ML20207T565
| ML20207T565 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/04/1986 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 2487N, SL-244, TAC-62135, NUDOCS 8703240136 | |
| Download: ML20207T565 (2) | |
Text
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' Georgia Power Company c
- - 6 333 Piedmont Avsnue
- 4. J,
3 Atlanta, Georgia 30308 Telephone 404 526-6526
' Mailing Address:
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Post Office Box 4545 Ddichg b
Atlanta. Georgia 30302 u 23 ll n 8352 GeorgiaPower L T. Gucwa
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h rte southem ekrtnc system Manager Nuclear Safety and Licensing ad P
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SL-244 2487N April 4, 1986 U. S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: JNG Region II - Suite 2900 50-321/50-366C 101 Marietta Street, NW Atlanta, Georgia 30323 ATTENTION: Dr. J. Nelson Grace Gentlemen:
Pursuant to discussions between Georgia Power Company (GPC) and NRC Region II. personnel, on_ November _18 and 19, 1985, thisCletterRformalizes
'GPC's' position and 4 interpretation of f Subarticle ~IWA;43007ofJSection XCtoi the L ASIE Boiler.c and. Pressure < Vessel - Code.
The subject subarticle of the Code pertains to welding and welder qualifications.
It is our position that welding procedures properly qualified in accordance with ASME Code Section IX under GPC's quality assurance program, by either a contractor or the owner, may be used by repair organizations.
This is not in agreement with the current Code committee interpretation XI-1-83-81 of Subarticle IWA-4300 Code interpretation XI-1-83-81 states:
" Question (2): In accordance with IWA-4300, may welding procedures qualified by the Owner be used on work performed by the repair organization (when the repair organization is not the Owner)?
Reply (2):
No, except when the Owner retains direct supervision of the welders being used to perform the weld repair."
The emphasis on " direct supervision" was added by GPC to amplify our disagreement with the-Code committee interpretation.
It is our position that the owner is the repair organization when the owner's quality assurance program is involved regardless of what organization does the work (
Reference:
IWA-2110(j ), 1980 Edition of ASME Section XI).
Further, when the owner is the " repair organization," the ASME Section XI IWA-4300(c)(1) requirement that the repair organization have " complete and exclusive administration and technical supervision of all welders" is satisfied through the quality assurance program without direct owner supervision.
Typically, in no other activity of
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U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 i
April 4,1986 Page Two I
plant maintenance,
- repair, or modification is direct 'supervison of contractor personnel recaired.
Weld procedures needed for complex and difficult repair welds are, in some cases, developed and qualified by the-owner or another contractor prior _ to award of contracts to perform repairs so that. regulatory approval s, when needed, can be pursued and repair-contracts -developed.
Our position is not unique and, we believe,.is 4
followed in the industry.
Further, it -is our view that qualification of welders can be performed by the owner in accordance with the owner's quality assurance program.
GPC considers that Section XI of the Code should provide for total owner control of contract welding performed within the owner's quality assurance program.
This position is based on the owner being held accountable for activities perfctmed under. the owner's operating license. A proposed change to Subarticle IWA-4300, reflecting GPC's position, has been submitted to the ASME.
This position. is considered to be appropriate since Subarticle IWA-4300, we believe, was intended to provide relief from Section IX requirements of the Code so that the owner could maintain direct control and assure proper documentation under the owner's quality assurance program.
The proposed change to the ASME Code would clarify wording relative to the issue of welding and welder qualifications.
The information provided herein documents our positioa and t
interpretation of Subarticle IWA-4300 of the Code.
We request that the NRC i
provide concurrence with GPC's position and interpretation or provide the l
NRC position on the subject Code subarticle.
Your prompt attention to this matter is appreciated.
Should you have any questions in this regard, please contact this office at anytime.
Sincerely yours, i
Wf4" L. T. Gucwa JAE/mb xc:
Mr. J. T. Beckham, Jr.
Mr. H. C. Nix, Jr.
Senior Resident Inspector w
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