ML20205K092
| ML20205K092 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/27/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 87-143, NUDOCS 8704010508 | |
| Download: ML20205K092 (3) | |
Text
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l VluGINIA ELucruIc Axn Pownx COMPANY 4
R icu xox u, Vinu xx A ununt W.L.MTHWAHT vorm Punannant s m..o'""'* ""
March 27, 1987 1
United States Nuclear Regulatory Commission Serial No.87-143 Attention: Document Control Desk N0/LNH:jmj Washington, D.C.
20555 Docket Nos.
50-338 50-339 License Nos.
NPF-4 NPF-7 i
Gentlemen:
I
}
VIRGINIA ELECTRIC AND POWER COMPANY j
NORTH ANNA POWER STATION UNITS 1 AND 2 ASME SECTION XI RELIEF REQUEST STRUCTURAL WELDING 1
i i
In accordance with 10 CFR 50.55a we are requesting relief from the provisions of ASME Section XI, 1980 Edition through Winter 1981 Addenda, subsections l
IWA-4300 (a) and (b) for structural welding.
ASME Section XI, subsection IWA-4300 requires that welding procedures and welder qualification be in accordance with Section IX.
IWA-4120 states that a
repairs shall be performed in accordance with the Owner's Design Specification i
and Construction Code of the component or system. The North Anna design and l
fabrication standard for supports invokes AWS D1.1, " Structural Welding Code" for welding qualification.
ASME Section IX is the proper code for qualification of welders and welding i
procedures used to weld piping and pressure vessels. Under some conditions it is not the most appropriate nor most conservative qualification code for procedures and welders used to weld component and piping supports. This is especially true when those supports are designed and fabricated in accordance with AWS D1.1 codes.
This is principally because ASME Section IX is mainly intended for use on pressure vessel and piping welding where the vast snaj ority of weld joints are relatively straight forward full penetration butt welds or simple fillet welds.
For this reason, an ASME Section IX procedure qualification may be run in only one position on plate and will qualify procedures for any type of joint. AWS D1.1 recognizes a limited number of joint details as prequalified and dictates other essential parameters which must be followed for the welding procedure to j
be deemed prequalified. For any joint detail varying from the prequalified joints the qualification testing that must be done per AWS D1.1 is more rigorous than that required by ASME Section IX.
For example, AWS D1.1 requires a test in each position to be qualified, requires tests for each product form q
to be welded (i.e., plate, pipe, or tube steel), and requires volumetric 0704010508 870327 i
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inspection of the test coupons. ASME Section IX would require a test in only one position, on only one product form, and without subsequent volumetric inspection.
Welder qualification is another area in which AWS DI.1 is, at least for tube steel welding such as used in supports, more restrictive than ASME Section IX.
For instance, the welder qualification test on plate that will qualify an ASME Section IX qualified welder for all plate groove welds and all plate and pipe fillet welds will only cover the AWS qualified welder for all plate groove welds and fillets and piping fillets in only two positions. The qualification test on pipe that will qualify the ASME Section IX qualified welder for all types of welds on plate and pipe in any position will not cover the AWS qualified welder for "T",
"Y",
and "K" connections on tube steel.
"T", "Y ",
and "K"
connections are used often with piping and component supports fabricated from tube steel and therefore the use of AWS Dl.1 for welder qualification is appropriate and conservative.
For the reasons stated above, we request relief from IWA-4300 (a) and (b) for structural welding.
Enclosed is a check for $150 for the application fee.
Very truly yours, h
i W. L. Stewart Attachment
s.
cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, CA 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station l
l l