ML19308D011

Responds to NRC 791214 Ltr Re Violations Noted in IE Insp Repts 50-508/79-10 & 50-509/79-08.Corrective Actions:Welders & Supervisory Personnel Instructed Not to Modify or Circumvent Requirements in CB&I QA Manual

ML19308D011
Person / Time
Site:	Satsop
Issue date:	01/18/1980
From:	Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19308D010	List: ML19308D011
References
GO3-80-91, NUDOCS 8002130085
Download: ML19308D011 (3)

Text

'

J P Washington Public Power Supply System A JOINT OPERATING AGENCY S

h r o on ,12 stu . wass,~oro ..s.i January 18, 1980 esone iro. ..:.. 2.

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REcDVE0 JAtt g4 ,g80 hg Nuclear Regulatory Commission, Region V Q LE Suite 202, Walnut Creek Plaza - .

1990 N. California Boulevard 'c.

Walnut Creek, California 94596 Attention: fir. G. S. Spencer Chief Reactor Construction and Engineering Support Branch Subject : WPPSS NUCLEAR PROJECTS 3 AND 5 NRC INSPECTION 0F WNP-3 AND WNP-5 DOCKET NUMBERS 50-508 AND 50-509

Reference:

1) Letter, G. S. Spencer to N. O. Strand, same subject dated December 14, 1979.

2) Letter, D. F. Knuth to all AEC Licensees, " Criterion for Determining Enforcement Action and Categories of Noncompliance", dated December 13, 1974.

Dear Mr. Spencer:

This letter is in response to your letter of December 14, 1979, which discussed the results of the inspeciion conducted November 6 through 9, 1979 of activities authorized by Nuclear Regulatory Commission Construction Permit Numbers CPPR-154 and CPPR-155. The letter identified three notices of noncompliance categorized in accordance with Reference 2, and required the Supply System to provide a res-ponse to these items.

The specific Nuclear Regulatory Commission Findings, as stated in your letter, and the Supply System responses are provided in Attach-ment I to this letter.

Should you have any questions or desire further information, please feel free to contact me directly.

Very truly yours, D. L. Renberger Assistant Director, Technology Attachment 8 0 0 213 0085~

S & O/

l. . . .

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ATTACHMENT I Nuclear Reaulatory Comission ' Finding A 10CFR50, Appendix B, Criterion V, as implemented by Section 17.4.5 of the Quality Assurance Program documented in the approved PSAR deviation 18-WP, states in part, that " Activities affecting quality...shall be accomplished in accordance with... instructions, procedures or drawings."

Chicago Bridge and Iron Special Instruction No. SI-2, Rev. 0 (Entitled " Field 4-Hour Coated 'leld Electrode Control") requires that weld electrode being g retugned by a welder..." shall be placed in a bakirg oven and held at 250 F (200 F minimum) for eight (8) hours prior to reissuance. This oven shall be marked "8-hour Holding Oven...".

Contrary to the above, on November 7,1979, the NRC inspector observed that welding electrodes were returned by a welder and placed in Unit 3 electrode Oven No. B, labeled " Issue Oven", and other electrodes subsequently issued from the same oven. The oven immediately below Oven No. B, was labeled Oven No. C " Hold Oven", and was not utilized during the transactions.

Corrective Actions Taken Chicago Bridge and Iron has instructed the welders and responsible supervisory personnel in the proper handling of welding materials. They have been in-structed not to modify or circumvent the storage, care and conditioning requirements as set-forth in Chicago Bridge and Iron's QA Manual.

The Supply System Quality Assurance surveillances of weld electrode issue has been increased to verify compliance with procedural requirements. The increased surveillance will remain in effect until the Supply System is satisfied with Chicago Bridge and Iron's implementation. Increased surveillances are scheduled to start during the week of January 14, 1980.

Nuclear Regulatory Commission Finding B 10CFR50, Appendix B, Criterion V, as implemented by Section 17.4.5 of the Quality Assurance Program documented in the approved PSAR deviation 18-WP, states in part, that " Activities affecting quality...shall be accomplished in accordance with... instructions, procedures or drawings."

Chicago Bridge and Iron General Welding Procedure No. GWPS-SMA-74-3431, Revision 1, states that, "The edges or surfaces of the pieces to be joined by welding shall be.. . cleaned of 011. . . ."

Contrary to this requirement, on November 7,1979, the NRC inspector observed that the welder performing welding on Unit 5 containment vessel Weld No. 53B was welding through an area (approximately 12 inches in diameter at the 15 ft.

mark) which was containminated with oil. .

Corrective Actions Taken The weld in question was completely removed. The plate edges were then cleaned and magnetic particle inspected to assure acceptable weld surfaces prior to seam welding resumption.

L

'J. Attachment I ..

Page 2 Cleaning of plate edges prior to welding, as specified in GWPS-SMA-74-3431, has been discussed with responsible supervisory personnel and welders involved.

Supply System Quality Assurance surveillances of weld preparation cleanliness have been scheduled.

Nuclear Regulatory Commission Finding C 10CFR50, Appendix B, Criterion IX, as implemented by Section 17.4.9 of the Quality Assurance Program documented in the approved PSAR deviation 18-WP, states in part, that "Special Processes, including welding...are controlled and accomplished...using qualified procedures...in accordance with applicable codes, standards, specifications, criteria and other special requirements."

The ASME Boiler and Pressure Vessel Code,Section IX, paragraph QW-251.2 requires that " Essential Variables are those in which a change...is con-sidered to effect the mechanical properties of the weldment, and shall require requalification of the WPS. Supplementary Essential Variables are required for metals for which other sections of the Code specify notch-toughness tests."

The notch-toughness requirement for containment-vessel material is specified in Section 3.8 of the PSAR. Paragraph QW-255.1(a) lists paragraph QW-409.1 as a Supplementary Essential Variable. Paragraph QW-409.1 specifies that variable, in part, as "...a change in the ranges of amperage, voltage or travel speed."

Contrary to the above, Chicago Bridge and Iron Walding Procedure Specification No. #7018/74-3431, Rev. 2 was not requalified for the change in amperage ranges provided in the procedure. For example, the WPS allows a current range of 100-180 amps for 1/8" rod in all positions, and 140-225 amps for 5/32" rod in all positions, whereas, related Welding Procedure Qualification Records Nos. 2631 and 3250 reflect a maximum current of 160 amps for 1/8" rod in overhead and down flat positions, and a maximum current of 190 amps for 5/32" rod in overhead and down flat positions.

WPPSS Response The Supply System does not agree with the NRC in that the subject Chicago Bridge and Iron Welding Procedure Specification (WPS) is not qualified in accordance with ASME Section IX-1974. The contract dated 1974 specifies that the 1974 Summer addenda of the ASME Code Section III NE and Section IX were to apply to the construction of the Unit 3 and 5 containment buildings.Section IX states that the WPS is to specify ranges for the welding variables and that the procedure is to be tested by demonstrating that a sound weld can be made within the specified ranges. One set of variables (voltage, amperage, etc.)

is chosen to demonstrate that the WPS is capable of producing a satisfactory weld.

The Code (Section IX) does not specify that the variables must be taken at either extreme of the range of variables nor does it require.more than one demonstration of the capability of the WPS to produce a sound weld. We believe ,

that the Chicago Bridge and Iron WPS and associated Procedure Qualification Record demonstrate; that the Procedure No. E7018/74-3431, Rev. 2 meets these code requirements.