ML20246F028
| ML20246F028 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/06/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-437, NUDOCS 8907130098 | |
| Download: ML20246F028 (8) | |
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h VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 6, 1989 U.S. Nuclear Regulatory Commission Serial No.89-437 Attention: Document Control Desk NAPS /JHL Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 o
Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/89-13 AND 50-339/89-13 REPLY TO THE NOTICES OF VIOLATION We have reviewed your letter of June 7,1989, which referred to the inspection conducted at North Anna Power Station between April 18 and April 21, 1989 and reported in Inspection Report Nos.
50-338/89-13 and 50-339/89-13.
Our responses to the Notices of Violation are attached.
Please note that we do not believe that the issue on weld material. segregation is a violation of 10 CFR 50, Appendix B.
Our position on violation 50-338 and 50-339/89-13-02 was discussed with Mr. N. Economos-on June 27, 1989.
We have no objection to this correspondence being made a matter of public record.
If you have any further questions, please contact us.
Very trJ1y yours, f
L.
W. L.
tewart Senior Vice President - Power Attachment I \\
9907130098 890706 PDR ADOCK 05000338 Q
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U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station
a RESPONSE TO THE NOTICES OF VIOLATION ~
l REPORTETi,JRING THE NRC INSPECTION CONDUCTED BETWEEN APRIL 18 AND APRIL 20, 1989 INSPECTION REPORT NOS. 50-338/89-13 AND 50-339/89-13 1
NRC COMMENT i
During the Nuclear Regulatory Commission (NRC) inspaction conducted on April 18 - 20, 1989, violations of NRC requirements were identified.
In accordance
.with the." General Statement of Policy and Procedure for NRC Enforcement
- Actions," 10 CFR Part 2, Appendix C (1989), the violations are listed below:
A.
10 CFR' Part 50, Appendix B, Criterion IX, as implemented by the' VEPC0 QA-Topical.(VEP-1-5A), requires that " Measures shall be established to assure that special processes, including welding, heat-treating,...,
are controlled and accomplished by qualified personnel using qualified procedures' in accordance with applicable
- codes, standards, specifications, criteria, and other special require:ents."
ASME, Boiler.and Pressure;1 essel Code,Section IX, 1983 Edition, V
identifies post weld heat treatment (PWHT), as one of the. essential variables. of the gas tungsten ARC welding (GTAW) process and subparagraph QW-407.1 of the subject code requires that a new procedure qualification record (PQR), be generated when PWHT is either added to or. deleted from production welding.
Contrary to the above, on April 14, 1989 PQR 1090, dated May 1988 which l
was qualified for PWHT production. welds, was selected for the weld-repai r of - valve S/N 02-TV-MS-201B rather than one requiring no
~ PWHT as required by subject code.
This is a Severity Level IV violation (Supplement I) and applies only to Unit 2.
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L RESPONSE TO VIOLATION A-9,
-1.
' ADNISSION OR DENIAL OF THE ALLEGED VIOLATION c
The violation is correct as stated.
2.
- REASON'FOR'THE VIOLATION The violation was caused by failure to follow Welding Technique- (i.e.,
- welding procedure) 109C.-
The failure to follow procedure occurred because the procedure and the Procedure Qualification Record (PQR) were not adequately reviewed for acceptability and conformance with.the requirements of ASME IX following the determination that the weld repair. could be ' performed under the authority of certain exemptions allowed by Section NB-2431 of ASME III.
The Inspection Report stated that the welders exceeded the two layer-limit of the gas tungsten arc welding (GTAW) deposited material by depositing'the root'plus three additional passes with the GTAW process.
The -' four GTAW passes that were performed on the weld constituted two
- layers. The configuration of the~ excavation required one pass to ' fill the root and the other three passes filled in the second layer of the GTAW..Therefore, the two layer requirement of Welding Technique 109C was met.
'3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 2-MS-TV-201B. was disassembled and the weld repair was post weld heat
- treated as required by Welding Technique 109C.
Personnel involved in the determination that post weld. heat treatment was not necessary for the weld repair on 2-MS-TV-2018 have reviewed the requirements of ASME Sections III and IX and have been reminded that the exeniptions allowed by Section III do not supercede any limitations of a qualified welding technique, i
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4.-
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Personnel involved in the selection and use of welding. techniques will ensure full compliance with the welding criteria specified therein.
il In ' addition, we are evaluating ~ the feasibility of qualifying a weld procedure for welding materials greater than 1-1/2 inches thick without post weld' heat treatment.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE' ACHIEVED The evaluation for qualifying a welding technique that does not require post weld heat treatment will be completed by December 1989.
In the interim and should qualification of this welding technique not be i
feasible, the requirements of the current welding. procedures will be followed.
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NRC COMENT B..
10 CFR 50, Appendix B, Criterion VIII, as _ implemented by. the. VEPC0 QA
-Topical Report (VEP-1-5A),. requires that measures shall be. established for' the identification control of materials...... to prevent the use of incorrect or defective materials.
Contrary.to the above, on April 20, 1989, two different heats of bare metal wire produced per ASME Specification SFA5.18. and -- procured per VEPC0 Specification FMS-102 were supplied in two different conditions -
as welded impact tested.(HT#F8525) and. stress relieved impact tested i
(HT#065496).
The material was not segregated or discreetly identified' and the procedures for controlling welding ' materials contained no provision for identification and/or segregating these materials.
-This is a-Severity Level IV violation (Supplement I).
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RESPONSE TO VIOLATION B 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION l
The example cited in the violation is correct as stated.
However, we do not believe this is a violation of 10 CFR 50 Appendix B.
Our basis is discussed below.
The welding techniques (i.e.,
welding procedures) used at Virginia Power nuclear plants provide the necessary guidance to allow the elimination of the need for identification and segregation of welding materials based on impact test parameters alone.
Specifically, welding techniques only allow two layers of weld material using the gas tungsten arc welding (GTAW) process.
This is in compliance with ASME l
Section III, NB-2431(c), 1986 Edition, which exempts welding material i
from being impact tested for GTAW in root deposits with a maximum of two layers (see paragraph 6 below).
The welding techniques were
- revised, in 1988, to provide assurance that weld repairs were consistent with applicable codes and standards, i.e., that only two GTAW 1ayers were deposited in joints requiring impact properties.
Therefore, because of the limit on electrode deposition by the welding techniques, it is not necessary to identify and/or segregate GTAW weld material received with or without stress relieved impact testing.
Please also note that the physical composition of the weld material is identical. The only difference is with the certification received. As a result, GTAW filler metal supplied by vendors with or without stress relieved impact testing is acceptable for Virginia Power use without segregation.
The Quality Assurance Department performs a 100 percent documentation review of weld travellers to verify that ASME code requirements are met, including the maximum number of root deposit layers.
In addition, l
Quality Control Hold Points are used to ensure that the physical inspections required by the ASME Code are performed.
1 Therefore, it is concluded that the current program to comply with 10 CFR 50, Appendix B, as implemented by the VEpC0 QA Topical (VEP 1-5A),
for weld material storage and segregation is adequate.
2.
REASON FOR THE VIOLATION See the response to item 1 above.
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3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACM1EVED No corrective actions are required.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l
No further corrective actions are required.
l 5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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ADDITIONAL INFORMATION l
The Inspection Report stated that the welders exceeded the two layer j
liinit of the gas tungsten arc welding (GTAW) deposited material by depositing the root plus three additional passes with the GTAW process 1
on 2-MS-TV-2018.
The four GTAW passes that were performed on the weld I
constituted two layers.
The configuration of the excavation' required one pass to fill the root and the other three passes filled in the
'3 second layer of the GTAW.
Therefore, the two layer requirement of Welding Technique 109C was met.
~1 To enhance the controls for welding materials, FMS-102, Filler Metal Procurement Specification For Carbon and Low Alloy Steel Bare Filler
- Metals, will be revised to note that it is not necessary to specifically identify impact testing requirements for welding materials being purchased a maximum of two layers is applied for GTAW root deposits per the requirements of ASME Section III, NB-2431.
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