ML19257C180

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Responds to NRC 790829 Ltr Re Violations Noted in IE Insp Rept 50-423/79-05.Corrective Actions:Heat Input Control Is Being Incorporated Into S&W ASME III Stainless Steel Welding Procedures & Will Be Completed by 800101
ML19257C180
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/28/1979
From: Counsil W
NORTHEAST NUCLEAR ENERGY CO.
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19257C179 List:
References
AEC-MP3-193, NUDOCS 8001250145
Download: ML19257C180 (2)


Text

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9 NORTHEAST UTILITIES l '""*"'o eme hT D CONNECTICUT 06101

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NUCLEAR ENGINEERING AND OPERATIONS September 28, 1979 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 ATTN: Mr. B. H. Grier, Director Docket No. 50-423 AEC-MP3-193 Gentlemen:

SUBJECT:

Millstone Unit No. 3 NRC Inspection Report No. 79-05 Pursuant to the provisions of Section 2.201 of the "NRC Rules of Practice", Part 2 Title 10, Code of c ederal Regulations, this report is submitted in reply to NRC Inspection Report No. 79-05 which informed the Northeast Nucler Energy Company of apparent nonconformance of NRC requirements.

Our response is included below for the two deficiencies listed:

Deficiency (423/79-05-01)

PSAR part 3.1.3.44 states that the corrosion tests of RG-1.44 part C.6 will not be incorporated into procedure qualifications; in lieu of this, the heat input and other essential variables of the procedure shall be monitored to assure that they are in the proper range to avoid sensitization.

Stone & Webster weld Specification W1008, pipe Specification W968, and technique sheets W12B, W12E, W12G, W22F for austentic stainless steel welding do not require monitoring of heat input, nor does the applicable quality control inspection procedure of the Stone & Webster ASME Section III Manual Part 13. (423/79-05-01)

Response: We recognize the PSAR states that Stone & Webster would not incorporate the corrosion tests indicated by Regulatory Guide 1.44 but would control heat input. In actuality corrosion tests w .e made for all of the welding procedurcs examined as well as all others to which RG-1.44 was applicable. Reports of these tests are available for review in Boston. In addition, heat input control is being incorporated into Stone & Webster ASME III stainless steel welding procedures and will be completed by January 1, 1980.

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  • 'E' Deficiency (423/79-05-02)

PSAR part 5.4 invokes NRC Regulatory Guide 1.31 Revision 1, and commits specifically to performance of ferrite measurements on stainless steel production welds. Stone &

Webster Specification W968 had included such measurements.

Addendum 1 to the specification deleted this requirement, and made reference to Stone & Webster filler metal specifications (e.g., ME-103,104, and 105). Licensing Document Change Request Form dated February 6, 1979 (no number identified) described a possible adoption of Revision 2, or maybe Revision 3 of Regulatory Guide 1.31. No clear cut decision was apparrnt from this document.

RG-1.31 Revisions 2 and 3 permit elimination of ferrite measurements on production welds, but impose mot e rigorous controls on the technique of measuring ferrite in filler metal tests. Stone & Webster filler metal specifications, series ME-103,104, and 105 were not revised to incorporate these more rigorous controls. (423/79-05-02)

Response: PSAR Section 5.1 states that Millstone 3 will comply with the intent of Regulatory Guide 1.31, Rev.1. As we understand it, the intent is to control micro-fissures in austentic stainless steel by controlling delta ferrite. Rev. 1 of the regulatory guide required tests on production welds. Such tests were originally included in Specification M-968. When Rev. 2 of the Regulatory Guide was published, it was decided to delete the production tests from our specification. It was determined our weld filler metal purchase specifications provide requirements beyond those provisions of ASME III and that the required tests stated therein, met the intent of Regulatory Guide 1.31, Rev. 2, with one exception. The deletion of the copper chill blocks was determined to be technically acceptable.

It is our position that we are meeting the full technical intent of both Regulatory Guides 1.31 and 1.44 on Millstone 3 and that the PSAR should not be used as the sole guide for regulatory compliance. Statements made in the PSAR reflect comitments agreed to by the NRC in provisions vf the Construction Permit. Changes to the PSAR are not necessary unless there are changes to the principal architectural and engineering criteria set forth therein.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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'Vi'lliam G. Co'linsil Vice President Nuclear Engineering & Operations cc: Nuclear Regulatory Commission Office of Inspection and Enforcement 1808 020 Division of Reactor Operations Inspection Washington, D. C. 20555