ML20044G009

Responds to NRC Re Violations Noted in Insp Rept 50-334/93-02.Corrective Action:Section of River Water Piping Containing Repaired Areas Replaced During Ninth Refueling Outage

ML20044G009
Person / Time
Site:	Beaver Valley
Issue date:	05/21/1993
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9306010314
Download: ML20044G009 (3)

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Q DSaver ' alley Power Station Shippingport, PA 15077-0004 JOHN D. SIEBER (412) 393-5255 '

Senior Vice President and Faz (412) 643-8069 t

Chief Nuclear Omcer Nuclear Power D, vision 3 gggy l

1 5

U.

S.

Nuclear Regulatory Commission Attn:

Document Control Desk Washington, DC 20555

Subject:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 50-334/93 Notice.of Violation

-[

In response to NRC correspondence dated April 14, 1993, and.in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with.the subject inspection report.

As requested, this reply addresses the actions taken to restore the i'

river water piping to its original construction margins and to.

preclude similar deviations in the future.

If there are any questions concerning this response, please contact Mr. N. R. Tonet at (412) 393-5210.

t Sincerely,

/

. D.

Sieber Attachment i

cc: Mr.

L. W.

Rossbach, Sr. Resident Inspector Mr.

T. T. Martin, NRC Region I Administrator Mr. J. P.

Durr, Chief, Engineering Branch Division of Reactor Safety, Region I Mr.

G.

E.

Edison, Project Manager Mr. M.

L. Bowling (VEPCO) 11 u) e 1

1 ELECTRK i

UDUN d 9306010314 930521

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PDR ADDCK 05000334 G

PDR

DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit No. 1 Pepiv to Notice of Violation Combined Inspection Report 50-334/93-02 and 50-412/93-02 Letter dated April 14, 1993 VIOLATION (Severity Level IV; Supplement I)

Description of Violation (50-334/93-02-01) 10 CFR

50. 55a (g) (4 ) requires that components which are classified as ASME Code Class 3

(or an equivalent system as determined by the original construction

code, e.g.

ANSI B31.1 for the River Water System at Unit 1) shall meet the requirements of Section XI of the ASME Boiler and Pressure Vessel Code.

Article IWA-4000 of Section XI of the ASME Code describes the Code repair procedures.

IWA 4340 requires the affected surfaces to be examined by magnetic particle or liquid penetrant inspection'to ensure that the indication has been reduced to an acceptable limit, or when repair welding is to be performed, the original defect shall be removed.

Contrary to the above during 1986 and 1989, the licensee repaired three areas in the River Water System because of pinhole leaks and wall thinning without assuring that al' flaws and surface degradation were removed prior to executing the repairs.

Discussion of the violation The violation cited paragraph IWA 4340 u; ASME Section XI.

This paragraph is in the 1986 Edition of Section XI but does not exist in the 1983 Edition of ASME Section XI, which is the code edition that Beaver Valley Unit 1

is required to meet in accordance with 10 CFR l

50. 55a (g) (4) (ii).

However, paragraph IWD-4 200 (b) (1) of the'1983 Edition of Section XI contains requirements similar to those cited'in the violation.

Beason for the violation At the time of the repairs, the actions taken'were considered to meet code requirements.

These actions included notification-of the Authorized Nuclear Inservice Inspector, grinding of the pinhole.

areas, magnetic particle examination of the ground areas, repair welding of the affected areas utilizing qualified welders, procedures and materials, and the performance of post-repair pressure tests.

I

i c R8 ply.to Notice of Violation Page 2 Corrective Action Taken The section of river water piping containing the repaired areas was replaced during the ninth refueling outage.

The replacement section l

was fabricated to the original design specifications and therefore

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restored that section of piping to its original construction margins.

Actions Taken to Prevent Recurrence The ASME Section XI Repair / Replacement Program (NPDAP 8.5) will be l

revised to provide guidance on the use of non-code repairs on ASME Code Class 1,

2 and 3 piping.

This revision will require that any proposed use of a temporary non-code repair be concurred with by the Nuclear Engineering Department and that the guidance provided by NRC Generic Letter 90-05 be met.

Date When Full Compliance Will Be Achieved I

The station is in full compliance at this time.

The revision to NPDAP 8.5 will be issued by August 31, 1993.

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