chattanooga, tennessee 37401 ost 13 1988 · 101 marietta street, nw, suite 2900 atlanta, georgia...

TENNESSEE VALLEY AUTHORITY

CHATTANOOGA, TENNESSEE 37401

5N 157B Lookout Place

OST 13 1988

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555

Gentlemen:

In the Matter of the Application of ) Docket Nos. 50-390Tennessee Valley Authority ) 50-391

WATTS BAR NUCLEAR PLANT (WBN) UNIT 1 - ASME SECTION III REQUIREMENTS FORWELDING ACTIVITIES

On June 26, 1987, a meeting was held between TVA and NRC in Bethesda,Maryland, to discuss the application of American Society of,,MechanicalEngineers (ASME) Section III requirements for WBN unit 1. The NRC positionprovided in a July 2, 1987 letter stated that ASME welding activities at WBNshould be performed to the Construction Code of Record, ASME Section III -1971 Edition through Summer 1973 Addenda. Also in the letter, NRC requiredTVA to review any ASME repair and modification activities involving weldingthat were performed following closure of the piping sy.s~tem N-5- data reports toidentify where work was performed in accordance with ASME Section XI or by anonstamp holder. TVA was required to identify these as exceptions to the Codeof Record and request approval from the NRC staff for the proposed alternativesas prescribed by 10 CFR 50.55a(a)(3).

In order to comply with NRC's position, TVA has realigned the WBN weldingprogram to require that welding activities affecting ASME code systems beperformed in accordance with the Construction Code of Record. Enclosure 1describes the current requirements for WBN unit I ASME code activities. Inaddition, TVA has reviewed work documents and identified the cases where workwas performed in accordance with Section XI or by a nonstamp holder. Thisletter identifies these cases, provides justification for work performed andplanned, and requests NRC approval of proposed alternatives to theConstruction Code of Record.

TVA considers the WBN Construction Code of Record to be the ASME Section III -1971 Edition through Summer 1973 Addenda and those specific provisions oflater versions of the code which have been adopted subsequent to the Code ofRecord. These provisions were submitted in TVA's letters to NRC datedAugust 21, 1987 and July 6, 1988.

Although NRC's position pertained to ASME Section III welding activities, TVAhas completed a review of both welding-related and nonwelding-relatedactivities associated with repairs, replacements, and modifications performedon ASME code piping systems subsequent to closure of the N-5 reports.

::8810200017 881013 io,0IPDR ADOCK 0500039'C) An Equal Opportunity EmployerA PFDC

U.S. Nuclear Regulatory Commission O T 13 1988

If additional examples of welding activities performed in accordance with ASMESection XI or by a nonstamp holder are identified in the future, they will besubmitted as a supplement to this letter.

TVA has assessed differences in the programmatic and technical requirements ofASME Section III and Section XI to determine the acceptability of the proposedalternatives. Enclosure 2 provides a comparison of the programmaticrequirements demonstrating that WBN unit 1 ASME Section XI welding activitiesprovide a level of quality and safety comparable to ASME Section IIIrequirements. Enclosure 2 also provides a comparison of technicalrequirements and identifies some provisions of ASME Section XI in the area ofpressure testing that are less restrictive than ASME Section III.

Enclosure 3 identifies the work representing exceptions to the Code ofRecord. The additional work and required testing described in enclosure 3will be performed by TVA in compliance with welding-related ASME Section IIItechnical requirements. As specified in enclosure 3, TVA is evaluating thetesting requirements for the Essential Raw Cooling Water (ERCW) System mortarlined piping, and the details will be provided as a supplement to this letteron or about March 25, 1989.

As committed in TVA's letter dated December 24, 1987, TVA will supplement theN-5 data reports for welding activities not already documented in accordancewith ASME Section III. In addition, TVA's N-5 program will provide for thedevelopment of a cross-reference between each work document that has not beendocumented in accordance with ASME Section III requirements and theappropriate N-5 data report form.

Enclosure 4 provides a list of the individual commitments identified in thisletter.

This letter and enclosures satisfy TVA's commitment to provide the results ofthe review effort described in my letter to you dated December 24, 1987. Asprescribed by 10 CFR 50.55a(a)(3), TVA requests approval of the proposedalternatives to the Construction Code of Record for WBN unit I ASME Section XIwelding activities performed after completion of the N-5 reports.

If there are any questions, please telephone 3. A. McDonald at (615) 365-8650.

Very truly yours,

TENNESSEE-VALLEY AUTHORITY

R. Gridley, anagerNuclear Licensing and

Regulatory Affairs

Enclosurescc: See page 3

3-

U.S. Nuclear Regulatory Commission 08T 13 1988

cc (Enclosures):Ms. S. C. Black, Assistant Director

for ProjectsTVA Projects DivisionU.S. Nuclear Regulatory CommissionOne White Flint, North11555 Rockville PikeRockville, Maryland 20852

Mr. F. R. McCoy, Assistant Directorfor Inspection Programs

TVA Projects DivisionU.S. Nuclear Regulatory CommissionRegion II101 Marietta Street, NW, Suite 2900Atlanta, Georgia 30323

U.S. Nuclear Regulatory CommissionWatts Bar Resident InspectorP.O. Box 700Spring City, Tennessee 37381

ENCLOSURE 1 0WATTS BAR NUCLEAR PLANT

PERFORMANCE OF ASME CODE ACTIVITIES ON UNIT 1

To comply with the NRC position, ASME code activities for WBN unit 1 are beinghandled in accordance with the requirements described below. Theserequirements have been incorporated into Site Director Procedure AI-9.15.Activities within the scope of ASME Section III must be performed by a stampholder organization in accordance with TVA's "Quality Assurance Manual forASME Section III Nuclear Power Plant Components" (NCM). Activities outsidethe scope of ASME Section III but within the scope of ASME Section XI may beperformed by a nonstamp holder organization. These activities are beingperformed and documented in accordance with the Nuclear Quality AssuranceManual as implemented by the WBN Section XI Repair and Replacement Program.

1.0 Purpose

The purpose of this specification is to describe:

(1) those work activities that may be performed by plant organizationsnot possessing ASME code accreditation (nonstamp holder); and

(2) those activities that must be performed by organizations whichpossess appropriate ASME code accreditation (stamp holder).

2.0 S

This specification applies to all work performed on ASME code classcomponents or piping systems on unit 1 before issuance of the operatinglicense.

3.0

3.1 TVA's letter to NRC dated December 5, 1986, Docket Nos. 50-390/391(L44 861205 800)

3.2 TVA's letter to NRC dated December 16, 1986, Docket Nos. 50-390/391(L44 861216 800)

4.0 beiitions

4.1 Repair - Those operations involving welding, heat treatment, ordefect removal which are required to restore an item to a safe andsatisfactory operating condition.

4.2 Modification - A planned change in plant design or operation,accomplished in accordance with the requirements and limitations ofapplicable codes, standards, specifications, licenses, andpredetermined safety restrictions.

0 -2-

4.3 flllacement - Spare and renewal components or pressure retainingparts of a component, such as valve body, disc, and body-to bonnetbolting. Replacement does not alter the design or operation of acomponent or piping system.

For the purpose of this specification, the term replacement shallalso apply where attachment to the pressure boundary is by weldingor mechanical means.

5.0 R quirements

5.1 The following kinds of activities must be performed byorganizati,rns possessing ASME Section III accreditation:

5.1.1 All repairs (see section 4.1) to pressure retaining portionsof TVA components or piping systems.

5.1.2 All modifications to pressure retaining portions of TVAcomponent or piping systems.

5.1.3 Replacement, by welding, of all pressure retaining portionsof TVA components or piping systems.

5.1.4 All pipe/tubing bending processes.

5.2 The permanent plant organizations that do not possess ASMESection III accreditation may perform the following kinds ofactivities:

5.2.1 Open and close bolted or threaded connections. Activitiesinclude, but are not limited to: removing and replacingthreaded pipe caps or plugs; opening and closing a flangedjoint or removing a flanged valve to perform inspections;and removal of reactor vessel head or instrument columns toperform inspections or maintenance. Opening and closing amechanical joint of an ASME Section III Class 1 component orsystem requires a leak test at nominal operating pressure inaccordance with PMP 1502.08.

5.2.2 Removal and reinstallation of pipe clamps and pipesupports. These activities include but are not limited to:removing and reinstalling pipe clamps and supports that aremechanically attached to ASME code class piping systems;reworking, modifying, or fabricating component supports; andinstalling pipe supports by mechanical means. ASMEsupport-to-pipe welds must be performed by an organizationpossessing ASME Section III accreditation.

5.2.3 Removal and reinstallation of component access openings andmanway cover plates (steam generators, pressurizers, etc.).

5.2.4 Replacement of nonpressure retaining components (i.e.,cotter pins or supports, valve packing, mechanical seals).

-3-

5.2.5 Pressure boundary replacements that do not require weldingand do not alter design or operation of a component orpiping system. Replacements shall be in accordance with theWatts Bar ASME Section XI Repair/Replacement Program.

5.2.6 Motor Operated Valve Analysis and Test System (MOVATS)testing of Limitorque valve operators.

5.2.7 Routine maintenance activities which include but are notlimited to lapping or replacement of nonintegral valveseatso adjustment or replacement of valve packing, pump sealmaintenance, etc.

5.2.8 Surface conditioning of welds by mechanical means forpreservice or inservice inspection.

5.2.9 Cutting into a code system (i.e., the piping or weld). ANIIinvolvement shall be required for all cutting activities.These activities do not include any welding.

5.3 Work described in 5.1 above shall be performed in accordance withthe TVA Nuclear Components Manual. Work described in 5.2 aboveshall be performed in accordance with the Nuclear Power NuclearQuality Assurance Manual.

ENCLOSURE 2

COMPARISION OF ASME SECTION III AND SECTION X1REQUIREMENTS

A comparison of ASME Section III and ASME Section XI programmatic requirementswas made and is summarized below.

SECTION III/SECTION XI: COMPARISON OF PROGRAMMATIC REQUIREMENTSFOR WELDING-RELATED ACTIVITIES

I PROGRAMMATIC I SECTION III I SECTION Xl I COMPARISON I COMMENTSI REOIUXRFMFNT I I .. I I.II I IWelder I Per Section IX I Per Section IX SameQualification I I jI .1I

II IIWeld I IProcedure Per Section IX I Per Section IX Same

Qual i fi cati on I III I I

QA Program NCA-4000 10 CFR 50 Comparable Each program identifiesAppendix B the attributes necessaryto establish workpractices and documen-tation required to assureand verify quality (e.g..design control, documentcontrol, work control,corrective action, auditsIetc.).

I IAuthorized I ANI for all workJ ANI - for pressure Comparable For welding activities,Inspection I involving pres- J boundary welding the same inspection isI sure boundary I ANII - for other required by Section XII j activities as Section III, ForSI I other activities, Section

I iXI and III identify thoseinspection requirementsnecessary to verify theSI I quality of the work.I I- I

Certification Not required ANSI N45.2.6 Moreof pressure restrictivetest personnellwho performthe visual Iexam I

(continued)

SECTION III/SECTION XI: COMPARISON OF PROGRAMMATIC REQUIREMENTS

FOR WELDING-RELATED ACTIVITIES (CONTINUED)

PROGRAMMATIC SECTION III I SECTION XI COMPARISON I COMMENTS

I-REQUIBEUMENT I I II I I

Certification ASNT-TC-lA ASNT-TC-lA Same

of NDE IPersonnel II I I

I IIIDocumentation N-5 Data Report NIS-1, NIS-2 and Comparable Section XI documentation

I I JSummary Reports I will be added to existing

I I N-5 data reports.

II I I

ASME Code- Required Not required Less Since the above

Symbol Stamp restrictive programmatic requirements

(NA/NPT) are the same or

comparable (as described),I

this Section III Irequirement has no

significant impact on

quality. I

TVA concludes that the programmatic elements of ASME Section XI provide a

level of quality assurance comparable to ASME Section III requirements.

A comparison of the ASME Section III and Section XI technical requirements was

made and the differences are summarized below.

SECTION III/SECTION XI: COMPARISON OF TECHNICAL REQUIREMENTS

FOR WELDING-RELATED ACTIVITIES

TECHNICAL I SECTION III I SECTION XI COMPARISON I COMMENTS

_REOUTREWENT I I I

NDE Acceptance NX-5000 NX-5000 plus Same or more ICriteria IWX-2000 (Pre- restrictive I

I Service inspection) II I

Authorized Required Piping, Valves, Less Work documents will be

Inspector and fittings restrictive provided to ANT or ANTI

acceptance of National Pipe for acceptance.

pressure Standard (NPS)I

boundary I inch and less

materials are exempt

(continued)

2418G

-3-

SECTION Ill/SECTION XI: COMPARISON OF TECHNICAL REQUIREMENTSFOR WELDING-RELATEO ACTIVITIES (CONTINUED)

I TECHNICAL I SECTION III SECTION XI COMPARISON j COMMENTSIREOUTREMFNT I I "' ,...

Pressure test None Piping and Less Additional pressure testsexemptions connections 1 inch restrictive will be performed to(pipe only) and less provide compliance withSection III technical

III requirements.

Test pressure 1.25 times Varies, derequirements system design on Code Cl

pressure

I I I

Visibility of Examination Insulationexamination area must be J left in p1area during visiblepressure Itesting. I

I I I

spendingass

may beace

Lessrestrictive

Lessrestrictive

Additional pressuwill be performedprovide complianceSection III technrequirements excejWP 1649,

Additional pressurwill be performedprovide complianceSection III technirequirements.

re teststoa withicalpt for

re teststoe withcal

TVA proposes to perform the compensatory actions summarized in the table abovefor work activities performed in accordance with ASME XI after completion ofthe N-5 reports.

ENCLOSURE 3

WATTS BAR NUCLEAR PLANT (WBN) UNIT 1WORKPLAN AND MAINTENANCE REQUEST REVIEW

The TVA review examined repair, replacement, and modification work activitiesthat had been performed on ASME code systems since the completion of thesystem N-5 data report forms. This review identified 215 workplans and 313maintenance requests that represent exceptions to the Construction Code ofRecord. This review of activities was documented on ASME review sheetsdeveloped specifically for this task (see page 7 of this enclosure). Theactivities were sorted into eight groups by the type exception and reviewedagainst the requirements of the Construction Code of Record. The eight groupsare detailed below along with TVA's justification for exception to the Code ofRecord for each group:

1. There were 76 workplans completed in accordance with'ASME Section XI bythe WBN construction organization that possesses the TVA corporate ASMENA/NPT stamp (stamp holder). These workplans met the ASME Section IIItechnical and programmatic requirements except for documentation.

WP 25462882300332633624384840004074430943974797

2560288630743271363138574007411643174437

2581293731123365R0,RI372438664013413843484460

2589296631203429R0,RI3741386740194188R143714462

2592298532243466R0,Rl3749R0,Rl39194047419243744481

2428R12986R0,RI32363539381639304064421443764516

Justification: The applicable ASME Section III technical requirements forthe work were met and, as described in enclosure 2, the programmaticrequirements of ASME Section XI are comparable to ASME Section III withrespect to quality and safety.

2. There were 61 workplans and 202 maintenance requests performed inaccordance with the ASME Section XI by WBN Construction (stamp holder),Maintenance, and Modifications organizations (nonstamp holders) that metthe technical requirements of ASME Section III.

WP 1956251331824574800581262738W10758-1E-6429-51554R02194

2080272832204720806881332759E6259-2E-5841-11554R1

2089278935694732807281673127E6259-3M5619-11403

22562792435150148077E5828-13331E6381-135943727

2490R0,R12490R2211951148080E5908-38201E6424-181204706

30893119455352138103E6184-18078W10297-1W10771-1

28383378337941703.82944854991429843894691

-2-

MR A-003023A-186461A-226089A-280230A-405744A-407077A-407273A-408960A-409614A-414599A-479418A-480172A-482460A-485744A-493241A-494726A-509620A-515148A-526515A-533087A-536224A-537152A-572255A-572758A-572768A-572780A-573247A-573355A-580359A-585306A-602733A-572772A-572727A-572756

A-074395A-187066A-227396A-400269A-406051A-407120A-407657A-408965A-409628A-415662A-479516A-480174A-482835A-488050A-493903A-503516A-509973A-520268A-527378A-533334A-537002A-538409A-572713A-572760A-572773A-572781A-573263A-573451A-580735A-595811A-572715A-572782A-572750A-573250



A-077959A-224359A-275574A-403983A-406985A-407188A-408874A-409154A-412681A-477835A-480155A-481498A-484130A-492293A-494709A-505318A-513865A-523616A-529234A-535846A-537109A-572221A-572746A-572763A-572778A-572785A-573345A-577086A-583810A-601971A-572770A-572724A-573388

A-078214A-224840A-275602A-405723A-407076A-407194A-408940A-409320A-412741A-478075A-480171A-481887A-484324A-492645A-494725A-508558A-515004A-523717A-529259A-535847A-537110A-572248A-572748A-572767A-572779A-572787A-573351A-578090A-584933A-602124A-572771A-572725A-574311

Justification: The applicable ASME Section III technical requirements forthe work were met including the pressure test being performed to the ASMESection III criteria for those activities requiring one. As described inenclosure 2, the programmatic requirements of ASME Section XI, withrespect to quality and safety, are comparable to ASME Section III.

3. There were 10 workplans and 2 maintenance requests performed in accordancewith ASMB Section XI by the WBN Construction# Modificationso andMaintenance organizations that met the applicable ASME Section IIItechnical requirements except for the pressure test.

WP 3437 3654N6477-1 2403

MR A-408902 A-408919

44592597

51864863

5210 E4845-1

0 -3-

Justification: For these activities, the pressure test was performed tothe ASME Section XI criteria of 1.1 times the system design pressure. Thecomponents included in these pressure tests were in the AuxiliaryFeedwater, Essential Raw Cooling Water, Component Cooling Water, and CrudSampling (water sampling) Systems. The maximum difference between theASME Section III test pressure and the. ASME Section XI test pressure is24 psi, based on the maximum design pressure of 160 psi for the affectedportions of these systems. TVA will retest these items to 1,25 times thedesign pressure to meet the ASME Section III technical requirements. Asdescribed in enclosure 2, the programmatic requirements of ASME Section XIare comparable to ASME Section III requirements.

4. There were 20 maintenance requests performed in accordance with ASMESection XI by a nonstamp holder.(WBN Modifications and Maintenanceorganizations) that met the applicable ASME Section III technical andprogrammatic requirements except for the provision for the authorizednuclear inspector (ANI) review of the work document as required by ASMESection III NCA-5261.

MR A-274819 A-400955 A-404602 A-404647 A-409172 A-477762A-484113 A-484114 A-484115 A-485986 A-490616 A-495093A-520332 A-525070 A-525327 A-526555 A-585495 A-585770A-573450 A-573452

Justification: As described in enclosure 2, the programmatic requirementsof ASME Section XI are comparable to ASME Section III requirements. Thesemaintenance requests will be provided to the ANI for review and comment.Any deficiencies identified will be resolved before unit 1 fuel load.

5. There were 3 workplans and 44 maintenance requests performed in accordancewith ASME Section XI by a nonstamp holder (WBN Modifications andMaintenance organizations) involving replacement of pressure boundarycomponents or parts by mechanical means (nonwelding-related).

WP 4352 2900 3094

MR A-037455 A-072173 A-074492 A-222515 A-226219 A-228760A-272465 A-275945 A-400485 A-402353 A-404153 A-404246A-405144 A-406959 A-407109 A-407110 A-407115 A-407137A-408868 A-408871 A-409157 A-414193 A-414595 A-414750A-480858 A-480893 A-481229 A-481488 A-485867 A-488830A-505400 A-513881 A-520163 A-526514 A-527210 A-529394A-533342 A-534124 A-534350 A-535189 A-536228 A-539132A-571227 A-591735

Justification: As described in enclosure 2, the programmatic requirements

of ASME Section XI are comparable to ASME Section III requirements. In

accordance with NX-6114.2 of ASME Section III, replacement of external

pressure boundary items requires that a pressure test be performed either

by the installer or the part manufacturer. According to NCA-5261, the ANI

shall have the opportunity to be assured that material used complies with

requirements of ASME Section III.

The following actions will be taken to comply with the applicable ASME

Section III programmatic and technical requirements for these workplans

and maintenance requests: (1) The procurement document for the replaced

item will be reviewed for a manufacturer pressure test. If a pressure

test was not performed, an appropriate pressure test according to ASME

Section III will be performed. (2) The workplans and maintenance requests

will be made available to the ANI and authorized nuclear in-service

inspector (ANII) as applicable for review. Any identified discrepancies

will be resolved before unit 1 fuel load.

6. There were 49 workplans and 15 maintenance requests performed to ASME

Section XI requirements by the WBN Construction, Modifications, and

Maintenance organizations that met the applicable ASME Section III

technical requirements with the exception of the pressure test

requirements. The pressure test requirements were not met on these

workplans and maintenance requests because either (1) the testing was

placed on hold pending resolution of this review, (2) the ASME Section XI

pressure test exemption for 1-inch diameter and smaller pipe diameter was

taken, (3) Code Case N-416 was used for the deferral of the pressure test,

or, (4) a pressure test was performed to ASME Section XI requirements--but

with a differential pressure greater than 24 psi described in group 3

above.

WP 2924 2941 3531 3548 4136 4301

4408 4788 4871 4936 5081 5312

5320 E3614-2 E5753-2 E5798-1 E5846-3 E5944-1

E5974-1 E6251-1 E6259-1 E6284-1 E6429-1 E6429-3

E6476-1 E6591-1 E6682-1 E6838-1 M5590-1 N6218-1

N6547-1 N6907-1 E5944-2 E6591-2 4879 4886

1623 4148 E6103-2 E6792-2 4355

2843 4479 E6272-3 E6792-3

3819 5190 E6607-2 E6697-1

MR A-407144 A-408928 A-414446 A-477794 A-484127 A-500591

A-507177 A-521219 A-534268 A-535576 A-535581 A-570530

A-573243 A-573244 A-580747

Justification: As described in enclosure 2, the programmatic requirements

of ASME Section XI are comparable to ASME Secti-on III requirements. TVA

will pressure test these items to ASME Section III technical requirements.

2418G

7. There were 15 workplans and 30 maintenance requests performed inaccordance with ASME Section XI by the WBN Construction, Modifications,and Maintenance organizations that involve defect removal from base andweld metal.

WP 175635933587

MR A-006038A-400964A-524516A-573268A-574301

2407NW438P-13592

A-074761A-408989A-538209-A-573352A-574303

2729N6276-18132

A-186870A-477846A-575337A-573377A-574441

32578155

A-222072A-485972A-585775A-573378A-574442

Justification: As described in enclosure 2, the programmatic requirementsof ASME Section XI are comparable to ASME Section III requirements. Theonly deviation from ASME Section III technical requirements was thepressure test-requirement. The following actions will be taken to complywith the applicable ASME Section IIi technical requirements for theseworkplans and maintenance requests: Each workplan and maintenance requestwill be reviewed to the ASME Section III criteria for base and weld metalrepair pressure testing. An appropriate ASME Section III pressure testwill be performed for those workplans and maintenance requests which wouldrequire one.

8. There was one workplan performed in accordance with ASME Section XI by theWBN Construction organization that met the applicable ASME Section IIItechnical requirements with the exception of the pressure testrequirements.

WP 1649

Justification: The work performed on workplan 1649 involved cutting theEssential Raw Cooling Water (ERCW) System to allow the placement of amortar lining on the inside as outlined in the WBN Final Safety AnalysisReport (FSAR), section 9.2.1.4.

34762876

A-222073A-519786A-599092A-573385A-567874

35903419

A-400253A-523623A-604803A-573387A-572764

As described in enclosure 2, the programmatic requirements for ASMESection XI provide a level of quality assurance comparable to ASMESection III requirements. TVA is evaluating alternative methods fortesting the mortar lined piping. TVA will provide the details of theadditional testing for the ERCW mortar lined piping as a supplement tothis letter on or about March 25, 1989.

--6-- -

TVA will review the documentation for welding-related work activitiesidentified in groups 1 through 8 above that were performed in accordance withASME Section XI after completion of the N-5 reports. TVA Vill develop aprocedure to supplement the N-5 reports, as appropriate, in accordance withASME code interpretation 111-1-83-175.

When work activities are evaluated to perform the compensatory actionsdescribed above, if it is determined that any additional hardships or unusualdifficulties exist in order to comply with the specified dispositions ingroups 1 through 7, exceptions will be requested on a case-by-case basis asprescribed by 10 CFR 50.55a(a)(3). This review will be completed and anynecessary exemption request sent to NRC before April 23, 1990, Actual workactivities and documentation will be completed before unit 1 fuel load.

-7-

ASME REVIEW

WORKPLAN :INITIATING DOCtYMEINT: ORGANIZATION : ASME SECTION

: • III ANI: XI ANII

SYSTEM : INITIATION DATE : COMPLETION DATE

DESCRIPTION OF ACTIVITY:

REASON FOR ACTIVITY:

REVIEW:Welding (Repair, MOD, and Integral Attachments)Replacement (Parts, Components, MODS & Additions)Heat TreatmentDefect RemovalGrinding/Surface Prep of WeldsPressure Tests (Hydro, Pneu, etc.)Other

INSPECTIONS:

CO MNTS:

C -

ENCLOSURE 4 W

LIST OF COMMITMENTS

1. The findings of the internal audit of the work document review will beresolved.

2. The appropriate X-5 data reports will be supplemented for weldingactivities not already documented in accordance with ASME Section II.3. TVA's N-5 program will provide for the development of a cross-referencebetween each work document that has not been documented in accordancewith ASME Section III requirements and the appropriate N-5 data report

form.

4. Pressure tests will be performed for the work documents identified ingroup 3 of enclosure 3 to meet ASME Section III technical requirements.5. Those work documents identified in group 4 of enclosure 3 will be madeavailable for ANI review and any discrepancies will be resolved.

6. Procurement documents for replaced components or parts identified ingroup 5 of enclosure 3 will be reviewed to determine if the manufacturerperformed a pressure test in accordance with NX-6114.2. Pressure testswill be performed as required for the work documents to meet ASMESection III technical requirements.

7. The work documents of group 5 of enclosure 3 will be made available forreview to the ANI and ANII as applicable, and identified discrepancieswill be resolved.

8. Pressure tests will be performed for the work documents identified ingroup 6 of enclosure 3 to meet ASME Section III technical requirements.9L The work documents identified in group 7 of enclosure 3 will be reviewedand pressure tests will be performed as required to meet ASME Section IIItechnical requirements.

10. The documentation for work activities performed in accordance with ASMESection XI after completion of the N-5 reports will be reviewed.11. A procedure will be developed to supplement the N-5 data reports forwelding activities performed in accordance with ASME Section XI aftercompletion of the N-S data reports,

12. When actual work activities are evaluated to perform the compensatoryaction described in enclosure 3, if it is determined that hardships orunusual difficulties exist in order to comply with the specifieddispositions, exceptions will be requested on a case-by-case basis asprescribed by 10 CFR 50.55a(a)(3).

13. TVA will provide the details of the testing for the ERCW mortar linedpiping,

chattanooga, tennessee 37401 ost 13 1988 · 101 marietta street, nw, suite 2900 atlanta, georgia...

Documents