ML20215B962
| ML20215B962 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/10/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-101, NUDOCS 8706170527 | |
| Download: ML20215B962 (5) | |
Text
{{#Wiki_filter:.- mosammsm Y Executive Offices 800 Boylston Street Boston, Massachusetts 02199 Ralph G. Bird Senior Vice President - Nuclear June 10, 1987 BECo Ltr. #87-101 Document Control Desk O.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket No. 50-293 License No. DPR-35
Subject:
NRC Inspection Report 50-293/87-15 i
Reference:
Boston Edison Company Letter Number 87-94
Dear Sir:
Attached is_ Boston Edison Company's response to the Notice of Violation contained in the subject inspection report. On June 2, 1987 members of Boston Edison Company management held a telephone conversation with members of NRC Region I involved with the subject inspection. Additional information not available at the time of the inspection was discussed. Based upon information discussed in this conversation, and presented in the attachment to this letter, we request that-Notice of Violation A be withdrawn. Notice of Violation B identifies a deficiency in our method of reviewing ISI contractor qualifications in that a potential for error was present. Although we agree that our written procedures did not provide adequate evidence of control over the review and selection of contractor ISI personnel, it should be noted that our practices have not resulted in the use of insufficiently qualified personnel. Please do not hesitate to contact me directly if you have any questions. hbL R.G. r 1 EM/la i Attachment cc: Regional Administrator, Region I Director, Office of Inspection U.S. Nuclear Regulatory Commission and Enforcement 631 Park Avenue U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 Washington, D.C. 20555 Senior Resident Inspector i [\\ 8706170527 870610 PDR ADOCK 05000293 G PDR
\\ i Attachment .I (/ - Boston Edison Company Docket No. 50-293 f Pilgrim Nuclear Power Station License No. DPR-35 1 Notice of Violation A i 10CFR50.55a (g) requires that ASME Code Class 1, 2, and 3 components meet the ] [~ inservice. inspection requirements set forth in the applicable edition of j Section XI of.the ASME Code. The Pilgrim Magnetic Particle Examination l } ' Procedure 50.20. Revision 2, implements the ASME Code Section XI inservice ) l L inspection requirements including the requirements that surface indications l not exceed the allowable size limit as specified in Table. IWB 3514-2 of Sec_ tion XI. Contrary to the above, on March 10, 1987 weld DB23-2-10 was found to have a . 3 surface linear indication (3/4" in length) that exceeded the limits specifled l within the site magnetic particle procedure and AMSE Code Section XI Table IWB 3514.2. This indication had not been identified or dispositioned during a previous magnetic examination performed by the' licensee. i i
Response
l 1 Investiaation of Violation j i Boston Edison has reviewed the chronology of activities associated with I the inspection of weld 08-23-2-10. This review determined that our_ j initial magnetic particle examination of October 18, 1986 was performed in -{ accordance with all applicable code requirements. Further review of the i facts associated with the NRC inspection of the weld on March 10, 1987 i revealed that the surface condition of-the weld had been altered between our examination and the NRC's by further surface preparation for ultrasonic testing. It is hypothesized that this additional surface l preparation produced the surface indication identified by the NRC. Based ) upon the intervening activity, i.e. the further surface preparation, it ] appears that the NRC's March 10,'1987 examination was not conducted on a a weld under the same conditions as the original magnetic particle exam and' l thus was not an accurate test case to determine the adequacy of our surface examination program. Based upon the forgoing, there appears to i have been no violation. The chronology of events is presented below. .l g Weld DB-23-2-10 was scheduled for both magnetic particle and ultrasonic examination during this refueling outage. To prepare the weld surface for examination the protective paint coating was removed from the pipe by means of a mechanical buffer. The original preparation removed paint two inches on each side of the weld which was adequate for magnetic particle examination. The magnetic particle examination (yoke method) was performed.on October 18, 1986 and found acceptable. 1 In order to conduct the ultrasonic examination, an additional two inches j of pipe surface required paint removal to allow for an adequate scan surface. It should be noted that after the completion of this additional surface preparation no additional magnetic particle examination was conducted. Page 1 of 4 u
On March 10, 1987, the NRC examined the weld and found a surface indication that exceeded the specified limits. Following NRC identification of the indication, BEco reinspected DB-23-2-1C on March 10, 1987 and initiated Nonconformance Report (NCR) 87-099 to document the l linear indication. On May 21, 1987 the nonconformance report 87-099 was dispositioned to require an ultrasonic thickness measurement. The wall thickness was determined to be 1.0134". The indication was then removed by mechanical process. Once the indication was visually removed a magnetic particle examination was performed and found acceptable. A second ultrasonic thickness measurement was performed to determine the new wall thickness which is 0.992". Therefore, 0.042" of material was removed to obtain an acceptable magnetic particle examination. Corrective Steps Taken 3 The Operational Quality Control Group (00C) reviewed documentation for all welds performed during the current outage to identify any similar problems. 000 identified three other welds that had additional surface preparation after the magnetic particle exam was completed. These welds were reinspected on' March 12, 1987 with no unacceptable indications i identified. We recognize that inconsistencies in repetitive magnetic particle examinations may invite questions as to the adequacy of the previously conducted examination. Therefore, to insure that subsequent periodic examination of the surface can accurately be compared to the "as left" condition of the surface, 000 prepared and issued Quality Control Instruction (QCI) 20.41, " Surface Preparation Requirements of Weldments that Require NDE". This new QCI requires that all NDE surface preparation of a weld be completed prior to that weld being released to inspection personnel. In addition, this QCI requires the examiner to document that i all surface preparation has been completed prior to the start of the surface examinations. If further surface preparation is required af ter the surface examination has been conducted, a reinspection will be performed to detect any changes in the surface conditions. All ISI NDE personnel at PNPS have reviewed QCI 20.41 and have documented i their understanding of the contents. The appropriate forms included in QCI 50.10 (Liquid Penetration ) Examination) and QCI 50.20 (Magnetic Particle Examination) have been ) revised to include documentation of adequate surface preparation. Date When Full Compliance Was Achieved Boston Edison continues to be in compliance. Additional BEco activities 1 associated with this item have been completed. QCI 20.41 was issued on March 26,1987. All ISI NDE personnel reviewed the procedure by April 15, 1987. On May 26, 1987 the indication reported on NCR 87-099 was removed by the grinding process; the area was reinspected by the magnetic particle process and found acceptable. Page 2 of 4
n Notice of Vio_1.ation B l, 10CRR50.55(g) requires that ASME Code Class 1, 2, and 3 components meet the inservice inspection requirements set forth in the applicable edition [ of Section XI of the ASME Code and 10CFR Appendix B, Criterion IX requires that' personnel qualifications be in compliance with requirements of applicable codes and standards. ASME Code Section XI, IWA 2300, 1980 Edition and Pilgrim implementing procedure QC 10.06, Revision 4, invoke ANSI 45.2.6 requirements'that a Level II visual examiner have four years of experience in testing or inspection or both of power plant, heavy industry or other similar f acility equipment. Contrary to the above, on March 7,1987, NRC ' review of tha ISI contractor i procedure no. QC-7, Rev. 3 in use at the site, disclosed tilat the procedure required only four months of total experience rather than the ANSI 45.2.6 required four years.
Response
Prior to the commencement of any nondestructive examination, qualifications of contractor personnel are reviewed by Boston Edison's NDE Level III certified inspector. All contractor personnel performing NDE - during RF0 #7 have a minimum of four years of actual NDE experience even though ISI contractor procedure No. QC-7, Rev. 3 required four months of total experience. It should be noted that this deviation had been previously identified by the NRC at another utility in November,1986 and corrective action by the ISI contractor was already in progress prior to the commencement of the NRC inspection at Pilgrim Station. The contractor's procedure was revised on November 26, 1986 to require a minimum of four years experience however, it was not issued at PNPS until March 12, 1987. Corrective Steps Taken and Results Achieved To remove the potential for misapplication of BECo requirements for qualification of NDE personnel, BECo Quality Control Instruction (QCI) 20.40 has been revised to require that all personnel performing nondestructive examinations be certified in accordance with SNT-TC-1 A and ANSI 45.2.6, 1973/1978 as applicable to the type of inspection to be performed. The QCI was further revised to state that prior to the commencement of any nondestructive examination, the contractor NDE certification procedures (such as QC-7) and personnel certifications receive a documented review by the Boston Edison Level III for verification of consistency with BECo commitments to codes and standards. l i Page 3 of 4 l l J
r. -- a Date'When Full'Compliancq,Was Achieved- 'f' Boston-Edison's position is that there was a deficiency in our procedure which might have allowed the use of inspectors which were not fully qualified to the level required by the BEco Quality Assurance Manual. However, there was no degradation in the implementation of the requirements of ANSI 45.2.6 for Level II visual examiners as implied in-the Notice of Violation. In order to-correct the identified procedural' deficiencies, QCI 20.40 was revised to incorporate the review of contractor procedures and personnel qualifications to the requirements of ANSI 45.2.6 1973/1978 as applicable and issued on March 20, 1987.. The revised, ISI contractor procedure 00-7 was received on site on March 12, 1987. 1 i i i i i J ] Page 4 of 4}}