IR 05000321/1982008
| ML20058C976 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/15/1982 |
| From: | Coley J, Crowley B, Herdt A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058C883 | List: |
| References | |
| 50-321-82-08, 50-321-82-8, 50-366-82-08, 50-366-82-8, IEB-80-08, IEB-80-8, NUDOCS 8207260497 | |
| Download: ML20058C976 (17) | |
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- C. T. Jones, Assistant 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
- J. M. Watson, Senior QA Field Representative
- J. A.-Edwards, Senior Regulatory Specialist
- S. B. Tipps, Superintendent Regulatory Compliance F. M. Burkette, Junior Engineer J. F. Banegas, Senior QC Specialist Other licensee employees contacted included security force members and of fice personnel.
Other Organizations
- T. N. Epps, ISI Group Supervisor, Southern Company Services (SCS)
- J. J. Glass, Site Engineer, SCS
- J. M. Agold, Project Manager, Southwest Research Institute (SwRI)
L. C. Reaves, Team Supervisor, SwRI
- R. F. Rogers
- P. Holmes-Ray
- Attended exit interview 2.
Exit Interview i
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The inspection scope and findings were summarized on March 5 and 19, 1982,
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with those persons indicated in paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings listed below.
(0 pen) Inspector Followup Item 321,366/82-08-01, SCS organizational proce-dure for PSI /ISI, paragraph 5.c.
i 8207260497 820716 PDR ADOCK 05000321 G
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(0 pen) Inspector Followup Item 366/82-08-08, Disposition of PT results on
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weld 2E11-1RHR-20-RS-1BC/2G21-1RWCU-6D-1, paragraph 7.c.
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(0 pen) Violation 366/82-08-09, Failure to follow procedures for fitup inspection of welds, paragraph 8.a.
(0 pen) Inspector Followup Item 321,366/82-08-02, Review of CB&I RT procedure RT2, paragraph 9.b.
(0 pen) Inspector Followup Item 321,366/82-08-03, Implementation of Regula-tory Guide 1.150, paragraph 11.b.
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(0 pen) Inspector Followup Item 321,366/82-08-04, Implementation of NUREG 0313 - Generic Letter 81-03, paragraph 11.b.
(0 pen) Inspector Followup Item 321,366/82-08-05, Implementation of NUREG 0619 - Generic Letter 81-11, paragraph 11.b.
(0 pen) Inspector Followup Item 321,366/82-08-06, Revision to SCS MT proce-dure to clarify powder removal method, paragraph 6.d.
(0 pen) Unresolved Item 321,366/82-08-07, Inadequate radiographic equipment in film viewing facility, paragraph 12.c.
3.
Licensee Action on Previous Inspection Findings
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(Closed) Unresolved Item 321,366/81-08-01, Eye examinations for welding inspectors.
This item pertained to the fact that final visual weld inspections were performed by CB&I welding QA supervisors who are not required to pass an eye examination. The visual inspections, performed by the welding QA supervisors (inspectors) are not code required inspections.
If the code requires a visual inspection, an NDE examiner, who has an eye examination, performs the test. For the work CB&I is performing, all welds receive some final NDE by an NDE examiner over and above the inspection performed by the welding QA supervisor. This item is considered resolved.
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. New unresolved items identified during this inspection are discussed in paragraph 12.c.
5.
Inservice Inspection - Review of Program (Unit 2)
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The inspectors reviewed the licensee's inservice inspection (ISI) program for the current outage in the areas indicated below. The requirements for ISI are specified in paragraph 5.2.8 of the FSAR.
In accordance with these requirements, the 1974 edition including S75 addenda of Section XI of the i
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ASME Boiler and Pressure Vessel Code is the applicable code.
Southern
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Services Company (SCS) has taken over responsibility as ISI contractor.
l The changeover from the previous contractor is still in process. For the current outage, the inspection responsibilities are divided as follows:
Class 2 examinations and selected Class 1 examinations.
SCS
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Manual and mechanized Class 1 examinations GE
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Examination of 50*o of recirculation system thermal sleeve attach-ment welds located in the reactor vessel inlet nozzles.
a.
The inspectors reviewed the SCS and SwRI programs listed in b. below to determine whether the programs had been approved by the licensee.
b.
The inspectors reviewed the following Georgia Power Company, SCS, and SwRI documents relative to the ISI Program:
(1) " Examination Plan for the 1982 Inservice Examination of Selected Components at Edwin I. Hatch Nuclear Plant, Unit 2",
Final Plan SwRI Project 17-6888 (2) SCS
" Nondestructive Examination Outage Plan, Edwin I. Hatch Nuclear Plant Unit 2, First Quarter 1982" (3) SwRI Nuclear Projects Procedure (NPOP) IX-FE-101-2, " Deviations to Nuclear Projects Operating Procedures" (4) SwRI NPOP IX-FE-103-2, " Weld Joint Identification Marking on Nuclear Power Plant Piping" (5) SwRI NPOP IX-FE-104-2, " Measuring and Recording Search Unit Location and Maximum Signal Amplitude Data During Ultrasonic Weld Examination" (6) SwRI NPOP IX-FE-116-0, " Recording Data From Direct Visual, Liquid Penetrant, and Magnetic Particle Examinations" (7) SwRI NPOP IX-FE-117-1, " Recording Indications From Ligaments, Bolting, and Piping Examinations" (8) SwRI NPOP IX-FE-119-0, " Measuring and Recording Search Unit Data During Ultrasonic Examination of Pressure Vessel Welds" (9) SwRI NPOP, X-FE-101-1, "Onsite NDE Records Control" (10) SwRI NPOP, XIII-AG-101-1, " Control of Nuclear Inspection Equipment and Materials" (11) SwRI NPOP, XVII-AG-101-1, " Data Storage and Retrieval"
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(12) SwRI Nuclear Quality Assurance Procedure (NQAP) 1-1, Revision 2,
" Introduction" (13) SwRI NOAP 2-1, Revision 2, " Organization" (14) SwRI NQAP 3-1, Revision 2, " Procedures, Instructions and Drawings" (15) SwRI NQAP 9-1, Revision 2, " Document Control" (16) SwRI NQAP 10-1, Revision 2, " Test and Inspection Equipment Con-trol" (17) SwRI NQAP 11-1, Revision 2, "Special Process Control" (18) SwRI NQAP 11-2, Revision 2,
" Procedure for Certifying Visual Examination Personnel" (19) SwRI NQAP 13-1, Revision 2, " Deviation and Nonconformance Control" (20) SwRI NQAP 14-1, Revision 2, " Corrective Action Control" (21) SwRI NQAP 15-1, Revision 2, " Audits" (22) SwRI NQAP 15-2, Revision 2, " Qualification and Certification of Quality Assurance Auditors" (23) SwRI NQAP 15-3, Revision 2, " Qualification and Certification of Quality Control Inspection and Testing Personnel" (24) HNP QA-01-05, Revision 5, " Job Functions and Responsibilities /QA Supervisor" (25) HNP QA-03-02, Revision 6, " Training and Personnel Qualifications" (26) HNP QA-05-06, Revision 8, " Site Preoperational Startup and Opera-tional Audits" (27) HNP " Plant Hatch Tentative Audit Schedule" dated 1981-1982 (28) HNP "QA Audit Plan for In-Service Inspection Program" (29) HNP-6, Revision 8, " Plant Review Board Administrative Procedures" (30) HNP-9, Revision 18, " Procedure Writing and Control" (31) HNP-10, Revision 12, " Document Distribution and Control" (32) HNP-820, Revision 12, " Plant Records Management" (33) HNP-904, Revision 4, " Inservice Inspection Program"
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(34) HNP-907, Revision 2, " Inservice Inspection Visual Examination 4'
Surveillance Procedure for Classes 1,-2, and 3 Pipe Supports"
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(35) SCS ADM-H/F-205, Revision 0, " Indication Notification" (36) SCS ADM-H/F-206, Revision 0, " Deviations to SCS Inservice Inspec-tion and Inservice Testing Procedures, Plans, and Programs"
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(37) SCS ADM-H/F-207, Revision 0, " Final Report Preparation" (38) SCS ADM-H/F-208, Revision O', " Data Control"
(39) SCS ADM-H/F-200, Revision 0, " Plan Revisions"
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(40) SCS ADM-H/F-450, Revision 1, " Qualification of Manual Ultrasonic Equipment" l
(41) SCS ADM-H/F-204, Revision 0, " Nondestructive Examination Outage Plan" (42) SCS GEN-H/F/V-100, Revision 0, " Procedure Numbering System" j
(43) SCS GEN-H/F/V-101, Revision 0, " Filing System" (44) SCS GEN-H/F/V-102, Revision 1, " Procedure Development and Revi-
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sion"
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(45) SCS Engineering Policies and Procedure, Procedure 7-3, Revision 0,
" Quality Assurance Audits of SCS Engineering Procedures"
(46) SCS QA Department Procedure 34.7-1, Revision 8, " Quality Compli-
ance Audits of SCS Engineering" r
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(47) SCS QA Department Procedure 34.7-3, Revision 3, " Quality Audits of SCS Engineering Procedures" (48) SCS QA Department Procedure 34.2-0, Revision 5, " Quality Assurance
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Department Organization" (49)
SCS QA Department Procedure 36.2-50, Revision 3, " Quality Assur-ance Department Indoctrination and Training" (50) SCS QA Department Procedure 34.2-51, Revision 4, "QA Auditor Cer-tification" l
(51) SCS AUX-H/F/V-302, Revision 0, "Preservice and Inservice Inspec-
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tion Documentation" (52) SCS AUX-H-301, Revision 1, Measuring and Recording Search Unit
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Location During Manual Ultrasonic Examinations"
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These documents were reviewed to assure that procedures and plans had been established (written, reviewed, approved and issued) to control
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and accomplish the following activities:
Organizational structure including qualifications, training,
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responsibilities, and duties of personnel responsible for ISI Audits including procedures, frequency, and qualification of
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personnel
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General QA requirements including examination report, deviations from previously established program, material certifications and identification of components to be covered Work and inspection procedures
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Control of processes including suitably controlled work condi-tions, special methods, and use of qualified personnel
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Corrective action
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Document control
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Control of examination equipment
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Quality records including documentation of indications and NDE findings, review of documentation, provisions to assure legibility
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and retrievability, and corrective action
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Scope of the inspection including description of areas to be examined, examination category, method of inspection, extent of examination and justification for any exception
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Definition of inspection interval and extent of examination
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Qualification of NDE personnel
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Controls for generation, approval, custody, storage and mainten-i ance of NDE records c.
In reviewing the SCS program and procedures of paragraph b. above, the
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inspectors noted that the program does not contain an overall admin-istrative/ organizational procedure for PSI /ISI detailing qualification
and responsibility for the various individuals and/or organizations involved.
Various administrative and NDE procedures specify certain responsibilities but there is no " tie-together" procedure.
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acknowledged that this area needs clarification and agreed to issue a i
procedure.
This item is identified as inspector follow-up item 321, j
366/82-08-01, SCS organizational procedure for PSI /ISI.
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In addition, the inspectors noted that procedure AUX-H/F/V-302 requires sign-off of the " Reviewed By" blank on all inspection data forms but did not designate what level of review was required.
An immediate procedure deviation was -issued to specify the type qualification required for the individual making the review.
Within the areas inspected, no violations or deviations were identified.
6.
Inservice Inspection - Review of Procedures (Unit 2)
The inspectors 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.
a.
The following procedures-were reviewed in the areas of procedure approval requirements for qualification of NDE personnel and compil-ation of required records:
(1) SCS UT-H-401, Revision 0, " Manual Ultrasonic Examination of Full Penetration Piping Welds (Thin Wall)"
(2) SCS PT-H/F/V-600, Revision 0, " Visible, Solvent-Removable, Liquid Penetration Examination Procedure" (3) SCS MT-H/F/V-500, Revision 0,
" Dry Powder Magnetic Particle Examination, Yoke Method" (4) SCS UT-H-400, Revision 1, " Manual Ultrasonic Examination of Full Penetration Piping Welds (Regular Wall)"
(5) SCS MT-H/F/V-501, Revision 0, " Wet Fluorescent Magnetic Particle Examination, Yoke Method" b.
In addition to the review above, procedure UT-H-401 v 2 reviewed in the areas of compilation of required records and procedure content relative to:
type of apparatus, extent of coverage including beam angles and
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scanning techniques, calibration requirements, search units, DAC curves, transfer requirements, reference level for monitoring dis-continuities, method of demonstrating penetration, levels for evalu-
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ation and recording indications, and acceptance standards. During this review, the inspector noted that paragraph F.6.b was not clear as to the direction of transducer movement for the transverse angle beam scan.
The procedure was immediately changed by deviation notice to clarify this point. No inspections had been performed.
c.
Procedure PT-H/F/V-600 was reviewed in the areas of compilation of required records and procedure technical content relative to: method j
consistent with ASME code, specification of brand names of penetrant materials, specification of limits for sulfur and total halogens for material s, pre-examination surface preparation, minimum drying time following surface cleaning, penetrant application and penetration i
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time, temperature requirements, solvent removal, method of surface drying, type of developer and method of application, examination technique, technique for evaluation, acceptance standards, and requal-ification requirements. During this review, the inspector noted that the procedure allowed surface preparation by blasting (grit or sand)
provided the blasting did not close discontinuities. The procedure did not specify a method for determining whether or not discontinuities were closed. The procedure was immediately changed by deviation notice to delete blasting as an acceptable surface preparation method. No inspections had been performed.
d.
Procedure MT-H/F/V-500 was reviewed in the areas of compilation of required records and procedure technical content relative to:
exami-nation method, surface preparation, use of color contrast particles, examination directions and overlap, pole spacing, and acceptance cri-teria. During this review, the inspectors noted that the procedure, although specifying different colors of particles, did not clearly specify that the color of particles contrast with the color of mater-tals being tested. This point was immediately clarified by issue of a procedure deviation notice. No inspections had been performed.
The inspectors further noted during observation of MT inspections, that the procedure is not clear as to the method to be used for removal of excess powder. SCS agreed that this area of the procedure needs clarifying and stated that after a determination is made as to the best method for powder removal, the procedure will be revised.
This matter is identified as inspector followup item 321,366/82-08-06, Revision of SCS MT procedure to clarify powder removal method.
e.
NDE procedures for the areas of examination listed below were examined to determine whether the procedures were consistent with licensee Technical Specification commitments and specified the examination category, method of examination, and the extent of examination.
(1) Class 1 Pressure Retaining Piping (2) Class 2 Pressure Retaining Piping (3) Class 1 Valve Bolting (4) Reactor Vessel Welds
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Within the areas examined, no violations or deviations were identified.
7.
Inservice Inspection - Observation of Work and Work Activities (Unit 2)
The inspectors 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 applic-able code.
a.
Personnel qualification records for three Level I, four Level II, and one Level III examiners were reviewed.
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b.
In process ultrasonic (UT) inspections, including malibro.tien was observed for the following welds:
Q CcItractor Weld Examination'~
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2E11-1RHR-24A-R-10LD0 Base Material Lamination
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2E21-2CS-10A-1 0 and 45 Scans jfSCS
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The inspections were compared with applicable procedures in the
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following areas:
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(1) Availability of and compliance with approved NDE procedures (2) Use of knowledgeable NDE personnel
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(3) Use of NDE personnel qualified to the proper level (4) Recording of inspection results
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(5) Type of apparatus used (6) Extent of coverage of weldment
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(7) Calibration requirements (8) Search units
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(9) Beam angles (10) DAC curves
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(11) Reference level for monitoring discontinuitie's (12) Method for demonstrating penetrati?n,
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Limits for evaluating and recording indicat. ions (14) Recording significant indicationsN
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(15) Acceptance limits c.
In process liquid penetration (PT) inspectioit was observed for the following welds:
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lontracto_r Weld
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2831-1RC-28A-12BC/2B31-1RC-4AA SwRI
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SwRI 2B31-1RC-28A-15BC/2B31-1RC-4AB
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2E11-1RHR-20-RS-3 LU-I
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2E11-1RHR-20-RS-3 SCS,
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The inspections were compared with applicable precedurcs' in the following areas:
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(1) Availability of and compliance with approved NDE Procedures (2) Use of knowledgeable NDE personel
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(3) Use of NDE personnel qualified to the proper level
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(4) Recording of inspection results
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(5) Method consistent with procedure (6) Penetrant materials identified and consistent with ASME Code i
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(7) Certification of sulfur and halogen content for penetrant materials
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(8) Surface preparation
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(10) Penetrant application and penetration time
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(13) Drying of surface prior to developing
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removal (15) Time interval between developer application and evaluation
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(16) Evaluation technique l
.(17) Reporting examination results
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During inspection of weld 2E11-1RHR-20-RS-1BC/2G21-1RWCU-60-1, the s'-
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inspector noted that for a large portion of the weld, the weld edges i
were rough and held excess penetrant. This condition was reported on
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the inspection report.
A review of previous inspection reports revealed that this condition had been noted on a previous inspection.
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The disposition on the previous inspection report did not clearly
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resolve the condition. The Georgia Power level III PT examiner agreed
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to evaluate the condition and determine if the inspection results had i
been properly dispositioned.
This matter is identified as inspector followup item 366/82-08-08, Disposition of PT results on weld 2E11-L 1RHR-20-RS-1BC/2G21-1RWCU-6D-1.
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Ouring PT inspection of weld 2B31-1RC-28A-12BC/2B31-1RC-4AA, the base
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material defect detected during the 1980 outage (See RII report 366/
80-13, item no. 366/80-13-03) was observed. The indication has not
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changed,
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In process magnetic particle (MT) inspection was observed for weld
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2B21-1MS-240-18PS and compared with applicable precedures 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
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(4) Recording of inspection results
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(5) Examination method i
(6) Contrast of dry powder particle color with background and surface
temperature
(7) Examination overlap and directions (8) Pole spacing and lifting power for yoke method (9) Acceptance criteria
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During observation of this inspection, the inspector noted that excess powder was being removed by the examiner blowing with his mouth. When questioned by the inspectors, the examiner demonstrated that small indications could not be disturbed using this method. Although ASME Section V only specifies that a " gentle air stream" be used and does not specify any particular method, the method used above doesn't offer much control. As noted in paragraph 7.c above, the SCS MT procedure will be revised in this area.
e.
In process visual (VT) inspection was observed for bolting on valves 2E11-F067 and 2E11-F060A and compared with the requirements of proce-dure HNP-916 in the following areas:
(1) Type of examination used (2) Lighting levels (3) Surface cleanliness (4) Tighteness (5) Acceptance standards Within the areas inspected, no violations or deviations were identified.
8.
Welding (Torus Modification) (Unit 2)
The inspector examined the licensee's welding practices as indicated below relative to torus modifications to determine whether these activities were in conformance with regulatory requirements and applicable industry codes.
the torus modifications for Unit 2 are being accomplished by CB&I in accord-ance with SCS specification SS-2114-02, Revision 1, " Modification of Torus and its Internals".
In accordance with this specification, the applicable code is the ASME Boiler and Pressure Vessel Code,Section III, Subsections NC, ND, NE, and NF,1977 Edition including Addenda through S79.
a.
The inspector observed the following welds in process:
Various Welds of Gusset Plates
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T-Quencher Support in Bay 12/13; Contract Dwg. 15, Rev. 9 Various Structural Welds
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T-Quencher Support in Bay 14; Contract Dwg.16, Rev. 3 Slip Joint (Outboard From Reactor) -
T-Quencher Bay 1; Contract Dwg. 8, Rev. 5 Various Welds (Stiffening)
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Downcomer Piping Az. 128 ;
Record Dwg. R54, Rev.1 Various Welds (Stiffening)
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Downcomer Piping Az. 135*;
Record Dwg. R55, Re L
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Various Welds (Stiffening)
Downcomer Piping Az.141*;
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(Example - Weld B4)
Record Dwg. RS6, Rev. 1 The welding was examined for procedure compliance in the following areas:
(1) Availability of welding procedures, instructions, and drawings at work stations (2) Welding procedure assignment (3) Welding technique and bead sequence (4) Welding material is specified type and traceable (5) Weld joint geometry, surfaces to be welded, fitup, etc.
(6) Alignment and assembly of parts to be welded (7) Preheat and interpass temperature (8) Condition of welding equipment (9) Interpass cleaning (10) Temporary attachments During observation of the above welding, the inspectors questioned the joint geometry for weld B-4 on record Dwg. R56. The fitup had been signed off by the Welding QA Supervisor (inspector).
However, one member of the joint, a full penetration butt weld welded from one side, was cut square and the other member slightly beveled. When the welding inspector who had accepted the fitup on the joint was questioned about the acceptability of the joint geometry, he was not familiar with drawing requirements. A review of the drawing revealed that a 15'
bevel is required on both members of the joint. Division 4, Section 8, paragraph 8.5.3 of CB&I " Nuclear Quality Assurance Manual For ASME Section III Products" requires that the welding QA Supervisor assure that joints are properly fitup and aligned prior to welding. This failure to follow procedures is considered to be in violation of Criterion V of Appendix B to 10 CFR 50 and is identified as item number 366/82-08-09, Failure to follow procedures for fitup inspection of welds.
b.
The inspector observed the following completed welds:
Weld B-10, record dwg. R33, Rev. 2 Weld RHR #4, record dwg. R19, Rev. 2
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Slip Joint (Reactor Side) Bay 14, Contract dwg. 8, Rev. 5 The welds were examined in the areas of:
(1) Surface finish and appearance (2) Reinforcement (3) Removal of temporary attachments (4) Surface defects c.
The inspector reviewed welder performance qualification records for the in process welds of paragraph a abov *
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Within the areas inspected, no violations or deviations were identified, except as noted in paragraph a.
9.
Nondestructive Examination (NDE) (Torus Modification) (Units 1 and 2)
The inspectors examined the licensee's NDE practices and procedures as indicated below relative to torus modifications to determine whether these activities and procedures are in conformance with regulatory requirements and applicable industry codes.
See paragraph 8 above for the applicable code.
a.
The inspectors reviewed the training and qualification records for two Level II examiners b.
The inspectors reviewed CB&I radiographic (RT) procedure RT 2, Revision 5, "100% Radiographic Examination Procedure for Welds", in the areas of:
(1) Type of material (2) Material thickness range (3) Type of radiation source and size or strength (4) Film brand or type (5) Minimum source to film distance (6) Blocking or masking technique (7)
Intensifying screens and filters (8) Qualification requirements (9) Surface condition (10) Processing requirements (11) Quality of radiographs (12) Film density limits (13) Radiograph identification (14) Location markers (15) Testing for back scatter (16) Geometrical unsharpness limitations (17) Selection of penetrameter (18) Evaluation and disposition of radiographs This procedure was reviewed in the RII office and the following areas were identified for followup at the site:
Paragraph 5.5.2 of the procedure states that a dark image of the lead letter "B" is acceptable on the radiograph, ASME Section V does not allow any image of the lead letter "B" on the film.
It is not clear how you could get a dark image of the lead letter "B" The procedure does not appear to adequately cover " Minimum Source to Film Distance" and " Screens Used" as specified in Section T-282 of ASME Section V.
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Further review of this procedure at the site is identified as an inspector followup items 321,366/82-08-02, Review of CB&I RT procedure RT 2.
c.
The inspectors observed MT inspection of various gusset plate welds on
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Unit 2 T-Quencher support in Bay 1/2, contract dwg.15, revision 9.
MT of welds on Bay 2 side were observed and compared with applicable MT procedure MT 13X, Revision 1.
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d.
The inspectors observed in process Unit 2 welds B-10 on dwg. R33, revision 2 and RHR #4 on dwg. R19, revision 2 during RT inspection.
The welds were visually inspected and preliminary film on weld B-10 reviewed.
Within the areas inspected, no violations or deviations were identified.
10.
Inservice Testing Program - Pumps and Valves (Units 1 and 2)
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The inspectors met with licensee representatives responsible for Inservice
Testing (IST) program for pumps and valves and briefly discussed the program requirements, organization, and implementation. The applicable code is the ASME ' Boiler and Pressure Vessel Code,Section XI,1974 Edition including Addenda through S75. Hatch Plant Procedure HNP-908, revision 1, has been j
issued as the site implementing procedure.
Within the areas inspected, no violations or deviations were identified.
11.
Inspector Followup Items (Units 1 and 2)
a.
Previous Items (Closed) Inspector Followup Item 321,366/81-08-02, Clarification of Georgia Power Company procedure for qualification of NDE personnel.
Revision 8 to procedure HNP-823 has been issued and is divided into one set of requirements for ANSI N45.2.6 and another set of requirements
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for SNT-TC-1A. This item is considered resolved.
i b.
The following items were identified for followup during future inspec-tions:
(1) (0 pen) Inspector Followup Item 321,366/82-08-03, Implementation of
Regulatory Guide 1.150. The licensee is of the opinion that this regulatory guide does not apply to BWR plants. This matter will
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be reviewed further during future inspections.
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(2) (0 pen) Inspector Followup Item 321,366/82-08-04, Implementation i
of NUREG 0313 - Generic letter 81-03. The licensee's letter of response dated June 19, 1981 has been reviewed. Implementation of this response will be reviewed further during future inspections.
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(3) (0 pen) Inspector Followup Item 321,366/82-08-05, Implementation of l
NUREG 0619 - Generic Letter 81-11.
The licensee's letters of
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response dated January 22, 1981 and September 1, 1981 have been i
reviewed.
Implementation of these responses will be reviewed
further during future inspections.
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12.
IE Bulletins (IEB's)
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(0 pen) IEB 80-BU-08, Examination of Containment Liner Penetration Welds,
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Units 1 and 2.
This Bulletin described a problem where backing ring type weld joints had been used for welding primary piping containment penetration flued head fittings to the outer containment liner sleeves.
For some
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plants these welds were ultrasonic (UT) inspected in lieu of radiographic (RT) inspected.
Later RT inspection revealed defects in excess of code requirements.
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a.
In response to the Bulletin, Georgia Power forwarded a letter dated
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November 3,1980 which provided a listing of fourteen (14) Unit I welds
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that had been liquid penetrant (PT) inspected in lieu of RT and 15
Unit 2 welds that had been PT and UT inspected in lieu of RT.
The
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inspector had the following questions concerning the listing for i
Unit 1:
(1) Was the ASME Boiler and Pressure Vessel Code,Section III, Nuclear Vessels, 1968 Edition used for Unit 1 penetration installation as stated in the Hatch FSAR Appendix K?
(2)
If the 1968 Edition of the ASME Code was used, did the licensees have an exception or waiver from the Code requirement to perform 100*; RT of single welded butt joints with backing rings?
(3) Was the NDE requirement of "HT" for penetration X-13B a misprint?
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If not, what does "HT" stand for?
(4) Why was penetration X-42 on this list when this penetration does not have a backing ring?
(5) Are there any other penetrations on the list that do not have backing ring type joints?
(6) Have penetrations been excluded from this list based on a drawing review in lieu of verification of construction weld joint records?
The licensee stated that answers to the above questions would be submitted to Region II in a supplemental response.
b.
As a result of a previous NRC inspection Georgia Power had committed to attempt to radiograph the flued head type penetrations. Radiography
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was to be undertaken during the respective maintenance / refueling outages for each unit. Georgia Power forwarded the results of this radiography and justification for not performing radiography when the
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RT appeared impractical, in a letter dated August 10, 1981.
The inspector reviewed the film for Unit 1 penetrations X-42, S-17, X-16A, X-8, and X-11. The results noted were either minimally readable or not
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readable. The licensee's justification for not radiographing penetra-tions listed in the letter dated August 10, 1981 appears satisfactory.
However, questiuns noted in paragraph a. above to be addressed by the i
licensee, and Unit 2 radiographs will be reviewed by the inspector before final disposition of the Bulletin.
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c.
During the radiographic review of the above film, the inspector noted j
that the high intensity light source on the licensee film viewer did not have an operable variable rheostat for controlling the light when low-density portions of the radiographs were being viewed.
The inspector also noted that the licensee did not have a densitometer in
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the viewing room. A densitometer and a variable intensity light source
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are required by the ASME Code,Section V, when viewing film.
The licensee stated that subcontractors viewing facilities are utilized
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when film are viewed for acceptance.
This practice of relying on subcontractor equipment is questionable since subcontractors are
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normally only onsite during fuel outages. Audits and problems, where film viewing equipment is needed, occur year-round and adequate equip-inent must be available to assure compliance with Code requirements.
This item is identified as unresolved item 321,366/82-08-07, Inadequate Radiographic Equipment in Film Viewing Facility.
i Within the areas examined, no violations or deviations were observed.
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