ML20212H242
| ML20212H242 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 01/16/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| NUDOCS 8701210313 | |
| Download: ML20212H242 (3) | |
Text
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DUKE POWER GOMPAhT P.O. HO X 3 318 0 CHAHLO f fE, N.C. 28242 v
.. nun N
January 16, 1987 U.S. Nuclear Regulatory Commissicn Document Control Desk Washington, D.C.
20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369, 50-370
Reference:
NRC/0IE Inspection Report 50-369/86-14, 50-370/96-14 Gentlemen:
Pursuant to 10CFR2.201 and Dr. J.N. Grace's letter of December 18, 1986, please find attached a supplemental response to the violation which was identified in the above referenced Inspection Report.
Very truly yours,
/)'
Hal B. Tucker JBD/162/jgm Attachment xc Mr. W.T. Orders NRC Resident Inspector McGuire Nuclear Station Mr. Darl Hood Office of Nuclear Reactor Regulation gT g
U.S. Nuclear Regulatory Commission
. ((
Washington, D.C.
20555 Dr. J. Nelson Grace, Regional Administrator U.S. Nuclear Regulatory Commission Region II
'\\l 101 Marietta St. NW, Suite 2900 f
Atlanta, Georefa 16123 lit 0701210313 870116 i
{DR ADOCKOS00g9
DUKE POWER COMPANY McGUIRE NUCLEAR STATION RESPONSE TO VIOLATION IN INSPECTION REPORT 50-369/86-14 AND 50-370/86-14 Violation 50-369/86-14-01, Severity Level IV 10CFR50, Appendix B, Criterion IX as implemented by Topical Report Duke-2-A, Section 17.2.9 requires in part that approved procedures qualified in accordance with applicable standards shall provide for documented evidence of acceptable accomplishment of special processes using qualified... equipment.
Contrary to the above, on June 10, 1986, there was no documented evidence to verify that certified material and calibrated equipment e.g. gauge, dial indicators, scales and shot peening material had been utilized for the qualification of shot peening procedure 1163-035-A Revision 3.
Response
1.
Admission or denial of the alleged violation:
Duke Power denies the alleged violation.
Duke Power is in compliance with the intent of Topical Report Duke-2-A Section 17.2.9 by providing control of (1) special processes through written procedures in accordance with applicable codes and standards and (2) instruments and gauges calibrations through our QA programs.
The licensee can provide evidence that properly calibrated equipment and certified materials were used in the process and personnel qualifications.
Duke does not believe that all uses of calibrated instruments and gauges should be documented in process and personnel qualification records.
However, it is important to ensure that all instruments and gauges used are calibrated to recognized standards and that a quality assurance program is in place to provide objective evidence when needed.
Babcock & Wilcox quality program is under Duke Power's auditing and evaluation program for vendors. Duke Power has no open procurement deficiencies at this time on Babcock & Wilcox.
NRC ASSESSMENT:
We have evaluated your response and disagree with your position concerning the failure to identify, on the qualification record, those elements considered casential to the Shot Peening Process. These included, but were not limited to, chot peening material, instruments and individuals who actually performed the qualification as described in the aforementioned Region II report. The fact that gcuges, instruments, material, etc., purportedly used by B&W for the qualification cf the process, were those controlled under B&W's QA program is not supported by the official performance qualification document, since none of these essential clements were recorded on this document. However, after careful consideration of the bases for your denial, we have concluded that the Severity Level should be decreased from Severity Level IV to Severity Level V.
i i
2 SUPPLEMENTAL RESPONSE:
Duke Power Company admits that all available or desired documentation was not included or attached to those qualified procedures and processes being implemented during shot peening of McGuire Nuclear Station steam generator tubes.
The vendor was on the McGuire Nuclear site performing work to a qualified procedure with qualified personnel which had been verified. We agree that more documentation could have been included with the procedures, however, both Duke Power and the vendor felt the documentation was adequate for the job.
Duke Power performs audits of the vendor's quality program and in the past had found no concerns in their calibration program or control of measuring and test equipment. Duke had also observed this work being performed for another utility at another site with no concerns noted.
Corrective action taken and results obtained Duke Power requested and obtained from the vendor, Babcock & Wilcox, the necessary documents to provide evidence that calibrated equipment was used during qualification of the applicable procedures and personnel.
Certified mill test reports of the shot peening material are also available. B&W has advised Duke Power Company that only two heats of peening material have been received by B&W and both have been subjected to the various test and are certified acceptable material. No shot peening material is accepted at B&W without acceptable test results.
Corrective steps which will be taken to avoid further violation I
Duke Power audited B&W's quality program and found no discrepancies in the areas audited. Duke has been advised that B&W is in the process of revising work order #21. Paragraph 6.1 of the work order will state "Whenever the special process i.
requires that calibrated instruments be used to further assure the validity of the l
data acquired, generated or otherwise important to the process, only measuring and test equipment that is of the proper range, type, and accuracy shall be used."
Paragraph 6.2 will state "The qualification of any special process or operator that requires the use of calibrated instruments during the implementation of the cpecial process, shall note on the qualification record the type, serial number, cnd calibration due date of the instruments used. A copy of the calibration documentation shall be attached to the qualification record or reading avaliable for review."
Date when full compliance will be achieved Duke Power expects to be in full compliance and will have verified compliance by the vendor by 6/1/87.
.