ML19309E489
| ML19309E489 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/16/1980 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2DLC-3505, NUDOCS 8004220483 | |
| Download: ML19309E489 (22) | |
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(1)414 435 Sixth Avenue Pittsburgh, Pennsylvania 15210 April 16, 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. 50-412/80-02 Gentlemen:
This is in response to the Unresolved Items and substantiated allegations applicable to the Power Piping Company, Donora, PA, performing piping fabrication activities for our Beaver Valley Power Station Unit No. 2 Project described in your letter to Mr. Woolever dated March 13, 1980.
We have noted that no ;tems of noncompliance were observed but that you required our written response for the items referenced above.
On receipt of your letter, we convened a meeting at the Beaver Valley Unit No. 2 site with our engineers and Power Piping in order to review the problems in detail and lay out course of action to be taken by our vendor as an initial corrective action phase.
Our conclusions from this review were that the problems could be classified into two main groups.
The fJrst group could be described as management program deficiency identified by Allegations 80-02-01 (Audits) and 80-02-02 (Training).
The second group was more technical and related to production practices and, in our view, ASME III, Division 1, interpretation.
These being described by Unresolved Items 80-02-03 and 80-02-04.
It is our intent to perform Duquesne Light Company initiated Quality Assurance audits to confirm our piping fabricator's actions prior to June 1, 1980.
8 0 0 4 22 0'tsC)
t lir. Robert T. Carlson Page 2 April 16, 1980 ALLEGATION 80-02-01 INTERNAL AUDITS WERE NOT BEING PERFORMED IN THE REQUIRED TIME PERIOD Quote:
"The PPCO Quality Assurance Manual identifies two types of audits.
The first is the management audit which is performed at the direction of corporate management.
The most recent management audit was performed on November 20-21, 1979.
Among other findings, this audit recommended that a reaudit be performed in the deficient areas on December 10, 1979.
The reaudit had not been performed at the time of this investigation on January 9, 1980.
In addition, the area of training was not audited due to the recent implementation of a new training program resulting from the revision of the Quality Assurance Manual.
The preceding management audit was performed on August 30, 1978.
The maximum period between management audits is twelve months as provided by the Quality Assurance Manual, Procedure D-QA-15, paragraph 2.1.
Therefore the November 20-21, 1979, Audit was three months late.
The August 30, 1978, audit identified the frequency, content, and records of the training program as a finding.
In light of this finding, the current management audit has not been performed in this area to verify corrective actions.
The second type of audit is the quality assurance audit performed at the direction of the Corporate Director of Quality Assurance.
A review of the 1978-1979 quality assurance audit records disclosed that 18 audit areas had not been performed in 1979, at the twelve month interval as required by the Quality Assurance Manual, Procedure D-QA-15, paragraph 3.1.
Conclusion This allegation was substantiated (50-412/80-02-01)."
End of quote.
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Mr. Rob rt T.
Carlson Page 3 April 16, 1980
RESPONSE
Power Piping Company Management took steps to strengthen their QA/QC program early in the second quarter of 1979.
A re-organization was initiated and new personnel were hired.
In order to maintai.n continuity and direction of the program during this period of change, Power Piping Company decided to forestall certain activities which included a delay of tha internal audit program.
Changes to the QA/QC organization, re-assignment of personnel and changes to the QA Manual were initiated during this period of delay.
During this period of delay, an on-going over-view by Power Piping QA Management was performed to ascertain the effect of the changes and personnel re-assignments.
The delay to the internal audit program was initiated the first week in July, 1979, and re-instated November 6, 1979, giving an affected period of four (4) months.
During the four (4) month period of suspended internal audits, Power Piping Company was subject to the surveillance and audits of the following organizations:
- 1) Stone and Webster Corporation - Boston, Massachusetts A complete QA program audit.
An audit team of four (4) auditors for five (5) days.
- 2) Hartford Steam Boiler Insurance and Inspection Company -
Pittsburgh Office An authorized inspection agency (ANSI N626.0) audit with a team of two (2) auditors.
- 3) The Resident Authorized Nuclear Inspector The resident ANI performed periodic and daily QA program i
surveillances.
None of the above organizations or individuals identified any major breakdowns in the QA program.
With reference to Management Audits, Power Piping Company made a decision to postpone the management audits required August 29, 1979 through November of 1979, during the preparation for the scheduled resurvey by ASME on November 28, 29 and 30, 1979.
This action delayed the audit by a period of three months.
We have discussed this decision with them and consider that it was made in error, although well' intentioned.
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Mr. Robert T. Carlson Pago 4 April 16, 1980 I!
Immediately following the pericd described above, Power Piping Company was subject to a full scale ASME survey for renewal of their Certificate ~ of Authorization.
The survey team consisted of five (5) members with Mr. Ed La Pan as team leader, and two (2) observers who also participated.
The team reviewed and performed observation of the QA program.
Power Piping Company was successful in demonstrating implementation of their QA Manual and compliance with the requirements of the ASME Code.
Only one relatively minor deficiency was noted during the exit 2
meeting, which related to the documentation of the qualification 4
of their NDE Level III.
This deficiency was corrected and their i
ASME Certification was renewed at the exit.
The failure to perform the internal and management audit on schedule was identified by Power Piping Company in their internal audits performed in November and the necessary corrective actions were initiated.
From the above description of the events affecting this allegation, we consider a possible error of judgment was made regarding the decision to delay management audits.
We submit, however, that the actions taken by Power Piping and with due c
consideration given to the third party reviews, inspections and audits performed as described above, the delay did not adversely affect the quality of the subassemblies produced during this l
time period.
We have instructed Power Piping Company to formalize the manner of controlling and assigning both management and QA internal audits.
They have produced a draft procedure to this effect, which has been subject to initial review by ourselves and found satisfactory.
This procedure for the assignment and controlling of audits at given time periods will be subject to audit by the Duquesne Light Company Quality Assurance Department or their agents.
ALLEGATION 80-02-02 POWER PIPING COMPANY'S TRAINING PROGRAM
.l Quote:
i "The training program was recently revised as outlined in the. Quality Assurance Manual, Section D-QA-1, dated November 29, 1979.
The management audit conducted on August 30, 1978, made several findings which indicated i
that training was not being performed at the scheduled frequencies nor were adequate records available to verify personnel participation.
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6 Mr. Robert T. Carlson Pago 5 April 16, 1980 The current management audit did not examine this area due to the recent implementation of a new training program and the obvious lack of records to support it.
Conclusion This allegation was substantiated based on the previous management audit findings and informal interviews conducted with Power personnel (50-412/80-02-02)."
End of gr,te.
RESPONSE
In accordance with our instructions, Power Piping Company performed a detailed review of the training records back to 1978 to ascertain the impact, if any, on the quality integrity of subassemblies produced or being produced.
In addition, an audit was conducted March 31 and April 1, 1980 by Power Piping Company of the existing training program and records to determine wh' ether the program was adequate and satisfied requirements.
A random selected number (100) of completed fabrications and their associated documentation packages were pulled.
The identity of the inspector and what inspections were performed was established.
Based on this information, a review of the training records of those individuals was initiated to establish the compatibility of the training received against the inspection activities performed.
Of the forty (40) individuals identified who performed the various inspections on the 100 selected fabrications, none of the training records could identify any major deficiency in training relative to their work assignments.
This review confirmed that during the period under investigation, a major component of Power Piping Company training program was the "On the Job" type training, and prior to the implementation of their procedure ITP-1, the documentation of this type'of training was minimal.
With the implementation of ITP-1, documentation has been improved and additional emphasis has been l
given to classroom type training.
The referenced audit revealed four discrepancies:
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Mr. Robert T. Carlson Page 6 April 16, 1980
- No Indoctrine. tion and Training records for Corporate Director of Quality Assurance.
(Corrective Action:
Revise Procedure ITP-1 so that management individuals may not require formal Indoctrination and Training.
Date completed:
4/2/80).
- Indoctrination and Training records lack some required information as necessary.
(Corrective Action:
Review all records and correct as necessary.
Date completed:
i 4/2/80).
Examples:
length of session, name of instructor, etc.
- No evidence of the assigned required Indoctrination and Training for one (1) individual; no revision to Procedure Matrix when certain individuals change job functions.
(Corrective Action:
Review Indoctrination and Training requirements for all individuals and evaluate whether necessary or not.
Where additional training is determined necessary, develop schedule.
Date of completion of schedule:
4/14/80).
- Instructors' Indoctrination and Training in the procedure while adequate, was not properly documented.
(Corrective Action:
Update records to include instruction.
Date completed:
4/2/80).
Corrective Action Requests (CAR's) were initiated by Power Piping Company to identify these discrepancies and to establish the corrective action commitment and the date for implementation.
It is submitted that the deficiencies identified do not indicate a basic deficiency in the revised training program now being implemented.
Resulting from Power Piping's investigation into the past training received by an instructor and its relationship with the inspections performed by him, it is submitted that the lack of consistent documentation of training was the major discrepancy.
It is further submitted that this discrepancy had no adverse effects on the quality of the piping subassemblies supplied to our project.
The actions taken by Power Piping will be subject to audit initiated by the Duquesne Light Company Quality Assurance Department or its agent.
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Mr. Robert T. Carlson Pago 7 April 16, 1980 UNRESOLVED ITEM 80-02-03 COUNTERBORE TOLERANCES (LONGITUDINAL)
Quote:
"A large majority of the nuclear class 1, 2, and 3 piping has a weld buildup applied to the area adjacent to the weld preparation, 360 degrees around the outside diameter and extending for several inches back onto the base metal.
The vendor stated that this buildup was to prevent encroachment on the minimum wall requirement when the pipe inside diameter was counterbored.
PPCO drawings, SK-101 and SK-103, specify a minimum depth of counterbore along the longitudinal axis of the pipe but no maximum.
This permits the counterbore to extend beyond the weld buildup area and possibly encroach on the specified pipe minimum wall.
Pipe spool N-ll41, sheet no. 1017017-14, Revision 0, exhibited the aforementioned condition.
This item is considered unresolved pending further inspection to verify that this was a unique occurrence (50-412/80-02-03)."
End of quote.
RESPONSE
Our initial action on receiving the referenced Unresolved Item was to have Power Piping Company verify that the specific pipe spool mentioned within the Unresolved Item te::t, N-ll41, Sheet No. 1017017-14, Revision 0, did not have a minimum wall violation, and we have been advised by them that the spool in question was checked and found to be acceptable.
We then obtained information from Power Piping that they had revised the appropriate drawings, SK-101 and SK-103, to give a maximum depth of counterbore along the longitudinal axis so the counterbore will not extend beyond the OD weld buildup in the future.
Regarding fabrications that had been completed in the past, we have been advised by Power Piping Company that the area of concern is subject to some form of grinding to assure a smooth transition.
We have also been advised that instructions were given to all assigned personnel who had performed inspections that minimum wall verifications received particular attention during and af ter grinding of the weld surface or any other areas that are noted to have been ground.
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Mr. Robert T. Carlson Pago 8 April 16, 1980 To demonstrate that Power Piping has verified minimum wall in areas where grinding has occurred, Power Piping has reviewed, for minimum wall violations, all its Nonconformance and Disposition Reports (NCDR's) pertaining to this Project.
A total of 63 NCDR's have been identified which address minimum wall violations.
Included in these NCDR's are minimum wall violations in the areas of concern (transition between base material and OD weld buildup).
7 It is submitted that with the actions to include the longitudinal tolerance on Power Piping Company's drawing for the future, the acceptance of the piping spool in question, and the attention to the ground areas by inspectors, that this matter is acceptable subject to Duquesne Light Company Quality Assurance audit of Power Piping inspectors' activities.
Resulting from the review previously described in this response, additional problems were revealed.
These problems relate to activities performed when minimum wall measurements identify the need for weld repair to re-establish minimum weld requirements.
In three (3) instances the final repair weld thickness measurement in the area of rectification was not documented, and in three (3) instances the depth of cavity requiring repair was not documented.
In all cases radiography was not performed.
The NDE performed was dye penetrant, which is acceptable if the depth of the repair is known and falls within the code requirements for dye penetrant examination only.
On receipt of this information from Power Piping, the Duquesne Light Company Site Quality Control initiated a Nonconformance and Disposition Report, and we have established that the pipe in question is available for confirmation inspection by radiography and wall thickness measurement.
Decisions on reportability will be made when the results of such inspections are obtained.
UNRESOLVED ITEM 80-02-04
'OUTSIDE DIAMETER WELD BUILDUP Quote:
"The ASME III Code, Paragraph ND-4130, provides for the repair of defects in the base materials, such as the weld buildup described above to repair the minimum wall condition.
Paragraph ND-2539.4 prescribes that, for repairs which exceed 10% of the wall thickness, radiography shall be performed.
The vendor could not provide objective
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-i Mr. Robert T.
Carlson Page 9 April 16, 1980 evidence that measurements were being performed to establish the percentage of weld buildup and that radiography was being performed on class 3 pipe repairs.
This item is unresolved pending further inspection at Beaver Valley Unit 2 to determine if any class 3 piping has been received and installed onsite which does not meet the foregoing i
requirements (50-412/80-02-04)."
End of quote.
RESPONSE
The basis for the Unresolved Item appears to rest on the inter-pretation of OD weld buildup prior to machining as being a repair to the base material.
It is our contention that weld OD buildup applied prior to machining does not fall under that interpretation, and the weld resulting from that OD weld buildup should be subject to the same examination as the butt weld itself.
We presented our position in conjunction with our engineers at the offices of the Authorized Nuclear Inspection Agency and at that time obtained their initial concurrence with our views.
In addition to that approach, a representative of our engineers has met with the ASME Section III subgroup on fabrication and i
examination, and again this subject was discussed.
The subgroup has taken the same interpretation as previously described.
We have further been advised that steps had been initiated to revise the code in accordance with our interpretation.
- However, since this is a very time consuming process, a " Code Case" is to be prepared and presented to the main committee as soon as possible.
The proposed " Code Case" will be addressing weld buildup prior to final counterboring, sizing or grinding, and will be including the statement similar to, "The deposited weld metals shall be examined in the same manner and to the same acceptance standards as the final butt weld".
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Historically there is a precedent for this approach.
ANSI B31.7, the original code for nuclear work, defined this matter clearly, but on subsequent issues of ASME Section III, the matter of OD weld buildup and its inspection appearr,.to have been dropped inadvertently.
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Mr. Robsrt T.
Carlson Pago 10 April 16, 1980 We have available detailed reports describing our engineers' interpretations as given to the Authorized Nuclear Inspection Agency.
If you consider that you would require more information, and in view of the large amount of detail in such a discussion, we would be pleased to discuss this matter with your representatives at a meeting set up for the purpose.
In conclusion, then, our position relative to Class 3 pipe received to our Beaver Valley Unit No. 2 Project is that the weld OD buildup has been subject to the same inspection criteria
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as the butt weld itself.
If we can be of any further assistance in this matter, please 1
advise.
DUQUESNE LIGHT COMPANY I
By e
(/ J.'Woolever Vice President i
cc:
Messrs.
V.
Stello (15)
W. G. Mcdonald t
l Mr. Robart T. Carlson April 16, 1980 Page 11 RJW:jh i
bcc:
Messrs. W. H. Bohlke l
F.
Salmon R. J. Swiderski i
J. A. Werling J. J. Carey E. J. Woolever N.
R. Tonet
-C.
N. Dunn i
R. J. Washabaugh G. W. Moore 1
H. A. Van Wassen i
R.
E. Martin I
J.
E. Williams
]
C. O. Richardson I
I Ref. NRC #395 i
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