ML18153A506
| ML18153A506 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/24/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 97-132, NUDOCS 9703280225 | |
| Download: ML18153A506 (5) | |
Text
e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 March 24, 1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 REPLY TO A NOTICE OF VIOLATION Serial No.
SPS/BCB/MAE Docket No.
License No.
NRC INSPECTION REPORT NOS. 50-280/96-13 AND 50-281/96-13 97-.132 R2.2 50-281 DPR-37 We have reviewed Inspection Report Nos. 50-280/96-13. and 50-281/96-13 dated February 24, 1997, and the enclosed Notice of Violation (NOV) for Surry Unit 2; The report identified one cited violation for undersized fillet welds in the fabrication of piping support* assemblies.
As described in our attached reply to the NOV, we have concluded that this violation was caused by the welder's failure* to fabricate the correct size fillet weld connections and by the weld inspector's lack of understanding of the weld acceptance criteria.
We have implemented actions to ensure that the weld acceptance criteria are clearly understood by both the welders and the weld inspectors.
We have also verified that our weld inspector training is satisfactory.
We have no objection to this letter being made a part of the public record. Please contact us if you have any questions or require additional information.
Very truly yours, James P. O'Hanlon Senior Vice President - Nuclear Commitments contained in this letter: None Attachment.
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U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station
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- REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED DECEMBER 15. 1996 - JANUARY 25. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/96-13 AND 50-281/96-13 NRC COMMENT:
"During an NRC inspection conducted on December 15; 1996, through January 25, 1997, a violation of NRC requirements was identified. In accordance with the 'General Statement of Policy and Procedures for NRC Enforcement Actions,'. NUREG 1600, the violation is listed below:
10 CFR 50, Appendix B, Criterion V, and. the licensee's accepted Quality Assurance Program, Updated Final Safety Analysis Report Chapter 1 T2.5, Instructions; Procedures, Drawings, require that activities affecting quality shall be prescribed by documented drawings and accomplished in accordance with these drawings.
. Drawings S-96040-2-C-004, S-96040-2-C-001, and S-96040-2-C-003 require 1/4" weld sizes for all fillet weld connections for supports H-2, H-4, *and H-10.
Contrary to the above, activities were not accomplished in accordance with documented.drawings.
On December 16, 1996, several fillet welds for pipe supports H-2, H-4, and H-10 completed in the mechanical shop and accept~d by the licensee's inspectors were measured to be 3/16" which were less than* the*
1/4" specified on drawings S-96040-2-C-004, S-96040-2-C-001, and S-96040-2-C-003.
This is a Severity Level IV Violation (Supplement I)."
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. 1.
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED DECEMBER 15, 1996 - JANUARY 25. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/96-13 AND 50-281/96-13 Reason for the Violation, or, if Contested, the Basis for Disputing the Violation Ttie violation is correct as stated and was caused by: 1) the welder's failure to fabricat~ the correct size fillet weld connections for pipe supports H-2, H-4, and H-10 and 2) a lack of understanding of the weld acceptance criteria by the inspector who performed the final inspection of the subject weld connections.
- Design drawings S-96040-2-C-004, S-96040-2-C-001, and S-96040-2-C-003 require a weld size of 1/4 of an inch for all fillet weld connections for pipe supports H-2, H-4, and H-10. The welder fabricated the welds to the nominal size specified by the drawings, but did not ensure that the welds measured at least 1/4 of an inch along the complete length of each.weld.
The subject welds were fabricated and inspected in accordance with American Welding Society (AWS) D1.1, "Structural Welding Code - Steel." The visual acceptance Qriteria of AWS D1.1 allows the weld _to be larger. than the size specified by the design drawing and specifies an allowable minus weld size tolerance of 1/16 of an inch (provided the undersized portion of the weld does not exceed 10%. of the total length-of the weld).
Virginia Power's weld acceptance criteria is consistent with the AWS D1.1 _criteria, except that the allowable minus weld size tolerance is zero.
The weld inspecto_r did not understand Virginia Power's acceptance criteria and mistakenly applied a plus or minus tolerance in determining weld acceptance.
- 2.
Corrective Steps Which Have Been Taken and the Results Achieved A Deviation Report was initiated to document the deficiency and ensure appropriate corrective actions were implemented.
Although the undersized welds would have been acceptable for the actual pipe support loads, each was prepared and rewelded to the correct size. The welds on the subject pipe supports were* reinspected and found to be acceptable.
These actions were *implemented before the piping support assemblies were placed in service.
The weld inspector's certification was revoked since the inspector did not
- understand all of the requirements for performing structural weld inspections.
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- 3.
Corrective Steps Which Have Been Taken and the Results Achieved (Continued)
- A summary of structural weld inspection requirements was prepared by the instructor who conducts weld inspector training. The summary was reviewed by both welders and weld inspectors through required reading to reinforce the
- inspection requirements.
The Quality Maintenance Team Coordinator, who is an AWS Level Ill certified weld inspector, subsequently evaluated the weld inspector's knowledge level using the job performance measures developed by the Nuclear Training Department for initial weld inspector certification. The inspector demonstrated a satisfactory knowledge of acceptable piping and structural weld inspection techniques and was later recertified to perform weld inspections.
The subject inspector was initially certified and approved to perform safety-related weld inspections on February 20, 1996. Documentation for safety-related structural welding that occurred subsequent to that date was reviewed..No additional structural weld inspections by the subject inspector were identified.
The training progr;:i.m for weld inspectors was reviewed to ensure the program provides appropriate instruction. No deficiencies were noted.
Corrective Steps Which Will be Taken to Avoid Further. Violations The corrective actions described in Section 2 are sufficient to preclude similar violations.
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The Date When Full Compliance Will be Achieved Full compliance was achieved on
- December 18, 1996, when the identified undersized welds had been rewelded to the correct size and reinspected.