ML19346A116

Responds to NRC 810320 Ltr Re Violations Noted in IE Insp Repts 50-518/81-04,50-519/81-04,50-520/81-04 & 50-521/81-04. Corrective Actions:Welders Restricted to Limits of Qualifications

ML19346A116
Person / Time
Site:	Hartsville
Issue date:	04/17/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19346A114	List: ML19346A115 ML19346A116
References
NUDOCS 8106050123
Download: ML19346A116 (7)

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TENNESSEE '/ ALLEY ' AUTHORITY

-w~ ncc ,a; :W.cssr : at-400 Chestnut Street- Tower II April 17, 1981' Mr. James P. O'Reilly,-Director-Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 ,

101 Marietta Street Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed-is our response to R. C.~ Lewis' March-20, 1981, letter to H. G. Parris transmitting Inspection Report Nos. 50-518/81-04,

-519/81-04, -520/81-04, and -521/81 regarding activities _at our Hartsville Nuclear Plant which' appeared:-to have been in violation of NRC regulations. As discussed with P. A. Taylor of.

your staff on Ap-il 14, 1981, TVA was granted a~three-day extension on the submittal Gaue of this response.- TVA anticipates ~

transmitting a final response to this report on or before May 4, 1981. ~If you have any questions, please call Jim Domer at FTS 857-2014 4

To the best of my knowledge,~ I declare the' statements contained .

herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY r)C ' ;- .,

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L. M. Mills, Manager j Nuclear Regulation and Safety Enclosure l

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o HARTSVILLE NUCLEAR PLANT RESPONSE TO NRC-0IE LETTER FROM R. C. LEWIS TO H. G. PARRIS DATED MARCH 20, 1981 v

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Reference:

Report Nos. 50-518/81-04, 50-519/81-04, 50-520/81-04, and 50-521/81-04)

This report responds to part A of the Notice of Violation described in Appendix A of the OIE inspection report referenced above. This is our final report on-this item of noncompliance.

Noncompliance Item - Severity Level V Violation 518-521/81-04-02 Appendix B, Criterion IX of 10CFR50, as implemented by PSAR Section 17.1A.9, requires measures be catablished to assure special processes, including welding, are. controlled. ASME Section IX with Interpretation IX-78-92 has been identified as the applicable code for welder qualification. Interpretation IX-78-92 limits the thickness qualified, by a combination process welder qualification -

pipe' test assembly of 3/4-inch wall thickness, to 1-1/2-inch maximum.

All TVA safety-related repair pipe welding requires preweld visual

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inspection.

Contrary to ,the above, on March 4, 1981, adequate measures were not established to control special processes, including welding, in that the following were noted:

(1) TVA Qual ~fication Test No. GT-SM-6-4-0-3-H, Revision a (a combination process welder qualification test, administered on 3/4-inch wall thickness pipe), paragraph 8.1, states that the welders are qualified for unlimitec pipe wall thickness.

(2) TVA has no documented acceptance criteria for preweld visual

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inspection.

This is a Severity Level V Violation (Supplement II.E).

Response

Admission or Denial of the Alleged Violation (1) TVA concurs with the findings cited in item 1 of the violation.

, (2) TVA concurs with the findings cited in item 2 of the violation.

Concurrence with item 2 is based on section 8.b(5)(a) 1 of the referenced report which indicates that repair only welding is in question.

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Reason For The Violation (1) The failure to identify-the inadequacy of Qualification Test No.

GT-SM-6-4-0-3-H is a result of an oversight by the writers and users of General Construction Specification 0-29M. Dre to limited application of the test at Hartsville, site personnel did not identify this discrepan,cy. ,

(2) TVA did not recognize the_ problem involving QCI W-109, " Weld.

Repair ASME Code."

L Corrective Steps Taken And Results Achieved (1) We have reviewed welder qualification records and determined that only two welders have been qualified to GT-SM-6-4-0-3-H.

The c6mputerized weld monitor program was reviewed for welds of 3/4-inch or greater thickness. This review confirmed that the above two welders did not weld'on any 324-inch or greater thickness.

(2) The acceptance criteria is not available in QCI W-109, " Weld Repair ASMS Code," but references the criteria listed in other approved QCI's. Inspection criteria in'use is based on QCI N-501, " Visual Inspection of ASME, Welds," which references General Construction Specification G-29M, section 1.M.1.2, paragraph 15.0. This paragraph addresses excavation configuration and cleanliness. Inspectors have been notified by their group leaders of the appropriate acceptance criteria, including excavation configuration, and informed of the location of this ,

requirement. Based on the use of alternate procedures and applicable acceptance criteria, we have det(rmined that no additional inspections or weld repairs will be necessary.

Corrective Steps Taken To Avoid Further Noncompliance (1) The welders who have been qualified to GT-SM-6-4-0-3-H will be restricted to welding on material up to 3/4-inch thickness.

A request for a change in Qualification Test No. GT-SM-6-4-0-3-H was sent to EN DES on March 18, 1981. As a result of this

. request, other combination process welder qualification tests are being evaluated to determine if similar problems exist. When these have been identified the site will further evaluate any other questionable welder qualification.

(2) CONST QA has been requested to evaluate QCI W-109 to determine if it has been incorrectly assigned as a QCI. Procedures which do not include acceptance criteria have not been assigned QCI status in the past. If this procedure is changed to a CEP, it will specify the applicable procedure containing acceptance criteria. If this procedure is not changed to a CEP, the acceptance criteria will be added as required.

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Date When' Full Compliance Will Be Achieved (1) The review of all combination process welder qualification tests

-and-any corrective action necessary as a result of:this review-will be complete by July.6, 1981.

(?). If this corrective action does not result in changes which require additional QCI or CEP revision, these procedures will also be corrected by July 6, 1981. If~ additional changes to'QCI's and CEP's are necessary, this work will be complete by August'1, 1981.

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e-HARTSVILLE NUCLEAR PLANT RESPONSE TO NRC-0IE LETTER FROM R. C. LEWIS TO H. G. PARRIS DATED MARCH 20, 1981

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Reference:

Report Nos. 518/81-04, 50-519/81-04, 50-520/81-04, and . -

50-521/81-04)

This report responds to part B- of the Notice of Violation described in Appendix A of the OIE inspection report referenced above.. This'is.our final report on this item of noncompliance.

Noncompliance' Item - Severity Level V-Violation - 518/81-04-04 Appendix B, Criterion V of 10CFR50, as implemented by PSAR Section 17.1A.5, requires activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with those proce'dures. . TVA General Construction. Specification G-29M, Process Specification 1.M.1.2(b), paragraph _1,4.9.1(a), requires bead width for 3/32-inch diameter type 7018 electrodes not to exceed ,

9/16-inch wide.

Contrary to the above, on March 5, 1981, activities affecting quality were r.ot accomplished in accordance with documented procedures'in that the welder of record for essential service water system point No. AIAES0680004 deposited a 7/8 inch ~ vide bead on that joint with a 3/32 inch diameter type 7018 electrode.

This is a Severity Level V Violation (Supplement II.E). This violation-is applicable to unit A1 only.

Response

r (1) Admission or Denial of the Alleged Violation TVA concurs with the findings cited in the violation.

(2) Reason for Violation Procedure requirements are not being adhered to by the welders or their foremen.

(3) Corrective Steps Taken and Results Achieved NCR HNPA-133 was generated to document conditions of excessive bead width. Welds which have structural. significance will be repaired. Scme welds, such as cladding, will remain as is since there is no indication that any of the essential variables for corrosion-resistant weld metal overlay have been exceeded under ASME Section IX, Subarticle QW281.

The welder cited for the violation has been identified, and will be retrained. A random inspection of all safety-related items that were welded by this employee will be performed. Additional rejectable _ welds will be repaired if_they have any structural significance.

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(4) ._ Corrective Steps Taken to Avoid Further Noncompliance Welder performance as applied: to excessive bead width is being-evaluated. Welders'in-question will have thsir certification.

cards' retained by the-Welding Quality Control Unit until they-have been retrainea in accordance with the Quality Assurance

' Training Plan and. reoriented by -their specific craf t. management.-

Welders must have,their certification cards before drawing welding material.- The welders' certification cards will be-returned by the Welding' Quality Control Unit upon receipt.of?

evidence of retraining and reorientation. . This ensuresithat;they will not weld until retraining is' accomplished.

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As-a general policy'for. future procedural violations,. welders will be. counseled,' retrained, disciplined, and/or removed from-their position as warranted by the. investigation' of the particular incident.'

(5) Date When Full Compliance'W111 Be Achieved'

-. We.will be in. full complianceLby'May'1, 1981.

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i HARTSVILLE NUCLEAR PLANT RESPONSE TO NRC-0IE LETTER FROM "

R. C. LEWIS TO H. G. PARRIS DATED MARCH 20, 1981

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Reference:

Report Nos. 50-518/81-04, 50-519/81-04, 50-520/81-04, and 50-521/81-04)

This report responds to part C of the Notice of Violation described in-Appendix A of the OIE inspection report referenced above. This is our first interim report on this item.of noncompliance. The final report will be submitted on or before May 29, 1981.

Noncompliance Item - Severity Level V Violatien 518-521/81-04-02 Appendix B, Criterion V of 10CFR50, as . implemented by PSAR Section 17.1A.5, requires that activities affecting quality shall be accomplished in accordance with documented procedures. TVA Construction Engineering Procedure No. 16.03 defines which conditions adverse to quality can be handled as a QCIR and which conditions must be handled as an NCR report with appropriate, management review.

Contrary to the above, requirements for handling of conditions adverse to quality were not being adhered to in that on March 6, 1381, there were a number of completed QCIR's in the records vault that described conditions which should have been escalated to nonconforming report status to obtain appropriate management attention.

This is a Severity Level V Violation (Supplement II.E)'.

Response

Admission or Denial of the Alleged Violation TVI is unable to make a determination of concurrence at this time. A significant audit finding (M80-10, Deficiency No. 4) on this cituation was opened on January 22, 1981, and evaluated as nonreportable. As a result of this audit finding, representatives of OEDC QA, EN DES QA, and CONST QA were organized to investigate the use of QCIR's and NCR's. The results of this group's findings, any decisions regarding the futura relationship of QCIR's and NCR's, and any procedure

, revisions required will be complete by the time of the final report.

We will supply a determination of concurrence on this violation by May 4, 1981.

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