ML19337A717
| ML19337A717 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/25/1980 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19337A716 | List: |
| References | |
| NUDOCS 8009290475 | |
| Download: ML19337A717 (4) | |
Text
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,A CORSum8IS James W Cook j
h Vste hessJune, AtsJiani hoject General Of fices: 1945 West Pernati Road, Jackson, Michecan 49201.(517)788 0640 August 25, 1980
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Mr J G Keppler, Regional Director 5q Office of Inspection and Enforcement gd 1(')4' Tl,L US Nuclear Regulatory Commission d
Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT - NRC ITEM OF NONCOMPLIANCE INSFECTION REPORT N0 50-329/80-20 AND NO 50-330/80-21 FILE:
0.h.2 UFI:
73*60*13 SERIAL:
8818 This letter, with its enclosure, is in response to your letter of July 10, 1980 which transmitted the results of your inspection of the Midland construction site on July 8-10, 1980 and which requested our written reply to a single item of noncompliance concerning welding material purchase controls.
Our further investigation, subsequent to your inspection, has located procurement data which does contain the applicable Code information required for the purchase of the subject velding material.
We have also determined that the heat treatment of the veld material qualifi-cation coupons is in compliance with the applicable Code. The enclosure provides our detailed response and substantiation of the above statements.
Based on the additional information, we believe that the infraction is not appropriate and request that you revise your findings.
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WRB/lr Enclosure
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I CONStBIERS POWER COMPANY RESP 0NSE j
TO Tile ITEM OF NONCO !pL1 ANCE DESCRIDED IN NRC INSPECTION REPORT NO 50-329/80-20 AND NO 50-330/80-21 NONCONFORMANCE-WELDING MATERIAL CONTROL (329/PO-20-01 & 330/80-21-01)
Descriotion of Noncompliance Appendix A of Report No 50-329/80-20 and 50-330/80-21 provides in part the l
following:
" Based on the. inspection conducted on July 8-10, 1980, it appears that certain of your activitics were in noncompliance with NRC i
j requirements, as noted below.
This item is an infraction."
"Bechtel Corporation Welding Standard WFMC-1, Revision 8, dated January 4, 1971, ' Welding Filler Material Control Procedure l
Specification' paragraph 2.1, states, in part, that, '.
. Uelding filler material ordering information shall include the appropriate requirements of the job engineering specification, the applicabic Code, an,d this procedure specification.
" Contrary to the above, on July 10, 1980, the inspector established 4
Bechtel Purchase Order No. 7220-F-5780, dated November 2, 1973 for 60,000 lbs. of E7018 electrodes did not specify the applicable code."
Response
i i
Subsequent to your inspection of July 8-10, 1980, a review of procurement docu-raents and weld filler material ordering specification was conducted.
In parti-cular, procurement records for.the cited purchase order No. 7220-F-5780, dated t
i November 2, 1973 were further investigated.
Purchase order No. 7220-F-5780 was for 30,000 lbs of.1/8 inch diameter and 30,000 lbs of 3/32 inch diameter, type E-7018, Arc Welding Electrodes.
. Investigation of the subject purchase order revealed the following additional l
informa tion:
i
'1)
The Bechtel specification for procurement of welding filler material, ap-plicable at the time of procurement was WFMC-1, Rev 0, dated }by 1973.
NOTE: The noncompliance cited Bechtel Specification WFMC-1, Rev 8, dated January 4, 1971.
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2)
Field !!aterial Request (FMR) No. FM-124, dated October 11, 1973, prepored for the subject purchase order, noted in the description, "No Subs per attached sheet."
NOTE: The attached sheet was not availabic for review at the time of your inspection during the period July 8-10, 1980.
3)
Subsequent to your inspection of July 8-10, 1980, attachment No. I to FMR FM-124, prepared for P.O. 7220-F-5780 was located.
- 4) Attachment No. 1, to FM-124, specifies weld filler material procurement to Specification SFA 5.1 (ASME Section II, Part C).
Attachment No. I also specifies the mechanical, chemical tests, and conditions required for veri-fication of weld filler materials. Attachment No. I consists of two pages; one page for 3/32" diameter electrode, and one page for 1/8" diameter electrode.
It is noted that Attachment No. 1 is page 12 of 13 of welding filler material Specification WFMC-1, Rev 0, dated Iby 1973.
Page 12 of 13 of Specification WFMC-1 format provides space for the addition of the re-quired ordering particulars, such as item no., quantity, and shipping destination.'
- 5) Revicu of material (certificate of analysis) receiving reports for the sub-ject purchase order, shows tha t they state that the material conforms to Specification AWS A 5.1-69.
Results of the required tests are reported and the resultu meet all of the requirements of the Bechtel Specification, the attachment, to the field material requisition, WFMC-1, Rev 0, and ASME SFA 5.1.
It is noted that AWS A 5.1-69 is identical to SFA 5.1. which is so stated in the ASME Code.
Consumer Power has initiated an audit af weld filler materials procurement and receiving documentation and includes documentation related to weld filler materials procured from 1973 to the prescat.
It is felt that the statement in the report that the stress relieving rime ap-peared to be in violation of the Code is in fact incorrect and that the subject E7018 electrodes meet the applicable Code in all respects.
The statement is found on page 4, from the " Details" section of the report.
Item 5 from this page says in part:
"It was further determined frota the material certification that the 60,000 lbs of E7018 electrodes purchased under this order was stress relieved for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> at l l 50"P.
This stress relieved t'ime appeared to be in violation of the 1971 Edition of ASMC Section III; however, the inspector determined it is technically acceptable."
The applicable Section of the 1971 ASME Code which covers this subject is NB-2430
" Weld Metal Test."
The conclusion of the inspection re, art appears to be based on the fac t that per paragraph NB-2431.2b, test coupons shall be subject,to the requirement that "the time at post veld heat-treatment shall he eight hours (this qualifies post weld heat treatment of ten hours or less)."
This Code section further states, "t.'here the post veld heat treatment of the component exceeds ten hours, the general test of NH-2411.1 shall be used."
This section requires that
3 the test coupons pont weld heat treatment holding tirae shall be at least 80 percent of the maxinum tine to be applied to the weld metal in the component.
The total holding P1lIIT tine is the cumulative PtillT time that the conponent will receive and includes the time during installation and any repair cycles.
The purpose of this extended PilllT holding time is to qualify the welding materials for fabrication conditions expected to be experienced in recognition that the mechanical properties will be reduced with Pll LIT time.
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8/22/80