ML20024E989
| ML20024E989 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/18/1983 |
| From: | Schuyler J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20024E986 | List: |
| References | |
| 83-192, NUDOCS 8309080070 | |
| Download: ML20024E989 (6) | |
Text
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PACIFIC GAS AND E LE C T RI C C O M PAN Y b b'-M b
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77 BEALE STREET
- S AN FRANCISCO CALIFORNI A 94.
[415)781 4211. TWX 910-372-6587 J.O.SCHUYLER v:ct recsscthf N JCLlat PO 4ER GE4tRAT 04 August 18, 1983 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Docket No. 50-323 Diablo Canyon Units 1 and 2 IE Inspection Report 83-10/83-13 -- Notice of Violation Pequest For Further Informatica
Dear Mr. Martin:
NRC Letter dated July 29, 1983 requested further information on PGandE response to a Notice of Violation transmitted by our letter dated June 20, 1983.
Enclosed is PGandE's response to this request.
Sincerely, Enclosure w
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F FGandE Response To Request For Further Information In IRC Ietter Dated July 29, 1983.
(IRC Inspection Report 83-10/83-13)
On May 19, 1983, IRC Region V issued a Notice of Violation as a result of IRC inspections conducted from March 30, 1983 through April 29, 1983. PGandE submitted the response to that Ibtice of Violation on June 20, 1983.
IRC Ietter dated July 29, 1983 requested further information in the following two areas:
1.
"In addition to the Ibtice of Violation, our letter of May 19, 1983 requested that you address the following two issues:
'(1) provide an assessment of the degree to which your welder requalification procedures and implementation practices, employed both in the past and at present, comply with the requirements of the ASME B&PV Code; and (2) the effect on welding quality of any identified failure to cmply with code requirenents.'
It is not evident from your response that you specifically addressed these two issues.
2.
Your response to item A.1 of the Notice of Violation did not recognize the failure of your contractor to follow approved procedures and did not address measures to assure procedural coupliance in the future."
.s Page 2 of 5 Response To Item 1 of EC Ietter Dated July 29, 1983 FGendE's response to the inspection report indicated that a discrepant method used by H. P. Foley Company to conduct a welder recertification was an isolated case and, therefore, did not specifically address the additional information request. However, in response to the R C letter of July 29, 1983,.
the following explanations are provided:
I Assessment of Degree of Coupliance Pullman Power Products Corporation arxl the H. P. Foley Company q
currently employ welders qualified in accordance with ASME Boiler and Pressure Vessel Code requirements. Pulbnan performs ASME N-stamp welding on plant pressure vessels and piping; Foley performs j
ASME welding on instrumentation tubing and ventilation piping. An assessment of the compliance of the H. P. Foley Coupany and Pullman Pbwer Products Corporation welder requalification procedures and implementation practices (employed both in the past and at present) to the requirements of ASME B&PV Code has been coralucted.
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'Ibe assessment indicates that, except for the discrepancy identified in the Notice of Violation, both the past and present applicable procedures used by the two companies are in couplete coupliance with ASME Code welder qualification and welder recertification t
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4 Page 3 of 5 Assessment of Degree of Compliance (ContirnW) requirements. Both contractors' procedures for ASME welder qualification are reviewed and approved by PGandE prior to implementation, to assure that all requirements of ASME B&PV Code are adequately addressed. Coupliance with procedures is verified through audits conducted by the contractor and PGandE.
Effect of Welding Quality
'Ibe recertification method identified in the EC special inspection was verified as being an isolated incident resulting from insufficient training of the H. P. Foley Company Quality Control Inspector responsible for supervising the retest, and was limited to recertification of a foreman not engaged in production welding.
'Iherefore, H. P. Foley's failure to comply with the procedural requirements had no effect on weld quality.
In stenary, it has been established, except for the isolated case identified in the inspection report, that contractors' procedures are in couplete compliance with the ASME B&PV Code welder qualifications and recertification requirements. Ebrthermore, the failure of H. P. Foley to cocply with procedural requirements had no effect on welding quality since the individual who was incorrectly recertified was not subsequently engaged in production welding.
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,e Paga 4 of 5 Response to Item 2 of IRC Ietter dated July 29, 1983 The following supplements our June 20, 1983 response to Item A.1 - Premature Removal of '%d Hold Tags":
PGandE recognizes that when the H. P. Foley Conpany Quality Control inspector prematurely removed 'bd Hold Tags" attached to structural steel beams at elevation 187 of the Fuel Handling Building Hot Shop, he did not follow approved procedures. Removal of the 'bd Hold Tags" was not allowed by QCP-3 Rev. 5 until the work was completed, inspected by Quality Control and the Nonconformance Report was signed off by the H. P. Foley Project Manager as being couplete.
The noted violation was an isolated case involving one individual.
~
The individual who prematurely removed the " Red Hold Tags" has been counselled as to where he violated procedural requirements and instructed on the need to follow approved procedures.
In ordar to address future generic procedural compliance, H. P. Foley has conducted training classes on inspection criteria and procedures for Quality Control inspectors; this includes Revision 6 of QCP-3. Additionally, H. P. Foley has increased the
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u-Page 5 of 5 rumber of Quality Control inspectors, thereby improving the ratio of inspectors to workers from 1 in 25 in January to 1 in 10 currently.
'Ibe H. P. Foley hiring policy has also been adjusted to provide a greater level of experience for the Quality Control inspectors than previously obtained. 'Ihis policy has increased the average level of experience for each individual from 21 months in January to 86 months in April. 'Ibe current average level of experience is 50 months. Rtrthermore, the time available for inspection has been increased by providing the inspector more support in the
=1ministrative work activities. Finally, H. P. Foley Quality Control /Qaality Assurance organization has been further strengthened to provide the necessary leadership to assure conformance with approved procedures.
H. P. Foley Procedure QCP-3 was revised on May 20,1983 (Rev. 6) to allow removal of " Red Hold Tags" after inspection and acceptance of repairs by the Quality Control inspectors and prior to final closure of a Nonconformance Report. Compliance with the revised procedure (QCP-3 Rev. 6) shall be audited by the H. P. Foley Quality Assurance Department and surveillance performed by the PGandE Quality Control Department.
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