ML20095H557
| ML20095H557 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/08/1984 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20095H538 | List: |
| References | |
| RSEP-84-406, NUDOCS 8408290028 | |
| Download: ML20095H557 (2) | |
Text
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((
w CD&L Carolina Power & Light Company H. B. ROBINSON STEAM ELECTRIbl PLANT ~ ~
POST. OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 Juil -a g n y
Robinson File No:
13510E Serial RSEP/84-406 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Atlanta, Georgia 30303 H. B. Robinson SIC Plant, Unit 2 Docket No. 50-261 License No. DPR-23 IE Inspection Report IER-84-11 Dear Mr. O'Reilly Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response.
Severity Level V Violation (IER-84-ll-01-SL5) 10 CFR 50, Appendix B, criterion V, requires that activities af fecting quality shall be prescribed by documented instructions or procedures of a type appro-priate to the circtanstances, and that these instructions or procedures shall include ' appropriate quantitative or qualitative a:ceptance criteria for deter-mining that important activities have been satisfactorily accomplished.
Section III of the ASME Code, states that, "each certificate holder is respon-sible for control of the welding electrodes and other material which is used in the fabrication and installation of components.
Suitable identification, storage, and handling of electrodes, flux, and other welding material shall be ma intained.
Precautions shall be taken to minimize absorption of moisture by elect rodes."
CP&L's Procedure for Storage and Control of Welding Filler Metal and Backing Rings WP-502, Rev.10, entslishes a maximum exposure time for E70XX series l
welding rods of four hours and a maximum exposure time of E80XX series welding rods of two hours.
Paragraph 4.10 of the licensee's procedure WP-502 requires that, when the maximum exposure tien has been exceeded the rods shall be re-turned to the control areas for reconditioning.
Contrary to above, the procedure does not segregate weld ends that have been issued and returned within their exposure limits. Therefore, these weld rods can he reissued immediately and a E70XX series weld rod with a maximum expo-sure limit of four hours could receive a exposure of seven hours in an eight hour shif t.
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' Mr. fames P. O'Reilly Serialt -RSEP/84-406 Page 2
Response
1.
Admission or Denial of the Alleged Violation CP&L denies the alleged violation.
2.
Reason for Denial of the Alleged Violation ASME Section III requires control of welding electrodes and CP&Ls procedure WP-502 revision 10, in ef feet at the time of this inspection, established the control of welding electrodes.
.WP-502 revision 10 provided control to minimize absorption of moisture by welding electrodes.
ASME Section III does not address reconditioning electrodes nor does it specify electrode exposure times. CP&L's procedure WP-502 revision 10 went beyond the. requirements of ASME Section III and requires that the electrodes exposed to.the atmosphere for greater than the time specified in table 4.9. ! to be reconditioned. WP-502 revision 10 also allowed electrodes e.ich were exposed for less than the time specified in table 4.9.1 to be placed back into the issue ovens. CP&L believes that the time specified was conservative. Not segregating the welding rods j
that have been returned to the issue ovens because they were exposed l
1ess than the time specified in tale 4.9.1 is not in violation of the requirements or intent of ASME Section III.
l 3.
Actions Which Have Been Taken In order to alleviate any concern the NRC may have on control of welding electrodes, CP&L has made the following conservative changes to WP-502 in revision 11.
A.
Coated electrodes returned to the issue station which were not issued in a portable rod caddie will be destroyed regardless of exposure time.
B.
Coated electrodes issued in a portable rod caddie shall be used or destroyed once they have been removed from the caddie.
If you have any questions concerning this response, please contact me or my staff.
Very Truly yours, 7#
R. E. Mor General Manager H. B. Robinson SEG Plant RDt/js
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