ML20070A363
| ML20070A363 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/29/1982 |
| From: | Tucker H DUKE POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20070A333 | List: |
| References | |
| NUDOCS 8212090239 | |
| Download: ML20070A363 (4) | |
Text
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- ** **ssent (yo4) 3y34533 p3 n 'i n9 ((0\\/ 8 Oc%ber 29, 1982 Mr. James P. O'Reilly, Regional Administrator U. S. Nucicar Regulatory Commission Region 11 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Re: RII:PKV 50-413/82-21 50-414/82-19
Dear Mr. O'Reilly:
Please find at: ached a response to Violation Nos. 413/82-21-01, 413/82-21-02 and 413/82-21-04 as identified in the above referenced Inspection Report. The response to Violation No. 413/82-21-03, 414/82-19-01 has not been completed; a response to this Violation will be sent by January 15, 1982. Duke Power Company does not consider any information contained in this Inspection Report to be proprietary.
I declare under penalty of perjury, that the statements set forth herein are true and correct to the best of my knowledge.
Very truly yours, E
/ Le llal B. Tucker RWO/php Attachment ec:
Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station Mr. Robert Guild, Esq.
Attorney-at-Law 314 Pall Mall Columbia, South Carolina 29201 Palmetto Alliance 2135 Devine Street Columbia, South Carolina 29205 8212090239 821118 PDR ADOCK 05000413 G
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1 Duke Power Company Catawba Nuclear Station Violation:
10 CFR 50, Appendix B, Criterion V, as implemented by Topical Report Duke 1A, Section 17, paragraph 17.1.5 requires that activities affecting quality be accomplished in accordance with established procedures. Duke Power Company procedure NDE 10, General Radiography Procedure, requires elongated indications greater than % inch in length to be rejected for production welds in materials up to 3/4 inch in thickness.
Contrary to the above, an activity affecting quality was not accomplished in accordance with established procedures on July 30, 1981 in that licensee personnel accepted a inch long rejectable defect in Class B Weld No.1FW12-6 in material 3/8 inch thick.
Response
1.
Duke admits the violation as stated.
2.
The reason the violation occurred is that the indication was evaluated as being a base metal indication in a valve which was acceptable to base metal acceptance criteria for the NDE method used by the manufacturer. The indication was later confirmed as being in close proximity to the weld. We agree that base metal indications in close proximity to welds should be evaluated by weld metal acceptance criteria in order to ensure conservative interpretations.
3.
The corrective steps which have been taken are:
a.
The indication has been repaired.
b.
The manufacturer of the valve was notified on August 5, 1982, to verify that similar problems had not been reported by other customers. This iten was reported to the NRC as SD-413/82-17.
4.
Additional corrective action will be to establish methods to assure conservative interpretations of base metal indicatione in close proximity to welds.
5.
Full compliance will be schieved by November 1, 1982.
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DUKE POWER COMPANY CATAWBA NUCLEAR STATION VIOLATION:
10 CFR 50, Appendix B, Criterion V, as implemanted by Topical Report Duke 1-A, Section 17, paragraph 17.1.5, requires that drawings include appro-priate qualitative acceptance criteria.
Contrary to the above, drawings did not contain appropriate qualitative acceptance criteria on December 16, 1981 in that clearance dimensions were not included in Drawing No. ICS-A-20.9 for instrumentation expansion coils.
This resulted in installation of the expansion coil for instrument No.
lRNFS5460 within 1/32-inch of steel tubing. This violated the 1/2-inch clearance requirement later determined to be appropriate by the licensee.
RESPONSE
1.
Duke Power Company admits this violation.
2.
Previous experience with Design drawings ICS-A-20 (Installation Field Practices) and CN-1499-MI20 (Instrumentation Pipe and Tube Supports) has resulted in adequate installations, therefore, it appeared that further criteria was not required.
3.
As a result of Unresolved Item 413,414/81-28-02, Revision 5 to ICS-A-20.4 sheet 1 of 2 was made on March 1,1982 to specify a 1/2 inch clearance tolerance for all expansion loops on safety class instrumentation impulse lines. Also ICS-A-20.4 sheet 1 of 2 Revision 6 was made on 9-16-82 to further specify a 1/4" tolerance between adjacent tubing within an expansion loop. These tolerances are based on worst case thermal and seismic movements.
Subsequent to the addition of these criteria five additional loops were identified in violation of the criteria. These loops have all been reworked to meet the new criteria.
4.
The addition of the clearance criteria to ICS-A-20.4 will prevent recurrence of this problem.
5.
Full compliance nas been achieved as of this date, October 29, 1982.
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Violation:
10 CFR 50, Appendix B, Criterion XVII, as Laplemented by Topical Report Duke 1-A, Section 17, paragraph 17.1.17 requires that sufficient records be maintained to furnish evidence of activities affecting quality.
Contrary to the above, insufficient records were maintained for an activity affecting quality on May 17, 1982 in that the QC inspection record for HVAC hanger no. 1-H-VZ-5006 contained only printed inspector names rather than a unique inspector signature, initials, or identification stamp.
Response
1.
Duke admits the violation as stated.
2.
The cause of violation was a lost record with subsequent improper documentation. It is agreed that the original hanger inspea. tion report was lost by the HVAC contractor and the subsequent it spection of hanger 1-H-VZ-5006, as a result of a design change reques:
initiated by the original inspection, resulted in the inspection report containing printed names.
3.
Corrective action which has been taken:
A review of 108 hanger inspection records by Duke Power Vendor Quality Assurance revealed this to be an isolated incident. Vendor Deficiency Report X2001 was written against the HVAC contractor concerning the validity of this inspection report. The hanger was reinspected June 1, 1982 and a new inspection report was placed in the hanger file.
4.
Bahnson has reemphasized the importance of maintaining inspection l
reports to their personnel.
5.
Full compliance has been achieved.
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