASME,Section XI (Summer 1975), and SNT-TC-1A, 1975, the licensee's contracted SNT-TC-1A level III representative (Fluor Pioneer, Inc.) qualification certifica-tion documents were expired. Moreover, the Fluor Pioneer, Inc. (FPI) written practice responsive to SNT-TC-LA,1975, had not been approved by FPI managers nor the licensee.

Response

Westinghouse, as an agent of Wisconsin Public Service Corporation, provided all services, including inspection personnel, required to fulfill our license obliga-tions pertaining to inservice inspection. Certifications for the Westinghouse inspection personnel were available for review by the NRC inspector.

In order to provide high assurance that all code requirements were met during the inservice inspection of the Kewaunee Nuclear Power Plant, Wisconsin Public Service Corporation provided a representative, known by us to be experienced and knowledgeable in the area of ISI, to monitor the inservice inspection activities. This representative was obtained under contract from our architect engineer and is the individual referred to in this citation. This contracted representative did not require qualification certification documents because he performed no inspection activities. The purchase order under which he was obtained specifically requests his services for " technical assistance and field supervision for inservice inspection activities associated with the spring,1978, refueling outage at the Kewaunee Nuclear Power Plant." Our internal quality assurance procedures require that the individual conducting an audit of the ISI level II, program be knowledgeable in the area of ISI and be of ASNT-TC-1A, The contracted representative qualification or have experience to the equivalent.

referred to in this item clearly met our requirements for equivalent experience and did not require documents of qualification certification to perform the job functions assigned to him under our contract.

Our position regarding this citation was discussed with the NRC inspector but apparently some misunderstanding still exists. Basically, in an attempt to ensure that the inservice inspection criteria were fully implemented, Wisconsin Public Service Corporation acted beyond its license obligations.

Unfortunately, this additional action precipitated a citation because, while not necessary undcr the circumstances, records of personnel qualification were not maintained. Since these records are not required under license commitments, a deficiency does not exist and this citation should be retracted.

Citations of this type, if allowed to stand or continue, can create a negative influence on licensees, causing a reduction in their efforts to perform at

Mr. R. F. Heishman August 9, 1978 Page 5 levels of safety and reliability beyond what is committed in the operating license or by the regulations. Such a si.tuation is not in the best interest of the public, the operating personnel, hor the owners.

Very truly yours, E. W. Jam -

Senior Vid.. President Power Supply & Engineering snf

.