IR 05000267/1988015
| ML20195H957 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/28/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8812010128 | |
| Download: ML20195H957 (2) | |
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NOV 2 81988
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In Reply Refer To:
Docket:
50-267/88-15 50-267/88-23 Public Service Company of Colorado ATTN:
Robert O. Williams, Jr., Senior Vice President, Nuclear Operations P.O. Box 840 Denver, Colorado 80201-0840 Gentlemen:
Thank you for your letter of Nove9ber 4,1988, in response to:
(1) our letter, Notice of Violation, and Notice of Deviation dated September 13, 1988, and (2) our letter, Notice of Violation, and Notice of Deviation dated October 5, 1988.
We have reviewed your reply and find it responsive to the concerns raised in the above notices. We also acknowledge your discussion with respect to Part 2 of Violation C in the Notice of Violation dated
. September 13, 1988.
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We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be t
maintained.
Sincerely, uw /.. w! D)
A. IL Bach L. J. Callan, Director Division of Reactor Safety cc:
Fort St. Vrain Nuclear Station l
ATTN:
C. Fuller, Manager, Nuclear Production Division
1 16805 WCR 191 Platteville, Colorado 80651 Fort St. Vrain Nuclear Station ATTN:
P. Tomlinson, Manager Quality Assurance Division 16805 WCR 19)
Platteville, Colorado 80651 Colorado Radiation Control Program Director Colorado Public Utilities Commission
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P.o. Box 840
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Denver, Co 80201 0840 16805 WCR 191/2, Platteville, Colorado 80651 November 4, 1988 Fort St. Vrain Unit No. 1 P-80396 3EW@WW FF+
U. S. Nuclear Regulatory Commission
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ATTN:
Document Control Desk Wathington, D.C.
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Docket No. 50-267 SU8 JECT:
NRC Inspection Reports 88-15 and 88-23 REFERENCE:
(1) NRC Letter, Callan to Williams, dated September 13, 1988 (G-88367)
(2)
a NRCLetter,CallantoWilliams}
dated October 5, 1988 (G-88401 i
Gentlemen:
i This letter is in response to the Notices of Violation and Notice of l
Deviation (Reference 1) received as a result of a special inspection
conducted by Region IV persor.nel during the pe" kd July 11 through August 5, 1988.
This letter also responds to the.Mtice of Violation and Notice of Deviation (Reference Z)
received as a result of a special inspection conducted by Mr.
L.
E.
E11ershaw at General Atomics International Services Corpora tion during the period i
September 12-16, 1988.
Since both these inspections are closely q
related, PSC requu ted an extension to the response to Inspection 88-l 15 (Reference 1). On October 11, 1988, Mr.
Robert Farrell, of the i
NRC, granted, by phone, this delay until November 4, 1988 and
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requested that PSC respond to both inspections in a single letter.
The following response to the items contained in the Notice of Violation (Inspection 88-15) is hereby submitted:
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A.
Failure to Follow Procedures for Control of Records
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Criterion XVII of Appendix 8 to 10 CFR Part 50 requires each
Ifcensee to establish requirements concerning record retention,
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such as duration, location, and assigned responsibility.
i Admi.11s tra tive Procedures Manual (ApM) Procedure Q-17. Issue 11, I
dated March 26, 1987, states in paragraph 4.5, Records Stora ge, J
"Records are stored in the Record Center building (see Attachment Q-170) which meets the requirements of a records facility as
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described by ANSI N45.2.9."
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P-88396 Page 2 November 4, 1988
Contrary to the above, it was determined that charts generated by control room recorders are not stored in the facility described
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in the above referenced orocedure.
Based on an interview with the supervisor of the Records Ce-ter, and confirmed by reference to the licensee's Record Retention Schedule, these particular lifetime records are retained on site for 1 to 2 years only.
After tha t time, the records are sent to the Rocky Mountain Records Storage Center, a comercial facility, located in Denver, Colorado.
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This is a Severity Level V violation.
(Supplement I) (267/8815-01)
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(1) The Reason for the Violation if Admitted:
The violation is admitted.
PSC's procedure Q-17. Quality Records, does make provisions for storing quality records i
offsite, but this provision applies only to those records tha t are microfilmed.
For those records in question (recorder charts), microff1 ming was not feasible.
The volume of the records, however, was significant and as a
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result of space limitations in the Records Center, the
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records were sent to an offsite storage facility with the intent that the offsite facility provided adequate records
protection. Although not intentional, this transfer of
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records represents a violation of Q-17 requirement 3.
I (2) The Corrective Steps Which Have Been Taken and the Results j
Achieved;
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Recognizing that the existing Records Center cannot accommodate the volume of records in question, and that l
modification activities of the Records Center could not be
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made until mid 1989, PSC began an immediate search of the
local area for an alternate facility that would provide ANSI i
N45.2.9 type storage on an interin basis.
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PSC is currently cemitted to the storage of Quality Records
in a facility that meets the requirements of ANSI N45.2.9-1974, with the approved exception that we have a 3-hour fire rated facility.
PSC has not been able to find a commercial facility that would fulfill all of the requirements of ANSI
N 0.2.9-1974, however PSC has located a corrnercial facility
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that meets the equivalent requirements of ANSI N45.2.9-1979.
PSC is firalizing a technical evaluation of this facility
with the intent of relocating the records in question on an interim basis to this facility as soon as possibl. _ _ _ - _ _ _ _ _ _ _ - _ _ _
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P-88396 Page 3 November 4, 1988 A PDR to Q-17 will be issued to accommodate provisions for this connercial offsite facility.
It is anticipated that the PDR and the transfer of records will be accompitshed by November 30, 1988.
(3) The Corrective Steps Which Will Be Taken to Avoid Further Violations:
PSC has initiated design modifications for the Records Center to enlarge the qualified storage area.
These modifications are currently scheduled for completion in mid 1989.
It is felt, however, that there will still be a need for an overflow facility.
In this respect, PSC will continue the evaluation of alternate fact 11 ties and will submit necessary changes to the UFSAR for the July 1989 update.
(4) The Date when Full Compliance Will Be Achieved:
Full compliance will be achieved with completion of the modifications to the Records Center and in conjunction with the UFSAR update.
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8.
Helium Circulator Installation Without Appropriate Authorization
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Criterion VIII of Appendix 8 to 10 CFR Part 50 states, in part,
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"Measures shall be established for the identification and control of materials, parts, and components, including partially fabricated assemblies..
These identification and control
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measures shall be designed to prevent the use of incorrect or defective material, parts, and components."
Paragraph 4.8 of APM Procedure Q-8. Issue 7, dated September 30, 1986, permits condt.fonal release of items which have not been accepted by Quality Assurance / Quality Control (QA)/(QC), provided that a conditional release request has been approved Ly the Nuclear Engineering Division (NED)
Site Engineering Manager / Designee and the QA Services Manager / Designee in accordance with Attachments Q-8A and Q-88 of the procedure.
Contrary to the above, S/N C-2101 helium circulator was installed fwith an attached hold tag signifying QA/QC had not performed
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receipt inspection) without submitting a conditional release
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request for the approval of the NED Site Engineering Manager and the QA Services Manager.
This is a Severity Level IV violation.
(Supplement I) (267/8815-03)
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P-88396 Page 4 November 4, 1988 (1) The Reason for the Violation if Admitted:
The violation is admitted.
The procurement system for FSV is established and supported by procedures that utilize the concept of a receiving warehouse, which is physically outside the plant protected area, to process incoming material.
The receiving warehouse not only provides a physical barrier in the control of material released for
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use, but it also facilitates receiving inspection and provides fnr a material hold area prior to material release.
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The receiving warehouse, however, is relatively small in size, and while the vast majority of material procured for FSV can be processed in the receiving warehouse, unusually large items must be transferred to alternate inspection locations to acconinodate adequate s torage while the receiving inspection process is completed. This relocation process is utilized infrequen:1y; therefore, methods for handling these types of materials are not specifically
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described by the procedural system and are handled on a case by case basis.
Given these circumstances, when circulator C-2101 arrived at FSV, a decision was riade to provide for an alternate receiving / storage location within the plant (namely, the turbine deck).
With full knowledge that PSC was extending the boundaries of the receiving warehouse, a QC "Hold Tag" that was intended as a receiving hold tag was placed on the circulator and it was transferred to the turbine deck for
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storage pending completion of receipt inspection activities.
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This activity set the stage for the sequence of events that
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followed.
After the circulator was transferred to the turbine deck, the "Hold tag" which was placed for receiving inspection control under the provision of Procedure Q-8, was inter Conformance Report (NCR)preted by plant personnel as a Non Hold Tag under the provision of Procedure Q-15.
Procedure Q-15 states in part
. Work shall not be
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allowed to begin or continue on the nonconforming part of an
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item until the NCR has been dispositioned and a pp ro ved".
The receiving inspection activities were not signed off
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because an NCR had been generated as a part of the receiving
inspection activities involving some material certification issues for some of the bolting material.
This NCR had been
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dispositioned and was in the final approval cycle when the
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decision was made to install the circulator.
The decision i
to inst 311, however, was made under the provision of Procedure 0-15 in that no work was being performed on the
j nonconforming part of the circulator, since the bolts in l
question, as identified by the NCR,were still accessible, i
and the NCR was in the approval cycle.
The circulator was
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in the installation process when it was identified that the receiving inspection had not been signed off and the "Hold Tag" was a receiving issue as well as an NCR issue.
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P-88396 Page 5 November 4, 1988 (2) The Corrective Steps Which Have Been Taken and the Results Achieved Upon notification that the helium circulator was being installed prior to completion of the receiving inspection process, stop work was implemented.
The NCR resulting from the incomplete inspection was completed and transmitted to the Receiving Inspector.
The Receiving Inspector completed the Receiving inspection Report (RIR) and removed the hold from the Receiving Inspection Tag.
(3)
The Corrective Steps Which Will be Taken to Avoid Further Violations There are few cases where material is too large and /or inappropriate to inspect at the receiving warehouse facility.
PSC considers the lack of adequate material control and the installation of circulator C-2101 without a full receipt inspection to be an isolated case.
Procedures exist for receipt inspections, but these procedures can be clarified to address these types of unusual circumstances.
Procedure Q-7 will be revised to address how PSC can store large items at a segregated, alternate location for receiving inspection.
This clarification will ensure that the circumstances are documented and that a receiving inspection "Hold" is on the material.
Additionally, Procedure P-5 will also be revised to address the identification, authorization and controls needed to establish alternate receipt inspection areas as well as the controls for releasing material from the area.
(4)
The Date When Full Compliance Will be Reached Procedures Q-7 and P-5 will be revised by January 15, 198. _ _ _ _
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t P-88396 Page 6 November 4, 1988 C.
Failure to Control Special Processes Criterion IX of Appendix 8 to 10 CFR Part 50 states, in part,
"Measures shall be established to assure that special processes, including welding, nondestructive testing,... are controlled and accomplished... using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Contrary to the above:
1.
Steam inlet piping stud threads (Part No. FP-91-M-19-4-42)
were fluorescent magnetic particle examined in one direction only, and not in the directions required by paragraph 4.2.7 of Procedure QCIM-24, Issue 4 effective date September 22, 1987.
2.
Repair welding of upper strut to scroll plate welds in the
"B" Helium Circulator, S/N 0-2105, was perfomed prior to qualification of the welding procedure specification.
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This is a Severity Level IV violation (Supplement I) (267/8815-j 06)
(1) The Reason for the Violation if Admitted: (Part 1)
The violation is admitted.
PSC agrees that the fluorescent magnetic particle examiastion of the steam inlet piping stud threads (Part No.
FP-91-M-19-4-42) was not perfomed in strict accordance with Procedure QCIM-24 Issue
"Fluorescent Magnetic Particle Inspection." The procedure
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required two directions of examination, with the lines of magnetic flux for the second examination being perpendicular a
to the flux direction in the first examination.
However, i
the fluorescent magnetic particle examination was conducted on the steam inlet piping stud threads with lines of magnetic flux "approxima tely" in two directions using a
three turn coil as allowed by ASME Code Section V.
(2) The Corrective Steps Which Have Been Taken and the Results Achieved:
(Part 1)
As an additional confirmatory non-destructive evaluation,
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the steam inlet piping stud threads were fluorescent dye i
penetrant examined on August 9,
1988.
This was in i
ccepliance with requirements contained in Attachment 1 of PSC letter P-88019.
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P-88396 Page 7 November 4, 1988
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In addition, a
"Nondestructive Examination Technique Validation" was conducted to verify that the technique utilized during the original examination of the steam inlet piping stud threads was viable.
The results of the validation concluded that the three turn coil technique produces valid test results and provides 100% coverage of test pieces.
(3) Corrective Steps Which Uill be Ta ken to Avoid Further Violations (Part 1):
Magnetic Particle Inspection Procedure QCIM-24 is being revised for clarification to require that at least two examinations shall be performed on each area.
The second examination shall be with 11 ries of magnetic flux approximately perpendicular to the flux direction in the first examination.
(4) Date When Compliance Will be Achieved (Part 1):
Full compliance was achieved October 28, 1988 with the issuance of the revised Procedure QCIM-24.
C.
Failure to Control Special Processes (continued)
(1) The Reason for the Violation if Admitted (Part 2):
The violation as presented is not accepted for the following reasons.
A welding procedure for the strut repair of C 2105 was qualified in accordance with ASME Code Section IX, and PSC Procedure Q-9, utilizing a P-5 base material.
It was detemined prior to start of the repair that the base material of the struts and scroll plate was actually a P-4 base material. At this point in time, a technical review of the procedure for P-5 base material detemined that this procedure would be applicable for welding a P-4 base material for the fo11 cuing reasons:
1.
All essential variables for the P-5 procedure were the same for the P-4 procedure as defined by ASME Code Section IX.
2.
Section IX does allow welding P-5 to P-4 base metals with a P-5 base metal qualification.
Since the essential variables of the two procedures were the same, it was interpreted that a P-5 qualification would
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be appifcable for a P-4 base materia,
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P-88396 Page 8
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Due to the higher alloy content of the P-5 base metal as comp 3 red to the P-4 base metal, the P-5 base metal is considered to be a more difficult material to weld.
Therefore, qualification of a P-S base metal procedure would indicate that a P-4 base metal coupon would pass qualification tests utilizing the same essential Variables.
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A P-4 base metal procedure qualification test in accordance with ASME Code Section IX was to be completed in parallel with the strut repair.
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An additional consideration involved the fact that the weld repair involved non-pressure retaining parts that are not ASME Code components.
In order to contro!
and assure that a procedure qualification test was completed, a Nonconfomance Report (NCR No.88-195) and hold tag were issued to document the technical position taken with regard to the weld procedure.
To disposition these documents, a qualification test was required prior to operation of C-2105.
It is PSC's position that the technical evaluations performed and the documented control provisions required prior to returning the circulator to service represent adeouate control of the welding repair in question.
Based on the PSC/NRC management conference of October 3, 1988, PSC is cognizant of NRC's concern of using the NCR process to enter into a predetermined non confoming
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l condition.
In retrospect, PSC recogritzes that it was l
inappropriate to utilize the NCR process as the vehicle for documenting the weld procedure deviation. As a result, a management Ta sk Team was appointed to evaluate the NCR process.
(2) The Corrective Steps Which Have Been Taken and the Results Achieved (Part 2):
A procedure qualification test utilizing P-4 base metal in accordance with ASME Code Section IX was completed prior to f
l reassembly of C-2105.
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P-88396 Page 9 November 4, 1988 The management Task Team evaluated the NCR process with the results that the existing procedures, when properly implemented, meet the requirements of 10 CFR 50, Appendix B, Criterion 15.
The Task Team also concluded that in this
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case, the NCR process, while providing the necessary elements of control, had been inappropriately applied.
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(3) The Corrective Steps Which Will be Taken to Avoid Further Violations (Part 2):
PSC will develop an alternate,,rocess to evaluate and document predetermined deviations from technical requirements.
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(4) The Date When Full Compliance,,Will be Achieved (Part 2):
1 The new process for evaluating and documenting predetermined technical deviations or potential non-conformances will be finalized and implemented by March, 1989.
The following response to the item contained in the Notice of
Deviation (Inspection 88-15) is hereby submitted:
Based on the results of an NRC inspection conducted on July 11 through August 5,
1988, a deviation from your commitments was identified.
The deviation consisted of failure to comply with
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comitments made to the NRC relative to procurement of helium cir:ulator fasteners.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
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AppendixC(1988),thedeviationislistedbelow:
Paragraph 6.0 of Attachment I to Public Service Company of Colorado (PSC) Letter P-88019 to the NRC comits, in part, with
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respect to current helium circulator fastener procurements to
require:
(1) chemical and mechanical certified mill test i
reports; (2)
furnace charts for all heat treating; and (3)
i fluorescent penetrant inspection of al' completed fasteners per i
ASME Code Section V.
Article 6, wi.h no linear indications in shanks or threads permitted.
In deviation from the ahove:
1.
PSC did not obtain chemical and mechanical certified mill test reports and heat treat furnace charts for Helium Circulator Part No.
C2101-300-95 (original Part No. C2101-300-53) spring plungers; and
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PSC perfonned a fluorescent magnetic particle inspection of only the threads of Helium Circulator Part No.
FP-91-M-19-4-42 steam
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inlet piping studs.
(267/8815-04).
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'P-88396 Page 10 Novemi;er 4, 198c (1) The Reason for the Deviation if Admitted:
The Deviation is admitted with the following mitigating circumstances:
It was concluded and reported in P-88019 that the damage to C-2101 resulted from caustic-induced stress corrosion cracking of certain fasteners in the circulator that had been exposed to turbine-drive steam with significant levels of sodium.
Letter P-88019 was submitted as a result of problems identified with certain fasteners in the steam-end only of the helium circulator and those corrective actions required to prevent recurrence.
Section 6.0, of letter P-88019 (entitled "Quality Assurance Requirements for Helium Circulator Fastener Procurement")
was added in direct response to questions raised by the NRC in letter G-87434, dated December 8, 1987.
The questions in this letter were related specifically to the use of A-286 and Inconel X-750 fastener materials in the repair of Helium circulator C-2101.
However, in Section 6.0 of P-88019, it was not made clear that the QA requirements listed were intended to apply only to the new A-286 and Inconel X-750 fasteners procured for use in the steam-end of the helium circulators.
The spring plunger does not function as a conventional fastener and the preload and service-related stresses on it are negligible.
For these reasons, the spring plunger was not considered as a "fastener" requiring the full complement of QA requirements intended for and applied to all of the other A-286 and Inconel X-750 true fasteners.
GA certifications, supported by Certified Mill Test Reports and a chemical analysis overcheck, were considered satisfactory to establish the quality of the spring plungers.
Letter P-88019 implied that the Inconel X-750 material to be used for the spring plunger would be procured in the same heat treated condition as the rest of the Inconel X-750 threaded fasteners.
At the time of the submittal of P-88019, this indeed was PSC's and GA's intent.
However, the spring plunger supplier later informed GA that they could not supply the material in the special heat treat condition, but rather, it could be supplied in accordance with Material Specification AMS-5667 Upon PSC review, it was concluded that while the Inconel X-750 supplied with a conventional heat treatment per AMS-5667 may not provide the greatest resistance to stress corrosion cracking, it would be a significant improvement over the original spring plunger
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P-88396 Page 11 November 4, 1988
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material (carbon steel).
This reasoning was the basis of justification for authorizing the use of the available, conventionally heat treated Inconol X-750. As further precaution against spring plunger failure, PSC plans to replace the spring plunger, along with certain steam-end fasteners, at Intervals of no greater than 40,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of circulator operation, as indicated in P-88019.
Since Section 6.0 of P-88019 did not make clear that the 0A requirements listed were intended to apply only to the new A-286 and Inconel X-750 fasteners, the implication was that these requirements would also apply to the steam inlet piping studs (FP-91-M-19-4-42).
PSC considers it technically acceptable to perfom a fluorescent magnetic particle inspection in lieu of a fluorescent penetrant inspection.
PSC also considered it technically unnecessary to perfom similar examination on the shanks of the studs since the shanks are not service-loaded.
This was an apparent deviation from the implied commitment identified in letter P-88019.
As indicated at the PSC/NRC management conference on October 3,1988, the root cause of the deviations stems from two primary areas.
First, the report provided two general pieces of infomation in Table 3 wherein overall material changes were identified and secondly in Section 6 wherein quality requirements for new fasteners were identified.
These two general pieces of infomation were not specifically tied together which led to interpretation problems.
The second issue resulted from PSC personnel treating the circulator report and the specific technical
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requirements as a
"perfomance based program" wherein acceptable technical substitutions could be made within the l
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constraints of our 0A program controls without the necessity
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of specific NRC notification.
Imediate Corrective Action Taken l
A memorandum dated August 8,
1988 was issued by the Manager Nuclear Engineering to all engineering personnel advising them of potential technical deviations and PSC's policy for compliance with NRC comitment!.
All steam inlet piping studs were given a fluorescent penetrant inspection in addition to the magnetic particle inspection.
Actions Taken to Prevent Further Recurrence At PSC's Senior Planning Team meeting on October 4, 1988 the elements of these technical deviations, as well as all other matters discussed at the October 3,
1988 PSC/NRC management conference, were discussed in detail with senior managemen _ - __
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P-88396 Page 12 November 4, 1988
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The following response to the item contained in the Notice of Violation (Inspection 88-23) is hereby submitted:
Failure to' Control Special Processes
Criterion IX of Appendix B to 10 CFR Part 50 states, in part.
"Measures shall be established to assure that special processes, including weldin accomplished.. g, nondestructive testing,... are controlled and
. using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Paragraph 2.2 Assurance Manual, Revisionof Quality Procedure No. 9 in General Atomics Quality A,
effective date February 16, 1986, states, in part,
"Special processes shall be performed... in accordance with qualified written specified in the Traveler or other work instructions." procedures, Contrary to the above, repair welding was pe rforr..ed on Helium
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Circulator S/N C-2101, in which the following conditions were j
identified:
1.
The repairs of cracked strut welds were performed using an improperly qualified welding procedure specification (WPS).
2.
The repair of a crack in the scroll was performed using a WPS which did not address all the required essential and nonessential variables.
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This is a Severity Level IV violation.
(Supplement I) (267/8823-01)
(1)
The Reason for the Violation if Admitted (Part 1):
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A violation for failure to document the technical i
justification for deviating from drawings and procedures is admitted.
PSC personnel were sent to General Atomics (GA)
facilities on October 10, 1988, to perfonn a special audit
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I concerning the welding repairs to circulater C-2101.
GA
repaired the cracked scroll (Inconel 718) and cracked strut
welds (1-1/4% Cr 1/2" Mo), as described and dispositioned in GA Nonconformance Report 11857 These two weld repairs
required different weld procedures.
The cracks in the strut i
welds and scroll were ground out and liquid penetrant
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examined to assure the removal of the cracks in accordance with GA Traveler PC 40973.
The scroll was weld repaired and
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liquid penetrant examined in accordance with GA Traveler PC 41064 The strut welds were weld repaired and liquid
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i penetrant examined in accordance with GA Traveler PC 41029.
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General Atomics QA inspector monitored preheat temperatures, interpass temperatures and electrical characteristics during the actual weld repairs of the
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cracks in the strut welds and scroll,
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e Circulator steam ducting assembly drawing 90-C2101-431 (Note
10) requires that the welding procedure and welders be
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i cual t fled to the requirements of ASME Code Section IX.
However, for the specific weld repairs, GA took the position
P-f4396 Page 13
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November 4,1988
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that since t'te scroll and the struts are not part of the primary or secondary closures and thus
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a re not ASME Code components, the welding procedures for the circulator repair need not be qualified in accordance with ASME Code Section IX.
However, GA did not document and justify in writing this deviation from the drawing requirements.
The actual weld repairs were conducted during the time period of January 14 to February 8,
1988, utilizing only PQR's and shop travelers.
The PQR for the struts was revised numerous times during and after completion of
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welding.
These changes resulted in confusion as to what actual variables were uttitzed during the strut welding repairs and welding of the test coupons.
The testing performed on the strut coupon consisted of radiographic examination, micro and macro examination, and microhardness testing.
No tensila or bend testing, as required by ASME Code Section IX, was performed.
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PSC determined the PQR for the scroll weld was not supported by bend tests as required by ASME Code Section IX which
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was a deviation from drawing requirements.
GA did not document and justify this deviation from the drawing requirements.
However, mechanical testing of the scroll weld coupon to determine tensile strength, yield strength and elongation had been performed at room temperature and at 450 degrees F.
GA also performed a technical evaluation of the weld repair area and determined the mechanical properties of the weld repair to be acceptable.
(2) The Corrective Steps Which Have Been Taken and the Results Achieved In letter P-88387, dated October 26, 1988, PSC describes in some detail, the results of a special audit conducted by PSC of GA activities related to this issue.
GA generated WPS's for the strut and scroll weld repairs.
In order to verify what welding variables were utilized for the strut and scroll weld repairs, PSC requested that GA revise the WPS's to reflect the actual essential and nonessential variables utilized for the weld repairs. GA was able to revise the WPS's from the NR's, shop travelers and data obtained from menitoring of preheat temperature, interpass temperature and electrical characteristics 69 ring the weld repairs.
The revised WPS's were reviewed by PSC and found to be in compliance with ASME Code Section IX requirements.
PQR's were also revised to reflect actual essential and nonessential variables utilized in welding the test coupons.
The revised PQR's were reviewed by PSC and found to be in compliance with ASME Code Section I, -.
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P-88396 Page 14 November 4, 1988 GA completed and tested a second coupon for the strut WPS in accordance with ASME Code Section IX requirements.
PSC reviewed the results in accordance with ASME Code Section IX requirements and found the results to be acceptable.
A nonconformance report for the drawing deviation of the scroll weld repair was issued by GA and accepted by PSC.
PSC completed an overall review of the innediate corrective actions and revised documentation, Based on this review, PSC has accepted both the scroll and strut weld repairs for circulator C-2101 as documented in PSC letter P-88387.
(3) The Corrective Steps Which Will be Taken to Avoid Further Deviations PSC reviewed the welding program to determine if these mistakes were programmatic or an isolated incident.
PIC revfewed Traveler 91-M-19-0001-2, Helium Circulator Steam Inlet & Water Piping Disassembly, PC 41436.
From review of this traveler and previous review of travelers during audits conducted January 1986, and 1988, it appears that this situation was an isolated incident.
The auditors reviewed the following welding procedures which are used for circulator repair:
Manual Shielded Metal Arc Welding of Carbon Steel (P1),
WS-206, Issue E, dated 4/1/80; GTAW of Carbon Steel (P1), WS-1, Issue E, dated 2/5/86; Manual GTAW P1 to P8, WS-112, Issue D, dated 3/21/80; Manual Gas Tungsten Arc Welding of Stainless Steel (P8) Pipe and Tube; WS-131, dated 2/12/86, Issue L; and Manual Gas Tungsten Arc Welding of Stainless Pipe and Tube (P8) WS-130, dated 8/31/81, Issue M.
The auditors also reviewed the General Atomics
"Welder Qualification Status Report, ASME Code Cer*ffied", dated September 13, 1988 Based on this review, PSC reached the conclusion that GA has adequate controls for their welding program.
As further action, however, to prevent recurrence:
1.
GA personnel involved with the violation have been re-instructed as to the need to develop qualified weld procedures for specialty repair welds.
2.
A restriction will be added to the PSC Approved Vendor List (AVL) to require GA to have PSC review and approve all welding procedures before GA performs repair welding.
This AVL revision will be completed November 14, 1988
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P-88396~
Page 15 November 4, 1988 i
(4) The Date When Full Compliance Will be Achieved
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l Full compliance will be achieved with issuance of the AVL.
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The following response to the item contained in the Notice of j
Deviation (Inspection 88-23) is hereby submitted:
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Based on the results of an NRC inspection condt :ted on September 12-
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16, 1988, a deviation from your comitments n is identified.
The
deviation consisted of failure to comply with comitments made to the NRC relative to procurement of helium circulator fasteners.
In
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accordance with the
"General Statement of Policy and Procedure for
NRC Enforcer.ent Actions," 10 CFR Part 2 Appendix C (1988),
the
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deviation is listed below:
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Paragraph 6.0 of Attachment I to Pubite Service Company of
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Colorado (PSC) Letter P-88019 to the NRC consnits, in part, with
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respect to current helium circulator fastener procurements to
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require fluorescent penetrant inspection of all completed fat teners per ASME Code Section V, Article 6, with no linear indications in shanks or threads permitted.
In deviation from the above, there was no documented evidence to show that fluorescent penetrant inspection had been performed on
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Helium Circulator Part No. C2101-300-95 (original Part No. C2101-j 300-53) spring plungers.
(267/8823-02)
As discussed in the response to Deviation 8815-04 above, PSC did not
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i and does not consider the spring plungers to be fasteners.
As also discussed above, the requirements inposed upon fasteners in letter P-
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88019 did not exp1tcitly exempt the spring plungers.
In letter P-
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88366, dated October 21, 1988, PSC comitted to provide the NRC better definition and clarification of quality assurance requirements a
relative to the procurement of circulator related fasteners. This letter, to be sent in January,1989, should resolve this issue to the NRC's satisfaction, i
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7.*P88396
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-16-N0Y'*D'# 4' l988
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"Should you have any further questions, please contact Mr. M. H.
Holmes at (303) 480 6960.
Sincerely, 1 e u.tfu. /af p;,4 R. O. Williams, Jr.
Senior Vice President,
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Nuclear Operations
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g R0W:0CG/em Attachment cc:
Regional AdministratL.', Region IV ATTN: Mr. 7. F. Westerman, Chief Projects Section B Mr. Robert Farrell Senier Resident Inspector Fort St. Vrain l
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