ML20045B574
| ML20045B574 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/09/1993 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306180086 | |
| Download: ML20045B574 (5) | |
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i Tertnessee Vaaey Authonty. Post Once Bow 2T/1 Soddy-De~sy, Tennessee 37379-2000 Robert A. Fenech v<e Pres 4 dent semyah Nums Piant June 9, 1993 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR FIANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/93 REPLY TO NOTICE OF VIOLATION (NOV) 50-327, 328/93-12-01 Enclosed is TVA's reply to Caudie A. Julian's letter to Mark O. Medford dated May 18, 1993, which transmitted the subject NOV. The violation involves a failure to follow specific procedure requirements in performing a liquid penetrant examination.
If you have any questions concerning this submittal, please telephone-J. W. Proffitt at (615) 843-6651.
Sincerely.
h' Robert A. Fenech Enclosure cc: See page 2
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Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike-f Rockville, Maryland 20852-2739 i
NRC Resident Inspector f
Sequoyah Nuclear Plant 2600 Igou Ferry Road Soody-Daisy, Tennessee 37379-3624 r
Regional Administrator U.S. Nuclear Regulatory Commission Region II l
101 Marietta Street, NW, Suite 2900 l
Atlanta, Georgia 30323-2711 i
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ENCLOSURE RESPONSE TO NRC INSPECTION REPORT NOS.-50-327/93-12 AND 50-328/93-12 I
CAUDLE A. JULIAN'S LETTER TO MARK 0. MEDFORD DATED MAY 18, 1993 Violation 50-327. 328/93-12-01 "10 CFR 50.55a(g) requires, in part, that, 'throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components.... must meet the requirements.... set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code...........'
ASME Section XI Paragraph IWA-2222, requires that, ' liquid' penetrant examination shall be conducted in accordance with Article 6 of ASME Section V'.
Paragraph T-650(c) of Article 6 of Section V of the ASME Boiler and Pressure Vessel Code, the applicable Code, requires, in part, that, ' broad areas of pigmentation that could mask indications of discontinuities are unacceptable, and such areas shall be cleaned and reexamined'.
" Paragraph 5.3 of licensee procedure N-PT-9, Revision 6, the applicable liquid penetrant examination procedure, requires, in part, that,
.......... no surface irregularities shall exist that could mask indications caused by unacceptable discontinuities'.
" Contrary to the above, on April 6, 1993, liquid penetrant testing was not accomplished in accordance with the above code and procedure requirements, in that, two 10" diameter Safety Injection System pipe welds (SIS-295 and SIS-296) were liquid penetrant inspected and accepted by the nondestructive testing examiner without removal of surface irregularities at the weld edges.
These surface irregularities resulted in broad pigmentation (bleedout of penetrant) at the weld edges.
Subsequent weld preparation and re-penetrant testing revealed that the surface irregularities and bleedout had masked a code rejectable (5/8" long) linear indication at the edge of weld SIS-295.
"This is a Severity Level IV *lolation (Supplement I)."
_ Reason for the Violation The procedure for liquid penetrant examination of American Society of Mechanical Engineers (ASME) and American Nuclear Standards Institute code components and welds requires the evaluation of examination results to be performed from 7 to 30 minutes after initial developer application. The reason for the violation was that the examiners did not-base their call exclusively on the condition of the developer during this timeframe.
ASME Code Section V, Article 6, emphasizes the importance of watching the initial reaction of the developer to monitor indications that tend to bleed out profusely during the performance of liquid. penetrant examinations (PT). The Level II examiners relied on the initial reaction of the developer as it was applied and monitored development of the weld surface in accepting the PT.
The following factors contributed to the inappropriate evaluation of the examination:
(1) the toe area of the weld was not adequately prepared and cleaned so that an effective examination could be performed, and (2) the craftsmen were given limited guidance on preparing weld surfaces for PT examinations.
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Corrective Steps That Have Been Takin_and the Resulls A hinyrd A problem evaluation report was initiated to document that Safety i
Injection System (SIS) Weldments SIS-295 and SIS-296 were not properly j
prepared for the PT.
All PT work was stopped. The onshift personnel certified to' perform' pts were given training concerning proper cleanliness and surface preparations.
In addition, personnel performance issues at Sequoyah Nuclear Plant (SQN) were discussed.
These training sessions were also held with the oncoming shift crews.
f Both examiners involved in the PT were immediately removed from the field and counseled on following procedures and their responsibilities as Inspectors. Both examiners were reevaluated by a TVA Level III l
nondestructive examination (NDE) specialist using a capability demonstration (CD) practical test in the PT discipline. Both examiners successfully completed the CD test.
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Briefings with all Level II examiners were held to discuss their responsibility to reject inadequately cleaned or prepared weld surfaces.
i Meetings with all SQN and Inspection Services Organization (ISO) NDE/QC t
supervisors, leads, and inspectors were held to discuss this incident,
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inspector responsibilities, importance of ASME, individual accountability, sensitivity, and expectations.
l The two ISO specialists responsible for preparing the welds on backshift I
were counseled and instructed on their responsibilities for ensuring and verifying weld preparation.
Site-specific training for.NDE contract personnel was revised to incorporate a discussion of:
(1) expectations and responsibilities for performing examinations with emphasis on not accepting weld surfaces.that have been inadequately cleaned or prepared. (2) discussion of current plant status and personnel performance issues, and (3) discussion of the procedures for each type of NDE examination that the contracting individual is certified to perform.
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A reexamination of welds performed by three other. contractors with similar weld configurations was performed to ensure adequacy of surface i
preparation and resulting evaluation. No problems with the evaluation
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were identified. Nine additional welds that were examined during previous outages were reexamined. Five welds were selected as part of the additional sample required because of the indication that was identified in Weld SIS-296, and the other four were selected to evaluate the extent of the condition. No indications were identified in these welds.
Weld SIS-296 was repaired to remove the linear indication. The 5/8-inch linear indication was cosmetic in nature and did not affect the structural integrity of the system.
A procedure change was initiated to clarify the evaluation criteria in the governing procedure.
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The Corrective Steps That Will be Taken to Avoid Further Violatien No additional actions are necessary.
Date_Mhen Iu11 Ccepliance Will be Achieved TVA is in full compliance.
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