GO2-83-820, Final Deficiency Rept,Item 269 Re Bechtel Power Corp Repair of Wrong Weld Area.Initially Reported on 830705.Remaining Two Welds Qualified Per Class Ii,Ansi B31.1.Two Welds Successfully Repaired & Reradiographed

Final Deficiency Rept,Item 269 Re Bechtel Power Corp Repair of Wrong Weld Area.Initially Reported on 830705.Remaining Two Welds Qualified Per Class Ii,Ansi B31.1.Two Welds Successfully Repaired & Reradiographed

ML20080J320
Person / Time
Site:	Columbia
Issue date:	09/09/1983
From:	Carlisle C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
10CFR-050.55E, 10CFR-50.55E, GO2-83-820, NUDOCS 8309260317
Download: ML20080J320 (9)

Text

.-

Washington Public Power Supply System P.O. Box 968 3000 GeorgeWashingtonWay Richland, Washington 99352 (509)372-5000 Docket No. 50-397 September 9, 1983 G02-83-820 O

Mr. J. B. Martin 9, n

Regional Administrator E 40.

C U.S. Nuclear Regulatory Commission S .: ;E Region V .

~G 1450 Maria Lane, Suite 210 '

3 Walnut Creek, California 94596 e C ',

Subject:

NUCLEAR PROJECT NO. 2 10CFR50.55(e) REPORTABLE CONDITION #269 BECHTEL POWER CORPORATION REPAIR OF WRONG WELD AREA

References:

1) Telecon QA2-83-129, dated July 5, 1983, C.S. Carlisle to J. Elin.

2) Letter #G02-83-671, dated July 28, 1983, C.S. Carlisle to J.B. Martin, same subject.

In accordance with the provisions of 10CFR50.55(e), your office was informed, by telephone, of the above subject condition on July 5, 1983. The attachment provides the' Project's final report on this condition. Please note that this report also responds to item of noncompliance 397/83-38-08 of the same subject.

If you have any questions, please contact Roger Johnson, WNP-2 Project QA Manager at (509) 377-2501, extension 2712.

C Program Director, WNP-2 LCF/kd

Attachment:

As stated cc: W.S. Chin, BPA N.D. Lewis, EFSEC A. Toth, NRC Resident Inspector Document Control Desk, NRC i

4 8309260317 830909 PDR ADOCK 05000397 \\

S PDR --

WASHINGTON PUBLIC POWER SUPPLY SYSTEM NUCLEAR PROJECT NO. 2 DOCKET N0. 50-397 LICENSE NO. CPPR-93 10CFR50.55(e) CONDITI0il #269 BECHTEL REPAIR OF WRONG WELD AREA FINAL REPORT Description of Deficiency Weld RHR-851-18.19, 12ARl-FW12A was originally aade, radiographed, repaired, reradiographed and accepted by WBG, the previous aechanical contractor. As a special task under the WitP-2 Quality Verification Prograra, Bechtel perforced a 100% review of the WBG weld radiographs. Upon reinterpretation of the W3G radiographs for weld RHR-851-18.19, 12ARl-FW12A, Bechtel concluded that a re-jectable indication had been overlooked, and further repairs were necessary to aeet Code rec,tireaents.

A nonconforaance report was prepared, the appropriate weld papers were issued, and the weld was excavated, repair welded, reradiographed and accepted by Bech-tel. However, because of an error in determining the location of the defect from the weld station markers on the WBG radiograph, Bechtel excavated, repair welded and reradiographed the wrong area. This layout error, which resulted in repairing and radiographing the wrong area, was not detected by Bechtel when they reviewed and accepted the repair radiographs. This deficiency was due to a failure to compare the original WBG fila, which Sechtel had found unacceptable, with the Bechtel repair film which was accepted. This error was discoveredo'y the NRC CAT inspector by comparing the original filra with the repair fila when he performed a randora check of 3echtel weld repair radio-graphs.

Analysis of Safety Implication Two of the 14 ceficient repair welds were in non-safety related Quclity Class II, AJSI 331.1 ;,iping systeras. Of the remaining 12 Quality Class I welds, two of the deficiencies were due to lack of complete fila coverage. One of these was completely cut out because of an isoaetric drawing nodification,-

snd the other one was free of weld flaws.

A linear elastic fracture mechanics analysis has aeen performed on the rac.io-graphic fic.: indicctions in the reasining 10 Qucli;y Cicss : ,.;e .:lds using the methodology of AS..E XI, Appendix A. This analysis snows taat the stress bre lower than the conservatively estimateo critical intensity values of KIc fcctors (120 ksi (KI) 5 ) and Kla (100ksi EASici2 ). XI, IUS-3512 provides the following acceptance criteria cased upon applied stress intensity factors:

1. For noraal conditions: KI x JIO e. Kla

2. For emergency and faulted conditions: KIx[24 K Ic As shown by the data presented in Table 2, the stress intensity factors for all weld flaws raultiplied by 10 are well below the conservatively estimated l critical value of 100 ksi in for KI . Frora this it can be conservatively concludedthathadtheweldrepaird$ficienciesgoneundetected,theywould not have adversely affected the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant.

FR269 - Page 2 of 4 Based upon the above information, it is concluded that the deficiency is not reportable under the rules of 10CFR50.55(e).

Cause of Deficiency The above described deficiency can be directly traced to a failure to compare the repair radiographs with the original radiographs to assure that the correct area was repaired, and the originally rejected discontinuity was satisfactorily removed.

The review, interpretation and acceptance of radiographs is a Bechtel QC respon-sibility. The governing procedures used by Bechtel QC for reviewing radiographs were RT-ASME, Rev. O and QCI W-1.00A. Neither of these procedures specifically state that the original film shall be compared with the repair film when review-ing and accepting radiographs for weld repairs. This procedure inadequacy is believed to be the underlying root cause responsible for the deficiency.

Corrective Action Weld RHR-851-18.19, 12AR1-FW12A, was documented on NCR #21688, repair welded (QCIR W-100A-6974), reradiographed (NDE Report #4073) and finally accepted on 6/24/83.

In addition to correcting the one specific deficiency identified on NCR-21688, Bechtel performed a 100% review of all other welds which were repaired, radio-graphed and accepted without comparing the rejected film against the repair film to confirm that the originally rejected defects were removed. From a complete review of all Bechtel RT reports, it was determined that Bechtel made and accepted 297 weld repairs without comparing the original film with the repair film. For each of these 297 welds, the necessary comparisons were made and it was determined that 13 additional weld repairs were incorrectly accepted. A complete description of these 13 deficient repair welds plus the one original weld repair deficiency discovered by the NRC Construction Apprai-sal Team is presented in Table 1.

The data in Table 1 shows that the deficiencies for all 14 welds have been satisfactorily resolved. The one ASME III/l and three of the four ASHE III/2 welds were successfully repaired and reradiographed. The one remaining ASr1E III/2 weld which did not have full film coverage of the repair, has been re-radiographed and accepted.

Six cf the seven ASME III/3 welds, which do not require radiographic examin-ation, successfully passed the Code required surface NDE (liquid penetrant) examination. The one remaining ASME III/3 weld was completely cut out due to an isometric drawing modification. These seven ASME III/3 welds were origin-ally radiographed as a part of the project welder performance evaluation program which was outside of the design specification and Code requirements. Fracture 4

Mechanics analysis using the methodology of ASHE XI, Appendix A, shows that the radiographic indications are within the acceptable limits for the design service conditions.

The remaining two welds were Quality Class II, ANSI B31.1. These two welds d

were successfully repaired and reradiographed.

FR269 - Page 3 of 4 With one exception, the failure to identify deficient weld repairs for all 14 items was due to not comparing the original film with the repair film.

The one exception was item 14 in Table 1, classified as category D (Weld FPC-669-1.7-2AFW2A). The error in this case was unrelated to comparing the origi-nal film with the repair film, but was simply due to a misinterpretation of or failure to identify rejectable indications on the repair radiographs. Fur-ther corrective action was taken to resolve this single case of a radiographic film interpretation error.

The radiographs for a sample of 61 original production welds was selected from a total population of 604 welds reviewed and accepted by the same Level II RT technician who made the interpretation error on repair weld FPC-669-1.7-2A FW2A. All of the film for the 61 sample welds was re-reviewed by Bechtel Level II or Level III RT technicians. The' radiographs for 60 of the 61 welds were found to have been correctly interpreted. One radiograph for one of'the welds was noted by the original Level II interpreter as containing borderline but acceptable porosity. Upon re-review by a Level III interpreter, it was deter-mined that although the original Level II interpreter had correctly identified the indication as porosity, he apparently made a computation error in measuring its size, calculating the area and comparing it to the code allowable limits.

What the original Level II interpreter had noted as borderline porosity-accept-able, was in fact borderline porosity-unacceptable to ASME Section III require-ments. This particular weld, EDR-066-11.17-FW2, has subsequently been reclassi-fied as Quality Class II, ANSI B31.1 which is not safety significant and does not require radiographic examination.

All remaining RT reports for the 543 other welds accepted by the same Level II interpreter were then reviewed to see if he had made any other borderline acceptable notations. Fot+ additional RT reports were found with this notation and the corresponding filh. was re-reviewed oy a Level III technician. The radiographs for all four of these RT reports were found to have been correctly interpreted and dispositioned by the original Level II interpreter.

Action to Prevent Recurrence The procedure inadequacy identified as the underlying root cause of the defi-ciency has been corrected by issuing Administrative Instruction #27, dated August 16, 1983, to supplement Bechtel procedure RT-ASi4E, Rev. O. This Adminis-trative Instruction contains the following specific provisions to prevent recur-rence of the described deficiency.

1. Repair weld film must be compared to the original rejectea film for area of coverage, number of defects and original defect removal.

2. For radiographic rejects, the Bechtel Level II interpreter must make a transparency of the rejected film showing the weld identification, the area of the weld requiring repair, and the location and type of defects to be removed. This transparency is given to the welding engineer respon-

! sible for making the repair to minimize layout errors which could result in repairing the wrong weld area.

3. Radiographic film for rejected welds is maintained in a suspense file by the Bechtel NDE group until repairs are completed so that the original film is readily available for comparison with the repair film.

FR269 - Page 4 of 4 A training session covering Administrative Instruction #27 was conducted by a 3echtel Level III technician and attended by all WNP-2 Bechtel Level II film interpreters on August 17, 1983.

It is believed the above described actions will prevent recurrence of the defi-ciency on the WNP-2 Project.

.- t T/8.E 1 IMRECTLY ACCEPTED ELD REPAIRS ,,

REPAIR /

ITEM CATE- ISO WELD /&E FREA tG REWmK TUTH GORY PU4ER f1MER CLASS REJECTED DESGIPTION fUTER DISPOSITION CLW LETE REWRKS 1 A PJR-851 18.19 12/R1FW12A 2 1-1/2" to 3-1/2" Cmcavity 21688 Repair 06/24/83 tRC CAT team audit findira 18" Concavity 21" Incorplete Fusion 2 A RFW-419-3 12-1PW12 1 65" - 66" Slag Inclusion 21827 Reair 03/05/83 3 B RlR-899 39.44 FK20R1 2 1-2 Coverage N/A Reshoot 07/16/83 Insufficient film coverage of mpair area. Reshot T.

4 B FPC-fG 1.4 2FK2 3 0-9 Coverage N/A Cut out N/A Insufficient film coverage of repair area. Pipe was cut oJt due to iso podificatims. Reshot not mquired.

5 C RlR-1968-5 P417R1 2 2-3 Incamlete 21767 Repair 03/09/83 Penetration 6 C FPC-4444-1 W120R1 3 0-1 Incomlete Fusim 21768 Accept N/A Surface NDE and fractum rmchanics as-is acceptable.

7 C FPC-fG 10.12 3FW3R1 3 1-4 Incamlete 21766 Accept N/A Surface TOE and fracture mrrhanics Pemtration as-is acceptable.

25-27, 2S-31 Incamlete Fusion 8 C FPC-670 1.2 4/MA 3 22 Incamlete Fusion 21824 Accept N/A Surface t0E and fractum rochanics as-is acceptable.

9 C FPC-687 7.13 6FM 3 1-3 Incomlete Fusim 21824 Accept N/A Surface NDE and fractum nochanics as-is acceptable.

CATEGORY DEFINITIONS:

A. Wrong ama mpaired and radiographed - rejectable indications not roted due to failum to camare film B. Insufficient film coveram of repainxi area not noted due to failure to camare film.

C. Correct ama mpaired md radiographed - rejectable indications mt roted dJe to failure to comare film.

D. Cormct area repaimi and radiographed - interpmtatim error made in myiewiry repair film.

Page 1 of 2

TABLE 1 (CmTIPUED) -

INCORRECTLV ACCEPT 8 WELD REPAIRS ',,

REPAIR /

ITEM CATE- 150 WELD ASif /REA N01 N01 Rt M

tOER GORY TU4ER fGFER CLASS REJECTED DES 0llPTION fuller DISPOSITIm COTLETE REFAKS

10 C FPC-6 0 1.6 4-1R1RM-1 3 8 Incomlete Fusion 21824 fccept N/A Surfaco TOE and fractum trechanics as-is ir.ceptable.

11 C OG-783 15.21 IFW1 N/A 11-12 Slag Inclusion N/A Repair 08/03/83 RiSI 101.1 - Quality Class II 14,17-19 Incamlete Fusion Reoair acceptable.

12 C OG-783 12.14 2FW2 N/A 16 Incomlete Fusion N/A Repair 07/27/83 ANSI B31.1 - Quality Class II Repair acceptable.

13 C W CS-629 1.4 16AFW16A 2 2-5 Inco mlete Fusion 21826 Repair 08/09/83

, 14 0 FPC-699 1.7 2AFW2A 3 12 Incomlete Fusion 21824 Accept N/A Surface TDE and fractum mechanics as-is acceptable.

j 4

1 1 .

i t

i I l CATEGORY DEFINITIONS:

l A. Wmng ama mpaired and radiographed - mjectable indications not noted d>e to failum to comare film i B. Insufficient film coverage of mpaired ama not noted due to failum to camare film.

] C. Correct area mpaired aid radiographed - mjectable indications not noted due to failure to camare film.

D. Correct area mpaimd and radiographed - interpmtation errcr made in myiewing repair film.

t l Page 2 of 2 I

i 1

TABLE 2 .

FPACREE KOWilG NRYSIS DATA ITEM tUPER 150 PU M WELD tU M PIPE WLL DESIGN DESIGN DINETER THIO <tESS PRESSLRE TDP

$ k It01 CATION It0lCATION LEtGTH DEPm KI /lU x KI fMTERIAL (inch) (irch) (psig) (F) (ksi) (ksi) (inch) (inch) (ksi/iii) (ksi /iii) 1 RfE-851 18.19 12/R1FW12A 14 0.375 500 480* 1.9 32 0.5 0.06 14.3 45 A106-B Pipe te A106-8 Pipe 2 RFW-419-3 12-1FW12 24 1.812 1300 575* 4.3 32 0.625 0.06 16.9 53 Al % B Pipe to A352 WCB Valve 3 RFR-899 39.44 FW20R1 '#LD GLY REQUIRED R4 /0DITI0th RADIOGRAPH TD PROVIDE 01PLETE UNER/E. TOT SB11TTED FOR FRffTLRE EDW115 NRYSIS AS RADIOTAPH SHOWED to DEFECTS.

4 FPC-605 1.4 2FK2 WELD Clrr QJT DLE TD PIPItG E001FICATIONS fDT SLB4ITTED FCR FRACTl0E KOMNICS REYSIS AS DIS 01EPRD WE LAD < OF 01PLETE FIU4 (DVER/E TOT ELD FLAWS.

5 RfR-1968-5 FW17R1 2 0.218 125 480* 0.3 36 0.125 0.06 7.4 23 Al % B Pipe to A234 W[P Eltov 6 FPC-4444-1 W120R1 2 0.218 150 175* 0.3 36 0.125 0.06 13.3 42 Al % B Pipe to A231 WBP Eltov 7 FPC-605 10.12 3FW3R1 10 0.365 220 175* 1.5 36 0.125 0.06 7.8 25 A106-B Pipe to 1.5 0.06 18.5 59 A234 WBP Eltov 1.75 0.06 20.4 64 8 FPC-670 1.2 4AFW1A 10 0.165 150 175* 2.3 30 0.563 0.06 12.5 40 A312-T301 Pipe to A312-T304 Pipe 9 FPC-687 7.13 6FW6 10 0.365 150 175* 1.0 36 0.375 0.06 14.5 46 A106-B Pipe to 0.125 0.06 7.6 24 A234 WPB Eltov 10 FPC-640 1.6 4-1RlFWi-1 8 0.322 150 175* 0.9 32 0.125 0.06 7.7 24 A106-8 Pipe to A105 Valve Page 1 of 2 .

TABLE 2 (OJNTItOED) .-

FPACTIEE K0W4ICS #RYSIS DATA '.*

ITD1 tdM'IR ISO fU43ER WELD PO EER PIPE 1RL DI/MTER THID K'SS DESIGN PRESSLRE DESIGN TEhP 4 4 It0ICATIQ1 It0lCATI0f4 LEtGTH K1 /lU x KI OEPTH MTERI/L -

(inch) (inch) (psig) (F) (ksi) (ksi) (inch) (irch) (ksi/IR) (ksi/I5) 11 OG-783 15.21 IFK1 QRITY CLASS II t0T SE11TTED Fm FRACRRE K0W4ICS RRYSIS 12 OG-783 12.14 2FW2 QRITY CLASS II t0T SUBMITTED Fm FRACTtRE KCHANICS #RYSIS 13 IPCS-629 1.4 16AFW16A 24 0.375 100 212* 1.6 32 0.5 0.06 14.1 45 A106-B Pipe to A352 WCB Valve 14 FPC-669 1.7 2AFW2A 6 0.134 150 175* 1.7 30 0.219 0.06 11.6 37 A312-T304 Pipe to 0.25 .0.06 11.6 37 A403-T304 Eltxx -

0.188 0.06 11.1 35 Page 2 of 2 .