ML19269E757

Responds to NRC 790504 Ltr Re Violations Noted in IE Insp Rept 50-395/79-10.Corrective Actions:Clarification of Work Guidelines for Piping Welding

ML19269E757
Person / Time
Site:	Summer
Issue date:	05/25/1979
From:	Mary Johnson SOUTH CAROLINA ELECTRIC & GAS CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19269E748	List: ML19269E757
References
NUDOCS 7906290580
Download: ML19269E757 (3)

Text

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                                                                                                                    , rG P           d C1 United States Nuclear Regulatory Commission                                                      C            J70-
                                                                                                        **               li ATTN: Mr. James P. O'Reilly                                                                                     f Director                                                                           j($         -{ ! -
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Marietta Building, 31st Floor 101 Marietta Street, NW Atlanta, Georgia 30303 Subj ect: V. C. Summer Nuclear Station Unit #1 Response to NRC Audit Report 50-395/79-10 dated May 4, 1979 Gentlemen: In response to the above captioned report, we have reviewed the infor-mation found there-in and find it contains no proprietary information. In addition, we have evaluated the circumstances relating to the item identified as 79-10-01 in the captioned report, which dealt with internal pipe weld profile requirements and have confirmed with the NSSS supplier that the weld is acceptable in the "as welded" condition. Examination of the background of this determination provides the following information:

1. Cause a) The piping installation specification (SP-220) and information provided by the NSSS to the Architect / Engineer to guide its preparation failed to reflect the desired condition that 27 ", 29" and 30" primary class 1 piping have " flush" welds as defined by the ASME code and that auxiliary class 1 piping (including the 14" surge line), have welds in the ASME III "as welded" condition on the inside diameter because the inside diameter is inaccessible. The requirement of SP-220, item 1:14.8.lA and 1:14.8.28 reflect opposite positions on

                                 " flush" and "as welded" requirements in relation to stress indicec.

2142 291 79062905F6 $0/5 / OFFlCIAL O

Mr. James P. O'Reilly Page 2 May 25, 1979 b) The Constructor failed to explicitly incorporate requirements in relation to either " flush" or "as welded" conditions into either the work or QC procedures. Neither the engineering nor the QA review of these procedures identified this as an item requiring resolution. Oral advice from the NSSS clarified the acceptability of "as welded" inaccessible I.D. welds but this was not documented. c) As noted in report item 395/79-03-02, NRC Inspectors observed primary loop I.D. and O.D. " flush" ground welds and requested licensee confirmation on all welds. During the subsequent inspection, the Constructor QC failed to prepare a noncon-formance notice on the presaurizer to surge line "as welded" I.D. weld due, in part, to oral clarification provided by the NSSS.

2. Immediate Corrective Steps Taken and Results a) NCN 670 was prepared on March 24, 1979, and dispositioned May 17, 1979 acceptable "as is" based on documented information provided by the NSSS dated April 18 and May 11, 1979.

b) Confirmation has been obtained from the NSSS that objective evidence is available for audit to indicate the use of the "as welded" index for the subject joint. c) Item 1:14.8.lA of SP-220 is being revised to delete any reference to surge line.

3. Corrective Steps Taken to Avoid Future Noncompliance a) Constructor personnel have had reinforced the requirement that oral " clarifications" are not permitted to guide work activities.

b) In view of the complications surrounding the weld profile concern, the failure of procedure reviews to identify and clarify the work and QC procedures in this area, is considered an isolated deficiency not requiring system corrective action. 2142 292

Mr. James P. O'Reilly

 ;     Page 3 May 25, 1979

4. Full Compliance Date All action described is complete with the exception of the

       -.        pipe erection specification change which is presently being processed by the Architect / Engineer.

We trust that you will find our actions to resolve this item appropriate and satisfactory. Please feel free to contact us if we can provide additional information in relation to this item or the subject reports. Very truly yours, DAN /MCJ/jls cc: C. J. Fritz G. C. Meetze 2142 293}}