IR 05000259/1987001

Insp Repts 50-259/87-01,50-260/87-01 & 50-296/87-01 on 870105-09.Violations Identified:Failure to Properly Incorporate Specified Ferrite Number in Purchase Documents & Improper Storage of Compressed Gas Cylinder

ML20210U650
Person / Time
Site:	Browns Ferry
Issue date:	01/29/1987
From:	Blake J, Coley J, Girard E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210U586	List: IR 05000259/1987001 ML20210U582 ML20210U627
References
50-259-87-01, 50-259-87-1, 50-260-87-01, 50-260-87-1, 50-296-87-01, 50-296-87-1, NUDOCS 8702180539
Download: ML20210U650 (12)

Text

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UNITED STATES

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NUCLEAR RE*mULATORY COMMISSION o REGION il 5 $ 101 MARIETTA STREET, N.W., SUITE 2000

• 2 o, ATLANTA, GEORGfA 30323 s,

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Report Nos.: 50-259/87-01, 50-260/87-01, and 50-296/87-01 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-280 Docket Nos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52, and DPR-68 Facility Name: Browns Ferry Inspection Conducted: January 5-9, 1987 Inspectors: [. 4 2.,1, /kf/7I E. H. Girard g / Date Signed bS & I 29 W]

Date Signed J. L. Coley

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Approved by: M. [.

J. J. Blake, Section Chjef

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Date Signed Materials and Processe 9Section Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was in the areas -of recirculation system piping replacement, review of previously identified enforcement matters and open item Results: Two violations were identified - Ferrite measurement requirements for welding material, paragraph 3.c; and storage of compressed gas cylinders,

, paragraph PDR ADOCK0500g9 G =

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. REPORT DETAILS

, Persons Contacted ~

-Licensee Employees

• R. L. ' Lewis, Plant Manager

• J..A.~ Savage, Compliance Engineer

• C. McFall,- Compliance Engineer . .

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• S. P. Stagnolia, Section Manager,' Nozzle Replacement Group

-*R. Bentley, NDE Engineer

. * Latimer, Supervisor, Inservice Inspection <

• H. E. Hodes, Engineer, Technical Support Mechanical Test Section L. Clardy, Quality Assurance, Supervisor J. C..;Pettitt, Section. Supervisor, Nozzle Replacement Group T. Everitt, Welding Engineer, Nozzle Replacement Group <

S. Logan, Manager, Industrial. Safety and Fire Protection -

Other licensee ' employees contacted included construction craftsmen, engineers, technicians, and office personne _

NRC-Resident Inspectors

• L. Paulk, Senior Resident Inspector

• C. A. Patterson, Resident Inspector -

• C. Brooks, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on January 9,1987 -with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection - findings. - No dissenting comments were received from the license Violation 259, 260, 296/87-01-01: . Ferrite Measurement Requirements for .-

Welding Material, paragraph Violation 259, 260, 296/87-01-02: Storage of Compressed Gas . Cylinders, paragraph Unresolved Item 260/87-01-03, Program Weaknesses .in NDE and Welding,.

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paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this; inspectio ___ .. _____

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3.- -Licensee Action ori Previous Enforcement Matters - (0 pen) Unresolved Item (259, 260, . 296/85-01-01):- Adequacy-of Actions'

Taken with Regard to Allegations Concerning Category 1 Support This item was opened to _ express concern that' the licensee' failed to sufficiently investigate the alleged violation ofL procedures:by a general foreman and a project engineer. During NRC Inspection 85-07, the Browns Ferry plant manager committed to a further investigatio This further ' investigation was completed by licensee Concerns. Program personnel in October 1986 land it confirmed that the -subject < general-foreman had knowingly and repeatedly violated procedural -requirements for work on safety-related item The charge against - the = project engineer was not -resolved. The tNRC . inspector notes,- however, that the' engineer's involvement appears much more: indirect and limited in-importance than that of the -general forema The NRC inspector previously reviewed _the further investigation performed by concerns program personnel, as described in NRC Inspection 86-4 In that inspection the inspector questioned licensee personnel as to 'whether any personnel action was anticipated in response to -the

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investigation - findings. The' inspector was informed that the need for'

personnel action would be determined by management in their review'of the matter. At that time the inspector informed the licensee that pending completion of the TVA management review, and NRC. examination of the.results of that review, the matter would remain an open ite During the current inspection the inspector. questioned TVA management as to the status of this matter.- The inspector was informed that the report of the investigation, completed and signed ' by' the Concerns Program investigator on November 16, 1986, was still_under review b Concerns Program Managemen The inspector noted that management's attention to resolution of this matter, originally _ questioned in 1985, has _ been exemplified by continued indecisiveness and dela The item remains ope (0 pen) Violation (259, 260, 296/86-04-01): Snubber Storage This violation involved snubbers which were improperly stored and tagged. The storage instructions for the- specific snubbers required

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them to be covered :with a water proof' tarp and required that all openings into the snubbers be . capped, plugged or sealed. Instead, the snubbers were uncovered and openings into snubbers were observed to.be unprotected. Parts had been removed from these snubbers and they were considered to be on " Hold." " Hold" tags required to be complete 3 and

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affixed to the snubbers to aid in identifying their '.' Hold" status did not- have proper identification entered. on them and were not properl attached to the snubber , - - - .. . . . - - . . - . - . . - - - .- -

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TVA's letter- of response to the violatiion dated April l0,1986, was reviewed and determined acceptable by Region II._ The stated corrective -

action was as follows:

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l (1)- Based on a visual examination - past' storage ' deficiencies .were .

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determined not to have caused deleterious conditions to the snubber '

L -(2) The snubbers ~ identified in the violation.were.placed in proper '

. storage conditions.

! -(3) Storage personnel were given training as to proper stora'ge i requirements 'and use of " Hold"- tag ;

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1 The NRC inspector held discussions-with the licensee's representatives  ;

and examined the corrective actions stated .in the-letter of respons '

1 Based on :the discussions = and examinations the inspector considers -

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that the corrective actions _. stated were performed. However, in his-examination, the inspector toured the licensee's' storage yard and found additional examples of snubbers stored uncovered in an open door -

building. Rust was observed on the surfaces of the snubbers. " Hold"- i

tags had not been applied to the snubbers, implying. that they were j considered acceptable for issue. The NRC. inspector questioned a TVA QA surveillance inspector, who had accompanied him in his tour, as to

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the acceptability of the conditions observe The TVA surveillance '

inspector stated that widespread improper storage. conditions had been l identified previously and that corrective ~ action - had been taken to assure the acceptability of improperly restored items prior to release. He indicated that the corrective action was as follows:.

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No safety related items are released from storage without QC l 4 authorization.

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Before they authorize release, QC inspectors. obtain engineering

, evaluations of'the acceptability of all items whose conditions are j w t unquestionably acceptabl '

The inspector noted that this permitted. items that were deteriorating

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because of improper storage to continue to deteriorate. The inspector informed 'he . licensee that their controls to limit' deterioration of

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stored items and assure that unsatisfactory items were not released '

would be reviewed in a subsequent inspection. and that the violation-l would remain open pending.that review.-

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, (Closed) Unresolved Item (259, 260, 296/86-42-01): Ferrite Measurement

Requirements for Welding Material i

! This item expressed concern that based on a review of material

, certifications, welding material purchased for recirculation system

! piping replacement did not comply with-engineering requirements. The

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subject paragraphengineering 4.2.4. Therequirements are specified licensee's Engineering by drawing Change (47A1408, Notice ECN) which specifies the . Unit 2 recirculation system piping replacement, ECN -

P0957, imposes drawing 47A2408 requirements, which, in turn, impose the drawing 47A1408 requirement The requirements of drawing 47A1408 which did not appear to be met were that the delta ferrite content of all stainless steel weld metal "shall-be determined in accordance with the magnetic instrument option of NB-2400 using Types A or C instruments" and that "the minimum delta ferrite content shall be 8 ferrite number."

During the current inspection, the NRC' inspector reviewed the licensee's. purchase requisitions and - found that the requisitions >

had failed to properly specify the engineering requirements for the welding material. The inspector observed the following:

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Purchase requisition 87 PBF-376995, for stainless steel Type 308L weld wire, failed to require delta ferrite determination by .

magnetic metho Purchase requisition 87 PBF-376996, for-IN 308L stainless steel consumable welding- inserts, failed to require that the delta -

ferrite be determined by the magnetic method and that the material have a minimum ferrite number of The licensee's failure to properly incorporate the _specified ferrite measurement methods and minimum ferrite number in their purchase documents is considered a violation of 10 CFR 50, Appendix B, Criterion IV. This is identified as' violation 259,260,296/87-01-01, Ferrite Measurement Requirements for Welding Materia This replaces the original unresolved ite . Unresolved Items Unresolved items are matters about which more inn emation is required to

' determine whether they are acceptable or may involve violations or devia-tions. One unresolved item identified during this inspection is discussed in paragraph . InspectionofReplacementofRecirculationPiping(Unit 2)(TI2512/13).

The licensee is replacing portions of their Unit 2 recirculation piping up to the reactor vessel inlet nozzle. The NRC inspectors examined selected aspects of the licensee's related work and records to verify. that the replacement activities were technically adequate and that they complied with NRC requirements and licensee commitmer t Details of the examination conducted by the inspectors are as follows:-

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1 Observation Welding and Welding .Related Activities (55050)_

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The _ inspectors observed . examples of welding and welding activities performed to install new safe ends' on the reactorivessel inlet nozzles

L and -to apply corrosion resistant cladding -(CRC) to unreplaced piping-

where it will be' joined' to replacement' piping. . Both the replacement

piping,-which is of a special composition, and the CRC were specified

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by the licensee to aid in avoiding the intergranular: stress corrosion cracking (IGSCC) that has plagued Boiling Water Reactor (BWR) primary:

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coolant stainless steel piping welds.

l The inspectors. observations of welding and welding activities were-directed to the following welds:

Nozzle N Weld Type H CRC l '

G Safe and to nozzle J Tacks for safe end to nozzle

i The inspectors observed the above welding and related activities and

, reviewed related procedures and in process records to verify .the

following:

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Work was conducted in accordance with work plans which coordinated

and sequenced all operations, referenced procedures or instruc-i tions, established _ hold points, and provided for production and QC ,

j sign offs. These documents were at the work statio '

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Welding procedures, detailed drawings, instructions and weld data j sheets were at the work station.

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Welding was performed in accordance with the parameters of the welding procedure (GTA-88C-5).

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Welding Technique and sequence requirements were specifie Base metals and welding filler materials were of the specified

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type and grade, and were traceable to test reports or certifica-tions.

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Weld joint geometry was as specified and surfaces to be welded had j been prepared, cleaned, and inspected in accordance with appli-

cable procedures or instructions.

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Components to be welded are assembled and held in place within

! specified gap and alignment tolerances.

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Welding technique of each welder was11n - accordance 'with the

, ' welding procedur '

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. Welding equipment-was in good. conditio In addition ' to the verifications listed above' the inspectorsLalso reviewed the certification records for the- following' welding and

inspection personnel assigned to the recirculation-system pipe replace-ment activities:

Site Quality Control Examiners C. W. C. Inservice Inspection Ultrasonic Examiners D. B. M. ' G. Welding Operators (Note: Qualification radiographs were reviewed)

Rice Posey Craft Moore Walls Taylor Atchley Call Casey Christopher Clements Gary Jackson Kimbrell Patterson While observing performance of the welds listed above the . inspectors !

noted that five cylinders-of compressed gas to be used for the welding were not properly secured. These cylinders.were stored in the reacto buildings, adjacent to the path used for exit. Also, they were not far from the drywell entranc The cylinders were only loosely secured-by a fiber rope draped around the valves at the tops of the cylinder Although~only one of the five improperly secured cylinders appeared to be in use, none had valve protection caps in place. Thir, is contrary to the Fire Protection Program Plan, Procedure No. FPF-01, which requires that:

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- Cylinders when -stored inside :shall not be : located near ' exits, stairways or in areas .normally ~ used or intended .for the safe exit of peopl Compressed gas cylinders shall be' secured ~in an upright position -

3/4 of ~the cylinder height from the floor:by wire, chain, or other:

. suitable mean '- Valve protection-caps shall be in place whenever the cylindercis- -

not connected for us The finspectors informed <the Industrial LSafety and Fire Protection manager of the improperly stored cylinders.on January 17, but observed that the conditions remained uncorrected on January 9. :Another example of an improperly secured compressed gas cylinder was observed by the-inspectors in the Power Stores Storage yard on-January 8. Furthers.th inspectors were informed that - the NRC resident inspectors had also

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observed and informed the licensee of improperly stored gas cylinders,.

as described in NRC-Inspection Report 86-4 The inspectors _-informed the licensee that their nonconformance with storage requirements of Procedure FPP-01- was considered a violation of 10 CFR 50,- Appendix B i Criterion This was . identified as violation 259, '260, 296/87-01-02, - ;

Storage of Compressed Gas Cylinders,

' Review of Radiographs (57090).

When the inspectors arrived at the Browns Ferry facility-on January 5, 1987, they were informed by the NRC resident inspector _ that the licensee was experiencing serious difficulties in producing welds' that !

would pass radiographic examinatio ,

During the inspectors surveillance of the welding activities delineated in paragraph a. above cognizant personnel were questioned as to the details of the problem, the cause, and the planned corrective action The inspectors found that none of the individuals ~ questioned gave the same reply as to the nature of the rejectable weld defects observed on the radiograph Prior to performing any production welding on the actual replacement-system piping, the licensee had prepared and welded mock-ups of the 4 welds to ~ aid in assuring the replacement work could be completed )

acceptably with minimum personnel exposures from the' high radiation ,

levels that exist at the replacement locations. Radiography performed '

on the mock-up welds had not identified rejectable defects. To aid in understanding the problems being experienced by the licensee in their '

production welding, the inspectors reviewed the radiographic film off the mock-up welds and the production welds performed to dat Also, film for welding operator qualifications was reviewed by~ the

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inspectors, as described in 5.a above. Based on their film review, discussions with licensee personnel and observations of welding activities the inspectors observed the following: *

(1) Radiographic Film for "B" mock-up of the nozzle to safe end' weld !

showed approximately'5 inches of lack of' fusion that had not been-

, rejected by a Level II radiographic examiner. Failure to identify welding discrepancies during the mock-up stage oof welding .

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allowed welding process errors to go uncorrected to production

welding activities.

. (2) There was no Level III radiographic exaufner overview prior.to production A

weldin (3) The indication reported in (1) above was also detectable by '

j- ultrasonic examination. Ultrasonic examination, however, had not i been performed on the welded mock-ups. The production welds will i

require preservice inspection using ultrasonic examination. Use

} of ultrasonic examination on the mock-up' would aid in asstring

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acceptable welding. .

l (4) The root pass installation weld for nozzle "G" safe end was accepted by a Level II radiographic examiner. This joint was

, subsequently rejected by the same radiographic examiner after

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several additional weld layers had been added to the joint. The discrepancy that rejected the weld was also on the film when the-root pass radiography was performed but was not recognized by the radiographer ,

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(5) Radiographic readers sheets for in-process. production radiographs indicated that certain film segments of the welded joint were acceptabl However, the radiographic examiner also had an

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overlay made for the welders to remove the weld in this segment because the area in the' film was actually considered unacceptabl (6) Mock-ups used to train welders for the nozzle to' safe-end weld did not have exactly the same joint preparation as the production weld. The production weld had a 12 degree taper on the bottom i

surface of the nozzle weld prep that was not on the mock-up. This taper could result in accenting a' root edge condition on film and could result in incorrect interpretation of the production

, radiographs. In addition, this condition is almost impossible to

! verify on the inside surface of the production weld.

l (7) The inspectors noted that the weld bead width on the mock-ups for 1 the CRC welds were very narrow. However. the first four produc-tion CRC welds had much wider weld beads, indicating that the

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b . welding.- The mock-up weld radiographs were acceptable, however, :i three of the first four production welds were unacceptable. : When

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i the licensee. reverted to the narrow bead widths for production CRC L welds the welds were radiographical.ly acceptabl ;

(8) During the review of QC examiners qualifications ~, one -visua '

examiner'was noted to have the results of several eye examinations in his folde One ~ eye certification issued in.1984 required the j individual to wear glasses when performing inspection activitie ;

) The-1985 and 1986 eye examination records did not' require glasse ,

n j (9) Welding parameters for the background pulse in welding procedur '!

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GTA-88C5 were incorrect due to a misplaced decimal point. This .

was an obvious typographical error to the welding machine operator i i because his welding machine limited his obtaining this setting.-

{ The NRC inspector, however, was concerned that if the licensee's -

review would allow typographical errorsuto go uncorrected in th ~

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welding parameters of their welding procedure, how reliable is the ;

technical. input to the procedure particularly wheniserious welding )

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! I The licensee had identified or was aware of the program findings i observed by the inspectors abov However, the licensee's welding i l

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problems appear to' result primarily from failure of TVA .  !

inspectors to properly evaluate radiographic information ~available  !

on previously welded mock-ups and failure of the welding . ,

organization to follow the welding techniques, welding parameters l and - joint preparation used on the mock-up specimen's. The cause  ;

, of the examiner failures and the.: deviations in welding appear to  !

be due to lack of examiner overview during mock-up stage of welding l

and inadequate management control of welding and inspection activitie !

i The inspectors finding were reported as unresolved item 260/87-01-03, l j Program Weakness in NDE and Welding Activitie j t Materials (35065 and 55050) ]

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i The inspectors reviewed in-process and completed records for the

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!- replacement piping and welding materials. The materials were as  :

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! i i Pipint, Type 316(NG) - Purchase. Requisition No. 84K05-834606 Heat.

i No. 1 lBN, NDE Serial No. 1147 A thru L (except E) j!

i i j Welding Material, IN308L Consumable Inserts - Purchase Requisition !

! No. 87PBF-376996, Heat No. 5493T308L j i -

j Welding Material, ER308L Wire - Purchase Requisition No. 87PBF-

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376995, Heat Nos. 58E0591 and S8A2688 l

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The records were reviewed by the inspectors to verify the following:

'(1) Procurement requisitions contain'or reference applicable technical requirements and QA requirements (2) 10 CFR 21 imposed (3) Supplier is'on approved list (4) Receiving inspection performed (5) Mechanical test results, chemical analyses and other examinations comply with ASME Code requirements and NUREG-0313, -Rev. 2 Draft Report (6) Material identification and traceability comply with ASME Code and licensee procedural requirements (7) Welding materials issued in accordance with licensee procedures Apparent deficiencies were found in the welding material procurement requisitions and are described in paragraph 3.c. abov Within the areas examined, no violation or deviations were identified except as noted in 5.c abov . Inspector Followup Items (IFIs) (Closed) IFI (259, 260, 296/84-40-03): Justification for Pump Test Allowable Ranges The licensee's new program for inservice testing of pumps and valves, which was submitted to the NRC on December 23, 1986, provides justifi-

! cation for the allowable ranges of pump test values specified in the licensee's procedures. This justification was reviewed by the inspector and appears acceptabl This matter is considered closed, (Closed) Inspector Followup Item 260/86-39-01, Enhancement of Examina-tion Procedure Needed On November 18, 1986, TVA's inservice inspection (ISI) personnel were *

requested by the ins procedure (N-UT-24)for pectors to demonstrate determining their ultrasonic the . thickness inspection of weld butter remaining on the reactor N-2 nozzles after the safe-ends are remove The ultrasonic procedure demonstration performed by the ISI examiners at the site was not successful in achieving the examination objective On November 20, 1986, the inspectors were requested by TVA to allow the

. ISI Technical Engineering Branch to come to the NRC Regional Office on

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, inspectors concluded -that the procedure could achieve its examination I objectives if Jenhanced to -_ insure . that the , following items were .

adequately' addressed: (1). examiners performing examinations using this-

- procedure should receive special training from the Technical Engineer - '

ing Branch ' on signal _ recognition; (2) transducers . used to performed ' .

these examination should be described in the examination procedure; and

.(3) an appropriate calibration block should be provided and described hn in the - examination : procedure. On January 8,1987; the inspectors

'i' reviewed procedure' N-UT-43, Revision 0, which had been written t replace N-UT-24, observed records of examiner training given on the procedure and witnessed a performance demonstration of the procedure by ,

3 site ultrasonic examiners. . Each of the inspectors concerns had been '

[ addressed by - the licensee and. the demonstration was successful in +

achieving.1ts examination objectives._- This . item i_s therefore i considered closed.

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e p - (Closed) IFI (259,' 260, 296/86-04-04): Storage of Radiographs i

j This item was. opened to identify inspector interest in instances .of j improperly stored radiographs identified by the licensee- in one of i their audits. During the current inspection the ~ inspector reviewed - records of the licensee's findings, corrective ~ actions, and closure of the original audit item. The inspector considers that no further

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![ review of this matter appears necessary.

' (Closed) IFI - (259, 260, 296/86-42-02): Possible' Improvements /Correc-

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tions to Instruction for Determining' Bolt Torque Requirem(nts

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This iten identified an NRC inspector's concern that the licensee's

! instruction for determining Bolt Torque Requirements contained some -

i data that was not fully legible and that the instruction appeared

! excessively complex.

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During the current inspection the NCC inspector discussed the subject'

.. instruction with the individual who prepared its_ previous revision and

! with other personnel involved 'in updating and improving the licensee's-procedures and. instructions. The-inspector accepted explanations as to i why the instruction was 'so complex ;and detailed. Licensee. personnel.

acknowledged the illegibility .of- some data . in ' the instruction, noted i

that clarifications could be readily obtained by going'to the source of

! the data, and stated that improved graphics would be incorporated in L the instruction by mid-1987. The inspector accepted these explanations j and, noting that-the instruction will.be subject to further review in routine NRC inspections, considers the matter close ,

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