ML19331C193
| ML19331C193 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/06/1980 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Robert Carlson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8008140299 | |
| Download: ML19331C193 (4) | |
Text
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FM (412) 471-4300 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 August 6, 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. 50-412/80-06 Gentlemen:
This is in response to the items of infraction cited in Inspection Report No. 50-412/80-06 and listed in Appendix A (Notice of Violation) attached to your letter to Mr.
E.
J. Woolever dated July 7, 1980.
NRC VIOLATION (80-06-01) 10 CFR 50, Appendix B, Criterion XIII, states, in part,
" Measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment... to prevent damage or deterioration. "
The Beaver Valley Power Station Unit 2, PSAR Section 17, paragraph 17.2.1.13A, also states, "The DLC QAP establishes measures to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."
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Mr. Robrrt T. Carlson Page 2 August 6, 1980 NRC VIOLATION (80-06-01)
(Continued)
DLC QA Manual-in QA Procedure DC-13 (Ha.31ing, Storage and Shipping), paragraph 13.3 states in part that " Specific procedures and instructions shall be written when necessary for the preservation, packaging and storage of items.
The procedures and instructions shall be utilized to assure that items subjected to deterioration or damage...
are cleaned and have necessary preservatives to prevent damage."
Stone and Webster FCP-ll Attachment 3.2 to Appendix 1 indicates that valves are classified for storage under storage Level C.
The document states that for Level C storage " Items shall be stored indoors or equivalent with all provisions and requirements as stated for Level B items except that heat and temperature controls are not required."
Level B states "The items shall be stored within a fire resistant, tear resistant, weather tight and well ventilated builling or equivalent enclosure...."
Contrary to the above, on June 3, 1980, the Valve 2-VV1-015-ll-3, Serial No. D-0021-3-2, was stored in an open box at the bottom level of the containment building, exposed to the weather and as a result showed evidence of wet corrosion.
This item is an infraction.
RESPONSE
As an immediate action resulting from the Infraction reported above, the valve in question was dried and cleaned, the crate lined with Visqueen, the valve body wrapped, and the wooden top secured.
This valve and valves in the same area were repositioned to provide better overhead protection, and a Visqueen covering was placed over the boxes.
In addition, Nonconformance and Disposition Report #6252 was issued.
We had recently reassessed our " interim" storage program, and the resultant revisions to our program may not have l
placed sufficient emphasis on the increased storage of
Mr. Robert T. Ccrlecn Prga 3
+
August 6, 1980 P.ESPONSE (Continued) equipment in permanent buildings.
This increased use of permanent buildings as storage areas resulted from our recent construction rescheduling.
In view of the possibility of the lack of em,tasis on the maintenance of storage conditions in permanent buildings, our Field Construction Procedure, FCP-ll, Appendix 1, Material Control Program, Section 9 has been revised to re-emphasize the application of these requirements under the conditions described.
The need for verification of the storage condition of equipment in the previously referenced areas has been re-emphasized to the Duquesne Light Site Quality Control, Material Control Section.
In addition, the contractor responsible for the storage of the referenced equipment has assigned specific personnel to perform a weekly inspection of the storage condition of equipment now stored in buildings.
Our Engineers have reviewed the condition of the valve in question and advise that there are no safety implications in the conditions caused by the inadequate storage of ' the referenced valve.
NRC VIOLATION (80-06-02) 10 CFR 50, Appendix B, Criterion IX, states, in part, that "...special processes, including... welding are controlled and accomplished...in accordance with 9pplicable codes, standards, specifications...."
The Beaver Valley Power Station PSAR, Section 17, paragraph 17.2.1.9A, also states, in part, that:
"...The DLC QAP establishes measures to assure that special processes, including welding...are controlled in accordance with applicable codes, standards, specifications...."
DLC QA Manual in QA Procedure DC-9 (Control of Special Processes), paragraph 9.4.2 states in part that "The AE/ constructor and NSS supplier are responsibla for the establishment and implementation of measures for controlling special processes...and shall supply contractors with procedures for controlling special processes."
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Mr. Robert T. Carlson Page 4 August 6, 1980 NRC VIOLATION (80-06-02)
(Continued)
Stone and Webster Field Construction Procedure, FCP-601.5, paragraph 11.12, states, in part, "Each welder shall be responsible for all welding materials...All electrode stubs or damaged electrodes shall be retained by the welder in a suitable container (stub bucket) for proper disposal at the issue station. "
Contrary to the above, on June 3, 1980, approximately 25-40 welding electrode stubs and damaged electrodes had been placed in a large trash container within the containment building.
This item is an infraction.
RESPONSE
We have investigated the above Infraction and have established that the basic cause of the failure to return used or damaged stubs to the designated disposal bin was related to the need to instruct welders' assistants in these requirements.
This matter has been corrected, but we request that our full response to this Infraction be postponed until the solution to our overall weld electrode control program problem is established.
This problem is the subject of our Potential Significant Deficiency Report, 80-04, reported to your Mr. L. Narrow by our Mr. H. VanWassen in a telephone conversation on the 1st of August, 1980.
We will provide you an interim or final report by September 1, 1980.
DUQUESNE LIGHT COMPANY By E7'J6/ N5 ole'ver Vice President cc:
V.
Stello (15)
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