IR 05000219/1985035

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/85-35.Citations in Violations A,C & D Valid,Per Rereview.Attachment a Provides NRC Position on Violations

ML20207J802
Person / Time
Site:	Oyster Creek
Issue date:	07/21/1986
From:	Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8607290258
Download: ML20207J802 (4)

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a violation. With regard to Violation C ( 3), ,<e r.,,to + .

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response described proposed corrective action,, eien thou,4h j,,,,;iq,,4v; . . . ,

citation. We will review these actions during a future In.pn,ti,,r, .

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that you respond, within 30 days of the date of this letter f r, I I ,,,,1 n ,4 sto i .,

structions of the original Notice of Violation to Citation O(2). A1:<,, ,,1+ h

_ recard to Violation A clease inform us of the date by which voor <r.rro,i1en action will be implemente

Sincerely, Original Signed By:

Harry B. Kister, Chief Projects Branch No. 1 Division of Reactpr Projects 0FFICIAL RECORD COPY Letter OYC 8607290258 860721 MS PDR ADOCK 05000219 G PDR I l I

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JUL 211986

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Docket No. 50-219

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GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen:

Subject: Inspection 50-219/85-35

This letter acknowledges receipt of your letter dated April 18, 1986 that

, responded to the findings identified in our inspection report 50-219/85-3 l Your corrective and preventive actions will be reviewed in a subsequent j inspectio .

! In your response you took issue with Violation A and portions of Violations C l and We have evaluated your responses, re-reviewed our original findings,

! and held additional discussions onsite regarding Violatten A. We conclude the citations are valid, therefore, none of the violations are withdraw Regarding Violation A, our understanding of your corrective action is stated in

! Attachment Attachment A also discusses our basis as to why item D (2) remains l a violation. With regard to Violation C (3), we note that your April 18, 1986, l response described proposed corrective actions, even though you disputed the i citation. We will review these actions during a future inspection. We request j that you respond, within 30 days of the date of this letter following the in-

structions of the original Notice of Violation to Citation 0(2). Also, with

! regard to Violation A please inform us of the date by which your corrective l

action will be implemented.

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Sincerely, p

Original Signed By Harry B. Kister, Chief

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Projects Branch No. 1 Division of Reactpr Projects

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0FFICIAL RECORD COPY Letter OYC

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PDR ADOCK 05000219 I G PDR 3 I \ I

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cc w/ encl:

M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey bec w/ enc 1:

Region I Docket Room (with concurrences) .

Management Assistant, DRMA (w/o encl)

Section Chief, DRP Robert J. Bores, DRSS

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, 4 Attachment A Violation A: This violation was for a partially inadequate corporate welding program. The details section of the report explained that your program is designed to meet the requirements of Section IX but does not address important aspects of AWS D1.1, namely, the AWS essential variable of weld joint geometry. In your response you stated your program was not intended to contain all requirements defined in AWS D1.1 and that you feel your program is adequate to meet the requirements of both ASME Section IX and AWS D1.1. You also reiterated your position that joint geometry is a non-essential variable by ASME Section IX, thereby, making it a non-essential variable for AWS D1.1 work done under the controls of the GPUN welding progra The facts relating to the particular weld indicated your program did not

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address AWS D1.1 nor ASME IX QW-202.2(b) requirements for partial penetration welds. The NRC agrees that an ASME Section IX program, such

, .' as the GPUN program, can be used to accomplish AWS D1.1 work as long as the requirements of AWS D1.1 are met. In this case they were not met because your program did not control the effective throat for the partial penetration weld. Additionally, the GPUN welding program does not address skewed tee joint welds which could become a problem are These matters were further discussed with you during NRC Inspection 86-19. During these discussions, you pointed out that you felt it was

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the engineers' responsibility to address these problems. The NRC agrees that engineering should be aware of the options available to them through the welding program when a weld joint is designed. However, the welding program should address the basic minimum requirements of the applicable codes it is designed to address. The NRC will follow up the engineering aspects of this problem in a subsequent inspection. At the conclusion of discussions between the NRC inspectors and your welding personnel, it was our understanding that you intend to revise Section 4.10 of the GPUN

%' idin- Standard as follcus;

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Paragraph 4.10.1.2 will be revised to address AWS D1.1 minimum effective throat requirements for partial penetration welds, and

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A new paragraph, 4.10.1.5, will be added to address skewed tee joint welds to include control of effective throat of skewed tee joint fillet welds as presented in Appendix B of AWS D1.1.

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Violation D.(2J: This portion of the violation identified failure of QC to identify inadequate partial penetration welds. Your response stated you did not concur with this finding because neither the weld package nor the

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engineering documentation specified criteria to which an inspection could be performed. As stated in the details of Inspection Report 85-35, the Structural Weld Record Sheets for the welds in question indicated they had been inspected and accepted by QC. By virtue of the fact that you now state 0FFICIAL RECORD COPY LETTER OYC - 0002. /17/86

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there were no inspection criteria, one would question the significance of the l QC signatures on the yeld packag It is important that QC inspection personnel be trained, experienced, and knowledgeable in the disciplines t they inspect. It is apparent in this example that this was nht the case. An inspector familiar with AWS D1.1 welding and associated inspection criteria would have identified the inadequate weld penetration as a deficiency and not accepted the weld. The function of a QC organization is, in part, to identify unacceptable conditions. To be effective in'this area,sa QC program should not be designed such that effective inspection dan only be accomplished when specific inspection criteria are giv,e *

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