IR 05000412/1986013: Difference between revisions

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{{Adams
{{Adams
| number = ML20204H311
| number = ML20207P242
| issue date = 07/30/1986
| issue date = 01/07/1987
| title = Insp Rept 50-412/86-13 on 860609-20.Violation Noted:Liquid Penetrant Exam Revealed Unacceptable Linear Indications on Base Matl
| title = Ack Receipt of 860905 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-412/86-13.Addl Concerns Re Subj Violations Will Be Addressed in Insp Rept 50-412/86-13
| author name = Harris R, Kerch H, Wiggins J
| author name = Ebneter S
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Carey J
| addressee affiliation =  
| addressee affiliation = DUQUESNE LIGHT CO.
| docket = 05000412
| docket = 05000412
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-412-86-13, NUDOCS 8608080076
| document report number = NUDOCS 8701150286
| package number = ML20204H285
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 13
}}
}}


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JAN 7 1987 Docket No. 50-412 Duquesne Light Company ATTN: Mr. J. J. Carey Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:
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Subject: Inspection No. 50-412/86-13 This refers to your letter dated September 5,1986. in response to our letter dated August 1, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions have been examined during inspection N /86-37 of your licensed program. Any further concerns regarding this matter have been addressed in Inspection Report No. 50-412/86-3 Your cooperation with us is appreciate
U.S. NUCLEAR REGULATORY COMMISSION
 
==REGION I==
Report No. 50-412/86-13 Docket No. 50-412 License N CPPR-105  Category A Licensee: Duquesene Light Company Robinson Plaza Building N Suite No.210 Pa. Route 60 Facility Name: Beaver Valley Power Station, Unit Inspection At: Shippingport, PA Inspection Conducted: June 9-20, 1986 Inspectors: b4  700 4 ."KercK!deadRea(forEngineer  date Vi71b J. Karri b
NDE Tec ician 7-3046 date Approved by: be f.'Wiggi
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hief, Material & Processes
      ? -38- N date J.(ction, E ,l[S
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Se DR Inspection Summary: Inspection on June 9-20, 1986 (Inspection Report N /86-13)
Areas Inspected: A routine, announced NRC independent measurements inspection was conducted at the utility construction site using the NRC Mobile Nondestructive Examination (NDE) Laboratory. Selected structural supports, fuel racks and pre-service inspection weldments were inspected, by a team of two regional based inspectors assisted by two contracted NDE personne Results: One violation was observed concerning an unacceptable indication in base material (86-13-01) and one violation was identified concerning liquid penetrant indications in weldment (86-13-02)
8608080076 860001 PDR ADOCK 00000412 G  PDR
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DETAILS 1.0 Persons Contacted Duquesne Light Company J. M. Jaworski, Senior Engineer, Mechanical and Welding D. K. Rohm, Assistant Director Quality Control R. M. Reba, Principal Engineer L. M. Rabenau, Compliance Engineer W. H. Sikorski, Director In-Service Inspection J. B. Andrews, In-Service Inspection Program Coordinator T. Heimel, Non-Destructive Examination Specialist R. Coupland, Director Quality Control J. R. Houghton, Duquesne Light Company Engineering Department M. Zaki, Duquesne Light Company Engineering Department C. R. Davis, Director Quality Assurance H. T. Schob1, Start-up D. W. Dreams, Assistant Director, Quality Assurance L. P. Williams, Director Start-up A. F. Mosso, Quality Assurance Non-Destructive Examination Stone and Webster Engineering Co. (SWEC)
G. Orr, Senior Training Supervisor D. P. Lessard, Assistant Superintendent K. Kirkman, Assistant Superintendent Construction J. R. Hurley, Contract Manager R. C. Wittschen, Licensing Engineer J. J. Purcell, Assistant Project Manager H. W. Durkin, Supervisor of Engineering Nuclear Energy Service (NES)
M. Shallis, Site Supervisor T. J. Koch, Project Manager G. Griffith, Director Plant Operations C. D. Cowfer, Director of In-Service Inspection Nuclear Regulatory Commission L. J. Prividy, Resident Inspector All of the above were present at the June 20, 1986 Exit Meeting.
 
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Sincerely, a ~.;  ,
n Orial::1 CiEn;d B'I5 Clifford J. Andcroca Stewart D. Ebneter, Director Division of Reactor Safety cc w/ enc 1:
E. J. Woolever, Vice President, Special Projects E. Ewing, Quality Assurance Manager R. J. Swiderski, Manager, Startup Group J. P. Thomas, Manager, Engineering R. E. Martin, Manager, Regulatory Affairs
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C. O. Richardson, Stone and Webster Engineering Corporation Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania
- 870115o286 87o107 PDR O ADOCK 05000412 PDR
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2.0 Purpose of the Inspection 2.1 An onsite independent verification inspection was conducted during June 9 through 20, 1986, using the NRC Mobile Nondestructive Exam-ination NDE Laboratory. This inspection was performed by NRC Region I personnel in conjunction with NRC contractor NDE personne The purpose of this inspection was to perform an independent exam-ination of selected piping weldments that were previously inspected and accepted under the licensee's Preservice Inspection Progra Also examined were structural steel weldments, piping supports and cable tray support weldments to ascertain the adequacy of construc-tion fabrication and of the welding quality control program to assure safety and reliability during plant operation. QC/QA records were reviewed to ascertain compliance to governing codes, standards and regulation .0 Independent Measurements The purpose of this independent examination of weldments was to verify the adequacy of the licensee's welding Quality Control Program applicable to ASME Class 1, 2 and 3 components. This was accomplished by duplicating those examinations required of the licensee by regulations and codes, and evaluating the results. In addition to those examinations, several other confirmatory examinations designed to verify conformance with material specifications were performed and compared to quality assurance record The NRC inspectors performed the examinations on randomly selected weld-ments that had been previously inspected and accepted by the licensee, as indicated by vendor shop and on-site QA/QC record .1 New Fuel Racks This inspection included the visual and liquid penetrant examination of forty fuel rack assemblie Examinations were performed using NRC procedure NDE-9 Revision 0 and the licensee's detailed drawings, procedures, standards and specification Results: During this inspection it was noted that weld symbols shown on SWEC drawings 12241-RV-20A indicated that welds were to be ground flush. The inspect]r found that the majority of these welds were in the as-welded condition. Subsequently, the licensee issued a Non-conformance and Disposition Report (N&D 33538) which was disposit-ioned use as is. The technical justification was that the intent of requiring that the welds be ground was to provide a smooth surface for liquid penetrant testing. The inspector noted that the as welded surfaces met the 250 rms requirement specified in the drawing and were acceptable in the as-welded conditio No violations were identifie .
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0FFICIAL RECORD COPY RL BV2 86-13 - 0001. /13/86
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3.2 Spent Fuel Racks (SFR)
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This inspection included examination of three (3) 8x8 fuel storage rack arrays and consisted of visual and liquid penetrant examination These items were previously inspected and accepted by the licensee, as indicated by vendor shop and onsite QA/QC records. The inspectors examined 75% of all welds denoted as critical in accordance with NES drawing 80E7653. Attributes examined during the visual inspection, were weld size, length, location and overall workmanship. Liquid penetrant inspection was performed to determine if any indications existed which were unacceptable or detrimental to the service of the componen The inspection of the spent fuel racks wac performed using NRC proce-dures NDE-14, Revision 0, NDE-9, Revision 1 and Addendas BV-2-9-1 and BV2-14 in conjunction with licensee detail drawings and site procedures, standards and specification Results: During liquid penetrant examination of a sample of critical welds denoted on detail drawing NES 80E7653, linear indications were found in two fillet welds on fuel bundle #16. As a result of the NRC finding, DLC/SQC NDE laboratory reexamined those welds with identi-fied linear indications. The results of the reexamination, substan-tiated the indications found by the NRC. The indication were dispositioned on Noncomformance and Disposition Report No. 32471 (DLC-SQC). Supplemental NDE and liquid penetrant records confirmed that unsatisfactory indications such as star cracks and linear indications were presen Based on the above, the inspector considered the existence of SFR weld indications a violation of 10 CFR 50 Appendix B requirements (412/86-13-02).
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3.3 Cable Tray Supports and Conduit Supports A random sample of cable tray supports located inside the Service building and the Main Steam Building were inspected. This inspection was performed using NRC procedure NDE-18, Rev. O in conjunction with site procedures and specifications. The attributes examined during this inspection were dimensional checks and checks for support lo-cation, support welding, and loose or broken support members. Also,
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the size and location of the Hilti conrete anchor bolts were compared to drawing requirement See Attachment 2 for specific items inspecte Results: No violations were identifie .
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3.4 Pipe Supports A sample of pipe supports located inside the primary containment and auxiliary building were examined. Attributes examined during this inspection, were dimensional checks and checks for support location, support welding and loose or broken support members. Measurements were compared with detailed isometrics / drawings indicating support location and orientation, support types and field weld requirement Results: During this inspection the inspector identified that draw-ing BZ-1078-331-0A did not conform to the actual pipe support install-ation. A further investigation revealed that E&DCR #2PA-M-1189 had been issued to modify the support. Reinspection with the correct information was performed by the inspector and no further questions develope See Attachment #3 for specific items inspecte Results: No violations were identifie .5 Steam Generator Support A visual and dimensional inspection of Steam Generator lower support assemblies A, B and C, located in the reactor containment building, was performed. The visual examination consisted of weld inspections
bec w/ encl:
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Region I Docket Room (with concurrences)
and surface material examinations. Dimensions were taken and com-pared to as-built dimensions shown on Steam Generator lower support drawing Results: A base metal linear defect was detected by visual inspec-tion of the lower horizontal beam member on the steam generator C lower support assembly. The indication was open to the surface and approximately 6" long. The inspector determined that this item had been previously inspected and accepted by the licensee with this defect not being identifie The licensee issued Noncenformance and Disposition Report No. 3281 The final indication size was 18 inches in length and 3/16 in dept The failure to identify and disposition this indication is a viola-tion of 10 CFR 50.55a requirements (412/86-13-01).
Management Assistant, DRMA (w/o enc 1)
 
DRP Section Chief A. Cerne, SRI, Seabrook W. Troskoski, SRI, BV-1 P. Tam, LPM, NRR T. Martin, DRSS S. Ebneter, DRS Robert J. Bores, DRSS
3.6 Pressurizer Support The inspectors conducted an ultrasonic examination of 16 full pene-tration weldments on the Pressurizer component support. The ob-jectives of this inspection were to verify weld integrity and to assess the adequacy of previous ultrasonic examinations performed by the fabricator. The examination was performed using NRC procedure
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\  W RI:DRS (JRI:DRS RI:DRS Lodewyk/ca s Strosnider Durr 12/11 /86 12/11 /86 -l/ 6l/*sf)/
 
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NDE-1, Revision 0, Addenda BV2-1-1, in conjuction with site proce-dures, specifications and as-built drawings. Weldments were randomly selected by a region- based NRC Nondestructive Examination (NDE)
0FFICIAL RECORD COPY RL BV2 86-13 - 0002. /13/86
Specialist, based on weld accessibilit Results: No violations were identifie .7 Windsor Probe The compressive strength of concrete poured around the reactor contain-ment was examined using the Windsor Probe test kit. Three probe results were averaged and a compressive strength was determined using standard conversion table Results: No violations were identified. The examination indicated that the concrete compressive strength exceeded the 6000 psi required by the governing site specificatio .8 Ultrasonic Examination (UT)
Ten pipe weldments were ultrasonically examined to verify the adequacy of the licensee's PSI program. The ultrasonic parameters used during this inspection were matched as closely as possible to those used during the original examination performed by the licensee's UT personnel. The instrument used was calibrated using NRC procedure NDE-2, Revision 0, and licensee's calibration block See Attachment 1 for specific weldments examine .
Results: Three (3) geometric reflectors, two (2) indications veri-fied as redirected sound path in austenitic stainless steel weldments and one (1) planer indication were identifie These results matched those previously identified by the licensee during its examinatio No violations were identifie .0 Preservice Inspection (PSI) Data Review Selected PSI data for the RCS System were reviewed to verify that exami-nations were done in compliance with the governing procedure and that applicable ASME Code and Regulatory requirements were met. The review also was undertaken to verify that the licensee had properly recorded ultrasonic evaluation A review of PSI /ISI procedure A 3.6, Revision 3, paragraph 2.93, indicated that the Supervisor of NDE Services or his designee shall review and accept the ultrasonic examination data for the licensee. This inspection revealed that this individual did not process the requisite ASNT NDE certifications. The licensee reviewed and changed procedure A 3.6 to indicate that the contractor's Level III would review and accept the examination results. The inspector interviewed the contractor's Level III
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who had reviewed the majority of PSI data for piping and concluded that his signature on each of the NDE data reports represented acceptance of those reports. The inspector thus concluded that the requirements of Section XI of the ASME code regarding acceptance of data had been me The inspector noted during the review of data reports, that the examin-ation record did not clearly state whether the weld was found to be acceptable or rejectable based on the results of the examination. The inspector was told that a master tracking list indicated the status of the welds. The inspector expressed a concern that completed ultrasonic exam-ination records should stand on their own relative to a statement of the acceptability of the weld examined. The adequacy of NDE records is considered unresolved pending licensee review of the inspector's concern described above (86-13-03).
Overall, the inspector found that the preservice piping inspection at Beaver Valley 2 and its documentation had been performed professionally and that a meaningful PSI program had resulte Results: No violations were identifie .0 Followup on Previously Identified Items (Closed) Unresolved Item 84-02-01: Technical Justification to waive D1.1 when using design allowables of AISC (Closed) Unresolved Item 84-02-02: Method to establish and control ' Engineers" authority to waive explicit rules of 01.1 not documented (Closed) Unresolved Item 84-02-03: Engineering justification to use Para A515 in D1.1 not documented (Closed) Unresolved Item 84-02-04: Engineering justification to waive 10 mil undercut rule for D1.1 FAB not documented (Closed) Unresolved Item 84-02-05: Engineering justification to substitute SWEC FC P601.8 figure 7 effective throat rules for Para. 61.1 of 01.1 rules not documented (Closed) Unresolved Item 84-02-06: Basis for qualification of welding over galvanized steel unistruts with E6010 not documented Background: During an earlier field inspection, an NRC inspector observed that several items had not been properly addressed in regard to the application of AWS D1.1 at Beaver Valley Unit During this inspection, the licensee's responses No. 2 NCD-04478 and 2 DLS-23722 and references No. 2 DLS-23064 and 2 DLS-23491 were reviewed. Procedures No. 2 BVM-7 for Preparation of Specification, and 2 BVM-102 for Pipe Support Welding Design Guide, were also reviewed. The inspector verified that the appropriate corrective action to these items had been take . - _ _ - - _ - - . - - - ---.
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T#    2NRC-6-094 o. 2 Unit Project Orynintion gr WI    Tom ) Ext.160 P.O. Box 328    Sept. 5, 1986 Shippingport. PA 15077 United States Nuclear Regulatory Coninission 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:
Based on these reviews, the inspector considers items 84-02-01 through 84-02-06 close (Closed) Unresolved Item 84-15-01: Potential PSI problems due to weld overlay of piping and lack of vendor as-built drawings and RT map During NRC inspection 85-05, the inspectabililty of the overlay welds was established. During this inspection, the inspector reviewed the RT maps and found them to be excellent. Also reviewed, were some of the required as built drawings (1104552 Revision 4, 1104J50 Revision 2, 1104J51 Revision 4 and 1101J46 Revision 1). The inspector also noted that in letter ND2 ISI: 0261 the licensee has requested SWEC to obtain the required as built drawings for the reactor pressure vesse Based on this and the previous NRC inspection of this subject, item 84-15-01 is close (Closed) Unresolved Item 86-05-01: Incomplete Transducer Certification Documentation The licensee performed calculations and physical measurements to determine that the transmit and receive crossover point and focal depth of dual transducers serial numbers J-22462 and J-22463 were adequate. The transducers were marked. Transducers serial numbers F-16030 and F-20320 listed in inspection report 86-05-01 as focused dual element were in fact found to be single element and thus did not require additional documentatio This item is therefore close .0 Unresolved Items i
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 Violatio DUQUESNE LIGHT COMPANY
An Unresolved Item is that for which more information is necessary for the NRC to determine whether the item is acceptable or a violation or deviation. An unresolved item is contained in paragraph .0 Exit Meeting An exit interview was held on June 20, 1986 with members of the licensee's staff. The inspector summarized the scope and findings of this inspec-tio No written material was provided to the licensee during the course of the inspection.
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By
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J.' J. CYrey 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)
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United States Nuclear R::gulatory Commission Mr. Stewart D. Ebneter, Director Inspection Report 50-412/86-13 Page 2 s
COMMONWEALTH OF PENNSYLVANIA )
SS:
COUNTY OF BEAVER  1 On this N/ '
day of / M53*_) ,
    / [ h , before me, a Notary Public in and for saifCdiimonwealth 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 the icregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledg h-Notary Public tbtD92/
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SKtitA M. FATTORE, MTARY Pb BLIC SHIPrillGP0ET BORD, BEAVIA CoulnY ET CommiSS40N EXPlRES SCT. 23,1989 Bomber, Possertsenis Associeties of IWortes
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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 Cod Section III, Subsection NF of the 1974 Edition of the ASME Boiler and Pressure Vessel Code governs the fabrication and inspection of safety related component supports for Beaver Valley Unit 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 dept Contrary to the above, an NRC visual exanination during June 9 - 20,1986 dis-closed that a previously inspected and accepted lower support assembly for Stean Generator C had a 6 inch linear indication sich was 3/16 inch deep, that had not been recorded or dispositioned as required by Specification 2BVS-4 This is a Severity Level IV violation (Supplement II).
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RESPONSE The linear indication reported by the NRC on the subject support was verified by Site Quality Control and identified on Nonconfomance and Dispositon (N&D)
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32,812. The final indication size was detemined to be 18 inches in length and 3/16 of an inch in dept The excavated area was blended into the surrounding base metal as required by the engineering dispositio Engineering review of the applicable calculation indicates that structural integrity of the support menber has not been compromised by excavation to this dept An indepth review of SWEC procurenent inspection records and of DLC's Site Quality Control installation documentation did not disclose any infomation which muld show that the indicai; ion was reported / addressed previously. Al-though the previcesly completed 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 perfomed. These inspections would have revealed the surf ace defec mm--. - - , . - - - , - -.---,y - - - - - - . - - - - . . . - - - - _ w- -
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Although failure to identify and rectify this indication during vendor-shop f abrication and inspection is not consistent with the requirenents of 2BVS-43, DLC maintains that the violation should not cite a non-cenfonnance with respect to ASME III, Subsection NF. BVPS-2 FSAR, Section 5.4.14.1 states, The conponent 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 and the ASME Code, Section III, Subsection NF, as guidelines. Strict aiherence 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 canponents of the support systens were develope Ac the subject defect has been acceptably dispositioned, and as a progran was in place to identify the defect, no further action is considered appropriat ,
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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 drawing 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 exanination Contrary to the above, an MRC 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 specification This is a Severity Level IV violation. (Supplement II).
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Response The Spent Fuel Racks we"e supplied by NES/Selanaco 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 weld This specification, Page 20 of 36, states that the critical welds may be liquid penetrant examined with a sanpling plan. A subse-quent review of the Vendor supplied documentation showed that an approved sanpling plan, NES/Selanco 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 sanpling p1a 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
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i 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 applicatio The results of this exanination is de-scribed in N&D 33,415 where detailed examination and rework activities were describe ,
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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 surveillanc In al l, Westinghouse QC vi sually 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
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not include the two welds previously identified on N&D 32,471. All welds were satisfactorily 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 assuned to be missing, resulted in a detennination that these j three welds are acceptable-as-is.


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Revision as of 05:04, 12 January 2021

Ack Receipt of 860905 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-412/86-13.Addl Concerns Re Subj Violations Will Be Addressed in Insp Rept 50-412/86-13
ML20207P242
Person / Time
Site: Beaver Valley
Issue date: 01/07/1987
From: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Carey J
DUQUESNE LIGHT CO.
References
NUDOCS 8701150286
Download: ML20207P242 (2)
v • d • e


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JAN 7 1987 Docket No. 50-412 Duquesne Light Company ATTN: Mr. J. J. Carey Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:

Subject: Inspection No. 50-412/86-13 This refers to your letter dated September 5,1986. in response to our letter dated August 1, 198 Thank you for informing us of the corrective and preventive actions documented in your letter. These actions have been examined during inspection N /86-37 of your licensed program. Any further concerns regarding this matter have been addressed in Inspection Report No. 50-412/86-3 Your cooperation with us is appreciate

Sincerely, a ~.; ,

n Orial::1 CiEn;d B'I5 Clifford J. Andcroca Stewart D. Ebneter, Director Division of Reactor Safety cc w/ enc 1:

E. J. Woolever, Vice President, Special Projects E. Ewing, Quality Assurance Manager R. J. Swiderski, Manager, Startup Group J. P. Thomas, Manager, Engineering R. E. Martin, Manager, Regulatory Affairs

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C. O. Richardson, Stone and Webster Engineering Corporation Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania

- 870115o286 87o107 PDR O ADOCK 05000412 PDR

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0FFICIAL RECORD COPY RL BV2 86-13 - 0001. /13/86

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bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

DRP Section Chief A. Cerne, SRI, Seabrook W. Troskoski, SRI, BV-1 P. Tam, LPM, NRR T. Martin, DRSS S. Ebneter, DRS Robert J. Bores, DRSS

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\ W RI:DRS (JRI:DRS RI:DRS Lodewyk/ca s Strosnider Durr 12/11 /86 12/11 /86 -l/ 6l/*sf)/

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0FFICIAL RECORD COPY RL BV2 86-13 - 0002. /13/86

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T# 2NRC-6-094 o. 2 Unit Project Orynintion gr WI Tom ) Ext.160 P.O. Box 328 Sept. 5, 1986 Shippingport. PA 15077 United States Nuclear Regulatory Coninission 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 Violatio DUQUESNE LIGHT COMPANY

/

By

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J.' J. CYrey 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)

l-es%pm!w.c- r (p n et _ - _ .

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

COMMONWEALTH OF PENNSYLVANIA )

SS:

COUNTY OF BEAVER 1 On this N/ '

day of / M53*_) ,

/ [ h , before me, a Notary Public in and for saifCdiimonwealth 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 the icregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledg h-Notary Public tbtD92/

/

SKtitA M. FATTORE, MTARY Pb BLIC SHIPrillGP0ET BORD, BEAVIA CoulnY ET CommiSS40N EXPlRES SCT. 23,1989 Bomber, Possertsenis Associeties of IWortes

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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 Cod Section III, Subsection NF of the 1974 Edition of the ASME Boiler and Pressure Vessel Code governs the fabrication and inspection of safety related component supports for Beaver Valley Unit 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 dept Contrary to the above, an NRC visual exanination during June 9 - 20,1986 dis-closed that a previously inspected and accepted lower support assembly for Stean Generator C had a 6 inch linear indication sich was 3/16 inch deep, that had not been recorded or dispositioned as required by Specification 2BVS-4 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 Nonconfomance and Dispositon (N&D)

32,812. The final indication size was detemined to be 18 inches in length and 3/16 of an inch in dept The excavated area was blended into the surrounding base metal as required by the engineering dispositio Engineering review of the applicable calculation indicates that structural integrity of the support menber has not been compromised by excavation to this dept An indepth review of SWEC procurenent inspection records and of DLC's Site Quality Control installation documentation did not disclose any infomation which muld show that the indicai; ion was reported / addressed previously. Al-though the previcesly completed 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 perfomed. These inspections would have revealed the surf ace defec mm--. - - , . - - - , - -.---,y - - - - - - . - - - - . . . - - - - _ w- -

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Although failure to identify and rectify this indication during vendor-shop f abrication and inspection is not consistent with the requirenents of 2BVS-43, DLC maintains that the violation should not cite a non-cenfonnance with respect to ASME III, Subsection NF. BVPS-2 FSAR, Section 5.4.14.1 states, The conponent 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 and the ASME Code,Section III, Subsection NF, as guidelines. Strict aiherence 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 canponents of the support systens were develope Ac the subject defect has been acceptably dispositioned, and as a progran was in place to identify the defect, no further action is considered appropriat ,

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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 drawing 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 exanination Contrary to the above, an MRC 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 specification This is a Severity Level IV violation. (Supplement II).

Response The Spent Fuel Racks we"e supplied by NES/Selanaco 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 weld This specification, Page 20 of 36, states that the critical welds may be liquid penetrant examined with a sanpling plan. A subse-quent review of the Vendor supplied documentation showed that an approved sanpling plan, NES/Selanco 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 sanpling p1a 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

,

i 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 applicatio The results of this exanination is de-scribed in N&D 33,415 where detailed examination and rework activities were describe ,

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 surveillanc In al l, Westinghouse QC vi sually 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 satisfactorily 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 assuned to be missing, resulted in a detennination that these j three welds are acceptable-as-is.

,

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_. . _ _ ._ ._ _

, ,'. .

t . NES has b;;n advised of th2 problens associated with the multi-pass weld 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 rack The BV-2 project is evaluating this finding for potential reportability under 10CFR50.55(e).

.

f a

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