IR 05000358/1981027
| ML20053E315 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 06/02/1982 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Borgmann E CINCINNATI GAS & ELECTRIC CO. |
| Shared Package | |
| ML20053E316 | List: |
| References | |
| NUDOCS 8206070791 | |
| Download: ML20053E315 (3) | |
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Docket No. 50-358 Cincinnati Gas and Electric Company ATIN:
Mr. Earl A. Borgmann Senior Vice President Engineering Services and Electric Production 139 East 4th Street Cincinnati, OH 45201 Gentlemen:
This is in response to your interim letter dated February 23, 1982, informing us of the steps you have taken to correct the items which we brought to your attention in Inspection Report No. 30-358/81-27 forwarded by our letter dated January 22, 1982.
We reviewed your response and have the following comments:
Item 1 We note that your measurements were taken using a calibrated dial indicator. Our measurements were tahan using conventional weld measuring methods which usually provide suitable dimensional accuracy.
We wish to point out that weld HP-43 is a full penetration butt weld and not a fillet weld on a thermoweld as stated in your response. We received your letter dated April 27, 1982, supplementing your initial response with regard to weld HP-43.
We will examine this matter during a subsequent inspection.
It is our view that a sample inspection of 18% of all shop and field welds in one system, the RHR System, is not sufficient to indicate a trend. Additional sample inspections in other safety related systems are required.
Item 2 The nonconformance report referenced in your response documented linear surface indications. The NRC liquid penotrant examination identified these same linear indications.
In addition, our examination identified what appeared to be lack of full penetration at the root of the double bevel groove weld inside the 1/2" x 3" relief cut in the lug.
It is our view that the nonconformance report mentioned in your response did not identify this lack of penetration, that this could Le a generic problem and further investigation is required on your part.
8206070791 B20602 DRADOCKOSOOOg
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Cincinnati Gas and Electric
JUN2 1982 Company Item 3 The additional information you provided indicates S&L design minimum wall thickness was met.
We have no further questions at this time. Concerning the weld identified as HP-12A actually being HP-12, it should be noted that we selected welds using site drawings and records.and that the wolds were actually located and identified in the field by CG&E personnel.
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Item 4 Our review of radiographs of safety related welds identified foreign particles, i.e., dirt, rust, and loose scale, on the inside of the pipe. The following is a list of the welds and the radiograph film areas where foreign particles were noted:
Weld No.
RT Area LP-29B 2-3 HP-1C 2-3 HP-9 2-3 HP-SW-32 2-3 1-FC-02-AB8-18(Weld A)
3-4 It is our view based on the sample we reviewed that this may be a generic i
problem. We are concerned that your reviewers did not identify any such problems during their review. Please assure that your site film reviewers-are properly instructed on how to recognize, identify, and document foreign matter and debris on the inside of pipe. We will examine this matter during a subsequent inspection.
Item 5
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Your response stated the investigation into this matter will be completed by May 31, 1982. We will review this matter upon receipt of your followup report.
Item 6
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We can not accept your position that CG&E will not specifically identify mismatch-by radiography. Our independent analysis performed by Franklin Research Center identified that the " straight line" condition that appeared on the radiograph of weld FC-100 masked an ASME Code rejectable region of lack of fusion at the root. 'Furthermore, ASME Code Section III requires that offset (mismatch) and sharp corners be faired at a 3 to 1 taper over the width of the weld to eliminate stress risers, corrosion crevices, and
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masking in the radiograpnic film.
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Cincinnati Gas and Electric
JUil 2 13S2 Company In response to a similar finding at Rancho Seco, the licensee requested that Bechtel Corporation perform a fatigue evaluation of this condition. This program did not produce evidence th-; failure would occur because of the presence of the imperfection. However, this program determined that (1)
controlling offset in the joint. (2) having a proper purge, and (3) using the proper welding technique were the three m st significant welding vari-ables in preventing this condition.
In addition, the program determined that the welding technique must result in a nearly flush or slightly straight contour on the inside surface of the root bead.
It is our view that the " straight line" condition an a radiograph could be detrimental to intended service. As a result, an evaluation of the existing piping should be included in your Quality Confirmation Program, more stringent fitup practices should be employed to reduce the possibility for mismatch, and when a condition that appears as a " straight line" is observed on the radiographic film it must be identified, documented and evaluated.
With regard to Items 1, 2, and 6, please inform this office in writing vithin 30 days of receipt of this letter of the actions you have taken or plan to take to resolve these matters.
The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paper-work Reduction Act of 1980, PL 96-511.
Your cooperation with us is appreciated.
Sincerely, h/ W 5%
h C. E. Norelius, Director v
Division of Engineering and Technical Programs cc:
J. R. Schott, Plant Superintendent cc w/1tr dtd 2/23/82:
DMB/ Document Control Desk (RIDS)
Robert M. Quillin, Ohio Resident Inspector, RIII Department of Health Harold W. Kohn, Power Thomas Applegate Siting Commission Thomas Devine, Associate Citizens Against a Radioactive Director, Institute for Environment Policy Studies Helen W. Evans, State of Ohio RIII RIII R I I h,. '7 ' RI I RIII R I W]ard/jp lY
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Y hf D ielson Little
. 'o r e l ius Streeter Davis 4/30/82
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