IR 05000302/1987011
| ML20209C086 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/08/1987 |
| From: | Blake J, Economos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20209C032 | List: |
| References | |
| 50-302-87-11, NUDOCS 8704280584 | |
| Download: ML20209C086 (7) | |
Text
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' UNITED STATES
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NUCLEAR RECULATCRY COMMISSION
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101 MARiETTA 5THEET, N.W., $u6TE 2suo
ATLANTA, GEORGIA 30323
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Report No.: 50-302/87-11
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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 InspectionConducte/. Ma h 9, 1987 CO f ~ --
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/! M Inspector:
28'
pm N.
on ros
/Date Si ned Approved by:
M & 87 J. J.
ak'e, Section Chief Da'te Signed En n ring Branch Di i on of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection related -to a review of letdown
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cooler replacement radiographs, a review of previously identified enforcement matters, licensee conducted audits and quality control inspection reports in the areas of welding and nondestructive examinations (NDE).
Results: No violations or deviations were identified.
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REPORT DETAILS
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Persons Contacted Licensee Employees
- P. F. McKee, Director, Nuclear Plant Operations
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- J. H. Lander, Director, Nuclear Projects and Outages
- W. L. Rossfeld, Nuclear Compliance Manager i
_*J. J. Warren, Site Welding Engineer K. R. Wilson, Manager, Site Nuclear Licensing i
R. Hathorn, NDE Supervisor, Materials Technology W. G. Neuman, III, Nuclear ISI Specialist
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F. V. Fusick, Supervisor, Site Nuclear Services M. D. Clary, Principal Nuclear Mechanical Engineer
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Other Organization-
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i Ronald D. Dreggors, Welding Engineer Consultant, Gilbert / Commonwealth i
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on March 19, 1987, with those persons indicated in paragraph 1 above.
The licensee was informed
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of the-inspection finding below which was discussed in detail.
No-dis-senting comments were received from the licensee.
(0 pen) Unresolved Item 302/87-11-01, Written Practice for Qualifica-l tion of Nondestructive Examination (NDE) Personnel, paragraph 3.
l The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92701)
(Closed) Inspector Followup Item 302/85-23-01, Weld Undercut Acceptance i
Criteria.
In-an attempt to close this item, the inspector reviewed I
applicable procedures and discussed the subject matter with the: Site J
Welding Engineer (SWE).
This effort disclosed that engineering had addressed the subject in procedure NWP-09, Rev.1 of the Nuclear Opera-tions Manual (NOM).
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(Closed) Unresolved Item 86-08-01, Discharge -Flange Misalignment.
As a
followup action on this matter, the inspector held discussions with the SWE who disclosed that specific actions had been taken in an effort to resolve the issue.
These actions included volumetric (radiography),
examination of the weld joint, and qualification of a welding procedure
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which duplicated the remelting of the_ upper (cover pass) portion of the.
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The inspector reviewed the radiographs of -the subject weld, RC-90-40, the welding procedure specification CR3-8/8-T(SPEC) and support-j ing procedure qualification records (PQR)' CR3-8/8-T(SPEC) Rev. O.
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i notation on the PQR, the licensee does not intend to use this WPS on any other application.
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(0 pen) Unresolved Item 302/85-23-02, WPS Validity. This item was identi-i fied when the licensee could not produce objective evidence to verify that
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FPC was the repair organization as defined in IWA-4300(c)(1)-(3) of ASME
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Section XI, during the contract period with Catalytic, Inc. (CI). Discus-sions with the' licensee's SWE disclosed that this matter was being active-ly pursued and that an official position would be available for NRC review on the next inspection visit.
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(Closed) Unresolved Item 302/85-35-01, Qualification of Level II Radiogra-
pher.
This item was identified when the inspector expressed concern over i
i the apparent -laxity in the licensee's qualification program for NDE j
examiners.
This was evidenced by the certification of an individual to a
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Level II examiner / interpreter (RT), approximately one month after the date of his employment. -The individual had approximately eight months of prio-experience as a radiographer involving non-code work.
There was no i
evidence that the individual had been certified under a written program, equivalent to SNT-TC-1A, Recommended ' Practice Guidelines, prior to his
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j employment with FPC.
By interoffice correspondence, J. C. Hicks to
J. L. Bufe', dated October'7, 1985, and other related records, the licens-
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ee's Level III examiner showed that the individual had met the minimum
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training guidelines, of the' SNT-TC-1A, Recommended Practice, and stated
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that in his opinion, the candidate's background coupled with one month 'of
on-site training in radiography was sufficient to. certify him to the
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Level II position in radiography.
The subject individual is no longer
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In addition, the aforementioned memorandum
indicated that Material Technology will implement programmatic changes to
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j further ensure the adequacy of individuals certifying to Level II RT by i
establishing, under the parameters of - the Practical Portion of the j
Level II examination, a film interpreters test.
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The inspector discussed the entire matter with the licensee's NDE site i
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supervisor and closed the Unresolved Item 85-35-01.- As part of tin work.
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effort in this area, the inspector reviewed Material Technology Adminis-
i trative Procedure (MTAP), Manual (Manual).
Procedures reviewed for
content are as follows:
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MTAP-2 Rev. 3 Preparation and Control of Administrative Procedures l
MTAP-3 Rev. 1 Preparation and Control of Special Process Specification l
MTAP-4 Rev. O Preparation and Control of FPC Welding Procedures
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I MTAP-6 Rev. 5 _ Certification of NDE Personnel in Accordance with
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SNT-TC-1A, 1980 Edition - and AWS.
Referenced ' SNT-TC-1A
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(1980 Edition), Documents Included ASME. Code Section XI i
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Within these. areas, the inspector discussed the following concerns with j
the site NDE supervisor:
a.
- Procedure.MTAP-6 Rev. 5,. paragraph 4.0, " Definitions", ' establishes-
the levels of qualifications along with the skills 'and responsibility i
at each respective level.
The wording'used to define the skills and responsibilities for each of the four designated levels is essen-
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i tially identical to that in SNT-TC-1A, Section _4, Levels of Qualifi-cation, with the exception that whenever the word "shall" appeared in
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the aforementioned section, in the procedure it was changed to
"should".
Regulatory Guide' 1.58, which endorses SNT-TC-1A for.
i qualification of NDE personnel, defines "shall" as the verb indicat-
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ing requirement and "should" is the verb indicating recomendation.-
i Therefore, what appears as a requirement in the endorsed document, l
has been diluted to a recommendation in the licensee's procedure and i
by extension, makes enforcement of this portion of the procedure an i
impossibility.
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Section 6.2, Examinations, describes in broad terms, the three i
phases, i.e., general, specific and practical, for each -of: the examination levels, i.e..
I, II, and II R.
For example, for the
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practical phase of the examination, the procedure states.that the j
practical portion of the examination allows the candidate to perform j
the actual NDE method on one or more specimens within the parameters
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of a specific procedure.
The test sample shall be~ approved by the
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Level III.
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As such, the procedure does not describe, in outline form, the
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i material that a candidate will be tested on for each of the above
phases and disciplines covered by SNT-TC-1A. This another example of ~
l vagueness in the document.
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j-These concerns were discussed with the site NDE supervisor who agreed l
i to pursue the matter further at the managerial level. The inspector i
stated that an unresolved item will be identified until a satisfacto-
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ry resolution can be obtained. ~ Unresolved Item 302/87-11-01,. Written Practice for the Qualification and ' Certification of NDE Personnel.
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(0 pen) Unresolved Item 302/86-40-01, Letdown Coolers-Evaluation of Re-placement Suitability, and Failure Analysis.
This item was identified because at the time of the previous inspection, December 8-11, 1986,'the licensee could not demor,trate that full compliance with IWA-7200 of ASME.
Section XI had been achieved for the Letdown Cooler Replacement. Discus-
l sions with the licensee indica'ted that, although the engineering evalua-j:
tion report was complete, the failure analysis investigation is in l
progress and that a report would be made available for evaluation once the l
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results are known, about the end of June 1987.
This matter will be pursued further during a future inspection.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. ~ The new unresolved item identified during this -inspection is discussed in paragraph 3.
5.
Letdown Cooler Replacement - Review of Radiographs (57090)
This work effort was a followup to that documented in Report 302/86-40.
At that time, the inspector reviewed radiographs for welds numbered MU-85-213.-214, and 221.
The applicable code of record is ANSI B31.7-69, Nuclear Power Piping.
The welds were radiographed in accordance-with procedure RT-003 Rev. 2 and code case #72, August 1970. The below listed radiographs were reviewed to ascertain whether radiographic quality was in accordance with the above code and procedural requirements in the follow-ing areas:
a.
Penetrameter type, size, placement b.
Penetrameter sensitivity c.
Film density, density variation d.
Film identification e.
Film quality f.
Weld coverage (overlap)
Weld Number NDE Report Number Pipe Size
- MU-85-216 MTL-86-114 3"
- MU-85-215 MTL-86-116-3" MU-85-245 MTL-86-117
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- MU-85-223 MTL-86-118 21"
- MU-85-218 MTL-86-119'
21"
- MU-85-217 MTL-86-120 21" The inspector noted that the film for each of these welds had been re-viewed by FPC's Level II RT examiner, the authorized code inspector and B&W's (contractor) Level III examiner.
The latter, reviewed the welds to satisfy preservice inspection (PSI) requirements of ASME Section XI.
In addition, the inspector reviewed the preservice inspection report on these welds submitted by B&W to the licensee as required by ASME Section XI.
Within the areas inspected, no violations or deviations were identifie._,___--_-_
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Independent Inspection Effort i
Review of QA Audits-and Quality Control Inspection Reports (QCIRs) on helding and NDE (35741)
The below listed audit reports, conducted by the licensee's Quality Programs (QP) group, and QCIRs were reviewed to ascertain whether accep-tance criteria were consistent with applicable code and regulatory re-
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quirements; deficiencies-identified during the audit have been resolved or
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they are currently being carried as an "open item"; the audited organiza-tion has responded in writing to the audit finding; and the distribution of audit reports and response was consistent with program requirements.
The reports reviewed were as follows:
j Audits
QP-266 2/5-27/85, Inspection and Examination areas audited included receipt inspections, nondestructive examinations, and inservice (ISI) inspection activities.
The audit team identified several concerns in the administrative area of the ISI program.
These i
l concerns have been addressed by the site organization (s) in charge and resolutions are pending for some while others were
closed.
OP-268 4/29 - 5/21/85, Special Processes areas audited included protec-tive costings, preventive maintenance on welding power supply machines, and calibration of welding related measuring devices.
OP-287 3/17 S/7/85, Special Processes creas audited included adminis-tretive controls on production welding which focused on control of welding material and adherence to welding specification requirements.
QCIRs87-012 Storage and Procurement 86-105 Metal Gasket in Pressurizer to Valve Connection in Deteriorated Condition 86-106
"A"-0TSG Emergency Feedwater Nozzle #6 Header Flange Repair 86-107 Weld Prep on Production Welds Not Meeting Pipe Specification
Requirements
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86-109 Service Water Pipe Welds on 1"B" Letdown Cooler Unacceptable 86-111 As-Built Pressure Gage Installation in Conflict with Design Drawing
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86-096 Production Weld Fitup in Violation with Applicable Code-097 Requirements86-071 Cracked Valve Seat Ring, RCV-139 and RCV-21
!86-081 Storage of Limitorque Box #159 Within these areas, no violations or deviations were identified.
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