ML20030B925
| ML20030B925 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/20/1981 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Martin T Public Service Enterprise Group |
| Shared Package | |
| ML20030B926 | List: |
| References | |
| NUDOCS 8108250194 | |
| Download: ML20030B925 (2) | |
See also: IR 05000354/1981004
Text
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AUG 2 01%1
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50-355
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Public Service Electric and Gas Company
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ATTil: fir. T. J. flartin
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Vice Pmsidant
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Engineering and Constmetion
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80 Park Plaza - 17C
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flewark, flew Jersey 07101
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Gentlemen;
Subject:
Combined Inspection Report lios. 50-354/81-04 and 50-355/81-04
This refers to your letter dated June 8,1981, in response to our letter
dated May 13, 1981.
Thank you for infoming us of the corrective actions taken in msponse to
Iten I.
These actions will be examined during a future inspectf on of your
licensed program. With respect to our finding that non-essential variables
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QW-410.1 and QW 410.5 are not adequately addressed, your response does not
provide silfficient justification to waive specifying the specific requim-
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monts stated in the code in the Weld Procedure Specification (UpS).
Based
on ASftE Section IX requirunents, you are requested tc specify under non-essential
variable QW-410.1 the beaa application technique qualified and under non-
essential variable QW-410.5 the types of initial and interpass cleaning nothods
qualified.
In your supplemental msponse addressing Iten II (below), please
confim that these itens will be specified in the WPS.
Your response to Item II concerning failure to perfonn radiography in accordance
,
with an approved radiography procedure, stated that this citation did not
constitute a violation of liRC mquirements and, bued on this belief, requested
that the citation be withdrawn. Reactor pressure vessel installation activities
are governed, in part, by GE/fiED Specification 22A42J2, Reactor Assembly,
Welding, Cleaning, Examination and Storage, Revision 6.
This specification
provides requirements for qualification of personnel for restricted access
welding and specifies radiographic examination of qut.'ification test nock-up
welds in accordance with ASflE Section III. Appendix B of Specification 22A4202
.
identifies the jet pump adapter to shmud support plate weld as requiring welder
l
qualification by mock-up test prior to making actual installation welds. The
penetrameter p?acement was not done in accordance with established procedural
requirements.
Based on the foregoing, and our review of your response, we have detemined that
the citation is valid. Please subnft a supplemental response addressing the
,
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mquirements of 10 CFR 2.201 as specified in our letter dated May 13,1981.
8108250194 810820
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Public Service Electric and
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Your cooperation with us is appreciated.
Sincerely.
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Cr1;!nal Signed By:
A . A. KfitilG-
R. R. Keinig, Chief
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Projects Branch f2, Division of
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Resident and Project Inspection
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J. Boettger, General Manager, Corporate QA
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Local Public Document Room (LPDR)
Nuclear Safety Infomation Center (NSIC)
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NRC Resident Inspector
State of New Jersey
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Region I Docket Room (with concurrences)
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Mr. Boyce H.
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6/8/81
Contrary to the above, as of April 3,
1981, GE I&SE WPS
HC 5001D, Revision 1, which had been reviewed and ap-
proved by GE I&SE, GE NED and Bechtel was in effect for
in process production welding and failed to list in de-
tail four nonessential variables and stated a thickness
range qualification for the SMAW process that was in
excess of that qualified by the procedure qualification
records.
Corrective Steps Which Have Been Taken and the Resultc
Achieved:
A.
The thickness range qualified by the applicable POR (.75
inches) is now reflected on DWP 5001D (WPS).
B.
GE I&SE will revise the WPS to include the cup size
range for which the procedure was qualified for the POR.
C.
In regard to listing of nonessential variables, it is
our position that the information, as presented, does
meet ASME Section IX requirements for the following
reasons:
1.
Stringer vs. Weave Beads - DWP 500lD references max-
imum bead width (.625" -- four times the diameter of
the filler material, wh' n ever is less) rather than
the statement stringer and weave beads are permit-
ted.
Heat input is the critical factor for the
welding GE I&SE is performing (see GE/NEBG Procedure
22A4202, Revision 6).
The information as listed
gives more concise direction to the welder (as op-
posed to just listing stringer and weave beads per-
mitted).
Since this is not a variable for welders
performance, it would not require requalification of
the welders.
2.
Initial vs. Interpass Cleaning - The statement on
DWP 5001D for this variable "As Required".
Since
the General Weld Procedure (HC-160A71203) does not
restrict the welder to any particular method of
cleaning the joint, the information as presented
meets the requirements of ASME Section IX.
Since
there is no restriction as to the type of cleaning
'
method permitted "As Required" serves the same pur-
pose as listing all of the available methods that
gn,ould be used to clean the welds.
Examples: Brush-
ing, grinding, slag hammers, needle guns, flapper
wheels, burring tools, etc.
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Mr. Boyce H.
Grier
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6/8/81
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Corrective Steps Which Will Be Taken to Avoid Further Items
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of Non-compliance
,
1
A review of all GE I&SE detail Weld Procedures have been
initiated to insure compliance with ASME Section IX.
Any
,
2
DWP's requiring revisions will be corrected and resubmit-
ted.
Prior to any DNP being used on Reactor Internals In-
stallation, it will be reviewed on site.
GE/NED who have reviewed GE I&SE's Welding Procedure DWP
5001D and dispositioned it " approved without comments" has
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advised Bechtel that their responsibility is for review of
documents to insure conformance to GE/NED requirements only
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and does not extend to checking for agreement between the
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Contractor's documents; such as the thickness range on the
POR and on the WPS.
ISE-PG-504 contains an administrative discrepancy.
The PQR
limits the SMAW process to a 3/4-in. wall thickness, while
the WPS allowed up to a 1-in, wall thickness.
It is not
,
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necessary for the POR to specify the allowable thickness
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range.
That information is shown on the WPS.
In the
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future, administrative discrepancies will be brought to the
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attention of the supplier by Bechtel for resolution,
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Date When Full Compliance Will Be Acheived:
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Review of applicable GE I&SE detail Weld Procedures will be
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completed by June 15, 1981.
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II.
Criterion V,
states, in ,, art,
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that: " Activities affecting quality shall be prescribed
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by documented instructions, procedures, or drav.ngs...
and shall be accomplished in accordance with these in-
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structions, procedures, or drawings."
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Section 16.4.5 of Chapter 16 of the PSQR states, in
part, that:
... quality related activities are docu-
"
mented and controlled by written procedures and
instructions."
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Paragraph 13.2 of the Technical Specification for Reac-
tor Vessel Internals Installation states, in part,
that: " Test and examination procedures and standards
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for acceptance shall be in accordance with these speci-
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fications and applicable codes and standards. :
Addi-
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tionally, Paragraph 4.1 of this technical specification
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Mr. Boyce H.
Grier
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6/8/81
states, in part, that: "All materials, fabrications,
examinations, testing...shall be in accordance with the
latest issue of the ASME Boiler and Pressure Vessel
Cod e . . . "
GB I&SE radiograph procedure 18XA9603, Revision 2,
states in Paragraph 6.6.7 that the penetrameter shall
be placed on the weld metal when the weld metal is not
radiographically similar to the base material.
Article 22, SE-142, Standard Method for
Controlling Quality of Radiographic Testing, states in
Appendix A that carbon steel and inconel are not radio-
graphically similar.
Contrary to the above, as of April 3,
1981, penetra-
meter placement for radiography of the welder Mock-up
qualification for the jet pump adapter to shroud sup-
port plate weld (carbon steel base metal with inconel
filler) was not in accordance with procedure 18XA9603
requirements.
The circumstances of the above incident have been reviewed
by PSE&G, our Architect Engineer and the General Electric
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Company.
Based upon this review, there was no violation of
NRC requirements.
The following information supports this
conclusion:
1.
The subject weld is a practice or mock-up weld which is
not a part of the power plant and did not consist of the
same materials as the actual production joints.
The RT
of the mock-up weld is a GE/NEBG requirement for war-
ranty purposes only.
2.
The specific instructions for RT of the mock-up weld,
including the acceptance criteria, are defined in the
mock-up procedure.
These should not be confused with
the GE I&SE RT procedure used for other production
3.
The production joint that corresponds to the mock-up is
not an ASME Section III weld and does not require volu-
metric inspection (RT) upon completion.
However, by
contract, the production welds must be made using proce-
dures and welders qualified to ASME Section IX.
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Mr. Boyce H.
Grier
-5-
6/8/81
4.
The radiographs in question were not used to qualify the
welder and/or procedure in accordance with ASME Section
IX.
Neither were the radiographs used for acceptance of
any nuclear power plant component or structure.
5.
GE/NEBG had reviewed and accepted the radiographs of
this mock-up weld.
Henc9, the only requirement to per-
fo rm this radiography has been satisfied.
Therefore, the procedural error during this in f o rma tional
radiograph of a welc~ which is not part of the power plant
had no adverse impar:t on any safety-related structure, sys-
tem or component.
We respect fully request this violation be
withdrawn.
Should you have any guestions, we will be pleased to discuss
them with you.
Very truly yours,
hN
CC:
Office of Inspection and Enforcement
Division of Reactor Construction and Inspection
D.C.
H.
E.
Morris
Bechtel Power Corporation
NRC Resident Inspector
Hope Creek Site
HJ1/1 1/5
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STATE OF NEW JERSEY)
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SS:
COUNTY OF ESSEX
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TilOMAS J.
MARTIN, being duly sworn according to law deposes
and says:
I am a Vice President of Public Service Electric and Gas
Company, and as such, I find the matters set fo rth in our
letter dated June 8,
1981, concerning combined NRC
Inspection Report 50-354/81-04 and 50-355/81-04 are true to
the best of my knowledge, information, and belief.
.
- '
hWN
, .Y
,
TilOMAS
MARTIN
.
Subscribed and sworn to before me
this 7 oay of
c.
,
1981
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YY
Notary Public of New Jersey
My Commission expires on [e[ . /6", /9f.f
flJ1/1 6