IR 05000298/1990011

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Insp Rept 50-298/90-11 on 900319-0406.Violation Noted Re Failure of Contractor to Certify Personnel Performing Ultrasonic Thickness Measurements.Major Areas Inspected: Special Process & Action on Previous Insp Findings
ML20034B194
Person / Time
Site: Cooper 
Issue date: 04/16/1990
From: Barnes I, Gilbert L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20034B190 List:
References
50-298-90-11, NUDOCS 9004260154
Download: ML20034B194 (8)


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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV-NRC Inspection Report:

50-298/90-11 Operating License: DPR-46'

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Docket: 50-298 Licenseef NebraskaPublic.PowerDistrict(NPPD)-

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P.O. Box 499-Columbus, NE 68602-0499

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Facility Name: CooperNuclearStation-(CNS).

Inspection At: 'CNS, Brownville, Nebraska and NRC' Regional Officel Inspection Conducted: March 19 through April 6,_1990, which included in-office-review of procedures during March 26-29, 1990 Inspector:

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[ L. D. Gilbert, Reactor Inspector, Materials Date and Quality Programs Section, Division of Reactor Safety Approved:

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w -16 - t o I. Barnes, Chief, Materials and Quality

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Date Programs Section, Division of Reactor Sa'fety Inspection Summary Inspection Conducted March 19 through April 6, 1990 (Report 50-298/90-11)

Areas Inspected: Routine, unannounced inspection of control of special processes and licensee action on previously' identified inspection findings.'

Results: The Station Operations Manual and approved contractor programs were

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founc'i.o be both consistent with Code requirements and to provide comprehensive-instructions for the performance of nondestructive examination special processes.

Program imp (lementation was generally effective, with.one non-cited violation identified paragraph 3) regarding the failure of a contractor to certify.

personnel performing ultrasonic thickness measurements of safety-related; piping. Review of previous inspection findings pertaining to control of welding-identified that the licensee has significantly enhanced its welding program l

controls and is effectively implementing program requirements.

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-2-DETAILS 1.

PERSONS CONTACTED

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NPPD

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  • G. R. Horn, Division Manager of Nuclear-Operations
  • G.. E.' Smith, Quality Assurance Manager
  • G. R. Smith, Licensing Supervisor
  • R. Brungardt, Operations Manager l
  • H. H. Jantzen, Instrumentation &' Control Supervisor-l'
  • J. L. Smith, Welding Program. Supervisor
  • M. Unruh,-Maintenance Supervisor.
  • R. Krause, Maintenance Engineer
  • L. Bray, Regulatory Compliance Specialist
  • J.. Flaherty, Engi neering Macger
  • J. Meacham Senio Managet :.f Operations i

B. Crow, Lead Mechanical Engireer R. Foust, Engineering Programs"Jupervisor R. L. Sherman, Nuclear Instructot Mechanical G. G. Stuchal, Resident Construction Manager q

PCI Energy Services (PCI)

T. D.-Grubbs, Manager Quality Assurance B. Tacito, Project Manager j

HQS Inspection, Inc. (MQS)

C. Brown, Site Supervisor / Level III Anchor / Darling Valve Company T. Staterfield, Field Welding Engineer

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NRC

  • W. R. Binnett, Senior Resident Inspector l
  • G. A. P ck, Resident Inspector
  • C. Paulk, Reactor. Inspector i

The inspector also interviewed other' licensee employees during the inspection._

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  • Denotes atttndance at exit interview conducted on April 6,1990.

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PREVIOUSLY IDENTIFIED INSPECTION FINDINGS j

2.1 Followup of Unresolved Items (92701)

2.1.1 (Closed)UnresolvedItem(298/8920-01): Licensee to clarify welding of'

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ASTM A500 materials in ASME Section IX qualified welding procedure specif! cations

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i in upgraded welding program. The inspector verified that the upgraded welding program provides specific instructions in Maintenance Procedure 7.7.3.1. concerning

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materials which are referenced in welding procedure specifications that may be p

welded and any exceptions require engineering evaluation. 'Also, the ASME '

Section IX Code now includes ASTM A500 materials. This item is considered

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I resolved.

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2.1.2 (Closed)UnresolvedItem(298/8630-05):. Licensee to complete ongoing document search and receipt of aolitional analysis of dissimilar metal-

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l weldments. The licensee completed the document search as documented in the

letter to NRC dated January 8,1987. -The licensee's analysis and Justification L

for Continued Operation was reviewed / accepted by NRR in the Safety Evaluation i

dated March 6,1987. - The licensee has also upgraded its welding program which includes provisions to ensure adequate weld documentation. This item is~

considered resolved.

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2.2 Followup of Violations (92702)

2.2.1 (Ciced) Violation (298/8915-01):

Failure to control welding activities. The licensee, with the assistance of welding engineering consultants from Bechtel Engineering Corporation, has completed the upgrading of its welding program. The welding program documents reviewed by the inspector are identified-in Attachment 1.

The upgraded welding program included the creation and staffing-of the position-of Welding Program Supervisor. The Welding Program Supervisor performs'an independent review of all procedures.and instructions for special processes, such as welding and

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nondestructive examination. The Welding Program Supervisor and three welding

specialists monitor the welding performed to CNS welding procedures. -This monitoring is separate from the QA surveillance activities and includes F

checking for adherence to procedures and assisting welders to resolve welding problems. The upgraded welding program reviewed by the inspector was found to have corrected the previously identified procedural deficiencies for:

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control of heat input for welding materials requiring. impact (notch toughness)

properties, (b) qualification of welding procedure specifications requiring postweld heat treatment, and (c) welding electrode holding oven temperatures.

Also, the incorrect radiographic examination technique used by a radiographer on two welder performance qualification specimens was documented on Nonconformance Report 89-103. The nonconformance report satisfactorily.

addressed the corrective action taken by the licensee and the contractor with respect to the nature and extent of the problem,. identification of production velding performed by the two welders, and actions taken to ensure that only qualified welders were used for making safety-related welds. Since the licensee has completed the upgrading of its' welding program and is adequately controlling the welding activities, this item is closed.

2.2.2 (Closed) Violation (298/8917-02):

Failure to control welding activities. The inspector monitored various welding activities performed by station personnel and contractor personnel and found that:

(a) welders had a copy of the welding procedure, (b) welders were knowledgeable of the procedural requirements,(c)amperageandvoltagemeterswereinstalledonthelicensee's

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welding machines, (d) welders were provided assistance in establishing actual

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-4-welding parameters, and (e) welders'were making a conscientious effort to a

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comply with the'procedurai requirements. The inspector also noted that_ the Weld Checklist, which specifies the engineering requirements for each production weld and documents the welding and inspection performed on each weld, was well thought out and was designed both to-be user friendly and to

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niake the craft responsible for the quality of their vork by~impcsing welder

.verif' cation hold points in addition to Quality Control inspection hold points.

The inspector discussed the surveillance of welding activities with the Quality Assurance Manager. The surveillance of welding activities is being scheduled on a weekly basis to ensure that all' activities, including the various -

contractors, are being included'in the QA surveillances for welding activities performed during the' outage..The inspector reviewed the documented QA surveillance activities and the Welding Surveillance Results for surveillances performed during the period of March 8 through April 2, 1990. Of the 24 QA

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surveillances performed on the various plant and. contractor welding activities, only one welding problem was. identified which involved a contractor making a repair.to a weld without an approved traveller for the repair weld. The

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problem was documented in a nonconformance report, corrective action taken, and the NCR closed by QA. Since, in addition to the inspector's observations, the QA surveillances included satisfactory results.for procedural compliance ~with respect to welding parameters, welding filler material control, and verification that welders are familiar with the variables of the procedures to i

which they are qualified, this item is closed.

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3.

CONTROL OF SPECIAL PROCESSES

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The purpose of this inspection was to verify that the licensee had established measures to assure that visual, liquid penetrant, magnetic particle, ultrasonic, and radiographic examinations are controlled and are accomplished by qualified personnel, using qualified procedures, in accordance with applicable codes,

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standards, specifications, criteria, and other special requirements.

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3.1 Visual Examination (57050).

l The inspector reviewed the visual examination procedures listed in Attachment 2 l

and found them to be consistent with the requirements of ANSI B31.7-69. The

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inspector verified that a PCI certified Level II QC inspector had accepted the-r final visual examination for 6 welds in the reactor water cleanup (RWCU) piping

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I system and that the completed welds met the acceptance criteria of the visual

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1 examination procedure. No violations or deviations were identified during this..

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portion of the inspection.

3.2 Liquid Penetrant Examination (57060)

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The inspector reviewed the liquid penetrant examination procedures listed in

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l Attachment 2 and found them to be consistent with the requirements of ANSI B31.7-69. The inspector observed the liquid penetrant examination _by MQS of a weld in the ventilation system and the liquid penetrant inspection by PCI of five welds in the RWCU piping system. The inspector verified that the

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examinations were performed in accordance with the liquid penetrant' procedure

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-5-l by a certified Level'II QC inspector and the penetrant materials were certified as acceptable for use on stainless steel materials.

No violations or

deviations were identified during this portion of the inspection.

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3.3 Magnetic Particle Examination (57070)

The inspector reviewed the magnetic particle e~ amination procedures listed in x

Attachment 2 aad found them to be consistent with the requirements of ANSI B31.7-69. The inspector was informed that the magnetic particle examination procedures were not Deing used at this time. No violations or deviations'were l

identified during this portion of the inspection.

3.4 Ultrasonic Examination (57080)

The inspector reviewed on April 4, 1990, the digital ultrasonic thickness measurement procedure, Procedure GQP 9.9, which PCI was using to identify minimum pipe wall thickness violations in the RWCU system replacement piping.

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The inspector determined that, although-the: personnel performing these thickness measurements had been trained on the operation of the digital-

ultrasonic thickness measurement equipment by PCI's Quality Assurance Manager on March 16, 1990, a qualification record had not been completed for two QC; inspectors performing thickness measurements. A nonconformance report,

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NCR 6401-90-025, was issued by PCI for failure to complete a qualification record as a prerequisite for personnel performing thickness measurements. This is an apparent violation for failure to document the qualification of

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inspection personnel; however, the violation is not being cited because it q

meets the criteria in Section V.A. of the Enforcement Policy.

l 3.5 Radiographic Examination Program (57090)

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The inspector reviewed the radiographic examination procedures listed in Attachment 2 for PCI and MQS and found them to be consistent with the requirements of ANSI B31.7-69. The inspector observed the radiographic examination by MQS

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of three RWCU system piping welds using PCI Procedure PI-6401-18 and two

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residual heat removal system piping welds for plant maintenance using MQS

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Procedure 20.F.071. The radiographic examinations performed by MQS were i

consistent with the requirements of each procedure. The radiographers and film interpreters were verified as qualified and certified as a Level II-or Level III in radiography in accordance with the requirements of each program.

j The inspector also reviewed the radiographs for the three welds in the RWCU i

system and a welder qualification pipe test.

No violations or deviations were identified during this portion of the inspection.

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4.

EXIT INTERVIEW An exit interview was conducted on April 6, 1990, with those personnel denoted in paragraph 1 in which the inspection findings were summarized. No information was presented to the inspector that was identified by the licensee as proprietar,

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ATTACHMENT 1 WELDING PROGRAM DOCUMENTS COOPER NUCLEAR STATION OPERATIONS MANUAL CNS Procedure 0.30, "ASME Section XI Repair / Replacement Procedure," Revision 3 Maintenance Procedure 7.7.1.1, " Welding Matrix," Revision 0

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Maintenance Procedure 7.7.2.1, "Weider Performance Qualification - ASME Section.

IX CNS-WQ1," Revision 0 Maintenance Procedure 7.7.2.2, " Welder Performance Qualification - AWS D1.1 and AWS D1.4 CNS-WQ-2," Revision 0 Maintenance Procedure 7.7.3.1, "CNS-GWS1 General Welding Standard for ASME'

Section IX," Revision 0 Maintenance Procedure 7.7.3.2, " General Welding Standard for Structural Steel

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CNS-GWS - AWS D1.1," Revision 1

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Maintenance Procedure 7.7.5.1, " Welding Material Care, Storage, and Control

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Procedure CNS-WFMC," Revision 1 Maintenance Procedure 7.7.10.1, "P1-A Welding Procedure Specification,"

Revision 0; and Procedure Qualification Report P1-A dated August 20, 1973 Maintenance Procedure 7.7.10.2, "PI-B Welding Procedure Specification "

Revision 0; and Procedure Qualification Report P1-B dated January 26, 1988-

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Maintenance Procedure 7.7.10.3, "P1-B (CVN) Welding Procedure Specification,"

Revision 0; and Proc?Aure Qualification Report P1-B dated January 26, 1988 Maintenance Procedure 7.7.10.4, "P1-G Welding Procedure Specification,"

Revision 1; and Procedure Qualification Reports P1-G dated January 26, 1988, PI-STRUCT dated February 3,1988, and P1-GIA dated January 9,1990 Maintenance Procedure 7.7.10.9, "P1-G (PWHT) Welding Procedure Specification,"

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Revision 0; end Procedure Qualification Report P1-G-1B with PWHT dated January 12, 1990

Maintenance Procedure 7.7.10.83, "P1-P8A Welding Procedure Specification,"

Revision 0; and Procedure Qualification Reports 111 dated September 8,1974, and 202 dated April 22, 1980 Maintenance Procedure 7.7.10.85, "P8-B Welding Procedure Specification,"

Revision 0; and Procedure Qualification Report 113 dated May 2, 1977 Maintenance Procedure 7.7.11.1, "AWS D1.1 Welding Procedure Specification,"

t Revision 0, Prequalified I

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-2-PCI ENERGY SERVICES (PCI)-

Welding Control Procedure WCP_-2, " Welder / Welding Operator Performance Qualification,"_ Revision 0 Welding Control Procedure WCP-3, " Weld Material Control," Revision 0 Welding Control Procedure WCP-5, " Weld and Base Materini Repair," Revision 0~

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Welding Control Procedure WCP-6, " Joint Design," Revision 0 Welding Procedure. Specification WPS-1, Revision 2; and Supporting Procedure-

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Qualification Records 58,-59, 71, and 92

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Welding Procedure Specification WPS-8, Revision _0; and Supporting' Procedure Qualification Records 44 and 63

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Welding Procedure Specification-WPS-18, Revision 0; and Supporting Procedure Qualification Record 105 ANCHOR / DARLING VALVE COMPANY Welding Procedure Specification WPS-W224 dated February 13, 1990; and-Supporting-Procedure Qualification Record WQ224 dated February 15, 1990 i

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ATTACHMENT 2 NONDESTRUCTIVE EXAMINATION PROCEDURES COOPER NUCLEAR STATION OPERATIONS MANUAL-

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Maintenance Procedure 7.7.50.2, " Visual Examination Procedure for ANSI B31.7,"~

Revision 0 Maintenance Procedure 17.7.50.3, " Visual Examination Procedure for AWS D1.1,"

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Revision 0 MQS-INSPECTION, INC. (MQS)

MQS Procedure 23.F.071-1970, " Penetrant Examination Visible Dye," Revision 0 MQS Procedure 21.A.031-1970, " Magnetic Particle Examination," Revision 0

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MQS Procedure 20.F.071-1970, " Radiographic Examination of. Welds," Revision 0

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PCI ENERGY SERVICES (PCI)

Project Instruction PI-6401-16, " Visual Examination," Revision l'

Project Instruction PI-6401-18, " Radiographic Testing," Revision 1 and Procedure Supplement dated March 20, 1990 General Quality Procedure GQP9.7, " Liquid Penetrant Examination and Acceptance Standards for Welds, Base Material and Cladding," Revision 2

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General Quality Procedure GQP-9.9, " Digital Thickness Haasurement," Revision 0

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General Quality Procedure GQP-10.1, " Qualification of Inspection, Examination.

and Testing Personnel," Revision 4

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General Quality Procedure GQP-10.1A, " Training, Qualification and Certification-of NDE Personnel," Revision 2 i

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