IR 05000313/1989042
| ML19325E910 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/02/1989 |
| From: | Barnes I, Gilbert L, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19325E904 | List: |
| References | |
| 50-313-89-42, 50-368-89-42, NUDOCS 8911130017 | |
| Download: ML19325E910 (9) | |
Text
p
--
,
.
,
,
,
,
,
..
. l;<
p
s e
,
'
j
, APPENDIX B
,
'
I" U.S. NUCLEAR REGULATORY COMMISSION L
REGION IV
r t.
NRC Inspection Report: 50-313/89-42-Operating Licenses: DRP-51
L 50-368/89-42 NPF-6
Dockets:
50-313 50-368 Licensee: Arkansas Power and Light Company (AP&L)
P.O. Box 551 a
l'
Little Rock. Arkansas 72203 t
Facility Name: Arkansas Nuclear One (ANO) Units 1 and 2 f
Inspection At: Russellville. Arkansas inspection Conducted: October 16-20. 1989 i
l
'
i inspectors: /
As
// 3 8 7
.
L/ D/ Gilbert. Reactor Inspector. Materials Date '
%nt Quality Programs Section. Division of
!
Reactor Safety
.
!
.
'
,
et il D
5t rt. Reactor Inspector. Materials Dat4
Q ity Programs Section. Division of
,
eact afety
-
,
,
i I(
h N7 Approved:
,
V w
,
I. Baines.
1er. P,aterials and Quality Date
'
4-Programs ection. Division of Reactor Safety
,
i
.,i
,
H
'
f i
l 8911130017 891103 PDR ADOCS: 05000313 Q
]
h
..-
- - -
.
.
' '
,
?
-P.
'
Inspection Summary Inspection Conducted October 16-20. 1989 (Report 50-313/89 42)
Areas inspected:
No inspection was performed for Unit 1.
t
,
inspection Conducted October 16-20, 1989 (Report 50-368/89-42)
Areas inspected:
Routine, unannounced inspection of the control of welding activities.
,
Results: A program for the control of welding activities has been developed by the licensee but program implementation exhibited areas of weakness as evidenced by inconsistencies identified in the areas of procedure compliance, quality
.
'
control (QC) surveillance, and document control. An apparent violation
-,
(paragraph 3.b) was identified for control of welding activities, and a second i
apparent violation (paragraph 3.d) was identified in the area of document
,
control. Additionally. QC surveillance of welding was being accomplished i
without specific procedural guidance.
,
I e
,
-
.
,
o
!l,.
- '
,
'^'
,
,
j(
-3-
!
,.
DETAILS-
'
.[
v r
persens Contacted
f
/. PAL
~
,,
- -
- N. Carns. Director Nuclear Operations l s
,
- R. Fenech. Plant Manager-Unit 2 t
- J. Fisicaro Manager Licensing
!
- L. Humphrey, General Manager. Nuclear Quality L
- J. Grisham, Manager Administration Services
- J. Fueller Manager, Central
- R. Sessones. Manager. Central Operations
,
'
- A. McGregor. Engineering Services Superintendent
- D. Mims. Plant Engineering Superintendent
- D. Crabtree. Engineering Program Superintendent
,
- J. Taylor-Brown. Quality Control / Quality Engineering Superintendent
- J. Barrett. Quality Control Supervisor
- D. Rackley Welding Coordinator
- S. Smith. Installation Superintendent
- D. Butler. Maintenance Trainer
- B. Hampton. Stores Supervisor -
' *J. Jacks Nuclear Safety & Licensing) Specialist G. Provencher Quality Assurance (QA Supervisor p
J. Brown. QA Auditor R. Hooper. Purchasing Superviser Fluor Daniel. Inc.
- D. Mauldin, Project Manager
- R. Holean Welding Coordinator
'
NRC
- C. Warren. Senior Resident Inspector
- R. Haag Resident inspector (
The inspectors also interviewed other licensee employees during the j
inspection.
- Denotes attendance at exit interview conducted on October 20, 1989.
l:
2.
Licensee Action on Previous identified items (92701)
L (Closed) Unresolved item (313/8906-01; 368/8906-01):
Radiographic examination procedure did not specify appropriate penetrameter selection l
requirements. The inspectors verified that the revised procedure for L
radiographic examination. Procedure 1402.172 Revision 1. contains the correct ASME Section 111 information for penetrameter selection for the single wall technique. Based on the procedure revision and the licensee's
!
l-
.
-
.
--,
-
,
<
,
s
,
'
- ,
,-
,
- ,
h i
',
4
.
,
i
~,
'
i
^
detennination that the incorrect penetrameter selection table had'not been I
~
,
v used on any single wall radiography, this unresolved item is resolved.
,
,
'
3., _ Welding Activities (55050and55100)
i The objective of this inspection was to verify that the licensee has
,
.
developed and implemented a program relating to control of welding
'
activities that meets the commitments in the Final Safety Analysis Report (FSAR).
a.
peview of Procedures
,
.
The inspectors reviewed the licensee's program for controlling safety-related welding activities to assure that welding is controlled ano accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards,
'
specifications, criteria, and other special requirements. The
,
licensee documents for controlling the welding program are listed in
the Attachment. These documents provide the programmatic requirements for: overall plant administration of the welding and ASME repair / replacement programs; installation, modification,
.
inspection, and documentation of piping systems and pipe supporth, l
hangers, and restraints for nuclear process piping; implementing and control of welding; welding filler material control; and welding inspection. The six welding procedure specifications (WPSs) listed v
in the Attachment were selected for review based on usage during the
&
'
outage. The WPSs and their supporting procedure qualification reports (PQRs) were consistent with the requirements of ASME Section IX.
i
'
There were no violations or deviations identified during this part of the inspection.
,
,
b.
Observation of in-Process Welding - Unit 2
,
The inspectors observed in-process welding associated with the replacement of safety injection valves and modifications to the pipe
-
supports for the reactor coolant pump seal sensing lines. New
'
replacement valves for safety injection Line 2CCB-14 were being welded as a subassembly in the onsite fabrication shop. The welding consisted of a socket weld connecting a 3/4-inch Schedule 160 pipe to
,
a 3/4-inch globe valve. The pipe and valve materials were specified on Drawing 2CCB-14-2 as Type 316 stainless steel. The inspectors observed welding being performed on Weld 1801 using the gas tungsten-arc welding process and WPS P8-T-Ag. During iaonitoring of e
the welding, the inspectors measured the travel speed used on the
'
'
second and third passes and noted that it was not within the range of the WPS. The travel speed used was 2 and 1 1/2 inches per minute.
respectively, while the Welding Procedure Specification (WPS) specified
'
,
the travel speed as 3-10 inches per minute. The weld was also being
_
_
,
' F y
,
F-5-
,
,
sprayed with demineralized water between weld passes to increase the j
cooling rate in order to expedite welding and to comply with the i
,
,
350*F maximum interpass temperature requirement of the WPS. The J
welding instructions did not include provisions for water quenching
'
or other means of forced cooling of welds. The welding of Weld 2101 j
on Drawing 200B-14-2 was observed after the WPS had been revised by
)
g engineering to permit welding with WPS P8-T-Ag using travel speeds of 1-10 inches per minute. The travel speed was now being monitored by the welder and was within the range specified in the revised WPS.
'Other welding observed by the inspector included the prefabrication i
of four pipe supports for the reactor ccolant pump seal sensing
!
lines. The welds were identified as FW11 and FW12 on Drawing 2CCC-7-H1, FW1801 on Drawing 2CCC-12-H1, and FW22 on j
Drawing 2CCC-14-H1.
Except for FW11, welding was performed using
'
WPS P1-A-B with E7018 electrodes and the shielded metal-arc welding
'
process. Welding of FW11 was performed using WPS P8-P1-AT-Ag with E309-16 electrodes and the shielded metal-arc welding process. While i
monitoring the welding performed on the safety injection piping and reactor coolant pump seal sensing pipe supports, the inspectors interviewed four welders with respect to welding variables specified in the WPS being used by the welders.
In general, the welders were not familiar with the limits or ranges for the welding variables specified in the WPS, such as, emperage, travel speed, and torch shielding cup size.
The inspectors also visually examined 25 completed welds for the reactor coolant pump seal sensing pipe supports. The welds were identified on Drawings 2CCC-12-H1 and 2CCC-6-H2.
Some of the welds were designated as fillet welds and others as flere bevel welds. The inspectors noted that, in the case of four of the flere bevel welds, the completed welds did not conform to the drawing requirements. The support drawing weld detail for these welds specified a "2-4" flare bevel weld. The "2-4" means 2 inches of weld on 4-inch centers.
However, the completed welds identified as Welds FW9, FW10. FW15, and FW16 on Drawing 2CCC-6-H2, Revision N-1 had been accepted by quality j
control (QC) but were welded continuously (no break in the weld) for
'
.the full 6 inches of length. This change in weld design was not authorized by engineering as required by Specification APL 2410.
These conditions (welding outside the WPS limits for travel speed, n
quenching of welds with water without a procedure, and changing weld design without engineering authorization) are considered to be an apparent violation of Criterion IX of Appendix 0 to 10 CFR
'
Part 50 and the approved quality assurance plan.
(313/8942-01;
'
368/8942-01)
i c.
Surveillance of Welding Activities During the inspection, the inspectors reviewed the licensee's activities related to the surveillance of in-process welding that
- _,
.
_.
)
'.
,,
{
,
j r
,
' f-
-6-
,
p
'
t
,
would include the monitoring of the WPS welding variables (i.e.,
travel speed, voltage, amperage, purge gas flow, heat input, etc.).
It was observed by'the inspectors that the licensee has established
a quality assurance auditing and surveillance program which includes the control of special processes.
!
.,
,
[
"I Paragraph 9.5 " Verification," in Section 9.0, ' Control of Special
-
,
Processes " of the ANO QA Manual Operations, states in part, i
"perfomance of special processes is verified by nuclear quality personnel through performance of the audit, review, surveillance and
{
,
t inspection activities."
!
.
v i
In reviewing recent welding OA audit and surveillance reports. it was
!
.
noted that the monitoring of WPS variables was not documented. The
'
>
v inspectors discussed this matter with the cognizant QA supervisor and.
the QA auditor of record.
The inspectors were informed that auditing o.
and surveillance of welding activities conducted by the site quality assurance personnel is primarily an evaluation of the programatic
aspects of the welding program, intended only to verify compliance
with regulatory and procedural requirements. Specific, day-to-day, i
in-process monitoring of welding variebles prescribed by the various
!
WPSs is a function of the quality control welding inspectors who
[
'
1 examine and record the actual welder performance acceptance criteria, s
'ANO QC Operating Procedure QC0-8 " Maintenance and Modification, QC
'
. Inspections " paragraph 5.2.2 states, " Surveil (s) - progressively
,
monitoring by randomly witnessing and inspecting items and work
!
operations before, during, and after in-process work."
i
'
Paragraph 5.4.3 states, " Surveillance of welding and NDE contractors shall be perfonned by QC at least once for each contract issued. The
-
activity selected'for surveillance shall be as directed by the QC
,
supervisor."
<
During discussions with the QC manager and QC supervisor, the e
>
inspectors were informed that surveillance of welding activities
'
performed by ANO maintenance and contractor welders is randomly
conducted; however, there is no specific welding surveillance t
procedure established, and only discrepancies noted during the
,
surveillance are recorded on a QC inspection record. While the I
.
L inspectors review of the 1988-89 QC inspection record log indicated
'
L that some surveillance activity of welding is being accomplished, there is no QC welding surveillance procedure nor record of welding
,
L examined during the surveillance activity.
The failure to not have a i
welding surveillance procedure established is considered to be a weakness in the licensee's quality control activities, d.
Welding Material Control i
The inspectors conducted a review to determine that a procedure had I
been established with respect to storing, disbursing, and handling of i
l'
.
.
_-
_-
_
s-
...,
!
[
-7-l
!
,
'
!
?
welding materials.
Procedures 1033.003 and 1092.011 are the l
procedures which delineate the requirements and responsibilities
o associated with weld material control and issue. The procedures
!
,
appear to be comprehensive and address the elements necessary for the
,
,
control and issue of welding materials.
{
L In order to verify implementation of the procedures, the inspectors t
observed the storage. issuance, and use of weldin) materials. The i
!
inspectors were informed that safety-related filler material is
'
'
issued from just one storeroom. The inspectors toured the storeroom (
- ,
.
,
and observed the storage and issue of weldi.ig materials, including
.
,'
.those electrodes required to be stored in ovens. This'also included i
[
a review of oven temperature control and daily monitoring records of i
the oven temperatures. The inspectors reviewed selected certified material test reports associated with the filier materials stored in i
,
,
?
the issue area to verify that the applicable AWF Code requirements
!
were addressed. During observation of the electrodes issue, the inspectors noted that only the heat number was being recorded for
!
coated electrodes on the request for filler material issue record.
'
while. Procedure 1092.011 specified that both the heat nuinber and lot
,
,
number shall be recorded for coated electrodes.
In discussing the matter with the individual responsible for issuing the electrodes, it l
was determined that the storeroom had not been provided with the
'
latest revisions of the procedures for over a year.
Review of
,
,
document control records revealed that the latest revisions for the i
two procedures were Revision 10 for Procedure 1033.003 and Revision 2 i
for Procedure 1092.011. However, the procedures being used in the
,
storeroom were Revisions 6 and O. respectively. This is an apparent
!
violation of Criteriot. VI of Appendix B to 10 CFR Part 50, in that i
t the latest changes to documents were not distributed and used at the location where the prescribed activity is performed.
(313/8942-02; t
,
368/8942-02)
.
e.
yelderOualification l
,
The inspectors were informed that no welders were being tested during the inspection period. The inspectors selectively sampled and
reviewed 9 welder certifications and compared each certification to
'
l the latest welder qualification matrix for plant welders and contract
i welders.
it was noted that the standard welder qualification test t
l for pipe butt welds used the more stringent radiographic examination
which is optional in lieu of bend testing for acceptance of welder l
qualification testing.
,
!
There were no violations or' deviations identified during this part of the inspection.
4.
Exit Interview
~
An exit interview was conducted on October 20. 1989, with those personnel t
L denoted in paragraph 1 in which the inspection findings were summarized.
'
,
- .
-
I
,
.
,o
i l.,<
.g.
'
L At the exit interview, Mr. Carns stated that he would provide documented commituents to the NRC the following week which would define actions being taken to ensure that welders comply with procedures. The licensee was contacted on October 25, 1989, and informed that the unauthorized change in weld design, discussed in paragraph 3.b, would be included as an
-
example of Notice of Violation, Item A.
No information was presented to the inspectors that was identified by the licensee as proprietary.
t
!
>
'
L I
i s'
I
'
.
I
>
b
'
(
r I_
p
.
,
,
ATTACHMENT LIST OF bOCUPENT5 REVIEWED Program Documents Overall Plant Administrative Procedure No. 1000.037 Revision 12, " Welding and ASME Repair / Replacement"
.
,
Specification No. APL-M-2415. Revision 2 " Technical Specification for Nuclear Welding Standards for Arkansas Nuclear One - Units 1 and 2" Specification No. APL-M-2410, Revision 2. " Technical Specification for
Installation, Modification, Inspection, and Documentation of Piping Systems and Pipe Supports, Hangers, and Restraints for Nuclear Process Piping and B31 Hanger Critical Piping for the Arkanses Power & Light Company Arkansas Nuclear One - Units 1 and 2"
,
Engineering Services Administrative Procedure No. 1092.011, Revision 2, i
- 1mplementing and Control of Welding"
'
4..
Materials Management Administrative Procedure No. 1033.003 Revision 10.
" Welding Filler Material Control" QC Operating Procedure No. Q00-6, Revision 3. " Welding Inspection" Welding Procedure Specifications (WPSs)
. PS No. P1-T, Revision 6 W
'
,
WPS No. P1-AT-Lh, Revision 8 WPS'No. P1-A-B, Revision 5
WPS No. P8-T-Ag, Revision 9
WPS No. P8-PI-T-Ag, Revision 6 WPS No. P8-P1-AT-Ag, Revision 6
.
l
'
1