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)

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• 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

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• SURRY POWER STATION RESPONSE TO NOTICE OF VIOLATION APPENDED TO INSPECTION REPORT 50-280/81-06 281/81-06 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.

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