ML20215E038

Responds to NRC Re Violations Noted in Insp Rept 50-412/86-13.Corrective Actions:Spent Fuel Rack Welds Reworked/Repaired.Future shop-repaired Welds to Be Liquid Penetrant Inspected

ML20215E038
Person / Time
Site:	Beaver Valley
Issue date:	09/05/1986
From:	Carey J DUQUESNE LIGHT CO.
To:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
2NRC-6-094, 2NRC-6-94, NUDOCS 8610140408
Download: ML20215E038 (7)

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'Af g 2NRC-6-094 Beaver Valley No. 2 Unit Project organization Telecopy ( 12) 3 Ext.160 I,E.G

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. Box 2 Sept. 5, 1986 Shippingport, PA 15077 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Stewart D. Ebneter, Director Divison of Reactor Safety

SUBJECT:

Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/86-13

REFERENCE:

Letter dated August 1,1986 (S. D. Ebneter to J. J. Carey)

Gentlemen:

The above-referenced letter transmitted a Notice of Violation as Appendix A. Attachments 1 and 2 of this letter provide Duquesne Light Company's (DLC) response pursuant to the requirements of 10CFR2.201 and the NRC's Notice of Violation.

DUQUESNE LIGHT COMPANY By J.~J. Ctrey Senior Vice President LMR/ijr NR/IR/50412 Attachment cc: Mr. P. Tam, Project Manager (w/a)

Mr. L. J. Prividy, NRC Resident Inspector (w/a)

Mr. W. Troskoski, NRC Sr. Resident Inspector (w/a)

Mr. J. Beall, NRC Sr. Resident Inspector (w/a)

NRC Document Control Desk (w/a) 8610140408 860705 PDR ADOCK 05000412 G PDR TE O l \

United States Nuclear R;gulatory Commission Mr. Stewart D. Ebneter, Director Inspection Report 50-412/86-13 Page 2

! COMMONWEALTH OF PENNSYLVANIA )

SS:

COUNTY OF BEAVER l On this //j day of / M/i/d

/[h , before me, a l- Notary Public in End for said Codmonwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file j the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.

I h-Notary Public

/

I SHERA M. FATTORE, NCit RY PbBUC SHIPPMGPORT B000, BEAVER CCUNTY NY C08tllS$10N EXPlGES OCT. 23,1989 Bulwr, Penneyhosis Association of Noterke

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ATTACHMENT 1 NOTICE OF VIOLATION 86-13-01 10CFR50.55a requires that structures shall be fabricated and inspected in accordance with the requirenents of the applicable edition of the ASME Boiler and Pressure Vessel Code.

Section III, Subsection NF of the 1974 Edition of the ASME Boiler and Pressure Vessel Code governs the fabrication and inspection of safety related conponent supports for Beaver Valley Unit 2.

The Specification for Fabrication of Stean Generator, 2BVS-43, implenents the requirenents of Subsection NF and requires that structural shapes with thick-nesses between 3/8 and 2 inches be conditioned by the renoval of injurious linear imperfections which exceed 1/16 inch in depth.

Contrary to the above, an NRC visual examination during June 9 - 20,1986 dis-closed that a previously inspected and accepted lower support assenbly for Stean Generator C had a 6 inch linear indication which was 3/16 inch deep, that had not been recorded or dispositioned as required by Specification 2BVS-43.

This is a Severity Level IV violation (Supplement II).

RESPONSE

The linear indication reported by the NRC on the subject support was verified by Site Quality Control and identified on Nonconformance and Dispositon (N&D) 32,812. The final indication size was detennined to be 18 inches in length and 3/16 of an inch in depth. The excavated area was blended into the surrounding base metal as required by the engineering disposition. Engineering review of the applicable calculation indicates that structural integrity of the support menber has not been conpronised by excavation to this depth.

An indepth review of SWEC procurenent inspection records and of DLC's Site Quality Control installation documentation did not disclose any information which would show that the indication was reported / addressed previously. Al-though the previously conpleted inspections had no specific attribute to check for surf ace blemishes, DLC acknowledges that the indication should have been identified and dispositioned as required by 2BVS-43. However, at the time of the NRC Inspection, the support was not painted and thus, the pre-painting inspection governed by existing IP-6.3.3, " Inspection and Testing of Protective Coatings" and FCP-804, " Inspection and Testing of Category I Coatings" had not been perfonned. These inspections would have revealed the surface defect.

l Although failure to identify and rectify this indication during vandor-shop f abrication and inspection is not consistent with the requirenents of 2BVS-43, DLC maintains that the violation should not cite a non-confonnance with respect to ASME III, Subsection NF. BVPS-2 FSAR, Section 5.4.14.1 states, The component supports for the stean generators, the RCPs, the reactor vessel, and the pressurizer are designed to maintain structural integrity of the RCS. . . The design criteria presented in Table 5.4-21 were developed using the AISC Manual of Steel Construction ard the ASME Code,Section III, Subsection NF, as guidelines. Strict adherence to Subsection NF is not required for the component support systens described herein, because Subsection NF was not in effect at the time the various components of the support systens were developed.

As the subject defect has been acceptably dispositioned, and as a progran was in place to identify the defect, no further action is considered appropriate.

ATTACHMENT 2 NOTICE OF VIOLATION 86-13-02 10CFR50, Appendix B, Criterion V requires that activities affecting quality be conducted in accordance with established procedures and drawings.

The NES Specification for the Fabrication and Inspection of the Neutron Absorb-er Spent Fuel Storage Racks, document 80A7780 Revision 0, states that any cracks or linear indications greater than 1/16 inch shall be considered un-acceptable and drawing 80E7653 denotes the critical welds that require penetrant examinations.

Contrary to the above, an NRC liquid penetrant examination of two critical welds on Bundle #16 revealed unacceptable linear indications that had not been previously recorded or dispositioned as required by the specifications.

This is a Severity Level IV violation. (Supplement II).

Response

The Spent Fuel Racks were supplied by NES/Selamaco in accordance with S&W Spe-cification, 2BVS-40. This specification stipulates that any required liquid penetrant examinations will be in accordance with the Seller's drawings. The Seller's drawings refer to NES Specification 808A7780 for inspection require-ments of critical welds. This specification, Page 20 of 36, states that the critical welds may be liquid penetrant examined with a sampling plan. A subse-quent review of the Vendor supplied documentation showed that an approved sampling plan, NES/Selamco 83007-CWSP, was used. A review of the liquid pene-trant report, Traveler #003031 for Fuel Rack NES-16, showed that the two welds in question were not liquid penetrant inspected by the vendor under his sampling plan.

The two 3/32 inch fillet weld areas found deficient, exhibited a multi-pass operation that was considered as indicative of a repaired area and N&D 32,471 was initiated following confirmation of the defect by DLC/SQC NDE. As the defect could not be ground out, i.e., not a surf ace blemish, per Engineering instructions, the bottom critical welds were examined on all 17 racks for indi-cations of multi-pass appl ic ation. The results of this examination is de-scribed in N&D 33,415 where detailed examination and rework activities were described.

Per the Engineering specification, the requirenents for the inspection of the Spent Fuel Racks is ASME Section III Sub-Section NF-5000. Therefore, the re-work specified by the disposition of N&D 32,471 was assigned to Westinghouse Construction Services, who applied their ASME III procedures and completed their work under DLC/SQC surveillance. In al l, Westinghouse QC visually inspected approximately 5440 welds on the 17 Spent Fuel Racks and identified 120 welds to be liquid penetrant examined, of which 75 were rejected. This did not include the two welds previously identified on N&D 32,471. All welds were satisf actorily reworked / repaired except for three under-sized welds which were subsequently transferred to N&D 20,174. Vendor analysis of the racks, where these welds were assumed to be missing, resulted in a detennination that these three welds are acceptable-as-is.

NES has been advised of- the problens associated with the multi-pass welds.

Specification 2BVS-40 will be revised to require that all shop-repaired welds be liquid penetrant inspected. NES will be notified that the BVPS-2 project has adopted this change with respect to future purchases of spent fuel racks.

The BV-2 project is evaluating this finding for potential reportability under 10CFR50.55(e).

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