IR 05000206/1980003
| ML13323A709 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/07/1980 |
| From: | Dodds R, Elin J, Haist D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323A703 | List: |
| References | |
| 50-206-80-03, 50-206-80-3, NUDOCS 8005220235 | |
| Download: ML13323A709 (10) | |
Text
00 U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No. 50-206/80-03 Docket N License N DPR-13 Safeguards Group Licensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Unit 1 Inspection at:
Camp Pendleton, California Inspection conducted: January 29-February 1 and February 6-7, 1980 Inspectors:
_31
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D. P. H st, eactor Inspector ate Signed. Elin, Reactor Inspector Dafe Signed Date Signed Approved By: 4h R. T. Dodds, Chief, Engineering Support Section DAte Signed Summary:
Inspection on January 29-February 1, 1980 and February 6-7, 1980 (Report No. 50-206/80-03)
Areas Inspected: Routine unannounced inspection of plant modifications required as a result of the Three Mile Island Lesson Learned Task Force recommendations (NUREG-0578). The inspection included selective examina tions of procedures and representative records, interviews with personnel, observation of work activities, and review of licensee action on unresolved and open items from previous inspection The inspection involved 37 inspector-hours onsite by two NRC inspector Results:
One item of noncompliance was identified in the area of control of weld filler material (details, paragraph 3f).
RV Form 219 (2)
8005220 3<
DETAILS 1. Persons Contacted a. Southern California Edison (SCE)
.H. L. Ottoson, NE&O D. E. Nunn, Manager, Quality Assurance J. M. Curran, Plant Manager J. D. Dunn, Project QA Supervisor G. W. McDonald, QA/QC Supervisor R. R. Brunet, Superintendent D. K. Nelson, Project Manager 1. A. Wharton, Supervising Engineer M. P. Short, Nuclear Engineer 2 J. R. Tate, SPO J. Lindberg, QC Inspector J. Buckles, Lead QA Engineer E. Gerloff, Project Engineer b. Bechtel Power Corporation (Bechtel)
E. Conely, Project Field QC Engineer T. Dadson, Senior Field Welding Engineer C. Paltoma, Superintendent
.
2. Site Tour The facility was undergoing an expected 17 day outage to complete install ation of modifications required by NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations. Minor piping modifications to the auxiliary feedwater system and the pressurizer relief and block valve nitrogen supplies were being made. Additional conduit and cables were being installed to support the required instrumen tation. The inspector identified poor housekeeping conditions in the auxiliary feedwater pump area including weld filler material stubs on the floor (see paragraph 3f.) and uncapped piping on spool nos. 381-1 and 397-1. The licensee took immediate corrective action on these item. Licensee Action on Previous Inspection Findings a. (open) Noncompliance (50-206/78-14/01) RPV Closure Stud Examina tion Calibration Techniqu Straight beam, axial scan ultrasonic examination of reactor vessel closure studs 1-14 utilized a back reflection technique for cali bration rather than a calibration block equipped with reflector as required by paragraph T-525.2 of Article 5 of ASME Code Section The licensee responded to this item of noncompliance on December 6, 1978. The licensee has prepared calibration blocks equipped with the reflectors as required by ASME Section V. The licensee evaluated the sensitivity of the back reflection technique used against the technique required by ASME Section V and presented evidence to the inspector showing that the back reflector technique is superior to the ASME Code technique for finding fatigue crack This evidence was provided to justify acceptance of the examina tion on studs 1-14. The licensee has committed to comply with ASME code requirements or provide documentation of equivalence or superiority of the methods used in accordance with IWA-2240 of ASME Section X This item will remain open pending review of the new inservice inspection (ISI) contractor's procedures for RPV stud examination b. (Open) Noncompliance (50-206/78-14/03) Failure to perform surface examinations of RPV closure nut Surface examinations of the reactor vessel closure nuts 1-14, class 1 components, did not include examination of threads in the base material as required by IWB-2500 and IWB-2600 of ASME Section X The licensee responded to this item of noncompliance on December 6, 1978. The licensee committed to examine the threaded area of closure nuts 1-14 at the next inservice inspection. This will satisfy the requirements of the code for a surface examination of all the nuts during the ten year interval which began January 1, 1978. This item will remain open pending review of the ISI contractor's examination plans and schedule for the next refuel ing outag C. _(Closed) Open Item (50-206/78-14/02) Examination procedures pro cedures provided leeway for examiners to change procedure vari ables without Level III approva The inspector reviewed field change authorization No. 203 which deleted the paragraph in procedure ISI-104, Section 9.7 and pro cedure ISI-105 section 9.6 which could be interpreted to allow an examiner to change procedure variables to perform an examina tion. This item is close d. (Closed) Open Item (50-206/78-14/05) Angle beam ultrasonic scanning procedure for RPV closure nut Examination-procedure No. ISI-105 for the reactor vessel closure nuts required ultrasonic scanning in only two axial direction In practice, examination scans were being performed in two axial
-3 and two circumferential directions. The procedure was revised to reflect the actual practice. This item is close e. (Open) Unresolved item (50-206/79-10/01) Safety related activities missing from special engineering procedur The licensee had prepared a special engineering procedure (SPE 157) to control safety-related activities during replacement of the feedwater nozzle reducers. Weld build-up activities had not been included in SPE-157. The licensee had incorporated use of the Bechtel WR-5, Field Welding Checklist into the SPE and the inspector had identified the following areas of concern:
(1) Absence of WR-5 form for weld build-up operations on the inside diameter of the 14-inch end of the reducer (2) Inconsistencies and omissions on the WR-5 forms of such items as Authorized Inspector hold points, quality verifications, designation of engineering specifications and drawings, non destructive examination requirements, and quality control hold point (3) Removal of the reducers from the shop to the final location inside the containment sphere without completion and sign off of WR-5 form The licensee had initiated corrective action request CAR-P-208 on June 11, 1979. Corrective action was later initiated to familiarize the station personnel with Bechtel forms WR-5, Field Welding Checklist, and WR-6 and 99, Welding Filler Metal Withdrawa Existing station procedures were to be reviewed and revised as nec essary to ensure an appropriate preplanning effort. The famil iarization program for station personnel began on November 8, 1979, however, the review of station procedures was considered unnecessary by station engineering personnel due to the recent use of QA or ganization personnel as the inspector group and improved separ ation of engineering and inspection responsibilitie The inspector reviewed the following station procedures for evidence of separation of engineering and inspection responsibilities:
Procedure Number Station Inspection Plan S-E-117 General-Inspection Procedure S-XII-Field Inspection Procedure N10.20 Control of Purchased Material, S-A-115 Equipment and Service Special TMI Engineering, Procurement, E&C 26-7-7 Construction, Quality Assurance and Corporate Documentation Service Pro cedure for Major Temporary Modifica tions to Safety Related Systems for SONGS 1
-4 The inspector determined that responsibility for quality control inspection rests with station engineering and supervisory personnel (procedures S-E-117, S-XII-1.4 and S-A-115).
Recent procedures (N 10.20 and E&C 26-7-7) provide for inspection of safety rela ted activities by the quality assurance organization, but only upon delegation by the station manage.The licensee maintains a Bechtel Quality Manual containing a mix ture of work plan procedures and quality control instructions for various work activities. The inspector could not find any refer ence to this manual or the circumstances for its use in the licen see's quality assurance program or procedure The licensee stated that for these modifications, Bechtel is per forming the work in accordance with Bechtel work plan procedures, SCE Quality Assurance personnel are performing quality control inspections with inspection planning based upon Bechtel work proce dures and quality control instructions, and SCE Quality Assurance personnel are auditing the activities. The licensee further stated that during the next refueling outage, Bechtel will perform work and provide quality control services for all safety related mod ifications except TMI modifications for which SCE Quality Assur ance personnel will perform quality contro The station will be allowed to perform quality control on non-safety related mainten ance activities only. The licensee's committments to clarify the QA/QC program are discussed in paragraph 6. This item remains unresolved pending a review of the licensee's corrective action f. (Noncompliance) Unresolved item (50-206/79-10/02) Weld Rod Control During the feedwater reducer modifications in June, 1979 the in spector had observed several E308 weld rod stubs in the vicinity of the "A" feedwater nozzle work station and approximately 25 E7018 coated weld rods (without a portable rod oven) and ten E308 bare rods in an open Bechtel tool box immediately outside of the con tainment equipment hatch. No weld rod issue slips were in the area and no welding was being don During this inspection; the inspector reviewed Bechtel Procedure WPP 19.20 for control of weld filler material and found the following requirements:
(1) Paragraph 4.4 - all welding filler material to be discard ed shall be destroyed by bending prior to discardin (2) Paragraph 4.6 - Individual welders shall keep their work areas clear of unauthorized or discarded weld filler materia Electrode stubs and damaged filler materials shall be placed in stub buckets. At the end of the work shift, the unused filler material shall be returned to the rod room for reissue or disposition by the rod room personne (3) Paragraph 6.1.1 - No welding filler material will be issued without a properly executed rod request for (4) Paragraph 6.1.6 - At the completion of the welder work shift, the portable rod warmer, pouch, all unused filler material and the welder's copy of the WR-6 or WR-99 forms shall be returned to the rod room attendan The licensee's quality assurance organization performed an audit of the Bechtel program for weld material control which resulted in no audit findings (audit report no. Bech-2-79)
There was no other audit history for this are The quality assurance organization also audited the station activities against procedure S-I-1.56, Weld Rod Management, and found:
(1) issue forms not including the job number or description; and (2) issue forms.not signed authorizing weld rod issue as required. Appropriate corrective action including train ing sessions and revision of the weld rod issue form is in progres During observation of the welding activities on the auxil iary feedwater system the inspector found a weld rod stub bucket available for use but found two E-705 stubs and two E-7018 stubs on the floor. In a cardboard box near the work area, apparently being used for trash, the inspector found four full length E-7018 low hydrogen weld rods that had not been bent and twenty E-7018 stub In a welder's tool box near the work area, the inspector found eighteen E6011, five E-70-S2 and four nickel coated weld rods. A weld rod issue form was not available and the Bechtel foreman indicated that no welding had been done that day and only E-70-S2 and E-7018 rod was being used on the auxiliary feedwater piping. These findings constitute an apparent item of noncomplianc g. (Closed) open item (50-206/79-10/03) Radiograph density of weld no. 391-1 The inspector had reviewed the radiographs of weld no. 391-10 (Feedwater reducer to nozzle weld for steam generator c) and it appeared to have insufficient density. There was no densitometer available at the time to check the densit The inspector measured the density of these radiographs with a properly calibrated densitometer and found the minimum and max imum densities to be 2.12 and 3.0, respectively for single view ing. These densities are in accordance with the ASME Code Sec tion V, Article 2, 1974 Edition. This item is close h. (Closed) Open Item (50-206/78-14/06) - Limited ultrasonic exam ination of feedwater reducer to pipe and nozzle weld Examinations were performed only from the reducer side of the 14-inch nozzle to reducer weld and examinations were not performed on thel10-inch reducer to elbow weld The inspector reviewed a letter from the Level III examiner show ing the configuration of the piping. An examination was not per formed from the nozzle side of the 14-inch weld because the nozzle is tapered. Ultrasonic examinations were not performed on the 10-inch weld because of the reducer taper on one side and the elbow on the other sid The Level III felt that the configura tions of these components do not allow a proper ultrasonic exam ination in accordance with the referencing code section. The Level III has recommended radiography as an alternate examination method. The licensee has committed to radiography of these welds at the next refueling outage in accordance with IE Bulletin 79-1 This item is considered close. Safety Related Piping a. Review of Quality Assurance Implement Procedures The inspector reviewed Bechtel weld procedure P1-At-LH, Rev. 3 and the supporting procedure qualification records for conform ance to ASME Section IX. No items of noncompliance or deviations were identifie b. Observation of Work and Work Activities The inspector observed fitup activities on Auxiliary Feedwater spool no. 381-1 and visually examined completed shop and field welds on Auxiliary Feedwater spool Nos. 381-1, 397-1 and 397-2 for conformance with ANSI B31.1-1977. No items of noncompliance or deviations were identifie c. Review of Records The inspector reviewed inspection planning data reports and ma terial receiving reports for 3-inch pipe (spool no. 397-1) mater ial heat no. L65394 and 4-inch pipe (spool 381-1) material heat no. L9382 The inspector also reviewed construction inspection planning report nos. 155 and 156 for shop welding activitie The inspector reviewed performance qualification records for four welders involved in the auxiliary feedwater modifications. All were currently qualified in accordance with ASME Section IX for the weld procedures and positions use No items of noncompliance or deviations were identifie. Electrical Modifications The inspector reviewed the electrical modifications made in response to NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short Term Recormendations. The installations were compared to the require ments of Reg. Guide 1.75 and IEEE 38 Specific documentation asso ciated with installation and qualification certification for specific equipment was not reviewed, however licensee procedures for quality assur ance and quality control coverage were discussed. The specific sys tems reviewed were:
a. Position Switches on Pressurizer Relief Valves, Pressurizer Relief Block Valves and Safety Valves The position switches were inspected and found to be of a type in use in similar applications inside containment although spe cific qualification documentation was not reviewed. The workman ship appeared consistent with general practice for installation of class 1E equipment and the requirements of Reg. Guide 1.75 and IEEE 384 for physical separation were met within the containment structur b. Redundant Power to Pressurizer Relief Valves A nitrogen supply system was installed to back up the low pressure air system that provides motive power to pressurizer relief valve Instrumentation associated with this system was inspected and found to be of a type generally qualified for use inside containment although specific qualification documents were not reviewed. Wiring associated with this instrumentation appeared to meet the require ments of Reg. Guide 1.75 and IEEE 384 for physical separation in side containmen Feedwater systems The modifications consisted of diverse methods of feedwater flow indication, specifically ultrasonic flow detectors on feedwater and auxiliary feedwater lines, steam generator level indication and condensate storage tank level indication. Additionally pro visions were made to incorporate automatic initiation of auxil iary feedwater, although this system will not be placed in ser vice until completion of further study of it's effects on the plant's accident analysi Some equipment, such as steam generator level indicators and limit orque valve operators on the auxiliary feedwater system, were found to be of a type generally qualified for class 1E service (although specific qualification documentation was not reviewed). Other equipment, such as the ultrasonic flow detectors, had no quali fication history. The selection of 1E qualified equipment was found to be in accordance with a description of these systems provided by letter from Southern California Edison Company to the Director of the Office of Nuclear Reactor Regulation dated January 23, 198 The inspector questioned that, as some non-class 1E systems would be powered from the class 1E bus, whether the design incorporated some isolation device other than a circuit breaker activated only by fault current in accordance with Reg. Guide 1.75. The licen see explained that the circuit breakers employed incorporate fuses to provide design overcurrent protection capability. This type of isolation is detailed in IEEE 384 and is in accordance with Reg. Guide 1.7 The licensee stated the modifications were to be in compliance with IEEE 384,paragraph 5.6.2 internal separation to the extent practical. In the control room panels, the 6 inch separation criteria was not met. Due to the existing layout, which also does not meet this criteria, it did not appear to the inspector that the separation could be easily accomplished. This item will be discussed with NRR personnel by the NRC Resident Inspector during their March 1980 visit to the sit. Exit Interview The inspector met with licensee representatives denoted in paragraph 1 at the conclusion of the inspection on February 1, 1980 to discuss the scope and findings of the inspection. In particular, the various activity dependent responsibilities and procedures for quality control inspections were discussed. The need for adequate training of crafts and surveillance of work activities during plant modifications was also discussed. The licensee
-9 recognized these problems and committed to develop, within 60 days, a program which clearly defines the responsibilities and modes of op eration of quality control and quality assurance taking into account the type of work being performed, the organization performing the work, and the procedures to be used to perform the work. The licensee committed to clearly define this information for the next refueling outage if the program is not effective at that tim The results of the inspection relating to the electrical modification were discussed with the Manager, Quality Assurance, by telephone on February 7, 1980.