ML20235Z238
| ML20235Z238 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/21/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bird R BOSTON EDISON CO. |
| References | |
| NUDOCS 8707270234 | |
| Download: ML20235Z238 (2) | |
See also: IR 05000293/1987015
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JUL P 11987
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' Docket No.
50-293
- Boston Edison Company M/C Nuclear
ATTN: Ralph G. Bird
.
Senior Vice President - Nuclear
800 Boylston Street
Boston, Massachusetts 02199
Gentlemen:
1
Subject:
Inspection No. 50-293-87-15
Thb ?etter is in respoiise to your June 10, 1987 letter regarding our
tran wittal of Inspection Report 50-293/87-15. Our transmittal was dated
May b 1937 and. contained two Notices of Violation related to your Inservice
Inspection (ISI) activities.
We have reviewed the information you have provided and our response is ai,
follows:
Notice of Violation A was issued after NRC inspectors identified a linear
indication in a weld that exceeded the code acceptable length. This finding
represents a failure to satisfy ASME Code requirements as required by
10 CFR 50.55a(g). Your June 10, 1987 letter provided no additional informa-
tion that would justify withdrawing the subject Notice of Violation.
With regard to Notice of Violation B, our Inspection Report (IR 50-293/87-15)
acknowledged that all contractor personnel performing. level II visual'inspec-
tion activities during refueling outage No. 7 satisfied the ANSI 45.2.6
requirement of a minimum of four years of actual visual inspection experience.
The breakdown occurred in the ISI contractor procedure No. QC-7, Rev. 3 which
required on.ly fcur months of total experience. Had any of the subject person-
nel not satisfied the ANSI requirement a higher severity level violation could
have resulted. The fact that this deviation in the contractor's procedure
was identified at another site and that the contractor was taking action to
correct the procedure does not relieve Boston Edison of the responsibility for
implementing appropriate measures to ensure that contractor activities are
completed in accordance with NRC requirements and license commitments.
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.
8707270234 870721
ADOCK 05000293
O
OFFICIAL RECORD COPY
RL PILGRIM 87-15 - 0001.0.0
07/21/87
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Boston Edison Company M/C Nuclear
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Your cooperation with us is appreciated.
Sincerely,
Or;ginal Signed By 3
William V. Johnston, Acting Director
Division of Reactor Safety
cc:
K. P. Roberts, Station Manager
Paul Levy, Chairman, Department of Public Utilities
Chairman, Board of Selectmen
Plymouth Civil Defense Director
J. D. Keyes
The Honorable E. J. Markey
Senator Edward P. Kirby
The Honorable Peter V. Forman
Sharon Pollard, Secretary of Energy Resources
Rachel Shimshak, MASSPIRG
Public Document Rnom (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commor, wealth of Massachusetts (2)
bec:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
Section Chief, DRP
W. Raymond, SRI, Vermont Yankee
T. Shediosky, SRI, Millstone 1&2
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H. Eichenholz, SRI, Yankee
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PA0 (2) SALP Reports Only
Robert J. Bores, DRSS
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M. Gay
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RI:DRS
RI:DRS
RI:DRS
R :DB
Durr
Johnston
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07//f/87
07/lJ/87
07/20/87
07/2) /87
0FFICIAL RECORD COPY
RL PILGRIM 87-15 - 0001.1.0
07/16/87
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80STONEDISON
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Executive Othces
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800 Boylstor' street
Boston. Massachusetts 02199
' Ralph G. Bird
Senior Vice President - Nuclear
June
10, 1987
BECo Ltr. #87-101
Document Control Desk
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Docket No. 50-293
License No. DPR-35
Subject: NRC Inspection Report 50-293/87-15
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 tnis letter, we request'that-
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Notice of Violation *A*be" withdrawn:
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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.
R . G'.
r$
EH/la
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
Hashington, D.C. 20555
Senior Resident Inspector
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Attachment
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Boston Edison Company
Docket No. 50-293
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Pilgrim Nuclear Power Station
License No. DPR-35
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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
Section XI of the ASME Code. The 4 Pi l g ri m ' Magnet i c" Pa rt i c l e < Exami nati on .
Pr.ocedu,re;50.2.0,Jevision 2.t. implements-the ASMEcCode ~Section'XI" inservice'
inspection.arequirementssincluding,the, requirements,that" surface-indications w
not exceedethe< allowable, size. limit,as-specifiedtin Table IWB<3514-2'of e
m
Section+XI. war-
Contrary to the above, on March 10, 1987 weld DB23-2-1C was found to have a
surface linear indication (3/4" in length) that exceeded the limits specified
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.
Response
Investigation of Violation
Boston Edison has reviewed the chronology of activities associated with
the inspection of weld D8-23-2-1C.
This review determined that our
initial magnetic particle examination of October 18, 1986 was performed in
accordance with all applicable code requirements.
Further review of the
facts associated with the NRC inspection of the weld on March 10, 1987
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
preparation produced the surface indication identified by the NRC.
Based
upon the intervening activity, i.e. the further surf ace preparation, it
appears that the NRC's March 10, 1987 examination was not conducted on a
weld under the Game conditions as the original magnetic particle exam and
thus was not an accurate test case to determine the adequacy of our
surface examination program. Based upon the forgoing, there appears to
have been no violation.
The chronology of events is presented below.
Weld DB-23-2-1C 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
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examination.
The magnetic particle examination (yoke method) was
performed on October 18, 1986 and found acceptable.
In order to conduct the ultrasonic examination, an additional two inches
of pipe surface required paint removal to allow for an adequate scan
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surface.
It should be noted that after the completion of this additional
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surface preparation no additional magnetic particle examination was
conducted.
Page 1 of 4
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On March 10, 1987, the NRC examined the weld and found a surface
indication that exceeded the specified limits.
Following NRC
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identification of the indication, BECo reinspected 08-23-2-1C on March 10,
1987 and_ initiated Nonconformance Report (NCR)87-099 to document the
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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
The Operational Quality Control Group (00C) reviewed documentation for all
welds performed during the current outage to identify any similar
problems. 00C 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
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, 00C prepared and issued Quality Control
Instruction (QCl) 20.41, " Surf ace Preparation Requirements of Weldments
that Require NDE".
This new QCl 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
all surface preparation has been completed prior to the start of the
surface examinations.
If f urther 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 151 NDE personnel at PNPS have reviewed QCI 20.41 and have documented
their understanding of the contents.
The appropriate forms included in QCl 50.10 (Liquid Penetration
Examination) and 001 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
associated with this item have been completed. QCI 20.41 was issued on
March 26,1987. All 1S1' NDE personnel reviewed the procedure by April 15,
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1987.
On May 26, 1987 the indication reported on NCR 87-099 was removed
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by the grinding process; the area was reinspected by the magnetic particle
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process and found acceptable.
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10CRR50.5S(g) requires that ASME Code Class 1, 2, and 3 components meet
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the inservice inspection requireraents 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 00-10.06, Revision 4, invoke
ANSI 45.2.6 requirements that a Level 11 visual examiner have four years
of experience in testing or inspection or both Of power plant, heavy
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industry or other similar f acility equipment.
Contrary to the above, on March 7,1987, NRC review of the ISI contractor
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procedure no. OC-7, Rev. 3 in use at the site, disclosed that the
procedure required only four months of total experience rather than the
/ "~ ANSI 45.2.6 requi' red four years.
Response
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Prior to the commencement of any nondestructive examination,
qualifications of contractor personnel are reviewed by Boston Edison's NDE
Level Ill 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
151 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 (OC1)
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 QC1 was further revised to state that prior to the
commencement of any nondestructive examination, the contractor NDE
certification procedures (such as 0C-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.
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Date When Full Compliance Was Achieved
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Boston Edison's position is that there was a deficiency in our procedure
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which might have allowed the use of inspectors which were not fully
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qualified to the level required by the BECo Quality Assurance Manual.
However, there was.no degradation in the implementation of the
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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 ',ssued on March 20, 1987. The revised, ISI contractor procedure QC-7
was received on site on March 12, 1987.
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