ML20112H724
| ML20112H724 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/09/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20112H717 | List: |
| References | |
| 606, NUDOCS 8501180011 | |
| Download: ML20112H724 (3) | |
Text
I VIuOINIA ELucinIc ann Pownu COMPANY 7
HIcun n
1 GINIA 2 0061 y nov
Dear Mr. O'Reilly:
We have reviewed your letter of October 4,
1984, in reference to the inspection conducted at North Anna Power Station between September 11, 1984 and September 13, 1984 and reported in IE Inspection Report Nos. 50-338/84-34 and 50-339/84-34.
Per a telephone conversation on October 31, 1984, between Mr. David Fortin (Vepco) and Mr. Virgil Brownlee (NRC), an extension until November 9,
1984 was granted to respond to the inspection report.
Our response to the specific infraction is attached.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Corpany has no objection to this inspection report being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours, W. L. Stewart Attachment cc:
Mr. Richard C. Lewis, Director Division of Project and Resident Programs Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station k
8501 %
0 PDR O
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f Attrehu nt Prgt 1 Serial No. 606 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/84-34 AED 50-339/84-34 NRC COMMENT:
Paragraph (a)(1) of 10 CFR 50.55(a) requires structures and components be fabricated and inspected to quality standards coumensurate with importance of the safety function.
ANSI B31.7, paragraphs 1-725.5.3,-727.4,-727.4.2 and Project Operating Procedure 3.1.2, Rev.
2, paragraph 6.5.4 delineate the requirements for maintaining control of welding practices.
Contrary to the above, on September 11, 1984, control over welding was not being maintained in that filler metal stubs were observed scattered around the weld area, debris and water had been allowed to accumulate around the weld area and to a lesser degree inside the valve casing and adjacent piping being welded; lack of fusion and severely discolored / oxidized weld metal was observed on the root of weld FW-4A even though it had been accepttd by QC on September 9, 1984.
This is a Severity Level IV violation (Supplement 1).
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
This violation is correct with regard to the loss of area control.
However, the statement concerning the lack of fusion and discoloration on the root of weld FW-4A is not correct.
At the time of the inspection, the weld had been completed to tne second hot pass.
The lack of fusion and discoloration are not unesual during the hot passes and were corrected as prescribed by the governing welding process procedure.
In addition, the QC acceptance signature mentioned in the NRC comment was only for the " fit-up" of the valve to the piping.
The root pass and subsequent hot passes are nornally not inspected if, as in this case, a final radiograph of the entire weld e. ec. be performed.
i (2) REASONS FOR VIOLATION:
The reason for the failures to adnoza to the welding control practices was personnel error. Thir was further complicated by the adverse working conditions surrounding the activity.
(3) CORRECTIVE STEPS WHICH MAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The following corrective actions were completed:
a) Filler metal stubs were found (fire weld stubs), accounted for and properly disposen of.
b) An inspection o!! other areas in which welding was being performed was conducted with no further discrepancies noted.
Atttchnint Pags 2 Serial No. 606 c) The water and debris was removed from the area prior to conducting any further welding activity.
d) The visual defects noted were removed by the normal corrective cleaning procedure.
e) The weld was con.pleted, radiographed and found to be acceptable.
f) During the welding process, the QC surveillance activities were increased to at least once per day to verify that the housekeeping requirements were being met, the weld material was being controlled and the welding operation was being performed in accordance with approved procedures.
The results of these daily inspections were satisfactory.
g) All pipefitter craf tsmen were reinstructed on the requirements in wcid material control.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The events leading to this violacion are considered to be an isolated occurrence. Therefore, no further corrective actions are warranted.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
No further corrective actions are required.
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