ML19341D148
| ML19341D148 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/19/1980 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| ST-HL-AE-575, NUDOCS 8103050004 | |
| Download: ML19341D148 (11) | |
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The Light Company sousion tighiing & rower n o. sox ivoo nouston, Texas 77ooi (713) 22s-92ii ST-HL-AE-575 SFN: V-0110 November 19, 1980 Mr. Karl Seyfrit g g, N '/ \\
<o g Director, Region IV d
Nuclear Regulatory Commission 611 Ryan Plaza Drive O
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Suite 1000 m
Arlington, TX 76012 3
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Dear Mr. Se:
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lM South Texas. Project tt f.b'/
Units 162 Docket Nos. STN 50-498, STN 50-499 Restart of Safetv-related ASME Welding This lc _ :r is to update our request of October 2, 1980, (ST-HL-AE-555),
relative to the reexamination, repair, and restart of safety-related ASME welding activities on the South Texas Project.
In order to verify the implementation of our corrective actions taken relative to ASME welding, we request that Jimited ASME welding be authorized to commence on November 24, 1980.
The specific ASME welding to be initiated is defined on Attachment 1 of this letter.
Equal priority will be given to tne reexamination and repair of ASME velds made prior to April 30, 1980, r.nd to the new production welding.
It is our plan to perfore the ree.xaminations and make the necessary repaire as expeditivasly as possible.
The com=itments listed on pages 10 and 11 of our Response to Order to Show Cause (dated July 28, 1980) relative to restarting ASME welding have been fulfilled, (See Attachment II).
In addition, the corrective actions listed in your letter dated April 17, 1980, relative to the Brown 6 Root Stop Work Order No. S21A have been completed.
The welding identified on Attachment I represents the first phase in our efforts to eventually achieve full production welding on a normal basis.
N 8103050 g
Houston Lighting & Power Compant November 19, 1980 Mr. Karl Seyfrit Page 2 Very truly yours,
- I G. W. Oprea, Jr.
Executive Vice President GWO/kss Attachments
Houston Lighting & Power Company ST-HL-AE-575 SFN: V-0110 Page 3 cc:
J. H. Goldberg D. G. Barker Howard Pyle R. L. Waldrop H. R. Dean D. R. Beeth J. D. Parsons G. B. Painter L. K. Enalish A. J. Granger R. A. Frazar ti. S. Phillips (NRC) d O. Read (Read-Poland,Inc.)-
M. D. Schwarz (Baker & Botts)
R. Gordon Gooch (Baker & Botts)
J. R. Newman (Lowenstein, Newman, Reis, Axelrad & Toll)
Director, Office of Inspection & Enforcement Nuclear Regulatory Comission Washington, D. C. 20555 i
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Houston Lighting & Power Company ST-HL-AE-575 SFN: V-0110 Page 4 M. L. Borchelt Executive Vice President Central Power 6 Light Company P. O. Box ',.121 Corpus Ch isti, Texas 78403 R. L. Range Central Power 6 Light Company P. O. Box 2121 Corpus Christi, Texas 78403
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R. ' L. Hancock Director of Electrical Utilities City of Austin P. O. Box 1088 Austin, Texc5 78767 4
T. H. Muehlenbeck City of Austin P. O. Box 1088 Austin, Texas 7S767
-J. B. Poston Assistant General Manager of Operations City Public Service Board P. O. Box 1771 j
1 San Antonio, Texas 78296 i
j A. vonRosenberg City Public Service Board P. O. Box 1771 San Antonio, Texas 78296 1
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Houston Lighting & Power company ST-HL-AE-575 SFN: V-0110 Charles - Bechoefer, Esquire Chairman, Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission-Washington, D. C. 20555 Dr. James C. Lamb, III 313 Woodhaven Road
- Chapel Hill, North Carolina 27514 Dr. Emr.eth A. Luebke Atomic Safety & Licensing Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Steven A. Sinkin, Esquire-116 Villita Street San Antonio, Texas 78205' Citizens for Equitable Utilities e/o Ms. Peggy Buchorn Route 1, Box 432 Brazoria, Texas 77422 Pat Coy Citizens Concerned About Nuclear Power 5106 Ccsa Oro San Antonio, Texas 77422 Richard W. Lowerre, Esquire Assistant Attorney General for the State of Texas P. O. Box 12548 Capitol' Station
' Austin, Texas 78711 Bernard M. Bordenick Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.~20555 i
ATTACHMENT I ASME Class 1, 2 and 3 Pipe Welding and ASME Subsection NF Pipe Support Welding I.
PRODUCTION WELDING RESTART-Restart of ASME Pipe Welding will begin with the following:
A.
Fabrication and welding in the site fabrication shop.
Typical work would include:
socket welding small bore pipe spools (all classes) butt welding large bore piping up to 3/4" wall thickness (class 3 only) fabricating hangers and pipe supports per ASME Subsection NF B.
Component Cooling Water System in the Unit 1 Mechanical Electrical Auxiliary Building, Cube 3C (ASME Class 3, Carbon Steel, approximately 35 butt welds).
II.
REEXAMINATION AND REPAIR WELDING A.
ASME Class 1, 2 and 3 Pipe Welding (Non-ECW) and ASME Subsection NF Pipe Support Welds The instruction defining the requirements and the scope of w,rk associated with this program has been prepared and issued.
A detailed plan and schedule for performing the reexamination and repair activities is being formulated and will be integrated into the overall project construction schedule.
Repair welding will be initiated on welds which have been found to contain unacceptable indications as a result of radio-graphy performed by tne Show Cause Welding Task Force.
Schedule The estimated time required to reexamine and repair i
ASME Class 1, 2 and 3 butt welds, socket welds and ASME Subsection NF pipe support welds is 12 months.
Assuming a start date of November 24, 1980, the program l
would be completed in December, 1981.
This time esti-mate is based on the following assumptions:
(1) Using one (1) inspection team (2 inspectors) to perform all surface PT and visual examination.
ATTACHMENT I - CONT'D.
ASME Class 1, 2 and 3 Pipe Welding and ASME Subsection NF Pipe Succort Welding (2)
Assigning two (2) welders full time to make all required repair welds.
(3)
Working a 40-hour week.
B.
ASME Class 3 ECW Pipe Welds Reexaminatl9n and repair of existing ASME Class 3 Essential Cooling Water System Pipe Welding will begin with that pipe which has been welded but not currently buried in backfill and proceed to that pipe which must have backfill removed.
, Schedule The estimated time required to excavate, re-examine, repair and backfill approximately 400 ECW field welds is 18 months.
Assuming a start date of November 24, 1980, the re-examination and repair program would be com-pleted in June, 1982.
The time required is based on the following assumptions:
(1)
Using one (1) radiographic team to perform all re-radiography.
(2)
Using one (1) inspection team (2 inspectors) to perform all surface PT and visual examinations.
(3)
Assigning two (2) welders full time to make all required repair welds.
(4)
Working a 40-hour work week..,
ATTACHMENT II RESTARTING ASME WELDING STATUS OF COMMITMENTS FROM RESPONSE TO ORDER OF SHOW CAUSE (HL&P letter of Julv 28, 1980 Paces 10 and 11) 1.
Reconfirmation by B&R's OA Department of the adequacy of the applicable ASME welding procedure qualifications.
Status All B&R ASME Welding Procedure Specifications (WPS's) have been reviewed subsequent to April 17, 1980, re-vised as necessary, approved by QA, and reissued for project use.
2.
Corrective action on items identified in the immediate action letter from I&E Region IV, dated April 17, 1980.
Immediate Action Letter Items 1.
Reconfirmed the qualification of site safety-related welding procedures by:
a.
Confirming the adequacy of existing welding procedure qualifications, or b.
Requalifying the applicable welding procedures.
2.
Completed corrective action for audit deficiencies documented in B&R Audit ST-35, by:
a.
Reviewing MECP's against ASME requirements and revising procedures as necessary.
b.
Reviewing procedures (MECP and welding) to assure that acceptance criteria have been approved by Level III OA personnel.
c.
Assuring that all welder qualifications h. ave been inspected by certified OC inspection ~
personnel.
d.
Determining the cause of failure to adhere to procedures for weld filler material control, and corrective action needed to assure adher-ence.
e.
Developing a Materials Engineering Procedure for the control of weld procedure qualifica-tions.
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ATTACHMENT II - CONT'D.
RESTARTING ASME WELDING STATUS OF. COMMITMENTS FROM RESPONSE TO ORDER OF SH0h' CAUSE (HLSP letter of Julv'28, 1980; Pages 10 and 11)
- Status, Immediate Action Letter Items 1.a.
See 1. above.
1.b.
BSR Materials Engineering and QA agreed that requalification was not required.
2.a.
Material Engineering Construction Procedures (MECP's) have been reviewed, revised to in-corporate applicable ASME requirements and approved by STP Level III QA personnel.
2.b.
MdCP's have been reviewed, revised to incor-porate ASME acceptance criteria, and approved by STP Level III QA personnel.
WPS's have been reviewed and approved by QA (see 1 above).
2.c.
ASME welders used on this program have been re-qualified.
Performance test welds are being inspected by certified QA inspection personnel.
2.d.
Procedure for controlling weld filler material, MECP-8, has been revised and is now clear and specific relative to weld material control.
Specific welding Engineering personnel have been assigned responsibility for controlling weld materials.
2.e.
Materials Engineering issued MES-001 on April 24, 1980.
QA approved MES-001 on April 25, 1980.
3.
Revision of certain sections of the B5R STP QA Manual to reflect recent changes in the QA program Status Sections 1 (Organization), 3 (Design Control), 9 (Control of Special Processes), and 15 (Control of Nonconforming Conditions) were revised.
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ATTACHMENT II - CONT'D.
RESTARTING ASME WELDING STATUS OF COMMITMENTS FROM RESPONSE TO ORDER OF SHOW CAUSE (HL&P letter of July 28, 1980: Pages 10 and 11, 4.
Approval of QA Manual changes by the ANI and ASME.
1 Status B&R's authorized inspection agency (Hartford) and resident ANI have reviewed and accepted the revised Sections 1, 3,
9 and 15.
5.
Review, revision and reissuance of implementing procedures affected by QA Manual changes where necessary.
Status Applicable MECP's and QAP's have been revised and reissued to reflect and correlate with QA Manual changes.
6.
Review, revision and reissuance of NDE procedures where necessary.
Status NDE procedures for RT, PT, MT and VT have been revised and reissued.
7.
Completion of personnel training in applicable revised procedures.
Status Personnel training in MECP's, QAP's and WPS's has been initiated and is continuing.
8.
Confirm the adequacy of Items 5, 6 and 7 above by an independent third party expert, a Level III Inspector certified by examination.
Status United States Testing has been subcontracted to provide a Level III individual to perform this review.
The Level.III has been independ-ently reviewing the revised MECP's QAP's and WPS's, and monitoring the train 4 3, qualification and certification programs for welders and VC rectors. _ - _ _
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ATTACHMENT II - CONT'D.
RESTARTING ASME WELDING STATUS OF COMMITMENTS FRCM RESPONSE TO ORDER OF SHOW CAUSE (HL&P letter of Julv 28, 1980: Paces 10 and 11)
Recommendations made by the independent Level III have been incorporated into the project welding program.
9.
Training and requalification of welders.
Status Welders have been re-trained and re-qualified.
10.
Reconfirmation of qualification and certification records of selected inspectors.
Status Quality Engineering has reviewed and reconfirmed qualifi-cation and certification of NDE inspectors.
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