ML18033B520
| ML18033B520 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/01/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010050210 | |
| Download: ML18033B520 (11) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) i',
ACCESSION NBR:9010050210 DOC.DATE: 90/10/Ol NOTARIZED: NO DOCKET FACIL:50-259 Browne Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 900830 ltr re violations noted in Insp Repts 50-259/90-26,50-260/90-26 6 50-296/90-26.Corrective actions:
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR I ENCL
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SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:1 Copy each to: B.Wilson,S.
BLACK 1 Copy each to: S.Black,B.WILSON 1 Copy each to:
S.
Black,B.WILSON 05000259 05000260 05000296 RECIPIENT ID CODE/NAME HEBDON,F INTERNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S t
NRR/DOEA DIR ll NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DI
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EXTERNAL: NRC PDR COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME ROSS,T.
AEOD AEOD/TPAD NRR MORISSEAUFD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS2 RGN2 FILE 01 NSIC COPIES LTTR ENCL 1
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1 NOTES:
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 28 ENCL 28
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 3740t 6N 38A Lookout Place 00T 01 1S90 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 NRC INSPECTION REPORT NOS. 50-259/90-26, 50-260/90-26, AND 50-296/90-26 REPLY TO NOTICE OF VIOLATION This letter provides TVA's response to the notice of violation transmitted by letter from B. A. Wilson.to 0.
D. Kingsley, Jr. dated August 30, 1990.
NRC cited TVA with a violation containing two examples.
TVA denies both examples of the violation.
The enclosure provides background information and TVA's response to NRC concerns raised in the subject report.
If you have any questions, please telephone Patrick P. Carier at (205) 729-3570 Very truly yours, TENNESSEE VALLEY AUTHORITY Mark 0. Medford, Vice President Nuclear Assurance, Licensing and Fuels Enclosure cc:
See page 2
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Voi0050210 901001 PDR ADOCK 05000259 8
PNU An Equal Opportunity Employer
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U.S. Nuclear Regulatory Commission 00T <11S80 cc (Enclosure):
Ms. S.
C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35609-2000 Mr. Thierry M. Ross, Project Manager U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 208 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
ENCLOSURE Reply to Notice of Violation 50-259, 260, 296/90-26 Restatement of the Violation 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes,
- requires, in part, that measures shall be established to assure that special processes, including welding
. are controlled and accomplished using qualified procedures in accordance with applicable codes ASME Boiler and Pressure Vessel Code (B&PV)Section IX, the applicable code for welding procedure qualification contains the following requirements:
A.
QW-200.2 states in part that the procedure qualification record (PQR) form shall list the actual variables used within the limits of a narrow range, rather than full range of the variables allowed.
B.
Where impact testing of materials to be welded is required, supplementary essential variable QW-403.6 is applicable, which specifies that for material thicknesses less than 5/8 inch the minimum thickness qualified is the thickness of the test coupon.
Contrary to the above:
(1)
PQR GT-SMll-0-3-C lists the full range of variables allowed for shielding gas flow, welding current and arc voltage rather than the actual variables used during the qualification welding.
(2)
PQR GT-SM11-0-3-C, an impact thickness was 1-7/8 inch and inch.
The minimum thickness inch as required by QW-403.6 tes ted PQR s tates that. the tes t plate the minimum thickness qualified was 3/16 limit for impact tested application of 5/8 was not listed.
This is a Severi.ty Level IV violation (Supplement I).
Admission or Denial of the Violation TVA denies the violation.
Exam le (1) of the Violation 1.
Reason for the Denial of this Exam le The ranges recorded on PQR GT-SMll-0-3C are the actual values observed during qualification of the test coupons and include the highest and lowest values observed.
TVA deliberately used a range of values in welding the test coupon and reco ded those values on the welding PQR.
O Enclosure Page 2
ASME Section IX permits the recording of actual values of the ranges of parameters.
1980 ASME Section IX, paragraph QW-200.2 states:
"A manufacturer may include all additional information he may consider helpful, such as the nonessential variables, but is only required to record the essential variables used."
The later codes clarify the recording of variables.
QW-200.2(a),
Summer addenda 1983 states as follows:
. Recorded variables normally fall within a small range of the actual variables that will be used in production welding.
(b) Contents of the PQR-The completed PQR shall document all essential and supplementary essential (when required) variables of QW-250 through QW-280 for each welding process used during the welding of the test coupon.
Nonessential or other variables used during the welding of the test coupon may be recorded at the manufacturer's or contractor's option.
All variables, if recorded, shall be the actual variables (including ranges) used during the welding of the test coupon.
If variables are not monitored during welding, they shall not be recorded.
It is not intended that the full range or the extreme of a given range of variables to be used in production be used during qualification unless required due to a specific essential or supplementary essential (when required) variable."
It is clear from the above that ASME Section IX does not require nor prohibit recording actual values of used nonessential variables for a range of observed values.
It is also clear that actual values used in welding the test coupon may be recorded for the range expected to be used in production welding.
This position is supported by the following ASME Code interpretations:
IX-79-73, IX-81-41, IX-80-23, and IX-79-71.
ASME Interpretation IX-81-41 defines narrow range and broad range and describes how a manufacturer specifies and qualifies an essential variable consisting of a range.
It states:
"...It is not generally practicable to have too narrow a range and meet the capabilities of control and measuring equipment, nor too wide a range and still meet the combinations of the several essential variables required for the application.
.The PQR should list the actual range of the variable as measured during the welding of the qualification test coupon."
2.
The Corrective Ste s Which Have Been Taken and the Results Achieved No cor ective steps are needed.
3.
The Corrective Ste s Which Will be Taken to Avoid Further Violations No corrective steps are needed.
4.
The Date When Full Com liance Will be Achieved TVA believes it is in compliance for the cited example.
Enclosure Page 3
Exam le (2) of the Violation 1.
Reason for the Denial of This Exam le PQR GT-SM11-0-3C records a "Thickness Range Qualified" of 3/16 inch through 8 inches.
Therefore, the PQR can be used as a reference document for non-impact applications down to 3/16-inch thickness's permitted by QW-451.
TVA agrees that the PQR cannot be used as a reference document for impact applications for thicknesses less than 5/8 inch and TVA has not been cited for having done so.
- Indeed, the material which the inspector observed being welded 'did not require an impact test.
Therefore, TVA believes that the welding activity was performed in accordance with applicable codes and standards.
TVA believes the ASME B&PV impact tested applications thickness of material that interpretation III-81-71.
this limitation on the PQR require this limitation to Code is clear that the minimum thickness for is 5/8 inch.
Furthermore, the minimum requires impact testing is clarified in code TVA is not aware of any requirement to list and respectfully submits that QW-403.6 does not be listed.
2.
The Corrective Ste s Which Have Been Taken and the Results Achieved No corrective steps are needed.
3.
The Corrective Ste s Which Will be Taken to Avoid Further Violations No corrective steps are needed.
4.
The Date When Full Com liance Will be Achieved TVA believes it is in compliance for the cited example.