ML20079G171
| ML20079G171 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 09/30/1991 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9110090005 | |
| Download: ML20079G171 (4) | |
Text
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,r(ut'4 h $il Bf it w a f%ttent 6.+at Cu,m aTH4'4 September 30, 1991 U.
S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC
'40555 c
Subject:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, Licenso No. DPR-66 Inspection Report 50-334/91-11 In response to NRC correspondence dated August 26, 1991 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the referenced inspection report.
If there are any questions concerning this response, please contact Mr. M. A.
Perqar at (412) 393-4968.
Sincerely, I'
1 4
D.
Sieber Vice President Nuclear Group Attachment cc:
Mr. J.
Beall, 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.
A. W. DeAga no, Project Manager Mr. M.
L. Bowling (VEPCO)
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DUQUESNE LIGHT COMPANY Nuclear Group f
Beaver Valley Power Station Unit No. 1 Reply to a Nqtice of Viola _t_lgn NRC Inspection S0-334/91-11 Letter dated August 26, 1991 VIOLATIQH (50-334/91-11-01)
Description of ViolatiQn Beaver Valley Power
- Station, Unit No.
1, Technical Specification 4.0.5, states that components classified as ASME Code Class 1, 2,
and 3
shall meet the examination requirements set forth in Section XI of the ASME Boiler end Pressure Vessel Code and Addenda applied to the particular component.
Accordingly, Duquesne Licht Company Inservice Inspection Program for Unit 1, invoked the requirements of the AGME Code Section XI, 1983 Edition Summer 1983 Addenda.
Paragraph IWA-3100(a) of Section XI requires evaluation be made of indications detected during inservice inspection.
Contrary to the above requit.inents, Duquesne Light Company did not
- identify, record and evaluate a
.250" linear indication on weld P12-H1-S-OS.
This indication was found by the NRC utilizing the same liquid ponetrant examination method performed by the alconsee.
ReploIL for Violation:
In the performance of a liquid penetrant examination a nondestructive examiner failed to
- identify, record and evaluate a.250" linear indication.
The appearance, location and characteristics of the indication and adjacent surface condition may have contributed to the failure to identify and record the indication.
The weld had been ground nearly flush and blended into the adjacent pipe surface.
Additionally, the entire examination area had been further conditioned with an abrasive
" flapper wheel".
The surface was adequate for liquid penetrant examination.
The indication was located within a shallow grinding depression at the toe of the weld.
The indication was less than 1/32" in width and exactly 1/4" in length.
Observation of the indication during the penetrant developing time indicated no significant growth in length, width or color intensity as development time increeced.
This would indicate a
very tight flaw with no significant depth.
4
Reply to Notice of Violation Page 2 CarrepMve Stepf_DAqplDd Remilinlghigy_qq:
Upon notification of the apparent violation, Duquesne Light Company (DLC) took the following immediate corrective actions:
The indication area was re-examined jointly by the USNRC NDE Technician and the DLC PT Level III.
This examination recorded the presence of the.250" linear indication, which was evaluated on Evaluation Report E-91-46 and found to exceed the acceptable flaw dimensions of Paragraph IWB-3514-2.
Maintenance Work Request (MWR) 912396 was issued to provide work instructions for removal and re-examination of the indication.
Following removal of the indicatica, the area was te-examined and no indications were recorded.
Ultrasonic thickneos measuremc7ts made prior to and following indicetion removal indicated tnat only.002" of material was removed to eliminate the indication.
Both examiners that performed the original examination were given practical proficiency examinations by the DLC PT Level III.
Both examiners performed well and no technique or procedural violations were observed.
Engineering Memorandum (LM) 101202 evaluated system integrity and operability during the time the indication remained undetected.
There were no safety or operability concerno due to the presence of the flaw indication.
An overview (re-inspection) of welds previoucly examined by the two personnel in question was performed jointly by NDE vendor personnel, the DLC Level III, and the DLC Quality Assurance Level III.
Forty-two (42) welds were identified as possible candidates for re-examination.
Thirty-one (31) were on the NRC lint for their possible examinations.
of the remaining eleven (11), six (6) were selected for re-examination.
These examinations are documented on QCR
- 384, and revealed no examination inconsistencies or unsatisfactory conditions.
Annual vision examinations for the two NDE personnel were conducted in August, 1991 and were satisfactory.
All of the investigative and corrective actions reinforce that the failure to record the indication was an isolated instance.
I' Reply to Notice of Violation Page 3 Corr e c ti v e S t e o s__lo_AyojJ1.Ju r t h e r V i qla t i o n s :
The following items were reviewed with all personnel performing NDE activities:
1.
Details and probablo criseu of the violation.
2.
The importance of recognizing the examination surface condition and its potential impact on examination results.
3.
The importance of attention to detail in identifying aad reporting deficient conditions.
Vendor NDE personnel will also be informed of these items during their indoctrination training and proficiency reviews.
Date When_DdlJComDliaDgg will be Achieved:
Full compliance was achieved on June 13, 1991 upon completion of all corrective actions associated with the violation.
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