ML20043A338

Responds to NRC 900409 Ltr Re Violations Noted in Insp Repts 50-317/90-01 & 50-318/90-01.Corrective Actions:Detailed & Specific Directions for Radiography Will Be Incorporated in Radiography Procedures within NDE Program

ML20043A338
Person / Time
Site:	Calvert Cliffs
Issue date:	05/15/1990
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9005210217
Download: ML20043A338 (7)

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. BALTIMORE OAS AND

ELECTRIC CHARLES CENTER e P.O. BOX 1475 o BALTIMORE, MARYLAND 21203 1475 1 l

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May 15,1990 i

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant ,

Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 . _

Combined Insnection Renort Nos. 50-317/90-01: 50-318/90-01 3 ,

REFERENCES:

(a) Letteifrom Mr. M. W. Hodges (NRC) to .Mr. G. C. ' Creel (BG&E),

i dated April.9.1990, same subject!  !

Gentlemen:

• Reference (a) forwarded Nuclear ; Regulatory Commission (NRC) Region I Combined Inspection Report 50-317/90-01; 50-318/90-01. Appendix A to ' Reference (a) is a Notice of Violation regarding deficiencies related to . non-destructive examination and-inservice inspection activities ' at; . Calvert Cliffs. Enclosure (1) provides - our response to the Notice of Violation. '

Should you have ~ any further questions regarding this matter, we will be pleased to discuss them with you. ,

Very truly yours, e

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Document C= trol Desk  :

May 15,1990 ,

Page 2 cc: D. A. Brune Esquire J. E. Silberg, Esquire R. A.Capra,NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC L. E. Nicholson, NRC  !

R. McLean, DNR i

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I ENCLOSURE f1)

REPLY TO A NOTICE OF VIOLATION INSPECTION _ REPORT _50-317/90-Ol* 50-31g/90-01 VIOLATION A Part 1:

1. DESCRIPTION AND CAUSE OF THE EVENT The first item contained in Violation A, of Nuclear Regulatory Commission (NRC)

Inspection Report 50-317/90-01; $0-318/90-01, indicates that welds determined to be unacceptable by radiography, were not documented in a Non-Conformance Report (NCR)as required by Calvert Cliffs Quality Assurance Procedure (QAP) 26.

Examples included welds performed on the Auxiliary Feedwater System. in the Fall of 1982.

Baltimore Oas and Electric (BG&E) does not accept this violation. As stated in the Inspection Report, Calvert Cliffs Quality Assurance Procedure (QAP) 26, '

Revision 41, Attachment B, lists deficient welding, under the category of Deficient Workmanship, as a Condition Adverse to Quality. An NCR can be issued for a Condition Adverse to Quality, however. Section 7.1 of QAP 26 states, "An NCR is not required if the conultion is reported through the mechanism of another Corrective Action . System that provides tracking and follow-up through closure; i.e., MR, LER, audits, etc."

The inspection Report states we were in non-compliance with QAP 26 because the Non-Destructive Examination (NDE) Program did not document welding defects through an NCR. Instead, an NDE report was generated, as part of the welding Maintenance Request (MR)/ Maintenince Order (MO) Package, to document and track corrective actions. We believe this was consistent with the allowed methods of documenting Conditions Adverse to Quality, in QAP 26.

In reviewing the pcocess for documenting NDE corrective actions, it was noted that although the NDE procedures ensured tracking and closcout of deficient welds before closing out an MR, other aspects such as documentation of repair deficiencies not corrected after the final NDE process, assessment of preventive actions, and trending required improvement. Revisions to the NDE procedures to.

correct these deficiencies will be completed by July 27, 1990.

QAP 26 is also being revised to clarify the interface between NCRs and other corrective action process.

Part 2:

1. DESCRIPTION AND CAUSE OF THE EVENT The second item conta'med in Violation A, Appendix A, of the inspection Report i describes two examples of poor radiographic work practices as a result of failing  ;

to follow procedures. Specifically, thirteen weld radiographs were accepted with  ;

density readings outside the allowable range and read points were not marked on '

welds that were not part of the Inservice Inspection Program. These practices, I affecting the quality of work, resulted in violations of code requirements, l

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ENCLOSURE fI)  !

REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-317/90-Ol* 50-31g/90-01 '

II. CORRECTIVE STEPS TAKEN AND RESUL'I1_. ACHIEVED  ;

The review of radiographic film requires the use of. numerous Codes and Standards I to establish the acceptance or rejection of a radiograph. To ensure complete and I accurate reviews, new directions regarding film interpretations were issued to all certified radiographers at _ Calvert Cliffs, via a controlled memo on April '13, 1990. As of April 13, 1990, a second review of all Calvert Cliffs radiographs .

has been required to ensure applicable Codes and Standards are used.

The individual performing the second party review must be a Baltimore Gas and Electric (BG&E) certified Level 11 or 111 radiographer, if no discrepancies in the initici interpretation are- found, and no problems with the film quality - are encountered, the second party reviewer will Initial the data sheet, indicating his acceptance. Discrepancies shall be resolved by the NDE Unit Supervisor, i

111. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS t

in addition to the second party review, more detailed and specific directions for

. radiography will be incorporated into the radiography procedures within our NDE program. These changes will be made by August 31, 1990.

IV. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED ,

Full compliance will be achieved by August 31, 1990, after the radiography procedures are changed, i t

VIOLATION B I. DESCRIPTION AND CAUSE OF THE EVENT Violation B, Appendix A, of the inspection Report indicates that BG&E's NDE Control Procedure 5.020 does not conform to the requieements of ANSI N45.2.6.

The ANSI standard is invoked by Subarticle IWA-2300 of ASME Section XI,1983 Edition through Summer _1983 Addenda. Specifically, these sections of the Code recommended the necessary qualifications for non-destructive examination ,

personnel that are certified _ to perform visual inspections (Type VT2, VT3, and VT4). The standard recommends a Level 11 Inspector acquire 3 years of experience before being certified whereas BG&E only requires 3 months.

Section 3.5 of ANSI N45.2.6, the standard referenced by the ASME code for qualification of inspection, examination and testirig personnel for nuclear power plants, is titled ' Education and Experience-Recommendations".

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. ENCLOSURE i1)

REPLY TO A NOTICE OF VIOLATION INSPEC110N REPORT 50-317/90-01: 50-318/90-01 The standard recommends a Level 11 inspector acquire 3 years of experience before being certified. The standard also recognires equivalent methods for demonstrating competency may be substituted for experience. Section 3.5 of the standard states, "These education and experience recommendations should be treated to recognize that other factors may provide reasonable assurance that a person can cornpetently perform a particular task. Other factors which may demonstrate capability in a given job are previous performance or satisfactory completion of capability testing "

Interpretation of this section has been provided in two ' ASME Boiler and Pressure Vessel Code Cases, N-448 and N-449. These Code Cases have been determined by the NRC to be suitable for use and are listed in NRC Regulatory Guide 1.147. Both Cases provide alternatives to IWA-2300 Sub-paragraph (c). Sub-paragraph (c) is where the ASME Code states personnel should be qualified in accordance with ANEl N45.2.6. The alternatives to Sub-paragraph (c) are the provisions provided in Sub-paragraphs (a) and (b) of IWA-2300,- i Sections (a) and (b) of IWA-2300 reference guidelines set forth in The American Society for Nondestructive Testing's (ASNT) procedure SNT-TC-I A,1980 Edition.

According to Code Cases N-448, and -449, providing a training program that is  ;

consistent with the' guidelines of SNT-TC-1 A to qualify examination personnel, is  ;

an acceptable alternative to ANSI N45.2.6.

CONCLUSION We believe the NDE Program at BG&E complies with the wording and intent of the ASME code. Our training program, which includes general and specific written examinations, as well as practical examinations, is consistent with the guidelines in SNT-TC-I A. We therefore believe we are in compliance with Title 10, Paragraph 50.55a of the Code of Federal Regulations.

VIOLATION C  ;

1. DESCRIPflON AND CAUSE OF THE EVENT .

i Violation C, Appendix A, of the inspection Report states that BO&E practices for :

the identification of weld ' center lines does not conform with the ASME Section XI,1983 Edition through Summer 1983 Addenda, requirements of IWA-2600 and Appendix 111, Supplement 2. Specifically, welds were identified during the-inspection that did not have _ center line reference markings.

ASME Section XI states, in IWA-2610,'that "A reference system shall' be established for all welds subject to surface or volumetric examination. Each 4 such wcld and area shall be located and identified by a system of reference points. The system shall permit identification of each weld, location of each .

weld center line, and designation of regular intervals. along the length of the i weld."

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. ENCLOSURE (1) ,

f REPLY TO A NOTICE OF VIOLATION i INSPECTION REPORT 50-317/90-Ol* $0-31g/90-01 The ultrasonic examination procedures at Calvert Cliffs used a system which permits the identification of weld center lines through the use of weld profiles and indication mapping. The procedures did not require the permanent marking of centerlines, b

II. CORRECTIVE STEPS TAKEN AND REEUL*fE ACHIEVED  !

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Our Inservice Inspection (ISI) Program will be improved by the use of permanent marking. On April 24, 1990, a memo was issued to all NDE examiners to require  ;

permanent weld zero and center line identification prior to any ASME XI surface  !

or volumetric . examination of piping welds. l l r III. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTilER ,

. YlOLATIONS ,

A procedure for identifying weld center lines will be issued which will address .

permanently marking the zero reference and the weld center line. This procedure .

will be in place by July 27, 1990.

IV. DATE WilEN FULL COMPLIANCE WILL BE ACHIEVED  ;

Full compliance was achieved on April 24, 1990, when the merrio requiring permanent markings was issued to all examiners. Additional guidance will be provided in ,

the procedure to be issued by July 27, 1990. j EXTENSION The original due date for this response was May 9,1990. A one-week extension was granted by Region I on May 8,1990. The extension was requested to allow sufficient time to resolve comments received on the first internal draft.

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