ML20054L208
| ML20054L208 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/18/1982 |
| From: | Woolever E DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20054L207 | List: |
| References | |
| NUDOCS 8207070264 | |
| Download: ML20054L208 (4) | |
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(412)787 - 5141 (412)923 - 1960 Telecopy (412) 787-2629 Nuclear Construction Omslon nobinson Piaza. Buiiding 2, suite 21o June 18,1982 Pittsburgh, PA 15205 United State Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Richard W. Starostecki Division of Project and Resident Programs
SUBJECT:
Beaver Valley Power Station Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/82-04 Gentlemen:
This is in response to the items of infraction cited in Inspection Report No. 50-412/82-04 and listed in Appendix A (Notice of Violation) at-tached to your letter to Mr. E. J. Woolever dated May 13, 1982.
NRC VIOLATION (82-04-01)
Section 17 of the BVPS-2 PSAR states that Duquesne Light Company has established a quality assurance program for Beaver Valley Power Station that establishes quality criteria for the contractors. The Duquesne Light Quality Assurance Program thru QA Procedure DC-2 and 10CFR50, Appendix B, Criterion II require the contractor to establish or work under an established Quality Assurance Program. They further require the program to be complied with throughout the plant life.
Contrary to the above, as of April 20, 1982, Schneider Power Corpora-tion failed to comply with Paragraph 8.4.1.1 for certification of weld procedure qualification test as required.
This is a Severity Level V Violation (Supplement II).
And from the " Details" section of the official report:
The inspector reviewed Section 1 - Organization - and Section 8 - Welding
- and the Beaver Valley Addendums to these sections cf the Schneider QA Manual.
Section 8.4.1.1 specifies that welding procedures shall be qualified in accordance with ASME Section III and IX, and shall be recorded on weld-ing procedure qualification test reports and certified by the Chief Weld Engineer. A sample inspection of the test reports indicated they were not always being certified to ASME III as required. For example, the procedure qualification test reports numbers 808762-707, 708, 709, and 710 are used for ASME,Section III work and are not certified as meeting the requirements of ASME III.
8207070264 820630 PDR ADOCK 05000412 C
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United States Nuclear Regulatory Commission page 2 o
This is contrary to the requirements of Schneider's Quality Assurance Manual and 10CFR50, Appendix B, Criterion II, " Quality Assurance Pro-gram," which states: "The applicant shall establish.
. a quality assurance program which complies with the requirements of this appendix.
This program.
. shall be carried out throughout plant life in accor-dance with those policies, procedures, or instructions."
This is a Severity Level V Violation (82-04-01).
RESPONSE
On receiving notification of this Infraction, an investigation was per-formed to establish the background of the activities related to Procedure Qualification Reports (PQR's). This investigation indicated that there has been an inconsistency in the approach to the contents of the PQR's during the period 1977 to 1982. During this period, the ASME Insta11er's QA Program relative to the review and approval of PQR's had been sub-jected to seven (7) revisions. All of these revisions, however, up until February 1982, can be classified as semantic changes. The intent remained the same--procedures being qualified in accordance with ASME Section III and Section IX.
These revisions covered the period mid-1977 to February 1982. During the period 1977 to 1979, the interpretation of the ASME Code by the ASME Installer was that ASME Section III should be included on the PQR in addition to the reference to ASME Section IX.
- However, during the period approximately 1979 up to February 1982, an interpre-tation of the Code was made by the Installer concluding that it was not necessary to include ASME Section III reference on the PQR. This inter-pretation was based on the following extract from Section IX of the ASME Code, which is quoted below:
"Section IX of the ASME Boiler and Pressure Vessel Code relates to the qualification of welders, welding operators, and brazers, and brazing operators, and the procedure which they employ in welding or brazing according to the ASME Code. Other Sections of the Code state the conditions under which Section IX require-ments are mandatory in whole or in part and give additional re-quirements. The reader is advised to take those provisions into consideration when using this Section."
This interpretation was applied to the effect that they only needed to take into consideration provisions of other sections of the Code. Thus, during this period, a possible inconsistency occurred regarding the need for the inclusion of "ASME Section III."
During an ASME survey of our Installer in February 1982, the Installer was required to amend his QA Manual with an emphasis on certification, as follows:
"8.4.1.1 Welding and welding repair procedures shall be pre-pared and approved by the corporate Welding Engineer.
They shall be qualified in accordance with ASME Code Section III and IX, and shall be recorded on Welding Procedure Qualification Test Report Figure 8-1 and certified by the Chief Weld Engineer."
United States Nuclear Regulatory Commission page 3 Because of the interpretation of the Code during the period 1979 to Febru'ary 1982, the two PQR's that were issued after February 1982 also did not include a reference to ASME Section III on the basis of the extract from the Code previcusly described.
On receipt of the Infraction, discussions were held with the ASME In-staller and the "N" Certificate Holder, and it was decided to accept the interpretation of the Resident NRC Inspector to the effect that PQR's should reference both Section IX and Section III of the Code when applicable.
Since the receipt of the Infraction, all PQR's af fected by ASME Section III have been amended where necessary by the Installer to include ASME Section III. All current PQR's will be available for use by July 1, 1982.
CORRECTIVE ACTION The investigation has revealed an inconsistency in the interpretation of the requirements of the Insta11er's QA Manual on this subject through the period 1977 through 1982. In order to prevent recurrence, our ASME Installer will issue an " impact" report on any future revisions to their QA Manual for review by the "N" Certificate Holder and ourselves.
It is our belief that this action will prevent interpretations occurring in isolation within the Insta11er's organization without the knowledge of the Project organization. We submit that Paragraph 8.4.1.1 is sub-ject to an interpretation problem when compared'with the extract of ASME Section IX, but we emphasize that the Welding Procedure Technique Sheet (WPS) is the document used by the crafts and inspection for the applicability of the PQR to the work involved. The contents of the PQR are reviewed for their applicability to the WPS and the section of the Code applicable to the weld. This review is not governed by the inclu-sion of the words "ASME Section III," but by the contents of the PQR.
Therefore, we do not consider that any adverse safety implication has occurred.
DUQUESNE LIGHT COMPANY By.
B' Jg W661ever Vice President SDH/wjs cc:
Mr. G. Walton, NRC Resident Inspector Ms. E. Doolittle, Prcject Manager Subscribed and sworn to before me this g day of 7&A/E / f f M.
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United States Nuclear Regulatory Commission page 4 COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF ALLEGHENY
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On this dayof.[FNE
,/ 9 [ d, before me, A 4 M A/ d.
NA ug 3 a Notary Public in and for said Common-1t wealth and County, personally appeared E. J. Woolever, who being duly sworn, deposed, and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal ou behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge, information and belief.
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A!AN B. BANAS. NOTARY PUPilC P0B'N50N TBe'.. AltfGHEhY COUNTY P/Y C0'e'.'IS$iCN EXPIFES APML 12.1936 Member. Pannsylvania Assacrahon of Notaries i.
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