IR 05000321/1980013

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IE Insp Repts 50-321/80-13 & 50-366/80-13 on 800311-14 & 25-28.Noncompliance Noted:Failure to Approve Inservice Insp Plan & Failure to Certify Welding & NDE Inspectors
ML19312E717
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 04/17/1980
From: Crowley B, Herdt A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19312E692 List:
References
50-321-80-13, 50-366-80-13, NUDOCS 8006090435
Download: ML19312E717 (9)


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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA sT N.W., SUITE 3100

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ATLANTA, GEORo tA 3o3o3 APR 211980

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Report Nos. 50-321/80-13 and 50-366/80-13

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Licensee: Georgia Power Company 270 Peachtree Street Atlanta, GA 30303 Facility Name: Hatch Docket Nos. 50-321 and 50-366 License No. DPR-57 and NPF-5 Inspection at Itatch site near Baxley, Georgia M//b!WO L

Inspector:

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Date signed Approved by:

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////7!h A. R. Herdt, Section Chief, RC&ES Branch

'Dat6 Signed

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SUMMARY Inspection on March 11-14, and March 25-28, 1980 Areas Inspected This routine, unannounced inspection involved 52 inspector-hours onsite in the areas of inservice inspection activities (unit 2) and maintenance welding program

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(units 1 and 2).

Results Of the 2 areas inspected, 2 items of noncompliance were found in 2 areas (Defi-ciency - Failure to approve ISI plan, paragraph 5.a. ; Infraction - Failure to certify welding and NDE inspectors, paragraph 8.b).

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DETAILS 1.

Persons Contacted Licensee Employees

  • H. Manry, Plant Manager
  • T. V. Green, Assistant Plant Manager
  • C. R. Miles, Jr., QA Field Supervisor
  • C. E. Belflower, QA Site Supervisor
  • D. A. McCusker, QC Supervisor
  • C. E. Rand, Jr., Manager Field Operations
  • J. M. Watson, Senior QA Field Representative
  • G. U. Deyton, ISI Engineer J. A. Edwards, Senior Engineering Associate J. F. Banegas, Senior QC Specialist R. M. Harrington, QC Specialist W. R. Prescott, Inspection Supervisor Other licensee employees contacted during this inspection included techni-cians, security force members, office personnel and ISI contractor inspection personnel.

Other Organizations Southwest Research Institute (SwRI)

  • J. M. Agold, Project Manager C. E. Trout, Team Supervisor T. A. Mayces, Senior Technician, Quality Assurance NRC Resident Inspector
  • R. F. Rogers
  • Attended exit interview.

2.

Exit Interview On March 14 and March 28, 1980, the inspector met with the licensee repre-sentatives noted in paragraph 1 above and summarized the scope and findings of the inspection of inservice inspection activities and maintenance welding.

The noncompliances of paragraphs 5.a and 8.b were discussed.

The reporta-bility of the Liquid Penetrant (LP) indication noted in paragraph 7.c was discussed and the licensee stated that if it was determined that the indica-tion encroached upon minimum wall, it would be reported.

It was further stated that the indication would be included in the ISI repor __

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3.

Licensee Action on Previous Inspection Findings (Closed) Unresolved Item, 366/78-10-01, UT indication in closure head flange weld. The indication is acceptable to the edition of Section XI the site is now working to.

When the site upgrades to later editions to Section XI (1977), the indication would require fracture analysis. The fracture analysis has been conducted with acceptable results.

4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

Inservice Inspection - Review of Program (Unit 2)

The inspector reviewed the licensee's inservice inspection (ISI) program in the areas indicated below. The requirements for ISI are specified in the Hatch 2 FSAR, paragraph 5.2.8.

In accordance with these requirements, the ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition and addenda through the summer of 1975 is being used for ISI.

The inspector reviewed the ISI program for the current outage to a.

determine whether the program had been approved by the licensee.

Paragraph F of revision 1 to Hatch Plant Procedure HNP-904 requires in part that, "...a written document by SwRI detailing the proposed work to be done...will be reviewed and approved prior to the outage date."

Contrary to this requirement the ISI was in process and the SwRI Project Plan had not been approved by the licensee.

This is considered to be noncompliance with Criterion V of Appendix B to 10 CFR 50, as implemented by paragraph 17.2.5 of the Hatch 2 FSAR, and is identified as item number 366/80-13-01, Failure to Approve ISI Plan. Discussion with responsible licensee personnel revealed that the plan had been reviewed and SwRI given permission to start work. Formal approval of the plan was simply overlooked.

Based on the fact that the plan had been reviewed by the licensee, review of the plan by the inspector revealed an accarate plan, and the plan was approved during the inspec-tion when brought to the attention of the licensee, this item is categorized as a deficiency.

b.

The inspector reviewed the following Georgia Power Company and SwRI documents relative to the ISI program:

SwRI " Project Plan for the 1980 Inservice Examination of Edwin I.

Hatch Nuclear Plant, Unit 2" SwRI Nuclear Operating Procedure (NPOP) X-FE-101-0, "Onsite NDE Records Control" SwRI NPOP XVII-AG-101-0, " Data Storage and Retrieval" SwRI NPOP IX-FE-105-0, " Recording Data from Direct Visual, Liquid Penetrant, and Magnetic Particle Examination of Welds"

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SwRI NPOP IX-FE-104-1, " Measuring and Recording Search Unit Location and Maximum Signal Amplitude Data During Ultrasonic Weld Examination" SwRI Nuclear Quality Assurance Procedure (NQAP) 2-1, Revision 1,

" Organization" SwRI NQAP 3-1, Revision 1, " Procedures, Instructions and Drawings" SwRI NQAP 9-1, Revision 1, " Document Control" SwRI NQAP 10-1, Revision 1, " Test and Inspection Equipment Control" SwRI NQAP 11-1, Revision 1, "Special Process Control" SwRI NQAP 13-1, Revision 1, " Deviation and Nonconformance Control" SwRI NQAP 14-1, Revision 1, " Corrective Action Control" SwRI NQAP 15-1, Revision 1, " Audits" SwRI NQAP 15-2, Revision 1, "Qualificatioc and Certification of l

Quality Assurance Auditors" HNP QA-01-05, Revision 4, " Job Functions and Responsibilities /QA Field Representative Office" HNP QA-05-14, Revision 1, " Quality Assurance Field Representative" HNP QA-03-02, Revision 6, " Training and Personnel Qualification" HNP " Tentative Audit Schedule for 1980" HNP "In-service Inpsection Program Audit Checklist" dated 3/10/80 HNP HNP-6, Revision 6, " Plant Review Board Administrative Procedures" HNP HNP-9, Revision 10, " Procedure Writing and Control" HNP HNP-818, Revision 11, " Temporary Procedure Changes" HNP HNP-904, Revision 1, " Inservice Inspection Program" These documents were reviewed to assure that procedur5s and plans had been established (written, reviewed, approved, and issued) to control and accomplish the following activities:

(1) Organizational structure including qualifications, training, responsibilities, and duties of personnel responsible for ISI i

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(2) Audits including procedures, frequency, and qualification of personnel (3) General QA requirements including examination reports, deviations from previously established program, material certifications and identification of components to be covered.

(4) Work and inspection procedures (5) Control of processes including suitably controlled work conditions, special methods, and use of qualified personnel.

(6) Corrective action (7) Document control (8) Control of examination equipment (9) Quality records including documentation of indications and NDE findings, review of documentation, provisions to assure legibility and retrievability, and corrective action (10) Scope of the inspection including description of areas to be examined, examination catercry, method of inspection, extent of examination and justification for any exceptions.

(11) Definition of inspection interval and extent of examinations.

(12) Qualification of NDE personnel (13) Controls for generation, approval, custody, storage and maintenance of NDE records Within the areas inspected, no items of noncompliance, except as noted in 5.a above, or deviations were identified.

6.

Inservice Inspection - Review of Procedures (Unit 2)

The inspector reviewed the ISI procedures indicated below to determine whether the procedures were consistent with regulatory requirements and licensee commitments. See paragraph 5 above for the applicable code.

The following procedures were reviewed in the areas of procedure-a.

approval and requirements for qualification of NDE personnel:

(1) SwRI NDT-300-1-18, " Dry Powder Magnetic Particle Examination" (2) SwRI NDT-600-15-39, " Manual Ultrasonic Examination of Pressure Vessel Welds" f

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(3) SwRI NDT-600-24-3, " Manual Ultrasonic Examination of Straight Cylindrical Sections of BWR Feedwater Nozzles" (4) SwRI NDT-800-36-24, " Manual Ultrasonic Examination of Thin Wall Piping Welds" (5) SwRI NDT-600-3-53, " Manual Ultrasonic Examination of Pressure Piping Welds" b.

In addition to the review above, procedure NDT-600-3-53 was reviewed in the areas of compilation of required records and procedure Technical content relative to: type o apparatus, extent of coverage including beam angles and scanning techniques, calibration requirements, search units, DAC curves, transfer requirements, reference level for monitoring discontinuities, method of demonstrating penetration, levels for evaluation and recording indications, and acceptance standards.

Procedure NDT-200-1-47, " Liquid Penetrant Examination, Color Contrast c.

Method", was reviewed in the areas of compilation of required records and procedure technical content relative to: method consistent with ASME code, specification of brand names of penetrant materials, speci-fication of limits for sulfur and total halogens for materials, pre-examination surface preparation, minimum drying time following surface cleaning, penetrant application and penetration time, tempera-ture requirements, solvent removal, method of surface drying, type of developer and method of application, examination technique, technique for evaluation, acceptance standards, and requalification requirements.

d.

In addition to the review above, procedure NDT-300-1-18 was reviewed in the areas of procedure technical content relative to: examination method, surface preparation, use of color contrast particles, examina-tion divertions and overlap, pole spacing, and acceptance criteria.

Within the areas inspected, no items of noncompliance or deviations were identified.

7.

Inservice Inspection - Observation of Work and Work Activities (Unit 2)

The inspector observed the ISI activities described below to determine whether these activities were being performed in accordance with regulatory requirements and licensee procedures. See paragraph 5 above for the appli-cable code.

Personnel qualification records for one I'* ct I, one Level II, and one a.

Level III examiner wera reviewed.

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b.

In process Ultrasonic (UT) inspection, including portions of calibration and review of associated in process data sheets, was observed for the following welds:

Line Weld Examination 2B31-IRC-28A

Lamination 2E11-2RHR-POP-A

Lamination, 0, 45*

2E11-2RHR-24A-BP

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I The inspection was compared with applicable procedures in the following areas:

(1) Availability of and compliance with approved NDE procedures (2) Use of knowledgeable NDE personnel (3) Use of NDE personnel qualified to the proper level (4) Recording of inspection results (5) Type of apparatus used (6) Extent of coverage of weldment (7) Calibration requirements (8) Search units (9) Beam angles (10) DAC curves (11) Reference level for monitoring discontinuities (12) Method for demonstrating penetration (13) Limits for evaluating and recording indications (14) Recording significant indications (15) Acceptance limits c.

In process liquid penetrant (PT) examination was observed for the following welds:

Line Weld 2B31-IRC-28A 12BC/2B31-IRC-4AA 2B31-1RC-4AA

2B31-1RC-28A 15BC/2B31-IRC-4AB 2B31-1RC-4AB

2B31-1RC-4BC

2B31-1RC-28B 12BC/2B31-IRC-4BC The inspection was compared with the applicable proc'edure in the following areas:

(1) Availability of and compliance with approved NDE procedures (2) Use of knowledgeable NDE personnel (3) Use of NDE personnel qualified to the proper level i

(4) Recording of inspection results

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i (5) Method consistent with procedure (6) Penetrant materials identified and consistent with code l

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(7) Surface preparation (8) Drying time following surface cleaning (9) Pentrant application and penetration time (10) Renewal of penetrant (11) Developer application including drying time prior to application (12) Examination technique and time between developer application and evaluation (13) Reporting of examination results During inspection of weld 12BC/2B31-1RC-4AA, a 1/8" linear star shaped indication was found in the base material just outside the weld. The weld is where the 4" bypass line " saddle" welds into the 28" recircu-lation line. The indication is in the " saddle" base material. By the end of the inspection, approximately 0.100" of metal had been removed and the indication was still present. Approximately another 0.120" could be removed before reaching minimum wall thickness. The licensee was evaluating the indication prior to further grinding. This item is identified as item number 366/80-13-03 for inspector followup to review licensee's final disposition of the indication.

Within the area inspected, no items of noncompliance or deviations were identified.

d.

Inprocess magnetic particle (MT) examination was observed for the pipe lug welds SPL-1A, 2A, 3A, 4A, 5A, and 6A on line 2E21-2CS-12A. The inspection was compared with the applicable procedure in the following areas:

(1) Availability of and compliance with approved NDE procedures (2) Use of knowledgeable NDE personnel (3) Use of NDE personnel qualified to proper level

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(4) Recording of inspection results (5) Examination method (6) Surface preparation (7) Color contrast particles (8) Examination directions and overlap (9) Pole spacing (10) Acceptance criteria Within the areas inspected, no items of noncompliance or deviations were identified.

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8.

Welding Maintenance Program (Units 1 and 2)

The inspector reviewed the licensee's program for maintenance welding. The review included a review of the applicable procedures and review of a sample of in process records for one " Maintenance Request" (MR) as follows:

a.

Procedures Any mainte0ance welding (regardless of code - ASME, B31.1, AWS, etc.)

is accomplished through the use of the MR and the " Weld Process Sheets".

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The QC department reviews all MR's and provides Weld Process Sheets as needed. The Weld Process Sheets provide welding and inspection require-ments for each weld. The inspector reviewed the following procedures which control the welding program through the use of MR's and Weld Process Sheets:

HN:

s, Revision 13, " Maintenance Request (MR)"

HNP-809, Revision 6, " Plant Modification, Approval and Implemen-tation HNP-821, Revision 5, " Quality Control Work Inspection" HNP-824, Revision 3, " Control of Special Procesues" HNP-6904, Revision 3, " Maintenance Welding" HNP-6915, Revision 2, " Weld Process Sheets" b.

Records The inspector reviewed the in process welding and inspection records for MR number 2-79-2816 which covered modification to the Control Rod Drive system for Unit 2.

The inspector also reviewed personnel quali-fication records for inspection personnel who inspected the welding associated with this modification. This review revealed that the inspectors were furnished by Butler Services and. certified by Daniel Construction Jompany and/or Alabama Power Company. There were no records to show certification by Georgia Power Company. According to paragraph B.I.d(2) of HNP procedure HNP-824, " Control of Special Processes" and HNP NDE procedures, " Personnel performing nondestruc-a tive testing shall be certified in accordance with HNP-823 and SNT-TC-1A."

Certification by a previous employer does not meet HNP procedure HNP-824 nor paragraph 9 and 10 of SNT-TC-1A. This matter is considered to be noncompliance with Criterion V of 10 CFR 50, as implemented by paragraph 17.2.5 of the Hatch 2 FSAR; is identified as item number 366/80-13-02, Failure to certify welding and NDE inspactors; and is categorized as an infraction.

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Within the areas inspected, no items of noncompliance, except as noted in paragraph 8.b, or deviation were identified.

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