IR 05000458/1989012

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/89-12

ML20247R255
Person / Time
Site:	River Bend
Issue date:	05/26/1989
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8906070186
Download: ML20247R255 (2)

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LMAY 2 6'1989 L ,

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Docket: 50-458/89-12 ~ ,

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. Gulf States Utilities

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d A1TN: Mr. ' James C. Dedden .;

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.P.O. Box-220 p .St. Francisville, Louisiana 70775 j Gentlemen: ,

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Thank you for your letter of May 12, 1989, in response to our letter and-

[ Notice of Violation dated ~ April 7,.1989. We have reviewed your reply and fin , ll p it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your: corrective actions during a future

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.. inspection to determine that full compliance has;been achieved and will bef s

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.2 Sincerel l Original Signed By- i L. J. Callan ' ~l ,

L. J. Callan, Director Division of Reactor Projects

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Gulf States Utilities e ATTN:- J. E. Booker, Manager-River Bend Oversight i P.O. Box 2951 Beaumont, Texas 77704

1 Gulf States Utilities ATTN: Les England, Director i Nuclear Licensing - RBNG R P.O. Box 220 St. Francisv111e, Louisiana 70775 l

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May 12,1989 -

RBG- 30889 File Nos. G9.5, G15. b U. S. Nuclear Regulatory Commission Document Control Desk '

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Gentlemen-

River' Bend Station - Unit 1 Refer to: Region IV Docket No. 50-458/ Report 89-12

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Pursuant to *0CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation'for ,

NRC . Inspection Report No.1 50-458/89-1 The inspection was 1 performed by Mr. L. D. Gilbert during the period of March 27-31, 1989 of activi+1as authorized by NRC.0perating License NPF-47 for-River Beni Station - Unit GSU's response to the violation is provided in the- attachmen This completes GSU's response to this ite This letter is being submitted on this date per telephone conversation with' Mr.- G. L. Constable on May 10, 1989. Should you have any questions, please contact Mr. L. A. England at (504)  !

381-414

Sincerely,

/ N J. C. Deddens Senior Vice President i River Bend Nuclear Group JCD/ E LAE/RJK/N/ch i i

Attachment cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 i Arlington, TX 76011 NRC Senior Resident Inspector P. O. Box 1051

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St. Francisville, LA 70775

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CODE (ISSION-STATE OF LOUISIANA )

PARISH OF WEST FELICIANA ).

In the Matter of ) Docket No. 50-458 50-459 GULF STATES UTILITIES COMPANY )

(River Bend Station, Unit 1)

AFFIDAVIT J. C. Deddens, being duly sworn, _ states that he is a Senior Vice President of Gulf States Utilities Company; that i

he is authorized on the part of said. company to sign and file with the Nuclear Regulatory Commission the documents l attached hereto; and that all such documents are true and i correct to the best of his knowledge', information and belie )

./ l J. C [Deddens }

Subscribed and sworn to before me, a Notary Public in 1 and for the State and Parish above named, this [ day of O , 19 b .

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West Feliciana Parish, Louisiana

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ATTACMENT Res'ponse to Notice of Violation 50-458/8912-01 REFERENCE:

Notice of Violation - Letter from R. D. Martin to J. C. Deddens, dated April 7, 1989.

L VIOLATION:

Criterion IX of 10 CFR Part 50 specifies that measures shall be established to assure that welding is controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes and other special requirement Procedure SPP-7004, Revision 3, specifies that welding procedure specifications shall be qualified in accordance with the ASME Boiler and Pressure Vessel Code Section IX, latest edition and current addend Contrary to the above: The 500 degree Fahrenheit maximum interpass temperature specified by Welding Procedure Specification (WPS) W3-01, Revision 4, was not qualified by the referenced procedure qualification reports for materials requiring. impact properties and post-weld heat treatmen ' Weldiac procedure specification qualifications were not accomplished using the latest edition and current addenda of Section IX of the ASME Code. For e.' ample, Procedere Qualification Reports (PQR) 88-11-WP and 89-88-TW-2 state that the qualifications were performed in accordance with Section IX, 1986 Edition and 1986 Addenda when the current addenda at the time was L! inter 1987 Addenda for one and Summer 1988 Addenda for the othe REASON FOR VIOLATION: Of the five (5) PQRs listed as qualifications for WPS W3-01, PQR 85-1-1, which was qualified at 400 degrees Fahrenheit, was used as justification for the maximum interpass temperature Ibait of 500 degrees Fahrenheit, in accordance with paragraph QW-406.3 of ASME Code Section IX. PQR 85-1-1 had acceptable impacts, tensiles, and the necessary interpass temperature during qualification and was therefore applied to the WPS. GSU failed to notice that PQR ,85-1-1 failed to meet ASME Code Section III, Table NB-4622.7(b)-1, " Exemptions to Mandatory PWHT" for preheat temperatur The documented preheat temperature on PQR 85-1-1 was 72 degrees Fahrenhei It needed to be 200 degrees Fahrenheit to qualify for a 500 degrees Fahrenheit maximum interpass temperature under NB-4622.7(b)- It was therefore incorrectly applied to WPS-W3-01 as justification for the Su0 degrees Fahrenheit maximum interpass temperatur Page 1 of 2 h

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b. The }987 and 1988 addenda to the ASME Code Section IX had been received but had not been distributed to the Code book holders. It has been determined that the distribution of the latest addenda to the Code book holders was an oversigh CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED: The WPS was revised on March 31, 1989 vie Weld Manual Change Notice (WPCN)89-006 to WPS W3-01 to correct the maximum allowable interpass temperature to 425 degrees Fahrenheit. A review of 492 ASME Code Section XI repair / replacement plans since May 17, 1985 was performed to verify that no impact work had been performed utilizing the non-qualified 500 degrees Fahrenheit maximum interpass temperature. None were foun b. On April 1, 1989, the 1987 and 1988 addetida were placed in 'the ASME Code books for future use. It should De noted that these changes in the later addenda do not affect the qualification of any POR CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS: The failure to incorporate the correct maximum interpass temperature in the WPS is considered to be an isolated case. However, a copy of this violation response will be distributed to GSU's QA organization and our Authorized Nuclear Inservice Inspector, who provide the weld procedure reviews and approvals, for required reading in order to detect a recurrence of this typ There is no evidence of a generic or programmatic problem from the identified root caus The latest Code addenda have been incorporated into the Code book Procedural compliance should ensure that the latest Code edition and current addenda will be used in the futur DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

By June 12, 1989 required reading of this violation response will be completed by those who review and approve weld procedure l Page 2 of 2