IR 05000412/1986013

Ack Receipt of 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)

Text

.

..

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

,

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

[h t

.

'

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

- _ _ _ _

____ - .__ _ _ _

r _ _

. ..

.

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

,

.

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

__,'

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

.

.

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

"

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 _ - _ .

'. .

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

'

!

l

.

t

!

!

_

_ _

'. .

. 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- -

. .

.

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 ,

.

_ _ _ - , _ , , .- -

. .

.

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.

,

- - - - - - , . -, . , . . , _ . . - _ . _-

_. . _ _ ._ ._ _

, ,'. .

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