ML20210H066
| ML20210H066 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/13/1986 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-6-022, 2NRC-6-22, 86-02, 86-2, NUDOCS 8604020687 | |
| Download: ML20210H066 (5) | |
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(412) 787-5141 8
Telecopy 1 R : n aza B di g 2 Suite 210 Pittsburgh, PA 15205 biarch 13, 1986 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Dr. Thomas E. Murley Administrator
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Non-ASME 8" - 90* Elbow Installed In ASME III Class 3 System Potential Significant Deficiency Report 86-02 Gentl emen:
This Potentially Reportable Significant Deficiency Report relat-ing to Non-ASME ~ d" - 90' elbow installed in ASME III Class III System is being submitted pursuant to the requirements of 10CFR60.55(e).
OLC has concluded that this itecn is considered.to be non-reportable per the criteria identified in 10CFR50.55(e). This is a final report..It is-anticipated that no additional reports will be submitted.
DUQUESNE LIGHT COMPANY By ~ J.W. Warey r-Vice President S DH/ sip Attachment cc:
Mr. P. Tam, Project Manager (w/a)
Mr. J. M. Taylor, Director (3) (w/a)
Mr. G. Walton, NRC Resident Inspector (w/a)
INP0 Records Center (w/a)
NRC Document Control Desk (w/a) khj4020687860313 ADocK 05000422 S
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r REPORT ON SIGNIFICANT DEFICIENCY #86-02 NON-ASE 8" - 90* ELB0W INSTALLED / ACCEPTED IN ASE III, CLASS 3 SYSTEM (1) Summary During a review of documentation, the ASE Installer's Document Review Group issued Document Deficiency Notice f 4437 with reference to the Identification Number of the installed elbow in question. This resulted in the issuance of N&D #8424.
This Document Deficiency Notice was the second one issued by the Document Review Group on the elbow.
They had previously issued Document Deficiency Notice #3695, where the signifi-cance of the response to _the deficiency indicated that there were two Identification Numbers on the elbow was not immediately realized.
The disposition of N&D #8424 was to replace the elbow.
(2)
Immediate Action Taken On January 30, 1986, Mr. S. D. Hall, Compliance Engineering in Duquesne Light Company's Regulatory Affairs Department, notified Mr. G. Meyer of the NRC Region I office of this potential reportable deficiency.
On February 27, 1986, Mr. S.
D. Hall,. DLC requested and was granted an extension for responding until March 14, 1986 from Mr. Len Prividy, NRC Resident Inspector.
Duquesne Light Company's Management required that an investigation of this incident be performed by the Director of DLC/QC and the Project Manager of the ASE Installer.
Their report, DLC-SQCL-Gen. Admin.-
- 0772, was distributed to Management on February 7,1986.
(3) Description of the Deficiency A Non-ASME 8" - 90* elbow, carrying the manufacturer's Identification Number stamping UX3M, was installed, accepted, and subject to successful hydrostatic testing.
The elbow was also stamped in one place with
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another Identification Number, CG8L. This number conformed to the iden-tification number assigned incorrectly by the Material Control Depart-ment and shown on the Weld Data Sheet. The Material Control Department assigned. Identification Number CG8L applicable to an. ASME 8" Long Radius Elbow (LR), but the requisition and drawing required an ASE 8" Short Radius Elbow (SR).
The investigation revealed a coincidental series of errors that enabled
.this elbow to be delivered to the Staging Area for installation. These errors occured in Material Control, QC requisition review, selection and delivery of the elbow from the Storage Laydown Area, and acceptance on receipt at the Staging Area.
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Even though the above errors occurred, the fact that the elbow was car-ring Identification Number UX3M, that differed from the document requir-ed. Identification Number CG8L, was recognized by Construction supervi-sion - in January, 1985.
The elbow was not, however, returned to the Laydown Area with appropriate instructions, but was held in the office used by the General Foreman.
The recognition of a problem existing in January was confirmed by interview and by action in January to requisi-tion a replacement elbow.
No further action was taken until May 30, 1985, when craf tsmen were assigned to locate various components, including-Item #36 (elbow),
related to 150 #101614.
Installation of the incorrect elbow commenced on May 31, 1985.
From interview, the QC Inspector ' accepted the elbow on the basis of a
. 'f al s e Identification Number stamping that-matched the Identification Number on the Weld Data Sheet.
The _ investigation included a detailed review of documentation, plus interviews with 21 personnel who were related or possibly related to this incident.
From this investigation, it was established how the Non-ASME elbow arrived at the Staging Area and was accepted by QC at.
installation.
A second series of interviews, with seven (7)
Supervisory /QC personnel, was held to specifically address the matter of improper stamping.
Although the history of the elbow was traced, information with reference to the authorization of or application of the improper identification. number was not obtained.
The report of investigation is available for review by NRC personnel as required, at the site.
(4) Analysis of Safety Implications A review.of the Certified Material Test Report (CMTR) for elbow Identification Number UX3M (Heat No.
B74117), furnished by the manufacturer, confirmed that the material-and size conformed to ASME A234WPB, being the equivalent standard, although not produced under the vendor's ASME III QA program, to that required for installation.
In addition, hardness checks of the elbow were performed in'the field, that r
gave some confirmation of. the strength of the material.
The elbow was installed utilizing weld procedures, qualifications and personnel in full compliance with the applicable. codes and QA program requirements for ASME installation.
A review of the pressure temperature ratings for a 600 lb. carbon steel ANSI rated fitting shows that the applicable pressure rating exceeds the system design pressure by approximately 500 psi.
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In conclusion, although a series of errors has occurred, the instal-lation and use of elbow Identification Number UX3M in the Auxiliary Feedwater System would not have presented an adverse safety condition.
Therefore, based on the above, this items is considered to be non-reportable under the requirements of 10CFR50.55(e).
(5) Corrective Action to Remedy the Problem (a)
The QC reviewer of requisitions was knowledgeable when questioned of the various abbreviations utilized for components, such as extra heavy, standard weight, ASME Class, etc., but was not aware of the significance of the abbreviations "LR" (long radius) and "SR" (short radius), that were appropriate to this incident. The train-ing program of QC Technicians who perform this activity, TCO VIIIC, has been revised to include all abbreviations, and has been com-pleted.
(b) The Material Control Board Card System and the Review Log generated by SPC ASME Engineering to be more clearly defined in its composi-tion to assure that fittings, with their various special attri-butes, are separated. This action will be completed prior to March 31, 1986.
(c)
The QC review of Document Deficiency Notices has been upgraded in order to speed up the process of implementing Noncon'ormance and Disposition Report action when applicable.
(d)
Instructions will be issued to the Warehouse /Laydown Storage Area personnel and those Construction personnel involved in the receipt of items at various Staging Areac to specifically check the Identi-ficaton/ Heat Number of the item against the Identification / Heat Number delivered or received. These instructions will be issued by March 15, 1986.
(e)
Instructions will be issued to supervision of the appropriate action to be taken #n an item is received at a Staging or Instal-lation Area when the Identification / Heat Number does not meet the requirements of the requisition.
These instructions will be issued by. March 15, 1986.
(f)
The deficient elbow has been cut. out from the installation and is currently segregated in the QA Vault for any possible future exami-nation. The replacement elbow is in process of installation.
It is emphasized this deficiency was revealed by the ASME Installer's documentation review program that is applied on a routine basis.
This review is now being related directly to the hydrostatic test schedule in order that any deficiencies will be identified prior to the hydrostatic test being performed.
In this in:,tance, the deficient component was installed in a portion of a system that can be isolated from the main system for re-hydrostatic test.
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4 (6) Additional Reports Based on DLC's conculsion that this item is considered not-reportable, no additical reports will to be submitted.
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