IR 05000259/1987019
| ML20215H281 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/10/1987 |
| From: | Georgiev G, Girard E, Hermann R, Mclellan T, Newsome R, Danni Smith NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20215H259 | List: |
| References | |
| 50-259-87-19, 50-260-87-19, 50-296-87-19, NUDOCS 8706240048 | |
| Download: ML20215H281 (14) | |
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ENCLOSURE 2 M(
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. UNIT.ED STATES NUCLEAR REGULATORY COMMISSION
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0FFICE OF SPECIAL PROJECTS DIVISION OF TVA PROJECTS Report Nos.:
50-259/87-19, 50-260/87-19, and 50-296/87-19 Docket Nos.:
50-259, 50-260, and 50-296 Licensee Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry Nuclear Power Station Units 1, 2, and 3
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Inspection Conducted:
April 20-24, 1987 4/8 /87-rM
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Inspectors:
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G. B. 'gGorgrev/TeamLe(dpr.
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&/f/27 T. McLellan
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D. Smith Ddte 61gned
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Newsom
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Date Signed Consultants:
M. Schuster, E. Martindale, W. Marini 0.
h 19!$ l R. Hdrmann,(Chfef Date Signed
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Engineering Branch Division of TVA Projects
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G706240048 870617 ADOCK0500g9 DR
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TABLE OF CONTENTS
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1.
Background Information
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Inspection Scope and Objectives...........
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Discussion.......................
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Inspection Details
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Persons Contacted and Documents Reviewed.......
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I 1.
BACKGROUND INFORMATION As a result of concerns expressed by employees of Tennessee Valley Authority)
(TVA) regarding the adequacy of TVA's welding program, a welding project (WP was established to review the welding program and take the necessary actions to ensure that future welding activities are conducted in accordance with TVA licensing commitments.
To accomplish this task, the WP was to evaluate the welding program at each TVA nuclear power plant in two separate work phases.
Phase I effort consists of a review of the written TVA welding program (design documents, policies, and procedures) to ensure that the welding program correctly reflects TVA's licensing commitments and regulatory requirements. Phase II effort will consist of actual reinspection of selected welds and the inspection results will be used to evaluate the implementation of the written welding program.
The sampled welds will also be evaluated to determine whether the welds made by TVA in the field meet the applicable code requirements and are adequate for service.
In both phases of the welding program, the WP was to identify and categorize any deficiencies in the existing program, correct the problems and implement changes to prevent recurrence.
2.
INSPECTION SCOPE AND OBJECTIVE l
The scope of this inspection included a review of (1) the information contained in the TVA Phase I report (2) a sample of FSAR commitment review forms and related specifications and drawings (3) the personnel qualification records I
and (4)pectors reinspecting welds under the scope of the TVA Phase II effort for ins a sample of engineering calculations completed by TVA.
The objective of this inspection was to assess the adequacy and validity of the information contained in TVA's Phase I report.
3.
DISCUSSION The NRC welding team (1) reviewed the information contained in the TVA's Phase I report (2) reviewed a sample of engineering calculations completed by TVA (3)
reviewed the personnel qualifications records for the TVA inspectors performing reinspection of welds under the scope of the Phase II effort (4) reviewed a sample of FSAR commitment review forms and related specifications and drawings and (5) conducted interviews with cognizant TVA personnel concerning status and resolutions of employee concerns. The team did not actually review the employee concerns because this inspection included only a programmatic review
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of the TVA welding program. TVA has not yet completed its evaluation of their Phase II reinspection results.
In general, the approach outlined in TVA's Phase I report contained the elements needed to determine whether TVA licensing commitments have been properly translated into the governing specifications and drawings.
However the NRC team identified several inadequacies that TVA must address in the Phase II report. These inadequacies include the following:
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Most of the selected packages cover welding activities that were performed
after 1981. Very few reviews were performed by the WP to determine how
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the licensing commitments were translated into the design documents prior l
to 1981.
l The NRC welding team also experienced difficulties in tracing the origin
of the allowables used for the engineering calculations in the structural component welding areas.
The NRC welding team identified instances in which the drawings did not provide a traceable path to verify whether the design output documents accurately reflect commitments TVA made in the FSAR to meet the applicable construction codes.
The NRC welding team found several instances in which FSAR commitments
were not reflected in the actual application, or in which FSAR was not properly revised to reflect the actual application.
Very few or no examples were included in the phase I report for certain
welding activities such as welding on 1-inch diameter instrument piping and welding on heating, ventilating and air-conditioning (HVAC) supports.
In the area of nondestructive examination (NDE), the review of the personnel qualification records revealed that the inspection personnel utilized by the TVA welding project had the required qualifications to perform the required weld reinspections.
However, deficiencies were identified during the review of radiographic examination procedures that TVA must address in its Phase II report. The radiographic procedures and their associated deficiencies were identified as follows:
Radiographic procedure BF-15 does not meet the requirements of the applicable construction codes for film interpretation.
The exceptions taken to radiographic procedure N-RT-1 which was used during the TVA's Phase II reinspection effort do not meet the requirements of the applicable standards for penetrometer requirements, geometric unsharpness, density requirements and double wall technique.
4.
INSPECTION DETAILS To facilitate the NRC welding team evaluation, the information reported in the l
TVA Phase I report was sorted into three areas:
(1) structural welding, (2) pipe, spiral duct and instrument welding, and (3) NDE.
Each of these is I
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4.1 Structurai Welding 4.1.1 Inspection Scope l
l A total of 52 FSAR commitment review packages were selected for review by I
the NRC welding team. The packages were selected to include the following (1) pipe supports, (2) instrument supports, (3) electrical supports I
areas:
(4) HVAC supports, (5) equipment supports, (6) structural steel fabrication, and (7) engineering calculations.
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I The NRC welding team also reviewed TVA process specification G29C to verify I
that the FSAR commitments were translated in this specification, which is the
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main controlling document for the structural welding areas.
Six engineering calculation packages also were reviewed for cor.servatism, organization, completeness, consistency of documentation and conformance to design require-ments (As contained in the FSAR, AISC Manual of Steel Construction, and TVA weld project procedure WP-07, Rev. 1). The NRC welding team did not review the accuracy of the design loads used in the calculations because such a review is outside the scope of this inspection.
4.1.2 Inspection Findings Listed below are the NRC team inspection areas and findings associated with the reviewed engineering calculations and FSAR comnittment packages:
(1)PipeSupports TVA reviewed 38 pipe supports as a part of their Phase I review. The NRC welding team reviewed 24 packages in the pipe support area; 23 of these packages provided a traceable path between FSAR commitments and the design output documents. However, the drawings associated with the remaining package BFEPC48, were dated April 22, 1968 and did not refer to process specification G29C as stated in TVA's Phase I FSAR/committment consistency review form.
Process specification G29C did not exist prior to 1970 thus a trail that the FSAR committments have been incorporated into the governing construction drawings could not be established in this case. The NRC welding team also noted that the period covered for 23 of the inspected 24 supports was 5/15/81 through 9/11/84, which indicated that TVA performed very few reviews to determine how the FSAR commitments were incorporated into the design documents before 1981. The 23 supports and the drawing issue dates are identified as follows:
TVA Item No.
Date TVA Item No.
Date BFEPC01 3/22/84 BFEPC26 9/11/84
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BFEPC02 3/22/84 BFEPC32 8/21/84 BFEPC03 6/27/84 BFEPC37 9/21/83 BFEPC04 3/01/84 BFEPC71 5/15/81 BFEPC05 7/10/84 BFEPC07 7/23/84
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Instrument Supports l
As a part of their Phase I work, TVA reviewed three instrumentation supports and one instrument component support.
The NRC welding team reviewed the same four items.
In all cases the team found an easily traceable path between the design output documents and the FSAR documents. The NRC team also noted that
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the time period for these items covered only 6/9/81 through 8/18/86.
Each of these items and its associated drawings is discussed below.
BFEPC45 - Instrument pipe support:
Drawing'47W1600-301A, dated 9/28/84, i
Rev. O contains the welding details needed to fabricate and install this instrument pipe support.
Note 4 on the drawing states that welding shall be performed per general construction specification G-29C. Specification j
G-29C requires that welding be performed in accordance with the American Welding Society (AWS) D1'.1. structural welding code. The AISC Manual also requires that welding be performed in accordance with AWS D1.1.
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BFEPC46 - Instrument pipe support:
Drawing 47W3600-257, dated 2/21/84,
Rev. O contains the welding details needed to fabricate and install this-instrument pipe support. Note 10 on the drawing states that welding shall be performed per general construction specification G-29C.
Specification G-29C requires that welding shall be performed in accordance with AWS D1.1. The AISC Manual also requires that welding be performed in i
accordance with AWS D1.1.
BFEPC47 - Instrument pipe support:
Drawing 47W600-314, dated 10/10/85,
Rev. I contains the welding details needed to fabricate and install this instrument pipe support. Note 2 on the drawing requires that welding be performed per general construction specification G-29C. Specification G-29C requires that welding be performed in accordance with-AWS D1.1.. The AISC Manual also requires that welding be performed in accordance with AWS D1.1.
BFEPC50 - Radiation monitor support:
Drawing 48N1111-2, dated 5/14/84,
Rev. O contains the welding details needed to fabricate and install this
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Note 1 on the drawing refers to " General Notes," Drawing 48E1300-1, Rev. O, which require that installation meet the AISC Manual requirements.
Note F6 on Drawing 48E1300-1, Rev. O requires welding to be performed in accordance with general construction specification G-29C.
Specification G-29C requires that welding be performed in accordance with AWS D1.1 Code. The AISC Manual also requires that welding be performed in accordance with AWS D1.1.
(3) Electrical Supports As a part of their Phase I work, TVA reviewed seven conduit supports and three electrical cable tray supports.
(The Phase I review did not include examples of junction box installations, panel board mountings, or switch gear instal-lations). The NRC welding team reviewed these 10 items.
Drawings for 3 of the 10 items.did not provide a traceable path to verify whether the design i
documents accurately reflect the FSAR commitments, u
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Drawings for the other seven items referred to process specification G-29C and the AISC Manual. However, the FSAR referred to the 8th edition of the AISC Manual while the drawings referred to the 6th edition. The 10 electrical items and the associated drawings are discussed below.
BFEPC44, BFEPC73, and BFEPC97 - Cable Tray Supports: Drawings 48N1040R0,
I 48N890, and 48N897 did not refer to the applicable construction code.
CFEPC58, CFEPC59, CFEPC60, CFEPC61, CFEPC62, CFEPC63, and CFEPC64 -
Conduit Supports: The drawings for these items referred to process specification G-29C and the 6th edition of the AISC Manual. The FSAR referred to the 8th edition.
(4) HVAC Supports TVA have reviewed one HVAC support as a part of its Phase I review. The NRC welding team reviewed this item which is identified as BFEPC87.
No problems or inadequacies were identified during the review. However, the NRC welding team
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concluded that TVA's Phase II inspection effort must include an adequate number of HVAC support welds to determine whether the FSAR commitments have been j
incorpora.ted in the applicable design documents.
(5) Equipment Supports TVA reviewed three equipment supports as a part of its Phase I review. The NRC welding team reviewed these three items, which are identified as BFEPC40, BFEPC49, and BFEPC50. No problems or inadequacies were identified during the review of itens BFEPC49 and BFEPC50; however, the drawings for item BFECP40 did not reference any welding standard; thus, the NRC team could not confirm that the FSAR committments have been met. The NRC team also concluded that TVA's
Phase II inspection effort must include an adequate number of equipment supports to determine whether the FSAR commitments have been incorporated in the applicable design documents.
(6) Structural Steel Fabrication TVA reviewed 45 items in the structural steel, miscellaneous steel, and embedded parts areas. The NRC welding team reviewed ten items.
Six of the reviewed ten items had drawings which did not provide a traceable j
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path to verify whether the design documents ~ accurately reflect the FSAR connitments. The items reviewed and the associated drawings are discussed below.
I BFEPC19, BFECP42, BFEPC55, and BFEPC77: No problems or inadequacies were
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identified during the review of these items.
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for those six items did not refer to the applicable construction code thus, they did not provide a traceable path.to verify whether the FSAR commitments were incorporated into the governing construction drawings.
(7) Engineering Calculations The NRC team found the engineering calculations it reviewed generally organized, and complete, with appropriate references (e.g., AISC Manual of Steel Construction and Design of Welded Structures by Blodgett). The assumptions related to weld configurations were conservative and conformed'
to TVA procedure WP-07, Rev. 1.
However, the NRC team could not trace the origin of the allowable values used by TVA to evaluate the' structural com-ponents, even though two design criteria [BFN-50-724, " Class I Seismic Pipe
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Support Design", Rev. 0 (9/26/86), and BFN-50-754, " Miscellaneous Steel l
Components for Class I and II structures, Rev. 0 (11/10/86)] were issued before.
inspection.
Subsequently, TVA has indicated that the origin of these allowable
values will be provided in the Phase II report. The items reviewed by the NRC welding team were as follows:
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TVA Item No.
Description 47B451-26-PS2-WP8 Pipe support - missing weld and increased weld size Const-SK-PS2-WP-16 Pipe support - missing weld and unacceptable j
fillet 47B588-3-PS3-WP23 Pipe support - missing weld and overlap 47A900-8-DSI-WP25 HVAC support - excessive gap, profile,
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overlap, and missing weld 48N1040-0TS2-WP-33 Cable tray support - lack of fusion CONST-SK-153-WPS1 Jet Pump instrument line support - burn through rough profile, underfill and insufficient throat 4.1.3 Conclusions In general, the NRC welding team found that TVA's Phase I report contained the elements needed to determine whether the licensing commitments have been properly translated into the governing specification and drawings. However, several inadequacies, (as identified in Section 4.1.2 above) were noted during this inspection. TVA must address those items in its Phase II report.
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4.2 Pipe, Spiral Duct and Instrument Welding l
4.2.1 Inspection scope A total of 14 FSAR commitment review packages were selected' for review by the NRC welding team. The package were selected to include spiral duct, pipe and instrument tubing welds. The NRC team also reviewed process specifications
' G28 and G29M to verify that the FSAR commitments are incorporated into those documents, which, are the major controlling documents for the pipe and in-strument welding areas.
In addition, the NRC team reviewed the information reported in the TVA Phase I report and reviewed the engineering calculations for one item.
4.2.2 Inspection findings The NRC welding team identified no problems during the review of engineering calculation for. item CEB-MAZ-83 and calculations were acceptable for evaluating the weld deficiencies associated with this item.
Listed below are the NRC team inspected plant areas and the findings associates with the reviewed FSAR commitment packages:
(1) Pipe Welding TVA reviewed 73 pipe welds as a part of their Phase I review. The NRC team reviewed 10 packages in the pipe weld area. These packages were selected to i
include various safety related systems such as recirculation, residual heat removal (RHR), control rod drive (CRD), emergency equipment cooling water closed cooling water (gh-pressure coolant injection (HPCI), reactor buildin (EECW), core spray, hiRBCCW), and the control air systems.
In addition, the NRC inspectors reviewed items representing various TVA safety classifications, such as classes A, B, C, D, and American Society of Mechanical Engineers, (ASME)Section III Class B.
The 10 reviewed packages covered the period from 1980 through 1983; the TVA sample covered the period from 1978 through 1985.
Drawings for 5 of the 10 packages did not provide a traceable path to verify whether the design documents accurately reflect the FSAR commitments.
In addition, three of those items also showed that the FSAR commitments were not carried into actual application or that the FSAR has not been revised to reflect the actual field condition. The FSAR also referred to ANSI B.31.1 while the Engineering Change Notice (ECN) and referenced documents required i
that welding be performed under the rules of ASME Section III, 1983 Edition.
I The 10 items reviewed by the NRC team and the associated drawings are discussed below.
BFEP/MEB-005 - 28 inch pipe-to-pipe weld on the recirculation system:
In the FSAR, TVA commits to meet ANSI B31.1.0 1967 Edition, and mandates
the use of type 304 stainless steel material. The ECN and the referenced documents required the fabrication to comply with the requirements of ASME Section III, Sumer 1983 Addenda, using type 316 stainless steel material.
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No reference to specification G-28 was found in the ECN and the referenced documents.
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BEP/MEB - 011 - 24-inch pipe-to-pipe weld on the RHR system: In the FSAR,
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TVA commits to meet ANSI B31.1.0 1967 Edition. The ECN and the referenced i
documents require the fabrication to comply with ASME Section III, Summer 1983 Addenda. No reference to specification G-28 was-found.in the ECN and the referenced documents.
BFEP/MEB-015 - 4 -inch fitting-to-)ipe weld on the recirculation system:
In the FSAR, TVA commits to meet AiSI B31.1.0 1967 Edition and mandates the use of type 304 stainless steel material.
The ECN and the referenced documents requires the fabrication to comply with ASME Section III, Summer 1983 Adden'da, using type 316 stainless steel material.
No reference to specification G-28 was found in the ECN and the referenced documents.
BFEP/MEB-071
.75-inch pipe-to-valve socket weld on the control air system:
The design output documents do not refer to the general construction specification G-28, which specifies the weld requirements.
In addition, piping drawings do not specify the TVA piping class.
BFEP/MEB-072-10 inch pipe to valve weld on the RBCCW system: There-is no
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identifiable commitment in the FSAR regarding welding requirements for the RBCCW system. The piping drawings do not reference the general construction specification G-28, which specifies the weld requirements.
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BFEP/MEB-022 - 6-inch pipe-to-fitting weld on the CRD system; BFEP/MEB-038
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- 4 inch )ipe-to-valve weld on the EECW system; BFEP/MEB-0JI - 1 inch-pipe-to-valve soc (et weld on the HPCI system; FREP/MEB-068-2 inch weldolet-to-14-inch
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pipe branch weld on the core saray system; and BREP/MEB-075 - square butt weld for 1.5-inch by 0.25-inch-thic( stiffening ring on the pressure su)pression chamber: No problems or inadequacies were identified during the N RC team review of these items.
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Instrumentation Tube Welding TVA reviewed three instrument tube welds as a part of its Phase I review. The NRC team review of these three items showed that all three items were 3/8
inch-diameter instrument tube welds. No examples of 1/2-diameter instrument pipe welds were included in the TVA's Phase I report. The drawings for the reviewed instrument tube welds did not provide a traceable path to verify whether the design output documents accurately reflected the FSAR commitments.
The NRC team also concluded that TVA's Phase II inspection effort must include an adequate number of of instrument pipe welds to determine whether the FSAR commitments have been incorporated in the applicable design documents. The I
three items that the NRC staff reviewed and the associated drawings are discussed below.
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BFEP/MEB-001, 002, and -003 - 3/8-diameter tube-to-instrument welds on j
instruments LT-3-208A and -2088: TVA's review determined that a " minor i
inconsistency" exists between the FSAR and design documents because the key design output documents--I&C design Drawings 47W1600-300, and 47W1600-301--do not explicitly specify the tubing class. When welding specification G-29M is used, specifying the tubing class is essential to determine whether or not the welds in question must comply with ANSI B31.1 Code. Note 8 of Drawing 47W1600-300 states:
" Class M and D piping per general construction spec. G-28."
The TVA's review indicates that this note "must be assumed to apply to the entire drawing series"; Drawing 47W1600-301 shows instruments LT-3-208A and -208B, but specifies no piping or tubing class since the identification "-3" in the instrument number denotes the feedwater system, and because piping Class D does not apply to the feedwater system, it can be reasoned that the subject welds are Class M.
Class M welds require welding to be performed in accordance with the requirements of ANSI B31.1.
The NRC team review of TVA's investigative reasoning (given above)
determined that Drawing 47W1600-300 pertains only to control air system piping.
Neither Drawing 47W1600-300 nor Drawing 47W1600-301 refers to the other or,,ntains any other information to indicate that they are part of a drawing series whose notes may be used interchangeably. Without being able to utilize Note 8 of Drawing 47W1600-300, several piping classes could be applied to the feedwater system welds.
Not all of those classes require welding to be performed in accordance with ANSI B31.1 Code.
Therefore, no traceable path exists to ascertain positively that the FSAR commitment to ANSI B31.1 has been adequately included in the design output documents for these welds.
(3) Spiral duct welding TVA reviewed one spiral duct item. The NRC team reviewed this item which is identified as BFM45.
No problems or inadequacies were noted during the NRC team review of this item. However, the NRC welding team concluded that TVA's Phase II inspection effort must include an adequate number of spiral duct welds to determine whether the FSAR commitments have been incorporated in the applicable design documents.
4.2.3 Conclusions In general, the approach outlined in TVA's Phase I report was found to contained the necessary elements needed to determine whether the licensing commitments have been properly translated into the governing specif-ications and drawings. However, several inadequacies (as identified in Section 4.2.2 above) were noted during this inspection. TVA must address those items in its Phase II report.
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4.3 Nondestructive Examination
4.3.1 Inspection Scope i
The NRC welding team reviewed four NDE specifications and five NDE procedures.
The NRC team also reviewed the qualification certification records for 8
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welding inspectors and 10 inservice inspectors. The welding inspectors had
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reinspected the welds sampled by TVA under its Phase II reinspection effort.
4.3.2 Findings The NRC team's review of the qualification records of TVA inspectors revealed that the inspectors were qualified to perform the reinspection required under TVA's Phase II program. With the exception of two radiographic examination procedures, the reviewed NDE procedures complied with the requirements of the governing codes and specifications. The two radiographic procedures and their associated deficiencies are discussed below.
Radiographic procedure BF-15 does not meet the requirements of the
applicable codes for film interpretation.
The exception taken to radiographic procedure N-RT-1 which has been
utili2.ed during Phase II reinspections, does not meet the requirements of the the applicable codes for penetrometer requirements, geometric unsharpness, density requirements, and double wall technique, i
4.3.3 Conclusions In general, the inspected NDE activities complied with the requirements of the applicable codes and standards. With the exception of the discrepancies identified with two radiographic procedures, the inspected NDE activities met the applicable construction standards and licensing commitments.
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PERSONS CONTACTED AND DOCUMENTS REVIEWED l
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H.P. Pomrehn, Site Director R.L. Lewis, Plant Manager
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M.J. May, Site licen',ing Manager C.W.. Hatmaker, Welding Project R.A. Montgomery, Welding Project B. Kron, Wedling Project D.H. Mickler, Division of Construction V. Budde, Welding Project R. Latie, Division of Nuclear Engineering J. Boone, Division of Nuclear Engineering R. Henley,-BFN Engineering Project J.T. Walker, BFN Engineering Project B. Blair, Quality Compliance R. Summer, BFN Staff Manager G. Wade, Inservice Inspection R. Downey, BFN Engineering Project NRC Resident Inspector:
G.L. Paulk, Senior Resident Inspector J. York, Resident Inspector (Bellafonte)
5.2 Document Reviewed General Construction Specification G-29 " Process Specification for Welding, Heat Treatment, Nondestructive Examination and Applied Field Fabrication Operations" General Construction Specification G-28 " Construction of Piping Systems for Boiling Water Reactor Nuclear Power Plants" General Construction Specification G-29M " Process Specification for Welding, Heat Treatment, Nondestructive Examination, and Applied Field Fabrication Operations" Nuclear Construction Issues Group (NCIG)-01, " Visual Weld Acceptance Criteria
for Structural Welding at Nuclear Power Plant '(VWAC), Rev. 2.
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NCIG-02." Sampling Plan for Visual Reinspection of Welds", Rev. O Office of Nuclear Power Nondestructive Examination procedure N-UT-6 " Visual Examination of Structural Welds Using the Criteria of NCIG-01", Rev. O.
Division of Nuclear Engineering-Design Criteria BFN-50-754 "Miscellaneious Stell Components for Class I and II structures", Rev. O.
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United Engineers and Construction (UE&C) Interim Evaluation of Electrical Cable Tray / Supports.
(TVA Structural Training Program).
TVA Welding Project Procedure (WP)-07 "DNE Plan for the Evaluation of Re-inspection Results Browns Ferry Nuclear Plant," Rev. 1.
Radiographic Examination Procedure BF-15 Radiographic Examination Procedure N-RT-1 Liquid Penetrant Examination Procedure 3.M.1.1 Magnetic Particle Examination Procedure 3.M.2.1 TVA's Welding Project, Browns Ferry Nuclear Plant Phase I Report.
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