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#REDIRECT [[A09166, Submits Results of Review of Allegation R1-90-A-0208 Re Maint/Weld Repairs on Moisture Separator Reheaters.No Procedural Violations Occurred During Repair Process]]
| number = ML20073C393
| issue date = 01/21/1991
| title = Submits Results of Review of Allegation R1-90-A-0208 Re Maint/Weld Repairs on Moisture Separator Reheaters.No Procedural Violations Occurred During Repair Process
| author name = Mroczka E
| author affiliation = NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Wenzinger E
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| docket = 05000336
| license number =
| contact person =
| document report number = A09166, A9166, NUDOCS 9104250199
| package number = ML20073C307
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 4
}}
 
=Text=
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January 21, 1991 Docket No. 50-336 A091E Mr. E. C. Venzinger, Chief Projects Branch No. 4 Division of Reactor Projects U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406                                                                                                <
 
==DearMr.henringer:==
 
Millstone Nuclear Power Station, Unit No. 2 RI-90-A-0208 Ve have completed our review of an allegation concerning activities at Hillstone Unit 2 (RI-90-A-0208). As requested in your transsittal letter dated November 27, 1990, our reeponse does not contain any personal privacy, proprietary, or safeguards inforniation. The material contained in this response may be released to the public and placed in the NRC Public Document room at your d'-cretion. The NRC letter and our response have received controlled and limited distribution on a "need to know" basis during the preparatiori of this response. Based upon our request on December 20 21,                            1990 1991.
Region I personnel extended the due date for RI-90-A-0208 to January Additional time was needed to resolve ttchnical issues in order to provide a complete response.
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              -- *Mr.' E. C. ' Vensinger, Chief .                                                "
U. S. Nuclear Regulatory Commission A09166/Page 2 January 21, 1991 Issue Maintenance (veld repairs) was performed on "MSRs" on Saturday, November 10
              -1990. The velders objected to the exclusion of OSD as it was their opinion that the repaird vere governed by the ASME Code. The velders were directed to
_ proceed. 1,ater OSD determined that ASME Section VIII was applicable. The Maintenance' Supervisor' ignored OSD, and the repairs continued to completion-without an NCR or QSD involvement.
Backstound The velding issue identified in this allegation concerns seal velding that-vas performed on the leaking manvty covers of the moisture separator reheaters
                -(MSRs). The MSRs are ASME Section VIII pressure vessels. The seal velds were applied to stop steam leakage from the gaskot joint of the manvays.
The ASME Section VIII Code does not address in-service repairs to pressure vessels as a separate and distinct part of the Code. These types of repairs-are normally classified as temporary repairs by our procedures. The reason these types of repairs-are classified as temporary repairs is beceuse the H                repsir does not fully: meet all Code requirements. Typically, this is due to operationalTrestrictions_(i.e., unisolable water or steam leakage which is present while the repair-is belag made).
          '    -While not addressed by the Code.=these types of repairs are allowed by our procedures and are consistent with_-the guidelines established for making      '
similar repairs _to ASME Class 3 systems that ste governed by the code requirements of the ASME Section XI Repair Replacement Program. In some cases, these repairs require the processing of a nonconformance report (NCR) prior to the initiation of the repair. In other cases, repairs are completed b
in accordance with a maintenance procedure and an NCR is not rt: quired.
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Additionally,.~the velds in question are not structural velds. No credit _is taken.for the structural integrity-of the veld.- The veld was made to stop leakage of a gasketed manvay and does not have any adverse effect on thi structural integrity of the pressure vessel.
Vith these points clarified, the following responses are provided to the questions: raised by-this issue.-
1.. What were the governing procedures for this work and vere they properly _
prepared and implementedt.
I'                      Response
                      'The procedures governing the velding performed on the MSR manvays were
                                    ~
Maintenance Procedures MP-270lV and VPS 033.
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              .Mr.' E.'C. Venzinger, Chief
              -U.-  S. Nuclear Regulatory Commission                                                  i A09166/Page 31 l
January 21, 1991 Maintenance Procedure MP-270lV provides instructions for writing,-
processing, and close out of work order packages issued by the Milletone Unit 2 Maintenance Department. In accordance with the guidelines specified in this procedure, a two-page work order package was assembled and processed to authorize-this vm.k. Per this procedure, no veld inspection plan.is required to imi lement veld repairs of this nature unless specifically required by an engineering evaluation or a noncon-          j formance report (NCR).
t In this case, the nature of the repair did not require a nonconformance report to be generated, and the engineering evaluation did not require the use of a veld inspection plan. The entire repair process was completed in accordance with the identified ptocedures.
: 2. Vere Code requirements required, included, and implemented?
 
===Response===
As previously stated, Section VIII of the ASME Code does not address veld repairs to in-service vessels separately f rom construction requirements.
There are no specific ASME Code requirements applicable to this type of repair. Our procedures specified that the identified velds be made by qualified velders, using a qualified veld procedure specifically intended for use in this type of-application. No credit is taken for the structural integrity of the seal velds. The sole purpose of these velds is to prevent leakaga.
: 3. Vas OSD constIted and were their comments answered?
 
===Response===
The guidelines provided by Maintenance Procedure HP-270lV do not require an inspection plan for this type of repair. -on thic basis, no OSD involvement was identified in order to complete the repair.
QSD noted the veld repairs in progress and questioned the need for an NCR since the work was being performed on an ASME vessel. These comments were addressed by the Maintenance velding engineer. References were made to the guidance provided by Maintenance Procedure HP-2701V and the appli-cability of VPS 033. An NCR vas generated to document and disposition these concerns on Code-applicability.
: 4. Vere any' procedures violated regarding this work item? Please explain.
 
===Response===
_Haintenance Procedure HP-270lV, Vork Order Processing, and ACP-0A-2.18, ASME Section XI Repair / Replacement Program, were the procedures referenced to_ implement'the subject repairs. The requirements and guidance provided l
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                                          .. . , .  . . . . . . . . - ~ .        -    . - _ _ .      . . _ . -  .. -
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4tr.'E. C. .Venzinger, . Chief I U.,S.-Nuclear Regulatory Commission A09166/Page 4
: January 21, 1991                                                                  .              .
byythese procedures were followed.                  No procedures were-violated during the repair. process. As a result of this issue, ve.are reviewing our mainte--
nance;velding practices to ensure that they fully considered construction Code requirements' prior-to=the initiation of work. 'If considered necessary, the' applicable procedures vill-be revised to provide additional guidance on when an NCR is needed prior to the initiation of work. This review is expected to be completed by July 1991.
After'our-review and evaluation,1ve find that this issue does not present any-indication of a compromise of nuclear safety. %Niappreciate the opportunity to respond and explain the basis for our actions. Please contact members of my staff if there are.any further questions on this. matter.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY 2s/
E. J. pckka'          #
Senior Vice President cci -V.'J. Raymond,' Senior Resident ~ Inspector, Millstone Unit Nos. 1, 2, and 3
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