ML19338C332

Responds to NRC 800617 Ltr Re Violations Noted in IE Insp Rept 50-482/80-11.Corrective Actions:Welding of Electrical Penetrations Halted.Completed Welds Checked for Accuracy

ML19338C332
Person / Time
Site:	Wolf Creek
Issue date:	07/16/1980
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19338C330	List: ML19338C332
References
NUDOCS 8008150146
Download: ML19338C332 (2)

Text

KANSAS CAS ANO EllCTRIC COMFANY

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July 16, 1980 Mr. W.C. Seidle, Chief Reactor Construction and Engineering Support Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan plaza Drive Suite 1000 Arlington, Texas 76011 KMLNRC-012 Re: NRC Docket No. STN 50-482/Rpt. 80-11

Dear Mr. Seidle:

This letter is written in response to your letter of June 17, 1980, which transmitted Inspection Report 50-482/80-11. As requested, each finding is being addressed in three parts:

a) Corrective steps taken and the results achievedt b) Corrective steps which have been taken to avoid further noncompliance 1 and

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c) The date when full compliance will be achieved.

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l Finding l

The IE Inspector determined that the limits for maximum reinforcement of butt welds specified in Daniel welding technique sheets N-1-1-BA-1, Revision 4 for welding carbon steel and N-1-8-BA-24, Revision 0 for welding I carbon steel to stainless steel, and Daniel Quality Control Procedure l

QCP-VII-200, Revision 5 for visual inspection are Less restrictive than required in NE-4000, paragraph NE-4426 of ASME B&PV Code,Section III,1974 Edition through Sumer 1975 Addenda. For example, for a material thickness

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of one inch, NE-4426 limits the maximum reinforcement to 3/32 inch, whereas, the welding technique sheets and Quality Control procedure permit a maxi-mum reinforcement of 3/16 inch.

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Response

l a) Our review of welding techniques N-1-1-BA-1 Rev 4 and N-1-8-BA-24 Rev 0 confirms that these techniques are intended l

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8 0080150 $

201 N. Market - Wetuta. Kansas - Mad Accress PO. Box 206 / Wehita. Kansas 67201 - Telephone: Area Code (316) 261-6451

• y Mr. W.C. Seidle KMLNRC-012 July 16, 1980 for welding performed under subsections NB, NC and ND of the ASME Code and do not provide for the maximum weld reinforcement requirements set out in Code Subsection NE.

Welding of electrical penetrations which was in progress was stopped. Daniel's QC Inspectors reinspected all completed penetrations in accordance with the weld reinforcement require-ments of NE-4426 and found that all completed welds on the electrical penetrations met the requireuents of NE-4426.

Welds which have been completed in the fuel transfer tube sleeve, except for one weld, were inspected and were found to comply with subsection NE-4000. One weld was encased in concrete and therefore the amount of weld reinforcement on the OD could not be directly measured. However, this weld was previously radiographed. An analysis of the radiograph densities shows that the weld reinforcement does not exceed the 3/32 inch maximum reinforcement requirement. In summary, all welds identified above meet ASME Subsection NE require-ments and are acceptable.

b) To prevent any future problem techniques N-1-1-BA-1 and N-1-8-BA-24 have been revised to include the weld reinforce-ment requirements of Subsection NE.

A recent audit of traveler preparation revealed only a few minor problems. We believe the traveler preparation process is basically sound and that the failure to incorporate the special weld reinforcement requirements from Subsection NE is an isolated occurrence. However, to further confirm this, KG&E will select a random sample of welding techniques and will have an independent review of these techniques performed to determine if applicable ASME code requirements have been clearly set out.

c) The revision of techniques N-1-1-BA-1 and N-1-8-BA-24 has been completed. The review of additional welding techniques will be completed by August 31, 1980.

' Please advise if you need additional information.

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l Yours very truly,

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GLK:bb cc: TVandel (NRC Site Insp.)

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