ML20054L328

Responds to NRC Re Violations Noted in IE Insp Rept 50-412/82-01.Util Reiterates Position That Field Weld 2SWS-066-F08,Line SWS-66-9A,Class 3 Piping,Meets Applicable Code Stds.Requests That Subj Be Reconsidered

ML20054L328
Person / Time
Site:	Beaver Valley
Issue date:	05/07/1982
From:	Woolever E DUQUESNE LIGHT CO.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20054L322	List: IR 05000412/1982001 ML20054L328 ML20054L368
References
NUDOCS 8207070404
Download: ML20054L328 (5)

Text

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due Ak MAY 7 1982 M us2pss4ooo 5:e ms. o u United States Nuclear Reguidtory Comnission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION: Mr. Richard W. Starostecki Division of Project and Resident Programs

SUBJECT:

Beaver Valley Power Station Unit No. 2 Docket No. 50-412 USNRC IE Inspection Report No. 50-412/82-01 Gentlemen:

This is in response to the itms of infraction cited in Inspection Report No. 50-412/82-01 and listed in Appendix A (Notice of Violation) attached to your letter to Mr. E. J. Woolever dated April 5, 1982.

NRC VIOLATION (82-01-01) 10 CFR 50, Appendix B, Criterion IX, requires that special pro-cesses including welding be controlled using qualified procedures in accordance with applicabic codes and standards. Paragraph NB-4232.1 of the ASME Boiler and Pressure Vessel Code,Section III, 1971 Edition, Winter 72 Addenda, requires that any offset within the allowable tolerance be fa red to at least a 3 to 1 taper over the width of the finished weld.

Contrary to the above, as of February 25, 1982, field weld number 2SWS-066-F08, line SWS-66-9A, Class 3 piping, was not faired to the required 3 to 1 taper over the width of the finished weld.

RESPONSE

ASME III includes requirments for controlling the transition, or slope, in butt weld pipe joints which are offset to misalignment or due to joining unequal inside diameter and outside diameter conditions. In particular, NB-4232.1, " Fairing of Offsets," re-stricts the degree of misalignment, or offset, between parts at the cmpletion of welding. The degree of offset is limited by Table NB-4232.1 and, in general, may vary fran 1/8t to 1/4t depending on the thickness (t) of the thinner mmber joined. Off-set of outside surfaces of pipe butt welds are required to be faired to at lease a 3:1 taper over the width of the finished weld.

Where parts of different outside diameters are joined and the ends B207070404 820624 PDR ADOCK 05000412 o PDR

Unites State Nuclear Regulatory Ctmnission page 2 1

are beveled and excess metal exists on the outside diameter of one side of the joint, the excess metal may be tapered off in accordance with Figure NB-4233.1. As-welded surfaces, in accordance with NB-4424, " Surface of Welds," are required to be sufficiently free from grooves, ridges, and valleys and have reinforement not in excess of the limits of NB-4426 and a maximum undercut of 1/32 in.

The cited field weld exhibited a varying degree of outside diameter surface conditions around the joint. At points of unequal outside diameter, the excess metal had been tapered away fran the joint.

The depression, or valley, at the toes of the joint was attributed to weld shrinkage, reinforcement, and undercut. The weld groove had been filled for the entire beveled portion of the joint.

When dealing with pipe butt welds in the as-welded condition, the cause of any dissimilar outside diameter condition is not readily apparent. However, when the parts are of the same nominal diameter at the joint and the weld groove is cmpletely filled and the slope between the toes of the weld does not exceed 3:1 and the amount of offset satisfies NB-4232, then the offset requirements of the code are satisfied. For the cited weld we are_of the opinion that this is the case. Weld reinforcement would be judged based on the amount U "D of the metal above the same reference line used for evaluating off-set. Undercut would be evaluated separately from the offset and reinforement criteria. The excess metal, or transition in thick-ness at the outside diameter joint, is controlled by preparing the weld ends in accordance with the requirments of Figure NB-4233-1.

Therefore, it is our position that field weld number 2SWS-066-F08, line SWS-66-9A, Class 3 piping, meets applicable code standards, specifications and safety requirements and that the acceptability of the cited weld be reconsidered.

NRC VIOLATION (82-01-04) 10 CFR 50, Appendix B, Criterion V, requires activities affecting quality to be prescribed by, and accomplished in accordance with documented instructions, procedures, or drawings. The licensee's Specification 2BVS-58, dated December 31, 1973, pages 1-37 requires that all austenitic stainless steel welding for Code Class 1, 2, and 3 piping cmply with NRC Regulatory Guide 1.31, Revision 1.

It further requires each bidder to contain in their program pro-visions for emplying with Regulatory Guide 1.31, and to control production welding. Regulatory Guide 1.31, Revision 1, Section C5 requires that production welds contain a minimum of 3 percent delta-ferrite at the weld metal surface.

Contrary to the above, Power Piping Cmpany Specification N-1141-P-1, Revision 3, Section 4.4 permits less than 1 percent delta-ferrite in production welds.

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

The inspector reviewed Power Piping Cmpany Specification N-1141-P-1, Revision 3, dated October 20, 1974, Delta Ferrite Control of Austen-itic Stainless Steel Welding, with respect to Regulatory Guide 1.31, Revision 1 and Duquesne Light Cmpany Specification 2BVS-58, dated

, , United States Nuc1 car Regulatory Conmission page 3 1

December 31, 1973. Revision 3 of N-1141-P-1 was approved on January 27, 1975, by St me & Webster for use at Beaver Valley, Unit 2. - Com-i pliance with Revision 1 of the Regulatory Guide'is required by the licensee's specification.

j The inspector found that N-1141-P-1, Revision 3, permits less than-1 percent delta-ferrite in production welds. This does not agrec

with the Regulatory Guide which requires a minimum of 3 percent

delta-ferrite in production welds.

This is considered a violation (82-01-04).  ;

RESPONSE

i l BVPS-2 welding of austentic stainless. steel, e.g., AISI Types 304

'. and 316 material, is performed with weld filler metal which is cer-1 tified to be capable of depositing a minimum of 5 percent delta-ferrite in an undiluted weld metal deposit. The type and number of tests and the required test results are in accordance with NRC guidelines in MTEB 5-1. The applicable NRC guidelines include

? Safety Guide 31, Regulatory Guide (RG) 1.31/1, MTEB 5-1, and RG 1.31/3. Requirements for testing weld procedure qualification 4

test coupons and production welds for delta-ferrite content were a principal subject of RG 1.31/1. MrEB 5-1 was developed to provide l MlC interpretation of delta-ferrite acceptance criteria. The i current revision, RG 1.31/3, no longer requires these production i tests. It was established that testing of the weld filler metal l supply would be sufficient to assure satisfactory production weld quality.

1 Power Piping Ccmpany (PPCo) Specification N-1141-P-1, Revision 3, was approved for use on 2BVS-58, shop fabricated piping, as an acceptabic program for ccuplying with NRC RG 1.31/1 based on infor-I mation that was received frun the NRC. Paragraph 4.4 of the PPCo specification requires that production welds exhibit an average delta-ferrite content of 3 percent minimum. Individual readings of 1_percont nr less were not included in _the four readings used to Tdetermine an average content for the -ioint provided_that_theymrs determinod h, roprocont local conditions._ This means of determining the average ferrite content was in accordance with the subsequently

!, issued NRC Branch Technical Position, MrEB 5-1, Interhn Position on

?

RG 1.31, Revision 1, " Control of Stainless Steel Welding," Paragraph B.3.a. and the prior information that had been received from the MIC.

PPCO Specification N-1141-P-1, Revision 3, contains quantitative rules for defining acceptable local conditions and requires detailed documentation where such local conditions are permitted.

Since MrEB 5-1 provided interim guidance to users of RG 1.31/1 and the limitations on the use of how ferrite readings by PPCo were i consistent with the criteria of MrEB 5-1, B.3.a, the intent of RG

1.31/1 for controlling stainless steel welding was satisfied. The l

i

' United States Nuclear Regulatory Ccmnission page 4 specification was not technically violated when the procedure was approve, therefore, no corrective action in response to the Notice of Violation should be required.

Sincerely yours, 0

j< /

E. J. Woolever, Vice President Nuclear Construction Division SDH/wjs cc: Mr. G. Walton, BV-2 NRC Resident Inspector Ms. E. Doolittle, NRC Project Manager

l United States Nuclear Regulatory Commission May 7, 1982 Page COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY On this 7th day of May,1982, before me, ENALD W. SHANNON ,a Notary Public in and for said Commonwealth and County personally appeared E.

J. Woolever who, being duly sworn, disposed, and said that (1) he is Vice President of Duquesne Light Company, (2) he is duly authorized to execute and file - the foregoing Report on behalf of said Company, and (3) the statement set forth in this Report are true and correct to the best of his knowledge, information, and belief.

WITNESS my hand and seal the day and year first above written.

AJ DONALD W. SHANNON, NOTARY PUBLIC PITTSBURQt ALLEGHENY COUNTY MY COMMISSION EXPIRES JUNE 7,1983 Member. Pennsylvama Association of Notarret

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