ML19211D367

Forwards Response to NRC 791219 Ltr Re Violations Noted in IE Insp Rept 50-338/79-47.Corrective Actions:Welding Procedures & Qualification Records Updated to Include Weld Metal Thickness Deposited by Each Process

ML19211D367
Person / Time
Site:	North Anna
Issue date:	01/15/1980
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
1171-121979, NUDOCS 8001180240
Download: ML19211D367 (3)

Text

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VIMGINIA Er.ecrutc ann Powen ConmNY nacn> town.Vxuorm couen January 15, 1980 Mr. James P. O'Reilly, Director Serial No. 1171/121979 Office of Inspection and Enforcement P0/IMr:baw U. S. Nilclear Regulatory Ormission Docket No. 50-338 Region II 101 Marietta Street, Suite 3100 License No. NPF-4 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

We have reviesed your letter of Decarber 19, 1979 in reference to the inspection conducted at North Anna Power Station Unit No.1 on Novenber 13-16, 1979 and reported in IE Inspection Report No. 50-338/79-47.

Our responses to the specific infractions are attached.

We have determined that no proprietary information is contained in the report. Accordingly, the Virginia Electric and Pomr Capany has no objection to this inspection report being made a matter of public disclosure.

Very truly yours, C. M. Stallings Vice President-Power ply and Production Operations Attachnent cc: 3'r. Albert Sc%ncer 1765 267 A40 n o o 1 18 0 c@~ O

At tachnent : Page 1 Response to Notice of Violation Itons Reported in IE Inspection Report 50-338/79-47 A. NRC Carment As required by Criterion V of Appendix B to 10 CFR 50 and irTplenented by VEKD Topical Report VEP-1-A Section 17, paragraph 17.2.5 specifies in part, that activities affecting quality are accarplished in accordance with instructions, procedures, and drawings. General Welding Procedure W-1.0 Rev.1 invokes ASE Section IX (74.Wl6) which under paragraph QV-2013, requires that cach welding process or procedure be qualified either separately or in carbination with other processes or procedures

... for the deposited weld metal thickness range for each of the processes or procedures... paragraph QV-351 of the same code requires that the limit of thickness for which a welder is qualified is dependent upon the thickness of the weld he deposits with each welding process.

Cbntrary to the above, on Novenber 16, 1979, procedure qualification records of weld process specifications and welder performance qualifi-cations involving carbination processes did not indicate the weld tretal thickness deposited with each welding process.

'Ihis is an infraction.

Response

Qualification records of welders and weld procedures involving a carbi-nation of weld processes did not indicate the weld metal thickness deposited by each process, as required by ASE Section XI QV-201.3 and QV-351, because the requirement was interpreted incorrectly and un-intentionally overlooked when the procedures were originally written.

Pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, the following infonnation is subnit ted:

1. Cor m tive stecs taken and results achieved:

Welding procecures involving canbination processes are presently in the p ocess of being updated to include the weld metal thickness deoosited by each welding process. hhen this is accomplished, full emnliance with the ASE codes will have been achieved.

2. Car ective steos which will be taken to avoid further non-carpliance:

we celieve that no further corrective action is required.

3. Date when full camliance will be achieved:

All necessary updating of welding procedures will be coTpleted and full ccr:pliance will have been achieved by March 15, 1980.

~ 1765 268

Attachnent: Page 2 B. NPC O m ,ent As required by Criterion XVII of Appendix B to 10 CFR 50, and inplanen-ted by VEPCD Topical Report VEP-1-A, Section 17 paragraph 17.2.17 specifies in part that quality assurance records relating to activities affecting quality shall be unintained as documentary evidence of work perfonnance. Paragraph (s) I-2-2120, I-2-2130, of ASME Section XI (74.S75) requires that ultrasonic equipnent be standardized for screen height and anplitude control 1inearity.

Contrary to the above, on Novenber 16, 1979, there was no documentary evidence to verify that code required standardizations were being perfonned on licensee owned ultrasonic instrunents used for volunetric examinations.

This is a deficiency.

Response

In the past, Ur instranents have been periodically calibrated to manufacturer specifications. During this calibration, standardization of screen height and anplitude control linearity was perfonned but not docunented.

Pursuant to Section 2.201 of the NRC's " Rules of Practice", Part 2 Title 10, Code of Federal Regulations, the following infonmtion is subnitted:

1. Corrective steps taken and results achieved,:

Calibration of ultrasonic equipnent for screen height and amplitude control lineari:v has been incorporated in a new UT procedure and will be docunented on a separate fonn. The calibration /standardi-zation will be perfonned by the equipnent operator at least once every 3 months as required by the AfAE codes.

2. Corrective stecs which will be taken to avoid further non-compliance:

we believe that no further corrective action is required.

3. Dite when full ccmliance will be achieved:

Inil comliance will be achieved by February 15, 1980.

. 1765 269