ML20141M266

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-369/92-02 & 50-370/92-02.Corrective Actions:Dpc Disputes Violations Based on Three Nuclear Sites,Procedures Been Developed Incorporating 1980 Edition of ASME Section XI

ML20141M266
Person / Time
Site:	Mcguire, McGuire
Issue date:	07/29/1992
From:	Mcmeekin T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20141M268	List: ML20141M266 ML20141M285
References
NUDOCS 9208100305
Download: ML20141M266 (6)

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, , Duke 1%wer Cornpany T C M uum ShGuur Nudrar Genrration ikpwtment lite l'rr.ident liiOO fl. gm ikrry Road (UG01A) (TOI)STS4MO llantmnllr, AC?b0ib UM (704)$iHM9 fat DUKEPOWLn July 29, 1992 U.S. Nuclear Regulatory Commission Attn Document Control Desk washington, DC 20555 Subjects McGuire Nuclear Station-Docket Nos. 50-369, -370 Inspection Report No. 50-369, -370/92-02 Gentlement Pursuant to 10CFR 2.201, please find attached Duke Pc ver Company's response to the violation given in Inspection Report 50-369, 370/92-02 for McGuire Nuclear Station. Please note that the response reflects the fact.that Duke Power company is disputing this violation'.

Should there be ,any questions concerning this matter, contact Larry Kunka at (704)875-4032.

Very truly ours,-

T. C. McMeekin McGuire Nuclear Site Vice President Attachment xc (w/ attachment).

Mr.-S. D. Ebneter- . Mr. P. K. Van Doorn.

Administrator, Region II . NRC" Resident' Inspector U.S.. Nuclear. Regulatory' Commission McGuire Nuclear Station 101 Marietta St., NW, Suite 2900 g- ' Atlanta, GA ~30323 Q)

Q3 Mr. Tim Reed CJ U.S. NucleariRegulatory Commission-C) Office'of Nuclear Reactor-RegulationL I W . Washington, D.C, 20555 [}

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McGuire Nuclear Station 2 RESPONSE TO VIOLATION VIOLATION 10 CFR 50.55a (g) (4) requires that inservice inspections be performed in accordance with the ASME Boller and Pressure Vessel Code and Addenda,Section XI. As facilities complete an inspection interval, they are required to comply with the latest edition and addenda of the ASME Code,Section XI, that is invoked by the regulations at that time. For the McGuire Station, the applicable edition of the ASME Code is the 1980 Edition with the 1980 Winter Addenda.

20 CFR 50.55a (g) (4) (iv) permits thL use of subsequent editions of the ASME Code provided that speci fled requirements are met and the Commission grants approval.

Contrary to the above, on February 6, 1992, an ultrasonic indication in item B02.011.001 was evaluated to the acceptance standards of Table IWB 3511-1 of the Winter 1981 Addenda of Section XI of the ASME Code without prior Commission approval to use that code edition.

THE BASIS FOR DISPUTING THE VIOLATION Duke Power CompMy disputes the violation based on the following:

In order to achieve consistancy in the application of nondestructive examinations between Duke Power Company's three nuclear sites, procedures have been developed which incorporate the requirements of both the 1980 Edition of ASME Section XI, with Addenda through Wintor 1980 and Winter 1981.

This was done because the'McGuire and Oconee code date is through Winter 1980 Addenda and the Catawba code date is through Winter 1981 Addenda.

Duke Power Company agrees that the " Code of Record" for McGuire Nuclear Station is the 1980 Edition of ASME Section XI, with Addenda through Winter 1980. Duke Power Company also agrees that Ultrasonic Procedure NDE-620, Revision 0 exceeds the requirements of ASME Section XI, 1980 Edition with Addenda through Winter 1980, as stated in the NRC report.

The NRC inspection report also states there is no evidence that the revised procedures were submitted to the ANI for approval. We are not aware of any request by the NRC to see such evidence. Documentation of the review by the Authorized

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Inspection Agency was available at the time of the NRC visit and is attached for your information.

In Paragraph 3.0 of Procedure NDE-620, Revision 0, (attached) the Winter 1980 and Winter 1981 Addenda'are referenced. This indicates that the procedure is applicable to work performed to either Addenda of Section XI. It does not however, indicato that McGuire Nuclear Station had changed its " Code of Record".

The indication in McGuire Unit 2 Pressurizer Weld 2-PZR-1, Item Number 802.011.001, referenced in the NRC inspection report, was recorded based on procedure criteria 2.5 times

, more sensitive than the recording criteria specified by ASME Section V, Articio 4, " Ultrasonic Examination When

, Dimensioning of Indications Is Required",1980 Edition, Winter 1980 Addenda. This article is specified by ASME Section XI, IWA-2232 for ultrasonic examination of ferric pressure vesscis greater than 2 inches in thickness. If the less sensitive recording criteria had been - used, the indication would not have been recordable under either:the Winter 1980 or Winter 1981 Addenda of Section XI.

We do not agree that a violation has occurred if the procedure meets or exceeds the requirements of the " Code of Record" even thou<h the procedure also meets the . requirements of a different Code Addenda.

Also, we do not agree that it is a violation to evaluate an itaication to a - more conservative -. acceptance standard than required by.the ASME Section XI,'1980 Edition, Winter 1980 Addenda, when that indication would not have been recordable under the rules of'the " Code of Record". .

Regulations-do not  ;

require us to seek approval to do more than the Code requires.

The following information is provided in support of our position:

1. Prior to writing the -examination procedures, the requirements of ASME Section XI 1980 Edition with Addende through Winter .1980 and Winter 1981 were reviewed by a NDE : Levol III Examiner. Where a conflict existed between requirements, the more conservative' requirement was used.

2'. The acceptance standards in the Winter 1981 Addenda of Section XI used 'for- pressure vessel welds between 2 ' 1/2 inches and 4- inches ars more

!- conservative'than the ASME-Section III-acceptunce.

standards. referenced in IWA-3100.of the Winter 1980 Addenda.

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3. The dif ferences between Code adoenda relative to I

ultrasonic examinations performed at Duke Power Company nuclear sites are the changes to tables IWB-3510-1, IWB-3510-2, IWB-3511-1 and IWB-3511-2.

These tables were changed to address material i

thicknesses 2 1/2 inches and greater, therefore deleting the requirement to use Section III

, acceptance standards. There are no other changes '

j in the Winter 1981 Addenda that would affect ultrasonic examinations.

l 4. These procedures meet or exceed the minimum i requirements imposed by the 1980 Edition of ASME Section XI, Winter 1980 Addenda and Winter 1981 '

Addenda. This was verified by the NRC inspectors in their report.

5. The specific procedure in question, NDE-620,

. Revision 0, was rey.!cwed and approved without comment by the Authoticed Inspection Agency on i February 11, 1991.(See attachment) d k

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Mr. C A Ireland Attachments (4)

NDE Procedures: NDE-600, Rev. O NDE-610, Rev. 0 NDE-620, Rev. O NDE 711, Rev. O E D Miller Quality Assurance Manager Technleal Support-GO _

Duke Power Company -

P. O. Box 1006 Charlotte, N.C. 28201 1006 I accept the proposed revisions as written:

I accept the proposed revisions as amended below:

4 Amend as follows: .

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PROCEDURE NDE-62( PAGE CS- 1 REVISION 0 I

DUKE POWER COMPANY ULTRASONIC EXAMINATION OF WELOS IN WROUGHT FERRITIC PRESSURE VESSELS GREATER THAN 2 QU ALITY ASSURANCE INCHES IN THICKNESS NDE PROGRAM Sht << s /['r /, (,. < a

/[V[9/ COVER SHEET

• D8t' Date

'I ' Anorodtb$"" 0"I'05,o#llfb*y"C' j LIST OF PAGES, FORMS, & ATTACHMENTS VALID FOR THIS REVISION:

REVISION Page CS-1 0 Page 1 0 Page 2 0 Page 3 .0 Pagt 4 0 Page 5 0 Page 6 0 Page 7 0 Page 8 0 Page 9 0 Page 10 0 Figure 1 0 Figure 2 0 Figurs 3 0 i F10ure 4 0 l Figure 5 0

! Figure 6 0 Figure 7 0 Figure 8 0 Figure 9 0 l Figure 10 0 Form NDE UT-1 0 Form NDE-620A 0 Form NDE-620B 0 Form NDE-6200 0 Form NDE-600C 0

• Indicates, pages affected by this revision.

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EQA301

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