ML20149B937
| ML20149B937 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah, Comanche Peak, 05000000 |
| Issue date: | 02/13/1986 |
| From: | Thompson H Office of Nuclear Reactor Regulation |
| To: | Hayes B NRC OFFICE OF INVESTIGATIONS (OI) |
| Shared Package | |
| ML082310326 | List: |
| References | |
| FOIA-87-726 NUDOCS 8602210556 | |
| Download: ML20149B937 (1) | |
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UNITsD 8TATEs NUCLEAR MEGULATORY COMMISSION
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f W e s t,0 MEMORANDLM FOR:
Ben B. Hay s, Director Office of nyestigations H. L. Thompson Jr TVA Oversight drou., Director FROM:
s Office of Nuclear <teactor Regulations SUB.1ECT:
Q2-85-027 TVA: ALLEGED VIOLATIONS OF TVA WELDING INSPECTION PROCEDURES This responds to your verbal request for a staff position on weld inspections as delineated in the memorandum, dated February 6, through carbo-zinc primer,for Ben B. Hayes.
1986, f rca James Y. Vorse In a separate meeting between B.D. Liaw, Chief, Engineering Branch, Division of BWR Licensing, and yPhilip V. Joukoff of your staff, the staff position on this issue was also explainedand discussed that can briefly be summarized as follows:
m For the initial acceptance, the AWS 01.1 Code requires that inspections of welds be performed prior to the application of a coating.
The staff has accepted this particular Code rule as cosunitted by all applicants or licensees without exception. However the reinspection of welds with or without coatings is not addressed bv dWS 01.1 or any other weld inspection standards. The staff has dealt with this issus strictly on a case-by-case basis.
As an example the staff recently responded to a similar question for reinspections of w, elds at Comanche Peake 5, gust 29, 1985 ite. The attached memorandum from W. V. Johnston for V. S. Noonan dated Au should help explainthebasesofthestaffpositIononthisissue.
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Enclosure:
As stated cc:
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Contact:
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AUG3s #85. !
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MEMORANDUM FOR: Vincent S. Noonan. Director ComanchePeakProject Division of Licensing -
Assistant Director William V. Johnston,& Environmental Technology FROM:
Chemical Materials,f Engineering Division o
SUBJECT:
VISUAL INSPECTION OF PAINTED SUPPORT WE 1
This is in response to your memorandum
, for J. P. Knight, Acting Director, Division, octed August 13 of 92ineerins position paper and formulate a coordinated staff poside.. By memorandum dated August 16, 1985 we proposed to you that we provide our reply by September 6,19E5..
1 The American Welding Society's 01.1 Code (Section 3.10.1 of D 1.1-75) requires that the initial acceptance inspection of welds be wrfomed prior.
to the application of a coating.
Reinspection of welds wit 1 or without
.coatjngs is not addressed in DI.1 or any other weld ins,pection standard.
Recently, the Nuclear Construction Issues Group (NCIG) prepared the document, T
"Visual Weld Acceatance Criteria for Structural Welding at Nuclear Power N:IG-01 Rev. 2 of 05/07/85, providity guidance on the sub-Plants" (VWAC), ion of tdids after coating "ituations whe
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... with t)e concurrence of__the Engineer." pect(esphasis added). There are s l
coating or other inspection techniques, such as' magnetic particle examinations, may be required. By experience, there are too many situations and options peculiar to individual sites, vendors, coating systems, or types of defects; such that an overall staff position on the acceptabilitr of Inspection of coated welds cannot and should not be established.
As we briefly stated in our Augus.t 16, 1985 memorandum, the staff has dealt with this issue strictly on a cass-by-case basis. However some guidelines can be provided that say be of benefit for the Comanche Peak froject:
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Rainspection thru paint may be acceptable to determine presence, location, length and size of welds in structural steel weldsents.
The apparent size of, fillet welds (leg length) is actually reduced when measured by gages with the presence of ? :cating, and accordingly, represents a conservative measurement.
TodetermineweldattributesrelatedtoqualityIcaldemonstrationofsuch as lack of fu cracks, porosit/, or slag inclusions the pract examinationsforthesetypedefectslhroughevenrelativelythincoatings (maximumof5 mils)hasnotbeenachieved. We have records of two instances wher6 a qualification program was attempted; i.e.
unmarked weld specimens with many inspectors, and various controls.,These quali-fication arograms were not successfully completed. The applicants decided tiemselves that the tests were inconclusive, and this approach was not used, mm l
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AUG 2 91985
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Vincent S. Noonan.
The Stone & Webster Position Paper makes compa'risons between the Comanche Peak Project and Wolf Creek Generating Station about the similarities of paint systems and their situations.
At the. Wolf Creek site, there were two samples of uncoated weld inspections performed to back up a 100% reinspection of accessible welds.
The first sample consisted of more than 40 percent of the accessible welds that were not The second sample was made of a random selection, by'ad by the NRC the NRC team, coated.
of 59 welds that were coated. The second sample was ins st visually and by magnetic particle technique as coated.
the welds in particle examination. ped of coating and reinspected by visual and magneticRes the sample were strip the basis for assuring the quality of coated welds and inaccessible welds in the population.
In short, weld attributes representing quality have not been proven to be reliably and consistently inspected when the welds are coated. Qualification tests attempted at Clinton and Zimmer sites were not tuccessful even with coatings 5 mils or less in thickness.
Accordingly, we do not believe that the resolution at Wolf Creek is appropriate for accepting Stone & Webster's position on this issue for this or any particular site.
!!otwithstanding the above discussicn, we suggest the following a;:pra:- ic-theComanchePeakproject:
The applicant be requested to propose a qualification program for inspection thru coating by their inspectors consistent with guidelines provided above, for certain weld attributes that are of structural signifi-ficance.
The staff envisio'ns that such a qualification program would be very much like the applicant of Wolf Creek did at that particular site.; and a random sample inspection be conducted to the NCIG acceptance criteria by third party, qualified inspectors and witnessed by NRC inspectors, of at least 64 welds with their coatings stripped and/or welds which have never been coated that are representative of coated welds to be inspected.
Results of this reinspection should be reviewed and assessed jointly by theMaterialsEngineeringBranch,CcsancheProject,andRegionIVstaff.
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Assistant Director William V. Johnste,& Environmental Materials, Chemical Technology Division of Engineering e
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