IR 05000302/1986040

Insp Rept 50-302/86-40 on 861208-11.No Violations or Deviations Noted.Major Areas Inspected:Letdown Cooler Replacement & Previously Identified Enforcement Matters

ML20210A664
Person / Time
Site:	Crystal River
Issue date:	01/13/1987
From:	Blake J, Economos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210A637	List: IR 05000302/1986040 ML20210A629
References
50-302-86-40, NUDOCS 8702060514
Download: ML20210A664 (7)

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Dere?o UNITED STATES

[ #o, NUCLEAR REGULATORY COMMIS$10N

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j REGION il 101 MARIETTA STREET, ,

• * ATLANTA. GEORGIA 30323

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Report No.: 50-302/86-40 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: December 8-11, 1986 NM

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Inspector: M . /9/7 N. Ecoriom ate Signid~

Approved by: /] -

/ 'i 7 J. J/Bla e, Section thief D(to Signed En heer ng Branch Di sto of Reactor Safety SUMMARY Scope: This routine, unannounced inspection related to the various aspects of letdown cooler replacement and the review of previously ident.ified enforcement matter Results: No violations or deviations were identifie lDk kbobK $shNho2 0 ppm

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REPORT DETAILS Persons Contacted Licensee Employees

• P. F. McKee, Director, Nuclear Plant Operations

• V. R. Roppel, Manager, Nuclear Plant Technical Services

• J. H. Lander, Director, Nuclear Projects and Outages

• J. J. Warren, Site Welding Engineer

• K. R. Wilson, Manager, Site Nuclear Licensing R. Hathorn, NDE Supervisor, Materials Technology W. G. Neuman, III, Nuclear ISI Specialist Other Organizations Gilbert / Commonwealth Ronald D. Dreggors, Welding Engineering Consultant National Inspection and Consultants (NIC)

Rick Vigne, QC Welding Inspector Fluor Mechanical Services, Inc. _(FLUOR)

Ron Mahaley, Project Engineer NRC Resident Inspectors

• J. Tedrow, Resident Inspector

• Attended Exit Interview Exit Interview The inspection scope and findings were summarized on December 11, 1986, with those persons indicated in paragraph 1 above. The licensee was informed of the inspection finding below which was discussed in detail. No dissenting comments were received from the license (0 pen) Unresolved Item 302/86-40-01, Letdown Coolers Evaluation of Replace-ment Suitability, and Failure Analysis, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio _

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, Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 302/85-17-01, Control of Field Welding. This item was reviewed on a previous inspection that was discussed and documented in report 302/86-03. The item was left open pending review of a new welding manual which had not been issued at that time, At this time, the inspector

ascertained that the welding manual had been issued and was being 4 implemente (0 pen) Inspector Followup Item 302/85-23-01, Weld Undercut Acceptance Criteria. In an attempt to close this item, the inspector reviewed applica-

, ble procedures and discussed the subject with the Site Welding Engineer (SWE). This effort disclosed that engineering had addressed the subject in

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simpler terms on an engineering drawing but the acceptance criteria had been

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inadvertently left out of the newly issued site procedure Therefore, welding personnel agreed to have this information incorporated into the procedure via a revision. This matter will be pursued further on a future inspectio <

(Closed) Violation 302/85-23-04 Failure to Fcilow WPS Requirements - The licensee's letter of response dated July 2,1985, has been reviewed and determined acceptable by Region II. The inspector held discussions with the SWE and examined the corrective actions as stated in the letter of respons The inspector concluded that the licensee had determined the full extent of

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the subject noncompliance, performed the necessary followup actions to correct the present conditions, and developed the necessary corrective conditions. The corrective actions identified in the letter of response have been implemente (0 pen) Unresolved Item 302/85-23-02,WPS Validity. This item was identified

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because during the time-frame of May 1985 the issue concerning qualification

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of welding procedures and whether the licensee was the repair organization at that time had not been resolved. During this inspection this subject was discussed with the SWE who agreed to review the issue and provide the inspector'with a report for review on a future inspectio (0 pen) Unresolved Item 86-08-01 RCV-8 Discharge Flange Misalignment. As a followup action on this matter, the inspector reviewed the licensee's interoffice correspondence and held discussions with the SWE. The inspector reiterated Region II's1 position on the use of procedure 8/8-TT-019 Rev. 5 for pipe alignment / repair without filler metal. As a result of this discus-sion the SWE indicated that he was undertaking specific actions to rectify the proble These actions included ' volumetric examination of the weld joint in question, and consideration for qualification of a procedure to allow for use in similar situations. This item will be reexamined on a future inspection.

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3 Unresolved Items ,

Unresolved items are matters about which more information is required to

- . determined whether they are acceptable or may involve violations or i deviations. The new unresolved item identified during this inspection is

. discussed in paragraph 5.c.).

' Letdown Cooler Replacement (55050B) m

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i _At the time of this inspection the. replacement coolers were in place'and the L

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fabrication of tie-in-welds was in progres The applicable . code was identified as USAS B31.7.1969 Edition (Code). Administrative controls were implemented through maintenance procedure MP-516 Rev. 4 " Removal and Re-placement of Letdown Coolers MUHE-1A and -1B." The replacement coolers were manufactured by Graham Manufacturing Company, Inc. (Graham).

. Completed welds and others in process were inspected for compliance with

code and regulatory requirements. These were as follows:

Joint

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Weld Size Configuration Status Cooler Comment MU-85-216 3" noz. to spool Complete IB Accept

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MU-85-221 3" spool to 2 Reducer Complete IB Accept i MU-85-222 -

Buttering on No Complete 1A Accept

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Buttering on Spool Complete 1A Accept MU-85-214R2 3" noz. to Spool Complete 1A Accept

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MU-85-213 3" noz. to Spool Complete 1A Accept l .MU-85-217 2h pipe to pipe fitup 1A Accept MU-85-223 2h pipe to pipe fitup 1A Accept In addition, the inspector checked these welds for the following attributes

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and/or conditions as applicable to assure that work was conducted in accor- dance with a " traveler"; welding procedures and/or drawings; WPS assigned in i accordance with applicable code; technique and sequence were specified; materials as specified; geometry as specified; fitup and alignment as

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specified; gas shielding and purging as specified; technique was -as speci- -

i fied; welding electrodes were as specified and consistent with the code; gas

! flow was controlled as specified; welding equipment was as specified; ( interpass temperature was controlled and consistent with the applicable

codes; interpass cleaning and backgouging were performed as specified; i process control system has provision for repairs consistent with applicable

) codes; weld repairs were conducted in accordance with specified procedures; l base metal repairs are properly documented; and welder identification.

i Completed welds were checked for weld reinforcement, arc strikes and weld I spatter, cracks, . laps, porosity, slag, oxide film and undercut did not

exceed prescribed limits. Within these areas the inspector noted that

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Quality Control Inspection Report, QCIR-86-108, had been issued on weld

MU-85-214 to cover repair work necessitated when three pieces of ER-NIC47 i.

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monel material was inadvertently issued for ER-316 (stainless steel). A portion of the filler metal, about four (4) inches long, was used on the weld before the welder recognized the problem and stopped the wor A repair procedure was issued and the rejected weld portion was excavated, inspected and welded out. The inspector reviewed the documentation package and discussed the matter at length with the welding engineer. The inspector expressed concern over this incident and received assurances that the rod issuing program would be reviewed and steps taken to minimize the possibility of such a recurrence. In addition the inspector reviewed the quality records of the following filler meta Material Size Heat # QCI# .

ER-316 1/16" 40560 69124 ER-316 1/16" A4136T316 33624 ER-316 3/32" C5007L316 33624 ER-316 3/32" C4136T316 33624 ER-316 1/8" 51156 33624 ER-316 1/8" 04136T316 33624 Insert 308 1/8" x 5/32" 3017R 110720 Insert 316 1/8" x 5/32" 14548 110685 Welder Qualifications For the welds identified above, the inspector retrieved welder stencil numbers for a review of performance qualifications record Stencils selected for this effort were as fcilows: PF-4, -6, -13, -193, -210, and -254. M e records were revieweo to ascertain whether the qualifi-cations weie consistent with code required essential variables for the proces Review of Radiographs l

l Completed welds were radiographed (RT) as required by 1-727.4 of the Code. The welds were radiographed in accordance with procedure RT-003 Revision 2 written to comply with requirements of the Code and ANSI B31, code case #72, August 197 The only final radiographs available for review were for welds:

MU-85-213, -214 and -22 The films were reviewed for radiographic and film quality, and the accompanying reader sheets were reviewed to l verify that all code required information was documented. The inspec-l tor noted that the film for each of these welds had been reviewed by l FPC's Level II RT examiner, the authorized code inspector and B&W's (contractor) Level III examine The latter, reviewed the welds to satisfy preservice inspection (PSI) requirements of ASME Section X Within these areas the inspector noted the following, (a) results of the PSI were documented on the same reader sheet used for construction code review. This approach was considered as inappropriate because of I

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differing acceptance criteria between the two codes, e.g. linear indications of certain size are acceptable under Section XI but rejectable by the construction code, (b) also the inspector noted that the film for RT portion 1 to 2 on weld MU-85-214 exhibited an indica-tion about 1/8" long which had been missed by FPC's Level II but identified and recorded as acceptable by the Level III. At the time of this inspection the inspector could not ascertain which acceptance criteria the Level III was using to make his determination, and whether his documentation of the finding was for the construction code or Section X Following the close of this inspection, the inspector discussed by telephone the above observations with cognizant FPC personnel who stated that B&W would be issuing PSI data reports on all the welds reviewed by their Level III and that appropriate corrections would be made to the reader sheet of the aforementioned wel c. Review of Replacement Components Quality Records Packages Following is a list of replacement items involved in the letdown cooler

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replacement whose quality records were reviewed to ascertain whether code required documents were on hand, complete and accurat Item Size Ht# QCI#

90 ELL, 3" sch. 160 JXMZ 90670 SA403 GR WP316 New Spool Piec " (sch. 160 N9429 109196 SA-312, Gr316 Heliflow Letdown S/N PO# QCI#

Coolers, 30-S6C-40LL 1A 48230-1 F9017539D 109204 IB -51145-2 F90500830 109218

The review disclosed that cooler IB was procured from Arkansas Power i and Light Company. This cooler was built under requirements of ASME

!Section III, 1968 Edition while 1A was built to the 1977 Edition, with winter 1979 addenda. Also the inspector noted that the documentation of 1B cooler included an internal note which stated that, "FPC Engi-nearing has reviewed B&W Q.R. Data Package #23-1159384-00 for the i suaject item and has found it equal to requirements imposed by FPC to P.O.#81396LS (Original P.O. for Letdown Cooler), see attached ' Engi-l neering Software Acceptability Letter." At the time of this inspection

!~ the inspector could not ascertain whether the requirements of the above purchase order had been applied the replacements. Also it could not be

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verified whether the licensee had fully complied with IWA-7220, " Veri-fication of Acceptability" of ASME Section XI. The inspector identi-fied this matter as an unresolved item until the suitability evaluation i

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report and the failure analysis report could be evaluated on a fut.ure

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inspection. Unresolved Item 302/86-40-01, Letdown Coolers Evaluation of l~ Replacement Suitability and Failure Analysi ,

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