IR 05000267/1988023
| ML20155F471 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/03/1988 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20155F449 | List: |
| References | |
| 50-268-88-23, NUDOCS 8810130275 | |
| Download: ML20155F471 (9) | |
Text
4 APPENDIX C U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-267/88-23 Operating License:
DPR-34 Docket: 50-267 Licensee:
Public Service Company of Colorado (PSC)
2420 W. 26th Avenue, Suite 15e
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Denver, Colorado 80211 Facility Name:
Fort St. Vrain Nuclear Generating Station (FSV)
Inspection At: General Atomics International Services Corporation (GA),
San Diego, California Inspection Conducted:
September 12-16, 1988 Inspector:
/o C
L. E. Ellershaw, Reactor Inspector, Materials Da$ie /
and Quality Programs Section, Division of Reactor Safety Accompanying Personnel:
F. B. Litton, Materials Engineer, NRR NW
/o/3/M Approved:
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I. Barnes, Chief, Materials and Quality Date Programs Section, Division of Reactor Safety inspection Summary la.pection Conducted September __12-16, 1988 (Report 50-767/88-23)
Areas Inspected:
Reactive, announced inspection of activities related to refurbishment of reactor Helium Circulator S/N C-2101 resulting from prev 4us inspection findings identified at FSV.
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Results: Within the area inspected, one violation (failure to appropriately i
control special processes, paragraph 2.b) and one deviation (failure to perform i
cocinitted fluorescent penetrant inspection on completed fasteners, i
paragraph 2.a) were identified.
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DETAILS l
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Persons Contacted i
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- D Alberstein, Manager FSV Services
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l E. V. Bak, Staff Manufacturing Engineer
- G. P. Connors, Manager, Reactor Quality Assurance (QA)
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- F. C. Dahms, Manager Engineering Resources
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- J. Lindgren, Research Staff Engineer l
- R. F. Maxwell, Manager. QA l
H. K. Nichols Circulator Project Manager t
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PSC l
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- P. L. Craun, Site Manager, Nuclear Engineering Division (NED)
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iM. Deniston, Superintendent. Operations e
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- J. M. Gramling, Supervisor, Nuclear Licensing - Operations l
l aM. H. Holmes Nuclear Licensing Manager
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- F. J. Novachek, Nuclear Support Manager l
- G. L. Redmond, Circulator Program Manager
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- A. Wong, Licensing Supervisor l
- D. Warembourg, Manager, NED
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- Denotes those persons attending the exit interview on September 16, 1988.
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- Denotes those persons participating in the exit interview by means of a
telephone conference call on September 16, 1988.
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2.
Previous Inspection Findings (92701)
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(Closed) Open Item (267/8815-05): This item pertained to PSC I
requiring only a certificate of confonnance from GA in regard to many l
of the detailed QA requirements for fastener procurement comitted to
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by paragraph 6.0 of Attachment 1 to PSC Letter P-88019 to the NRC
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dated January 22, 1988.
This resulted in the NRC inspector being l
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unable to specifically verify implementation of these commitrents
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l during an NRC inspection of the fastener procurement process
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conducted at FSV and documented in NRC Inspection l
Report 50-267/88-15.
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The NRC inspector reviewed PSC's Purchase Order (Pe) N8157 dated
August 13, 1987, through Supplement 2 to GA Technologies Inc.
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(currently known as General Atomics International Services i
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Corooration) for the labor and materials to repair "D" Helium l
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Circulator S/N C-2101.
This review was perfomed to assure that the
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0A requirements comitted to in the above letter (P-88019) had been delineated in this P0.
It was confirmed that these comitments were l
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addressed in the P0, with most being incorporated by Supplement 1 dated April 11, 1988.
To verify that GA had, in turn, passed on the applicable requirements to their suppliers, the NRC inspector reviewed the following P0s for the specified items:
(1) PO 094552 to SPS Technologies dated November 5, 1987, for 94 each, 3/4-inch X 1.925 long bolts, of A-286, P/N 90 C2101-300-45 which was subsequently changed to P/N 90-C2101-300-105. After receipt, GA modified some of the bolts by drilling a 1/8-inch hole through the bolt making them P/N 90-C2101-300-52 which was subsequently changed to P/N 90-C2101-300-104.
It was noted that GA's P0 imposed the following requirements whir.h were consistent vith PSC's PO: Appendix B to 10 CFR Par; 50,10 CFR Part 21, ultrasonic examination (UT) in accordance with Article 5 in Section V of the ASME Code, fluorescentpenetrantexamination(PT)inaccordancewith
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Article 6 in Section V of the ASME Code, GA's QA personnel to witness UT and PT, and all fasteners to be from the same heat.
The bolts were receipt inspected by GA which included a 100 percent visual examination (VT), a sampled dimensional inspection, and a sampled hardness verification.
In addition, GA tested two bolts for mechanical properties and for chemical analysis.
The NRC inspector reviewed this data and the certified material test reports (CMTRs) from Carpenter Technology Corporation, the material manufacturer.
The PT
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report from SPS Technologies and the Certificate of Processing
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from General Inspection 1.aboratories, Inc., who performed the UT, were also reviewed.
The PT and UT procedures which were identified as having been used were on file at GA and had been l
reviewed and approved as meeting the applicable Articles of Section V of the ASME Code.
SPS Technologies was approved in
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accordance with GA's QA Manual, Second Edition, Quality Procedure No. 4. Revision A. Amendment I dated October 6, 1987.
(2) PO 094569 dated December 2, 1987, to A1G Engineering.
The NRC inspector reviewed the following three items:
(a) One hundred and four each 1/4-20 UNC-2A X 5/8-inch long hex head bolts of Inconel X-7',0, GA P/N 90-C2101-300-46 which was subsequently changet to p/N 90-C2101-300-100 A/C.
(b) Thirty-eight each 1/4-20 UNC-2A X 1)-inch long socket head cap screws of Inconel X-750, GA P/N 90-C2101-300-44 which was subsequently changed to P/N 90-C2101-300-99 A/ ;
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-4-(c) One hundred and sixteen each 1/4-28 UNF X 3/4-inch long socket head cap screws of Inconel X-750, GA P/N 90-C2101-460-10 which was subsequently changed to P/N 90-C2101-460-13/H.
The GA P0 imposed the following requirements: Appendix B to 10 CFR Part 50, 10 CFR Part 21, material to be ASTM B-637 except stress rupture testing is waived, perform the specified modified heat treatment for Inconel X-750 and provide the furnace charts, PT per Article 6 in Section V of the ASME Code, thoroughly clean in alcohol, and the material must be of denestic manufacture.
The above items were receipt inspected by GA on February 17, 1988, with each item being documented on a separate Receiving Inspection Plan (RIP).
The receiving inspection consisted of 100 percent VT, and a sampled dimensional check and hardness check. GA also performed a chemistry analysis and mechanical property tests on two samples from each item. The NRC inspector reviewed this data, the CMTRs from Carpenter Technology Corporation (the material manufacturer) and A&G Engineering, the furnace charts and heat treat certifications from Precision Heat Treating Company, and the PT reports from Hadd Company Inspection Laboratory.
The documentation attested to all of the applicable requirements above.
The supplier was approved in accordance with the GA QA Manual noted above.
(3) PO 059475 dated September 4, 1986, to A&G Engineering for 12 each bearing bolts, 3/4-10 UNC 2A X 10 3/4, 410 stainless steel material, GA P/N 90-C2101-546.
The quality requirements were invoked on the PO by use of numbers which pertained to specific standard quality clauses that are identified in GA's Document No 0014-1. A comparison of the numbers noted in the P0 with the clauses in the document revealed that all of the applicable requirements were identified.
GA performed a receipt inspection that was documented on RIP 059475-1 dated April 7,1987, which showed that YT and dimensional inspection was performed along with a review of the received documentation.
The NRC inspector reviewed the documentation which included A&G Engineering's CMTR and PT report, and furnace charts and heat treat certification from Precision Heat Treating Company. The CMTR acknowledged that 10 CFR Part 21 was applicable and provided the material identity, che-.ical analysis, mechanical properties, and hardness values.
In addition, the heat treatment times and temperatures were stated as "Hardening at 1800'F 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, oil quenched per MIL-6875 except terper at 1150'F 25' for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Air Cool." The NRC inspector questioned GA as to why the heat treatment was noted as apparently being
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i-5-different from what was required by MIL-6875.
It was explained that technical requirements are noted on the applicable part
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drawings.
GA provided the NRC inspector with a copy of the drawing for this part and it was identified that Note 3
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specified the tempering temperature noted above.
It was also noted that the CMTR. attested to the parts having been
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manufactured under ASME Quality System Certificate No. 455.
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A&G Engineering was approved in accordance with the GA QA manual.
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(4) PO 094568 dated January 29, 1988, to Production Tools, Inc. for
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36 each spring plungers, :nconel X-750, GA P/N 90-C2101-316-2.
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The P0 stated that the body plungers and plugs were to be AMS 5667 material and the springs to be AMS 5698 or 5699
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material. The use of domestic material was required and 10 CFR Part 21 was imposed.
The applicable standard quality clauses
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i were invoked along with Appendix B to 10 CFR Part 50, and the parts were designated QA Level 1 (safety-related).
The
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PO referenced a Ylier Engineering part number for the spring plungers which indicated that Production Tools, Inc. was to
place the order with Vlier Engineering.
l GA perfomed a receipt inspection of the parts which was l
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documented on RIP 094568-.1 dated April 22, 1988.
This included l
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a documentation review and a VT and dimensional inspection.
GA also performed a chemistry analysis on one body, one plunger,
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one spring, and one set screw.
They also performed a spring
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rate test on one spring plunger.
It should be noted that GA i
identified the copper content of the plunger as being above the i
maximum allowed.
The analysis identified the copper content i
l as being 0.57 percent while AMS 5667 and 2269 allow a maximum of i
0.53 percent.
It was also identified that the silicon content l
of the spring was 0.61 percent whereas AMS 5698 and 2269 allow a maximum of 0.5 percent.
Both conditions were written on
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l Nonconformance Report (NR) 12058 which was dispositioned j
"use-as-is."
The NRC inspector reviewed the documentation provided by the vendors.
A certificate of confomanet from Vlier Engineering dated April 8, 1964, attested to the fact that the 36 parts were
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dimensions, plunger forces, and materials. A CMTR dated September 30, 1987. ' rom Howmet Turbine Components Corporation
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provided the materict identity, chemical analysis, mechanical
test results, and the raterial hardness in the solution annealed
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i and precipitation heat treated ccnditions.
Furnace charts were
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not available, thus the actual times and temperatures could not
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be established. AMS 5667, however, shows the equalization (solution annealing) heat treatment to consist of being heated i
j to 1625'F 225*, holding at heat for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 0.5, and cooling
in air.
The precipitation heat treatment is shown as being i
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heated to 1300*F 25', holding at heat for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> tl, and i
i cooling in air to room temperature.
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j A certification of compliance dated March 11, 1988, from Titan j
Spring Company shows Inconel 750/AMS 5699 and a heat treatment of 900'F for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Another document titled "Certification of l
Shipment" shows the material specification AM3 5699 and
Inconel X-750, chemical analysis, wire wrap test, and as shipped
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tensile properties. This document was superimposed over a
shipping invoice dated July 16, 1986, which shows that the t
i material was sold to Titan Spring Company.
The sellers name was I
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The NRC inspector questioned GA regarding the 900'F heat
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j treatment, in that it did not relate to any of the various types (
of heat treatments addressed in AMS 5699.
GA could not provide
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a response without first contacting Titan Spring Company.
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Subsequent to the inspection, the NRC inspector telephoned GA to (
find cut what infonnation had been obtained regarding the heat j
trea tment. GA responded by statin that Titan Sprin Company had sent GA a corrected Certificat on of Compliance n which the 900'F was no longer shown as being the heat treatment I
temperature.
Instead, new data was entered showing a
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precipitation heat treatment of 1200'F for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
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In any event, the heat treatment information provided with j
respect to the components of the spring plungers does not meet l
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l the requirements specified in Section 5.2 of Attachment 1 to
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P-88019.
Section 5.2 requires that fasteners made from
I Inconel X-750 be solution annealed at 2025'F 225'F, held for 1 i
i to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and cooled within 5 minutes to 800*F or less and then
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be followed by a precipitation hardening at 1300*F 225'F for
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j 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> +2, -0 hours, and air cooled, j
This information has been presented in view of the fact that a deviation had been identified (267/8815 04) during the NRC
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inspection at FSV in which it was established ti.at PSC had
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failed to comply with the comitments made in Attachment 1 to l
P-88019 relative to PSC failing to obtain chemical and
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mechanical CMTRs and heat treat furnace charts fer the spring l
plungers, j
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It was further noted, during the inspection at GA, that another i
comitment in Attachment 1 to P-88019 had not been complied with:
1.e., there was no documentation attesting to the performance of the required fluorescent penetrant inspection of the completed fasteners (spring plungers).
This failure to comply with the commitments is an apparent deviation.
(267/8823-02)
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(Closed) Unresolved item (267/8815-07):
This item pertained to the
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information provided to the NRC inspector during the FSV inspection
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in which he was informed that GA had not prepared a welding procedure
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l specification (WPS) for the repair welding of the upper strut to
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scroll plate welds in the S/N 0-2101 helium circulator, j
l The NRC inspector reviewed the applicable drawings, shop travelers, i
and NRs associated with the repair welding of the struts and scroll of Helium Circulator S/N 0-2101.
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Note 10 in Drawing 90-C2101-431 Weldment. Steam Ducting, states that i
i all welding procedures and welders shall be qualified to the l
requirements of Section IX of the ASME Boiler and Pressure Vessel
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Section IX of the ASME Code describes the requirements for and the
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i relationship between a procedure qualification record (PQR) and a l
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WPS. The PQR is a record of variables recorded during the welding of i
j a test coupon, and as a minimum, all essential variables for each l
j welding process used shall be documented.
PQRs may be revised by
having additional infonsation recorded at a later date provided the
information can be substantiated as having been part of the original
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qualification condition by laboratory record or similar data.
The l
l WPS must reference the supporting PQR, The WPS may be in any fonnat i
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i process is included or referenced.
Changes to nonessential variables i
may be made provided such changes are documented by either an f
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amendment to the WPS or by use of a new WPS. Changes to essential i
variables require requalification of the WPS by either a new PQR or l
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an additional PQR.
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The NRC inspector reviewed NR 11857 dated October 8, 1987. This NR i
addressed two nonconforming conditions:
(1) a crack in the scroll
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j of the hole, and on the other side, extending 0.350 inches to t,he
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radius and continuing u) the wall for a distance of 1.400 inches, and
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a ).250 inches crack li(e indication on one side of bolt hole No.10; l
and (2) cracks in the welds in the same general area of all
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16 struts.
The disposition stated to repair by grinding out the defects and then i
weld repair the areas.
The NR identified a shop traveler which was i
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to be used for each condition. Conditions (1)and(2)weretobe i
repaired by following the operations delineated in shop traveler l
PCs 41064 and 41029, respectively. A review of both shop travelers i
revealed that each one referenced a WPS to be used.
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1 Shop traveler PC 41064 for the scroll repairs, operation 20 states, j
"Clean, preheat & weld repair scroll area per WPS-C2101-431-801."
i This operation was signed off by both production and Quality Control i
j on February 1,1988. The NRC inspector reviewed WPS C2101-431-801
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-8-l which was dated November 2, 1987.
The WPS addressed the manual aas tungsten are welding process (GTAW).
There was no reference to a j
PQR. However, PQR C-2101-431-801 dated November 2, 1987, was l
provided to the NRC inspector as being the qualification for the WPS.
All of the applicable essential variables were addressed in the PQR.
Review of the WPS revealed, however, that one essential variable and
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seven nonessential variables were not addressed.
l Shop traveler PC 41029 for the strut repairs, operation 20 states,
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"Clean, preheat a weld repair struts per WPS-C2101-431-802." This
operation was signed off by production and QC on February 4 and 9,
1988, respectively.
There was no evidence of a WPS by that number,
however, the shop traveler which was used to perform the sample strut
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weld repair for qualification purposes was numbered C-2101-431-802.
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Operation 10 cf this traveler states, "Weld per welding procedure j
specification W-27 and WPS-C2101-431." This operation was completed on January 12, 1988.
There was some apparent confusion in that there was no evidence of the existence of WPS C-2101-431. WPS W-27 dated July 20, 1978, was established for manual GTAW, and was qualified by
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PQR W-27 on July 20, 1978.
The WPS was requalified by i
PQR C-2101-431-802 dated March 19, 1980, in which several essential
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and nonessential variables were changed on the PQR, but not on the
WPS.
PQR C-2101-431-802 was subsequently revised on August 4, 1988.
However, conflicts still existed between the essential and
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nonessential variables listed in the WPS and PQR.
The NRC inspector
was informed that the variables noted in the PQR dated August 4 I
J 1988, were actually those used in the repair welding.
If this were
the case, a new WPS should have been initiated to address the
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cha r.ges.
In any event, this failure to properly qualify and/or j
q document the qualification of the WPS is an apparent violation of L
j Criterion IX of Appendix B to 10 CFR Part 50 and GA's approved QA
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j progam.
(267/8823-01)
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i It should be noted that, prior to the exit interview. GA presented
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the NRC inspector with two new WPSs with attached PQRs for the weld
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repairs made to the scroll and struts.
The NRC inspector did not
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i review these documents for adequacy.
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Other Observations,Noted in Inspection Report 50-267/88-15 i
During the NRC inspection at PSC, it was noted with respect to the comitments in Attachment 1 to P-88019, that PSC's applicable procedure did not address:
(1) comitted chamfering of the edge of
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the C-2101-431 counter bolts (paragraph 5.5 of Attachment 1 to
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P-88019), and (2) comitted cleaning of bolt holes to remove previous
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thread lubricants (paragraph 5.6 of Attachment 1 to P-88019),
j During the inspection at GA, the NRC inspector requested the applicable procedure (s) which addressed thesu items.
GA infonned the
j NRC inspector that these actions were not proceduralized; however, j
they were included in the appropriate operations of the shop J
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travelers r'
with circulator C-2101.
The NRC inspector rt: viewed 1 velers to verify that these commitments wate included.
ler PC C-2101-300 was initiated on December 10,
1987. Oper-ddresses the machining, reaming, back
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s spotfacing
ag all (15) 13/16-inch diameter holes to 0.070 10.010 X d'-
. move all burrs.
This operation is for the C-2101-431 cco..cer bores and was signed off complete on March 1, 1988. Regarding the removal / cleaning of old lubricants, the other nine travelers all referenced this type of cleaning operation with quite specific instructions.
The NRC inspector verified, by this review, that the specified commitments had been performed.
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Exit interview t
An exit interview was conducted on September 16, 1988, with the GA and licensee personnel denoted in paragraph 1. 'During this interview, the NRC inspector reviewed the scope and findings of the inspection.
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