IR 05000266/1983020

IE Insp Rept 50-266/83-20 on 831213-16 & 840110-13. Noncompliance Noted:Failure to Follow Steam Generator Replacement Project Procedures

ML20087F865
Person / Time
Site:	Point Beach
Issue date:	02/23/1984
From:	Kleinsorge W, Blake J NRC Office of Inspection & Enforcement (IE Region II)
To:
Shared Package
ML20087F850	List: IR 05000266/1983020
References
NRC-2020-000157 50-266-83-20, NUDOCS 8403190247
Download: ML20087F865 (17)

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'- R8e i    UNITED STATES o  NUCLEAR RE2ULATORY COMMISSION g
[  o   REGION 11 I  'E  101 MARIETTA STREET, .

ATLANTA, GEORGIA 30303

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Report:No.:~50'266/83-20 - Licens$e: Wisconsin Electric Power Company

 ~ 231 West Michigan Milwaukee, WI 53201 Docket No.: 50-266
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License No.: DPR-24 Facility Name: . Point Beach

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Inspection at P ch te near Two Rivers, Wisconsin Inspector: , A-. [[,h[ DateSignedh K

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Approved by: ;L[# 3[6 4 J. . , Ek6, Section Chief Da'te Signed t i eering Program Branch D vi ion of Engineering and Operational Programs , SUfEARY Inspection on December 13-16, 1983 and January 10-13, 1984 Areas Inspected This routine, unannounced inspection involved 62 inspector-hours on site in the areas of modification progress (Unit 1), steam generator replacement project-(SGRP),(Unit 1) and preservice inspection (PSI) (Unit 1).

_Results y Of the three areas inspected, no-violations or deviations were identified in two

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areas; .one apparent violation was fou:.d in one area (Violation " Failure to Follow SGRP ' Procedures" - paragraph 6a(1), 6a(2)(b), 6a(4)(a)2_, 6c(2)(c) and 6f(2))~. No deviations were-foun e V

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8403190247'840305 PDR ADOCK 0500026

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l REPORT DETAILS

' Persons Contacted Licensee Employees
*J..J. Zach, Plant Manager  _
*D. ' B. Tate, Administrator - Special Projects
-*R. E. Link, Superintendent - Engineering, Quality and Regulatory Services
*R.' L. Harris, Superintendent - Reactor Engineering
*A. L. Reimer, Site Supervisor
*F. A. Flentje, Supervisor - Staff Services Other licensee - employees contacted included technicians and office personne Other Organizations
*M. J. Brigham, Project Manager - Morrison - Knudsen (M-K)
'*A. J. Walcutt, Project Quality Manager, M-K
*B. W. Garrow, Lead Site Quality Assurance Engineer Westinghouse (W) _

Other organizations employees contacted included construction craftsmen, technicians and office personne NRC Resident Inspectors-R. L. Hague ._

*B.. Fitpatrick
* Attended exit interview Exit Interview The inspection scope and findings were summarized on January 13, 1984, with

~ those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail. the inspection findings listed

- below. - No dissenting convents were received from the license (Closed) Violation 266/83-20-01: " Failure to Follow SGRP Procedures" -

paragraphNos.6a(1),6a(2)(b),6a(4)(a)2,6c(2)(c)and6f(2).

(0 pen) Unresolved Item 266/83-20-02: " Unavailable Documents From WP 2912 A

 & B" - paragraph 6f(1).

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3.- Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item 266/83-24-01: " Unaddressed Nonessential Variables".

The licensed made appropriate corrections to WPS Nos. N-8-8-A and N-3-3-CP prior to implementation. This matter is consider close . (Closed)' Unresolved Item 266/83-24-02: " Discrepancies in FQP 2.1 and FQP 2.2".

t The licensee made appropriate corrections to FQP 2.1 and 2.2 prior to implementation. This matter is constdered close (Closed) Unresolve'd Item 266/83-24-03: " Discrepancy in FQP 9.3", The licensee made appropriate corrections to FQP 9.3 prior to imple-mentation. This matter is considered close (Closed)UnresolvedItem 266/83-24-04: " Discrepancy in FQP 9.6".

The licensee made appropriate corrections to FQP 9.6 prior to imple-mentation. This matter is ' considered close . (Closed) Unresolved Item -266/83-24-05: " Radiographic Examination Program Discrepancies".

The licensee made appropriate corrections to FQP 9.4 prior to imple-mentation , This matter is considered close . Unresolved Items Unresolved items 'are matters about which more information is required to determine whether- they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 6f(2). Independent Effort Modification Progress (Unit 1) The inspector conducted a general inspection of cold shop warehouse, turbine deck and Unit 1 containment to observe modification progress and activities such as welding, meterial handling and control, house-keeping, and storag "

.Within.the areas examined no violations or deviations were identifie s
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6. SteamGeneratorReplacementProject(SGRP)(Unit 1) The Point Beach Nuclear Plant Unit 1, owned by Wisconsin Electric Power Company (WEPC0), is replacing the lower steam generator assemblies. The work is being accomplished by Westinghouse (11) the customer / client of Morriscn-Knudsen (M-K). The hierarchy of project documents is: WEPC0-Point W NSID Steam Generator Repair Beach Quality Supplement Program, and QA ProgramW

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NSID Plan QA Program, Supplement, _ Tl SGRP Quality Procedures, and M-K Quality Procedures. The applicable codes for the SGRP are listed below:

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ASME Section III 77S79

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ASME Section V 77S79

- ASME Section IX 77S79
- AWS D1.1-1982
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SNT-TC-1A-1975 Welding (55050B)

(1) Production Welding The inspector surveyed ongoing welding activities and selected typical inprocess operations representing different welding processes, procedures and joint configurations for detailed revie The weld joints selected are listed belo The review was conducted to determine the following: work conducted in accordance with a " traveler"; welding procedures and drawings available; WPS assigned in accordance with applicable code; technique and sequence are specified; materials as specified; geometry as specified; fitup and alignment as specified; temporary attachments consistent with applicable code; gas shielding and purging as specified; preheat is as specified; technique is as specified; welding electrodes are as specified and consistent with the code; gas flow is controlled as specified; welding equipment is as specified; interpass temperature is controlled and consistent with the applicable codes; interpass cleaning and backgouging are performed as specified; process control system has provision for repairs consistent with applicable codes; weld repairs are conducted in accordance with specified procedures; base material repairs are properly documented; welder identifica-tion; peening not done on root or final weld surface layer; and contractor / licensee has periodic welding equipment preventative maintenance program.

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, Drawing Weld N Note 23400-19-W-003-D 8A RC Loop Butt 23400-19-W-003-D 9A RC Loop Butt 23400-19-W-012-D 8B RC Loop Butt 23400-19-W-012-D 9B RC Loop Butt 2830-E-121 Weld Repair 2914-B 28 Weld Buildup 2340D-19-W-003-D 5A Feedwater Butt 1516E-27-W-001-D 38A Feedwater Thermal Sleeve With regard to the inspection above, the inspector noted that the frequency of oscillation for weld 98 on December 14, 1983, was 67 cp Welding procedure Specification N-8-8-A identified as the applicable procedure for the above weld, requires a maximum frequency of oscillation of 60 cpm. The inspector discussed the above with the licensee on the same day. On December 15, 1983, the inspector noted the same condition existed for joint 8 Therefore, both welders and the QC inspectors failed to follow procedure. This is an example of Violation 266/83-20-01 discussed further in paragraph 6f(2).

(2) Base Material and Filler Material Compatibility for Welding-(a) The inspector reviewcd the base and filler material combina-tions employed to evaluate the suitability of applicatio (b) The inspector reviewed the M-K program for control of welding materials to determine whether materials are being purchased, accepted, stored, and handled in accordance with QA proce-dures and applicable code requirements. The following specific areas were examined:

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Purchasing, receiving, storing, distributing and handling procedures, material identification, and inspection or welding material issuing station Welding material purchasing and receiving records for the following materials were reviewed for conformance with applicable procedures and code requirement Type Size HT N MK N ER-308 3/32" A464380 W-04-001 ER-308 1/8" S468120 W-04-004 ER-7018 1/8" JJ-006 W-01-007 ER-308 0.045" 465890 W-03-002 E-8018-C3 3/32" JJ-038 W-02-002 _ _ _ .

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With regard to the inspection above the inspector noted the following:

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 - Contrary--to FWP 7.1 Rev. IP paragraph 4.5.5. , welding filler . material heat numbers were not listed on receiving inspection report R-004 Contrery to FWP. 7.1 Rev. IP paragraph 4.6.3. , MRN No. R0136 was not listed the certified material test reports associated with that receiving inspectio Therefore procedures were not followed to maintain trace-ability of welding filler materia This is an example of Violation 266/83-20-01 discussed further in paragraph 6f(2).

(3) Welder Performance Qualification-The inspector reviewed the M-K progran for qualification of welders and weiding operators for compliance with Q' procedures and applicable code requirement The following welder qualification status- records and " Records of

. Performance Qualification. Test" were reviewed:

Welder Symbol , P-4, P-5, P-7, P-9, P-10, P- tl, P-13, P-14, P-17, P-18, P-19, P.-20, P-23, P-22, P-23, P-24, P-26, P-30, P-31, P-3E, P-33, P-35, and P-3 . (4) Preheat and' Post Weld Heat Treatment (a) Preheat

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The inspector reviewed the M-K program for weld preheating to determine whether procedures were avail-able when specified; procedures specify accept &51e methods and provide requirements for monitoring and recording preheat, before during and if specified after welding entil post weld stress relie The inspector observed preheat controls in process for the below listed joints to determine whether procedures were being followed, and temperatures were within specified limit e~e-- __

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Drawing Weld N Note 23400-19-W-003-D 8A RC Loop Butt-23400-19-W-003-D 9A RC Loop Butt 23400-19-W-012-D 8B RC Loop Butt

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23400-19-W-012-D 9B- RC Loop Butt 2830E-121 Weld Repair-2914B-28 . Weld Buildup 2340D-19-W-003-D SA Feedwater Butt 1516E-27-W-001-D 38A Feedwater Thermal Sleeve With regard _to the inspection above, the inspector noted that the preheat temperature on the A-generator. steam . drum weld repair (2830E-121) was 204"F. Welding Pro-cedure Specification M-3-3-B-P identified as the applicable procedure for the above repair, requires a

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, minimum preheat temperature of 250 F. Therefore, the welder. failed to follow procedure. This. is an example - of Violation 266/83-20-01 which is discussed further in paragraph 6f(2).

~(b) Post Weld Heat Treatment (PWHT)

  ~ ~ ~1- The inspector reviewed the M-K program _for PWHT ~ to determine whether procedures are available; has a system capable of nmeting-the heating and cooling rates, netal temperature, . temperature uniformity .and control limits

, are specified and consistent with the_ applicable codes; procedure covers both local and furnace heating if used; and furnace atmosphere controlled if used.

, _ 2, The inspector, by ' direct observation and record review, . examined the below listed PWHT operations to determine whether components were instrumented; sufficient thermo-couples were used; PWHT temperature and holding time specified were adhered to, and consistent with applic-

,   able codes; procedures were available for intermediate in-process stress relief if applicable; temperature control was exercised for the entire temperature cycle; and measures were taken to avoid sensitization if applicabl '

Drawing Weld N Note

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1516E-27-W-003-D 37A Steam Generator Girth 1516E-27-W-012-D_ 378 Steam Generator Girth

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Tte inspector examined the cumulative stress relief i records for the below listed welds to determine whether total time-at-temperature was consistent with the applicable code and welding procedure specification Drawing Weld N Note 1516E-27-W-003-D 37A Steam Generator Cirth 1516E-27-W-012-D 378 Steam Generator Girth (5) Examination of Welds The inspector visu:lly examined completed and accepted welds as described below to determine whether applicable code and procedure requirements were being me (a) The below listed welds were examined relative to the following: location, length, size and shape; weld surface finish and appearance (including inside diameter of pipe welds when accessible); transitions between different wall thicknesses; weld reinforcement -- height and appearance; joint configuration of permanent attach-ments and structural supports; removal of temporary attachments; arc strikes and weld spatter; finish-grinding or machining of weld surface -- surface finish and absence of wall thinning; surface defects -- cracks, laps, and lack of penetration, lack of fusion, porosity, slag, oxide film and undercut exceeding prescribed limit Drawing N Weld N Note 1516E-27-W-001-0 20A Feed Ring Support Lugs 1516E-27-W-001-D 21A Feed Ring Support Lugs

3516E-27-W-001-D 22A Feed Ring Support Lugs 1516E-27-W-006-D 208 Feed Ring Support Lugs 1516E-27-W-006-D 21B Feed Ring Support Lugs 1516E-27-W-006-D 22B Feed Ring Support Lugs 1516E-27-W-003-D 6A Feedwater Butt 1516E-27-W-012-D 68 Feedwater Butt 1516E-27-W-003-D 37A Steam Generator Girth 1516E-27-W-012-D 37B Steam Generator Girth 23400-19-W-012-D SB Feedwater Butt 23400-19-W-003-D SA Feedwater Butt (b) Quality records for the above welds were examined relative to the following: records covering visual and dimensional inspections indicate that the specified inspections were completed; the records reflect adequate quality; history records are adequat E

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 (c) The inspector verified that approved procedures are available for the nondestructive examination of welds when required by applicable code and/or contact requirement b. Visual. Examination (570508)
(1) Work Observation The inspector, by direct observation and record review, reinspected / reviewed the visual examinations indicated below to determine whether the . inspection procedure clearly specified required tests; the procedure was available; required tools were available; test attributes were consistent with the procedure; defects were evaluated in accordance with the procedure; correct acceptance criteria was used; and tesults were reported in the prescribed manne Drawing N Weld M Report N W-003-D  SA 2914A-80-6-X 2340D-19-W-012-D  SB 2914B-80-6-X 1516E-27-W-003-D  19A 2830C-125-7-X 1516E-27-W-003-0  19B 2830H-140-X 1516E-27-W-003-D  37A 2913A-200-6B-X 1516E-27-W-012-D  37B 2913B-200-6B-X (2) Record Review (a) The inspector reviewed the qualification documentation for the below listed examiners in the following areas:

Employer's name, person certified, activity qualified to perform, effectiveness period of certification, signature of employer's designated representative, basis used for certifi-cation and annual visual acuity, color vision examinatio SGA V-II DA V-II J0 V-II WRR V-II BS V-II DS V-II MH V-II MC V-II BW V-II JN V-II (b) The inspector reviewed the below listed visual examination reports for compliance with procedure record requirements.

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s 9~ Report N , 2912-B-110-2A-X 2912-A-115-3-X 2911-C-575-X

,-       2911-C-675-X-2911-D-575- NCR-021-1- NCR-021-5-X
      ' NCR-027-1-X NCF.-027-5-X NCR-027-5-X
  ,     2912-B-115-2A-X L    (c) _The inspector ' independently verified the visual inspection g     results using the licensee's/ contractor's procedure for the
    ' below listed report Report No
      : 2830C-125-7-X

IR-2830-H-140-X 2913A-200-68-X'

      - 2913B-200-68-X
      - 2914A-80-6-X Q       29148-80-6-X Liquid Penetrant Examination (570608)'

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  (1)L Work Observation The inspector observed the liquid penetrant examinations of weld
   ~ joints indicated below: to' determine whether. procedure clearly specified the applicable test; procedure was available; sequencing and timing of examination in accordance with applicable code /and contract; . materials available :and properly lentified; examiner
   ' identification; location and extent of examination clearly -

defined; and procedure compliance in the follosing areas: surface preparation; penetrant type;. application method; penetration time;

   -surface temperature; penetrant removal; drying; developed type and

- application;- and developing time; evaluation in accordance with-procedure and with correct acceptance criteria; and surfaces }_ . cleaned at. conclusion of examinatio Drawing N Weld N Repcrt N F-W-003-D FW-38A 2830-F-175-7-A-X . d

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(2) Record Review (a) The inspector reviewed the qualification documentation for the below listed examiners in the follcwing areas:

Employer's name; person certified; activity qualified to perform; effective period of certification; signature of employer's designated representative; basis used for certifi-cation; and annual visual acuity; color vision examinatio JNS PT-II l CS PT-II CB PT-II DA PT-II BS PT-II MH PT-II (b) The inspector reviewed the below listed liquid penetrant

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examination reports for compliance with procedure record requirement Inspection Report N B-110-1AX 2912-A-110-1-B1X  ! 2911-C-580-X ) 2911-0-580-X 2912-A-110-1-AX 2911-D-670-X 2912-A-1-B-X 2912-A-115-1-A-X NCR-017-2-X NCR-017-6-X-NCR-021-2-X NCR-021-6-X-NCR-021-2-X NCR-021-6-X NCR-027-2-X NCR-027-6-X 2912-B-115-1A-X (c) The inspector reviewed the " certification of containment content" for the below listed liquid penetrant materials to determine whether the analysis for halgen.and sulfur is consistent with applicable requirement Type Batch N Penetrant 26H1 Remover 324C4 Developer 315C6 Developer 228F39 l

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With regard to the inspection above, the inspector noted that-liquid penetrant developer, Batch No. 315C5,- indicated used in inspection ' report 2911-D-580-X oces not exist in the licensee's inventory of liquid penetrant material The licensee investi-gated and determines that the liquid penetrant examiner failed to follow procedure FQP-9.2 paragraph 4.17 which requires all liquid penetrant examinations to be correctly documented on the non-destructive examination report form. Therefore, the liquid penetrant examiner failed to follow procedure. This is an example of Violation 266/83-20-01 discussed further in paragraph 6f(2). , d. Magnetic Particle Examination (570708) e (1) Work Observation The inspector observed the magnetic particle examinations indi-cated below: to determine whether the procedure clearly specified applicable test; procedure was available; equipment materials available and identified; sequences and timing of examination in accordance with applicable code /and contract; examiner identifi-cation; location and extent of examination clearly defined; and

 . procedure compliance in the following areas: type and color of particles; surface preparatian; surface temperature; technique and coverage; prod condition / usage, magnetizing current; prod or pole spacing; yoke lifting power; and demagnetization; indications properly evaluated and reporte Report N ,

JRP/12-15/001 (2) Record Review (a) The inspector reviewed the qualification documentation for the below listed examiners in the following areas: Employers' name; person certified; activity qualified to perform; effectiveness period of certification; signature of Employer's designated representative; basis used for certifi-cation; and annual visual acuity, color vision examinatio JN MT-II TR8 MT-II J0 MT-II u - - - - - - -- - -- - _ - - - - - - - - - - - - - - _ - - - - - - - - - - - - - _ _ - - - - -

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 (b) The inspector reviewed the calibration- records for the below listed equipmen Equipment Econospect-MK-108 ESC-1000 (c) The inspector reviewed the below listed magnetic particle examination reports for compliance with. procedure record requirement Report No C-125-2-AX JRP/12-15/001 e. RadiograhicExamir.ation(57090B)

s (1) Work Observation The inspector observed the radiographic examinations indicated below: by film review to determine whether the procedure clearly specified applicable test; procedure was available; sequencing and timing of examination in accordance with applicable code /and

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contract; examiner identification; location and extent of examina-tion clearly defined; equipment and materials at the work station and properly identified; procedure compliance in the following areas: types of material; material thickness range; type of radiation source, effective focal spot or effective source size, X-ray equipment voltage rating and equipment manufacturer, as applicable; film brand or type and number of films in cassette; minimum source to film distance; blocking or masking technique, if used; type and thickness of intensifying screens and filters; exposure conditions for procedure qualifications, if applicable; radiographic film processing requirements; quality of radiographs

 - limits on mechanical, chemical or other blemishes, such as fogging, process marks, scratches, finger marks, loss of detail or false indications; film density limits for single and composite viewing; use of desolaters for assuring compliance with film density requirements; system of radiograph identification; use of location markers; records for showing film and source location with reference to the part being radiographed; use of intensifying screens; methods of reducing and testing for backscatter; descrip-tion of-or reference to the welding procedure; material type and thickness restrictions for isotope radiography; geometrical i unsharpness limitations; selection and use of penetrameters including: penetrameter design; selection of essential hole; penetrameter thickness including special requirements for single and double wall viewing; number of penetrameters; shims under penetrameters; radiographic technique requirements for double wall
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viewing; and evaluation and disposition of radiographs records requirement Drawing N Weld N W-003-D FW-8A

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23400-19-W-003-D FW-9A 23400-19-W-003-D FW-5A 23400-19-W-012-D FW-5B 1516E-27-W-003-D FW-37A

 '(2) Record Review The inspector reviewed the below listed radiographic packages to verify the following radiographic film quality attributes:

penetrameters; type; size placement, and sensitivity; density,

 ' density. verification; identification; quality; and weld coverag Drawing N Weld N D-19-W-003-D  FW-8A 23400-19-W-003-D  FW-9A 2340D-19-W-003-D  FW-5A 2340D-19-W-012-D  FW-5B 1516E-27-W-003-D  FW-37A Review of Quality Records The inspector reviewed the below listed ' completed work packages to verify that all required inspections had been completed in the sequence require N Title

' 2912A " Reactor Coolant Pipe Installation" 29128 " Reactor Coolant Pipe Installation"

 .(1) With regard to the inspection above, the inspector noted that the c  below listed documents were not available at the time of this inspectio Liquid Penetrant Inspection Report No. 2912-A-110-9-A
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Visual Inspection' Report No'. 2912-A-115-2-AX -

 - Attachment Nos. 1, 2, and 3 to work package 2912A dated
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 - Weld Data Cards and Inspection Reports for- steps 63 and 76 in work packages 2912A and 2912 . -. . . .. - - - - - - ,

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Pending NRC review of the above documents, this matter will be

 ' identified as unresolved item 266/83-20-02: " Unavailable Docu-ments from WP 2912 A & B".

(2) With regard to the examination above, the inspector determined that the liquid penetrant examination of the OD root weld required by W drawing 23400-19 Revision 5 was not accomplished for FW-8A and 9A on drawing 2340D-19-W-003-D and FW-8B and 9B on drawing 23400-19-W-012- Therefore, drawing requirements were not followed. The above failure to follow drawing requirements combined with the examples of failure to follow procedure dis-cussed in paragraph nos. 6a(1), 6a(2)(b), 6a(4)(a)2_, and 6c(2)(c), are in violation .of 10 CFR 50, Appendix B, Criterion V which ' requires activities affecting quality to be accomplished in accordance with drawings and procedure These examples were identified during the site visit on December 13 - 16, 1983; by the January 10 - 13, 1984, visit the licensee had corrected all of the abov The inspector verified that the licensee had determined the full extent of the subject violation; performed the necessary followup actions to correct the present conditions; and developed the necessary corrective actions to preclude recurrence of similar circumstances. -This matter will be for record purposes, identi-fied' as Violation 266/83-20-01: " Failure to Follow SGRP Proce-dures", and is considered close Within the areas examined, no violations or deviations were identified except as noted in paragraphs nos. 6a(1), 6a(2)(b), 6a(4)(a)2_,, 6c(2)(c) and6f(P.). 7. - Preservice Inspection (PSI)'(Unit 1) The inspector reviewed the PSI program, procedures and observed work activi-ties as indicated -in the following paragraphs to determine whether the program, procedures and work activities were consistent with regulatory requirements and licensee commitments. The applicable code for PSI is the ASME B and PV Code, Section XI,1977 Edition with Addenda through Summer 197 Review of Procedures (730528)

 (1) Approval-The inspector reviewed the below listed procedures to ascertain whether they had been approved by authorized license personnel and Level III examiner ., ,

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Procedure N Title W MRS 2.4.2. Gen. 23 Rev. 5 " Multi-Frequency Eddy Current Inspection of Heat Exchanger Tubing Preservice - Inservice"-

 -W OPR 610-3, Rev. 3  " Control of Field Service Activi-ties"
 -W MRS 2.4.2 Gen. 19  " Installation and Removal of Eddy Current Positioning Devices"

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' W MRS 2.2.2 Gen 12 " Steam Generator Tubsheet Marking" W MRS 2.2.2 Gen. 6, Rev. 4 _

   " Post-Activity Sign-Off for Area Cleanliness".

-- (2 ) Eddy Current Examination The inspector reviewed W procedure MRS-242-GEN 23, Revision 5, for technical adequacy in tWe following areas:

 - A two channel- examination unit is specifie Two channel examination indication equipment is specifie A criteria has been established for maximum sensitivit ~ A criteria has been established for determining material permeabilit .The method of examination is describe Methods of calibration and calibration sequence is aescribe Calibration simulator is describe .

Acceptance criteria is specifie '(3)' Records The inspector reviewed W Procedure MRS-242-GEN 23, Revision 5 to ascertain whether it specifies completion of required record bservation of Work and Work Activities (73053B)

 (1) Examiner Qualification The inspector reviewed the qualification records for the below listed. examiners to determine whether their qualification was
 - consistent with the licensee'r procedures and regulatory require-
 .ment Examiner  Level & Method BKP   IIA - ET JTS   I - ET SJB   II - ET
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MN 4 A, and comparhd these' activities with W' Procedure MRS-242-GEN-23 W m W Revision ~5, and'the' Code in the following' area ;i.; - m - - - M3 The?2-channel Eddy Cuprent Examination equipment has been _ffs , ;"If identified cincludir.g~ indicator,' meter,- tube, strip recorder

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