ML20002B909

Forwards Response to Violations Noted in IE Insp Rept 50-338/79-47.Corrective Action:Welding Procedures Involving Combination Processes Will Be Amended to Include Weld Metal Thickness Range as Deposited by Each Individual Process

ML20002B909
Person / Time
Site:	North Anna
Issue date:	09/17/1980
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20002B906	List: ML20002B905 ML20002B907 ML20002B909
References
1171A, NUDOCS 8101070309
Download: ML20002B909 (2)

Text

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c dU September 17, 1980 Mr. James P. O'Reilly, Director Serial No.

ll71A Office of Inspection and Enforcement N0/JRH:sim U. S. Nuclear Regulatory Commission Docket Nos.

50-338 50-339 Region II License Nos. NPF-4 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 NPF-7

Dear Mr. O'Reilly:

In reference to the follow up inspection of your audit no. 50-338/79-47 conducted at North Anna Power Station by Mr. Nick Economos on September 11 through September 12, 1980, we offer the following explanation. See attachmen t.

Very truly yours, f lA B. R.kylvia Manager-Nuclear Operations and Maintenance Attachment cc:

Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 I

Division of Licensing Mr. B. Joe Youngblooda Chief License Branch No.1-l Division of Licensing r

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OFFICIAL COPY 81010i20}07 l

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-- Response to Notice of Violation Items Reported in IE Inspection Report 50-338/79-47

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NRC Comment

As required by' Criterion V of Appendix lB.to 10.CFR 50 and implemented G

.by Vepco Topical Report VEP-1-A ' Section '17, paragraph 17.2.5 specifies in part, 'that ' activities affecting quality are accomplished in accordance General Welding Procedure

.ith instructions procedures, and drawings. ~

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W-1.'0 Rev.1 invokes ASME Section IX -(74.W76) which under paragraph OW-2013, requires that each welding. process or-procedure be qualifled either separately or in combination with other processes or procedures

....for the deposited weld metal thickness range for each of the processes

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or procedures... paragraph QW-351 of'the same code requires that the limit of thickness of the weld he deposits with each welding process.

Contrary ' to the above, on November 16,~1979a procedure qualiflcation

^ records of weld process -specifications and welder performance qualifi-cations involving combination processes 'did not indicate the weld metal

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thickness deposited with each welding process.

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This is an infraction.

Response

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Procedure' qualification records of weld process _ specifications and welder performance qualification records involving combination' processes

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Due to misinterpretation of applicable codes and a misunderstanding of proper documentation, this item has not been resolved to date. _It has been and is' the contention that the' welder qualifications met acceptable criteria in that the alloted thickness ranges have been adhered to on the various processes but not individually documented on combination processes.

As a result of this finding, it is our intention to review past records to assure that the thickness ranges allated for the combined processes have not been violated.

Pursuant to Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, the following information is ' submitted.

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Corrective steps taken and results achieved:

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Welding procedures involving combination processes will'he amended as needed to include the.. weld metal thickness. range as deposited by each individual process. _ ~

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Corrective steps which will be taken to avoid further non-compliance:

We believe that no further corrective action is required.

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