ML19350A565

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Forwards Addl Response to NRC Re Violations Noted in IE Insp Rept 50-370/80-12.Corrective Actions:Established Procedures for Training Nondestructive Exam Personnel to Meet Guidelines & Intent of SNT-TC-1A
ML19350A565
Person / Time
Site: Mcguire
Issue date: 12/08/1980
From: Parker W
DUKE POWER CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19350A542 List:
References
NUDOCS 8103160498
Download: ML19350A565 (3)


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December 8, 1980 WCE PetSsDENT TELE *=o%g: Anta 704 Seta= Paoosevion 3 7 3-4c 8 3 Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Subject:

McGuire Nuclear Station Docket No. 50-370

Reference:

RII:LDZ 50-370/80-12

Dear Mr. O'Reilly:

As requested by Mr. L. D. Zajac of your staff, please find attached a supplemental response to the item of noncompliance identified in the subject inspection report.

Very truly yours,

/

William O. Parker, Jr.

GAC:scs Attachment

DUKE POWER CONTANY MCGUIRE NUCLEAR STATION Supplemental Response to IE Inspection Report 50-370/80-12 Item The NRC requested supplemental information on the following items:

1 and 2.

Mr. Zajac expressed the opinion that since Duke Power Company has adopted the ASNT Recommended Practice No. SNT-TC-1A in the QA Topical Report, that the exact letter of SNT-TC-1A must be used in establishing procedures for training NDE personnel.

Response

1 and 2.

Examiner candidates are required to demonstrate proficiency by use of process control Form M-4A during practical exams. These forms, M-4A, contain more than ten (10) check points.

In addition, documented practical exams given within the last 1-1/2 years do contain ten or more checkpoints.

Paragraph 1.4 of SNT-TC-1A states:

"It is recognized that these guidelines may not be appropriate for certain applications.

In developing his written practice as required by paragraph 5, the employer shall review the detailed recommendations presented herein, and shall modify them as necessary to meet his particular needs."

Project QA, QA Engineering and Services and Construction have established procedures for training NDE personnel which meet the intent and guidelines of SNT-TC-1A, but in certain areas (the items 1 and 2 addressed by Mr. Zajac are examples), the procedures do not meet the " letter" of SNT-TC-1A.

We feel that training procedures comply with SNT-TC-1A and the Topical Report based on SNT-TC-1A's statement in paragraph 1.4.

Item 6.

The configuration described does not appear to conform to ASME criteria. Has additional welding been done?

Response

6.

No welding has been performed since this item was identified.

Qualified QA and QC personnel have carefully reinspected the two welds.

The two welds in question, CA2FW 12-3 and RN2F 520, join heavy wall valves to schedule 40 piping. Valve 2CA8 was weld prepped to a normal 37 1/20 bevel with a secondary bevel of 450 on the thicker portion of the valve.

Duke welders have' overlapped the weld (CA2FW 12-3) onto the 45 secondary 0

bevel in certain areas.

This overlapping actually decreases the weld slope and the slope falls within the code requirement of a minimum 3-to-1 taper, but when measured all areas meet or exceed taper requirements.

It is our position that this weld is acceptable.

Weld RN2F 520 overlaps valve 2RV 69A. The valve has a 37 1/2 bevel at the weld prep with a 3-to-1 taper from the 37 1/20 weld bevel up onto the valve. Again the overlapping decreases the slope and falls within the code requirements of a minimum 3-to-1

r. aper.

It is our position that this weld is acceptable.