ML18139B290

Responds to NRC 810313 Ltr Re Violation Noted in IE Insp Repts 50-280/81-06 & 50-281/81-06.Corrective Actions: Disputes Violation.Qc Inspector Misunderstood NRC Inspector. QC Inspector re-examined & Found to Have Adequate Knowledge

ML18139B290
Person / Time
Site:	Surry
Issue date:	04/07/1981
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18139B289	List: ML18139B290
References
203, NUDOCS 8105070429
Download: ML18139B290 (3)

See also: IR 05000280/1981006

Text

• * * i ' -.. '\I-, " ,,...... .-VrRGINIA ELECTRIC AND PowE*~'G~~;~~

RIC:aMOND,VIRGINJ:A.

23261 : 1 f.P:\ i'.3 P,\\. 3b April 7, 1981 Mr.* James P. O'Reilly, Director Office of Inspection

and Enforcement

U. S. Nuclear Regulatory

Commission

Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Dear Mr. O'Reilly:

Serial No. 203 NO/RMT:ms

Docket Nos. 50-280 50-281 License Nos. DPR-32 D:PR-37 We have reviewed your letter of March 13, 1981 in reference

to the inspection

conducted

at Surry Power Station between February 9-12, 1981, and reported in IE Inspection

Report Nos. 50-280/81-06

and 50-281/81-06.

Our response to the specific infraction

is attached.

We have determined

that no proprietary

information

is contained

in the reports. Accordingly, the Virginia Electric .and Power Company has no obj tion to these inspection

reports being made a matter of public disclosure.

The inf.ormation

contained

in the attached pages is true and accurate to the best of my knowledge

and belief. Attachment

City of Richmond Commonwealth

of Virginia L *7-c /' Acknowledged

before me this~-day of 0;e,.--,~, *Notary Public My Commission

expires: --? -.:J_ b cc: Mr. Steven A. Varga, Chief Operating

Reactors Branch No. 3 Division of Licensing

8105070L/~f

19 Ji.':,--Very truly yours, 7~ _ a._ R. Sylvia M.n!~er -Nuclear Operations

and Maintenance

-.*

• * SURRY POWER STATION RESPONSE TO NOTICE OF VIOLATION

APPENDED TO INSPECTION

REPORT 50-280/81-06

-50-281/81-06

Attachment

Page 1 NRC COMMENT 10 CFR 50, Appendix Criterion

IX as implemented

by Topical Report VEP-l-3A Section 17.2.9 requires in part that measures shall be established

to assure that special processes

are controlled

and accomplished

in accordance

with applicable

codes, standards, specifications, criteria, and other special requirements

aimed at assuring adequate fillet throat for piping fillet welds are depicted in the applicable

code (USAS B31.l-1967

edition).

Contrary to the above, of February 11, i98 l, a de qua te measures had not been established

to assure proper measurement

in that a QC inspector, whose tion included verification

of piping fillet weld sizes, could not demonstrate

the fillet weld size measurement

process. This is a Severity Level V Violation (Supplement

!I.E.). VEPCO RESPONSE 1. 2. 3. ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION;

The violation

is not correct as stated. THE REASONS FOR THE VIOLATION

IF ADMITTED;

Although exception

has been taken to the alleged violation, the following

description

of circumstances

is provided.

It is felt that there was a misunderstanding

rather than an inadequate

knowledge

of inspection

criteria.

The QC inspector

in question stated that he thought the NRC inspector

was asking a general question about the use of the fillet gauge rather than a specific question about the acceptance

criteria of B31.l. The question that was asked by the NRC inspector

was whether or not the fillet gauge had to touch the center of weld. The QC inspector

responded

by stating it was not necessary

in all cases. It should be noted that the piping systems are inspected

to B31.1 and the structural

welds inspected

the AWS Dl .1. AWS Dl. 1 allows 1/16 inch clearance

between the center of the weld and fillet gauge. Both QC inspectors

stated that they had the impression

that they were only demonstrating

the use of the fillet gauge and were not actually conducting

an inspection

to any particular

acceptance

criteria.

The situation

is considered

to be a misunderstanding

between the NRC inspector

and the QC inspector.

The QC inspector

in question was re-examined

and was able to adequately strate knowledge

of the measurement

process. CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED;

The QC inspector

in question was found to have adequate knowledge

during re-examination.

All welds previously

-accepted by this inspector

were re-inspected.

No discrepancies

were found. In addition, SO welds in Containment

Ill and 25 welds outside Containment

were randomly selected and re-inspected.

These were welds previously

accepted by other QC inspectors.

No discrepancies

were found.

• VEPCO RESPONSE (Cont'd) Attachment

Page 2 4. CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS;

Mockups of typical fillet welds were made and each QC inspector

was required to demonstrate

his proficiency.

The results were satisfactory.

Each QC inspector

had received additional

instruction

to ensure that there is n~ misunderstanding

in the use of the fillet gauge. S. THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED;

Full compliance

has been achieved.

• ,J ,._ * -:':