ML20132G216
| ML20132G216 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/19/1996 |
| From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Cross J DUQUESNE LIGHT CO. |
| References | |
| NUDOCS 9612260207 | |
| Download: ML20132G216 (3) | |
See also: IR 05000334/1996005
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December 19,1996
Mr. J. E. Cross
President
Generation Group
Duquesne Light Company
Post Office Box 4
Shippingport, Pennsylvania 15077
SUBJECT:
INTEGRATED INSPECTION REPORT 50-334/96-05 AND 50-412/96-05
Dear Mr. Cross:
This letter refers to your August 23,1996 correspondence, in response to our July 24,
1996 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
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Sincerely,
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Original Signed By:
Peter W. Eselgroth, Chief
Projects Branch 7
Division of Reactor Projects
Docket Nos. 50-334; 50-412
cc w/o cv of Licensee's Response:
Sushil C. Jain, Vice President, Nuclear Services
T. P. Noonan, Vice President, Nuclear Operations
L. R. Freeland, Manager, Nuclear Engineering Department
B. Tuite, General Manager, Nuclear Operations Unit
K. L. Ostrowski, Manager, Quality Services Unit
R. Brosi, Manager, Nuclear Safety Department
cc w/cv of Licensee's Resoonse
M. Clancy, Mayor
Commonwealth of Pennsylvania
State of Ohio
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9612260207 961219
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Mr. J. E. Cross
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Distribution w/cv of Licensee's Response:
Region i Docket Room (with concurrences)
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PUBLIC
Nuclear Safety Information Center (NSIC)
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D. Screnci, PAO
NRC Resident inspector
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P. Eselgroth, DRP
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D. Haverkamp, DRP
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B. Welling, DRP
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C. O'Daniell, DRP
Distribution w/enci (VIA E-MAIL):
J. Stolz, NRR
D. Brinkman, NRR
W. Dean, OEDO
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R. Correia, NRR
R. Frahm, Jr., NRR
inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: G:\\ BRANCH 7\\REPLYLTR\\BV9605.RPL
To receive e copy of this document, indicate in the box:
"C" = Copy without attachment / enclosure
- E' = Copy with attachment / enclosure
- N* = No copy
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OFFICE
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NAME
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DATE
12/11/96
12/tf /96
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12/ /96
OFFICIAL RECORD COPY
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Mr. J. E. Cross
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Distribution w/cv of Licensee's Response:
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Region i Docket Room (with concurrences)
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PUBLIC
Nuclear Safety Information Center (NSIC)
D. Screnci, PAO
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NRC Resident inspector
P. Eselgroth, DRP
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D. Haverkamp, DRP
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B. Welling, DRP
C. O'Daniell, DRP
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Distribution w/enci (VIA E-MAIL):
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J. Stolz, NRR
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D. Brinkman, NRR
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W. Dean, OEDO
R. Correia, NRR
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R. Frahm, Jr., NRR
Inspection Program Branch, NRR (IPAS)
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Duquesne Lkyt Company ggy m rst ia
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SNppingport. PA 15077-0004
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THOMAS P. NOONAN
(412) 393 7622
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August 23, 1996
Fax (412) 393-4905
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U. S. Nuclear Regulatory Commission
Attention: Document Control Desk
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Washington, DC 20555-0001
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Subject:
Beaver Valley Power Station, Unit No.1
Docket No. 50 334, License No. DPR-66
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Integrated Inspection Report 50-334/96-05 and 50-412/96-05
Reply to Notice of Violation
,
In response to NRC correspondence dated July 24,1996, and in accordance with
10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the
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subject inspection report.
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If there are any questions concerning this response, please contact Mr. Roy K.
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Brosi at (412) 393-5210.
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Sincerely,
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Tnomas P. No an
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Mr. L. W. Rossbach, Sr. Resident Inspector
Mr. H. J. Miller, NRC Region I Administrator
Mr. D. S. Brinkman, Sr. Project Manager
\\ Mr. P. W. Eselgroth, Chief, Projects Branch No. 7
Division of Reactor Projects, Region I
DEllVERING
QUALliY
ENERGY
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DUQUESNE LIGHT COMPANY
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Nuclear Power Division
Beaver Valley Power Station Unit No. I
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Realv to Notice of Violation
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Integrated Inspection Report 50-334/%-05 and 50-412/%-05
Letter dated July 24,1996
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VIOLATION (Severity Level IV, Supplement VIII)
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Description of Violation (54334/96-05-02)
10CFR50.55a(g)(4) requires, in part, that components classified as ASME Class 1,2 and
3, meet the requirements of Section XI of the ASME Code.
The 1983 Edition, Summer 83 Addenda, of Section XI of the ASME Code, Mandatory
Appendix III, and DLC UT Procedure UT-303, Paragraph 3.2.2.3, requires piping welds
to be examined with the sound beam parallel and transverse to the weld scam.
Calibrations are to be performed using the reflector perpendicular to the sound beam.
The ASME Code,Section XI, Mandatory Appendix III, Article III 3230, and DLC UT
Procedure UT-303, Paragraph 3.2.2.3, require the use of side drilled holes to construct
the distance amplitude correction (DAC) curve and the inside diameter (ID) notch to
establish reference sensitivity.
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Contrary to the above, during the 1996 refueling outage, the licensee failed to perform a
calibration for ultrasonic examinations using a reflector perpendicular to the sound beam
for examinations with the sound beam traverse to the weld seam (circumferential
examinations) on six ASME Class 2 pipe weld examinations (calibration sheets C-%-27,
C-%34, C-%40, C-%47, C-%51 and C-%54).
Also, for two calibrations (calibration sheets C-%57 and C-%46) side drilled holes
were not used to construct the DAC curve.
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Beaver Valley Power Station, Unit No. I
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Reply to Nctice of Violation
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Reason For Violation:
A.
The six reports identified above, where circumferential calibrations were not
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documented were confined to the same team of two contracted NDE technicians.
Based on further investigation of this problem, it appears that the circumferential
calibrations had been performed, but documentation was not maintained nor
included on the calibration reports. The root cause evaluation concluded that this
oversight was due to a combination of procedure complexity, ineffective
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contractor training and failure to identify the deficiency during subsequent data
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review.
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B.
The two calibrations performed without using the side drilled holes were for
examination of dissimilar metal nozzle to safe-end welds.
The root cause
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evaluation concluded the calibration technique specified by the Duquesne Light
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Company (DLC) UT Level III and applied by the contracted NDE technicians was
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not previously qualified.
This deficiency was also not identified dunng
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subsequent data review.
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Corrective Actions Taken And Results Achieved:
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A.
Station Problem Reports 1-96-488 and 1-96-489 were generated and formal root
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cause evaluations were completed on the calibration problems identified in the
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violation.
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B.
The effects on the ultrasonic (UT) examinations that were performed without a
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proper circumferential calibration were evaluated. The eye.luation determined
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that, even without the circumferential calibration being performed, flaws oriented
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transverse to the weld would still have been detected; however, the flaw location
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would not have been accurate.
Since the circumferential examinations were
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completed in these instances with no recorded indications, the examinations
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performed are considered to be technically valid.
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C.
A review of the calibration reports for the ultrasonic examinations completed for
the Unit 1 Eleventh Refueling Outage was performed and no additional
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circumferential calibration deficiencies were identified.
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Beaver Valley Pcwcr Station, Unit No.1
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Reply to Notice of Vi:lation
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Page 3
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D.
An NDE demonstration and engineering evaluation of the calibration sensitivity
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of the ID notch versus the 1/2T side-drilled hole was conducted. The results
demonstrated the ID notch calibration for the refracted longitudinal technique
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used, produced a greater examination sensitivity than that of the code-specified
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side-drilled hole calibration technique. The greater examination sensitivity using
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the ID notch was subsequently demonstrated to the satisfaction of the Authorized
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Nuclear Inservice Inspector (ANII) as an alternative examination method as
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permitted by paragraph IWA-2240 of ASME Section XI.
Therefore, the
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examinations performed are considered technically valid.
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Actions Taken to Prevent Recurrence:
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As a result of the root cause evaluation conclusions, the following corrective actions
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have been taken:
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A.
The DLC UT Level III was counseled as to the expectations and requirements
when reviewing NDE calibration and examination records.
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B.
The ultrasonic calibration report form was revised to more clearly define the
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calibration orientation (axial vs. circumferential).
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C.
Quality Services Procedure 2.5 was revised to provide procedmal controls for the
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site specific training of contracted NDE personnel on DLC NDE procedures.
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D.
DLC Ultrasonic Procedure UT-303 was revised to clarify procedural requirements
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and allow for the use ofID notch calibration.
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Date When Full Comollance Will Be Achieved:
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As described above, Duquesne Light Company is in full compliance at this time.
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