IR 05000321/1985026
| ML20138C366 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/01/1985 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138C338 | List: |
| References | |
| 50-321-85-26, 50-366-85-26, NUDOCS 8510220418 | |
| Download: ML20138C366 (15) | |
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A Meu UNITED STATES NUCLEAR REGULATORY COMMISSION
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REGION 11
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j 101 MARIETTA STREET, N.W.
- ATLANTA GEORGIA 30323 s
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Report Nos.: 50-321/85-26'and 50-366/85-26 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: OPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Conducted: September 9-13, 1985 Inspector:
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Date Signed Approved by:
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J. J B1 ei Section Chief
.Date' Signed Engi ee ing Branch Div si n of Reactor Safety
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SUMMARY Scope:
This routine, unannounced inspection entailed 39 inspector-hours on site
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in the area of maintenance welding and nondestructive examination (NDE) (Units 1 and 2).
Results: One violation was identified - Failure to follow inspection program for class 2 tubing welds - paragraph 5.b(4)(a) and 5.c(1)(b).
No deviations were
identified.
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8510220418 851003
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PDR ADOCM 05000321
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REPORT DETAILS 1.
Persons Contacted Licensee Employees H. C. Nix, Site General Manager T. V.~ Green, Deputy General Manager
- J. A. Bets 111, Acting Site General Manager
' *P. E. Fornel,- Manager of-Quality Assurance (QA)
C. T. Jones, Manager of Engineering J. Wilkes, Manager-of Special Projects
- D. A. McCusker, Superintendent of Quality Control (QC)
- G. A. Goode, Superintendent of Engineering and Services
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D. G. Morgan,' Nuclear Procurement Services Supervisor - Onsite
- S. J. Bethay, Regulatory Compliance Supervisor J. Hadden, QC Supervisor
- P. Norris, Senior Plant Engineer
- D. C. Garner, Senior QA Field Representative R. L. Hodges, Maintenance Forman - Retrofit J. Shuman, ATTS Site Project Engineer Other licensee employees contacted included craftsmen, engineers, te@nicians, QC inspectors security force members, and office personnel.
NRC Resident Inspector
- G. M. Nejfelt
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized -on September 13, 1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below.. No dissenting comments were received from the licensee.
(0 pen) Inspector Followup Item 321, 366/85-26-01, Examination on New Welding Program-paragraphs 5.a.,'5.b.(1)(c),5.b.(3)(a)and5.c.(1)(a).
(0 pen) ' Inspector Followup Item 321, 366/85-26-02, Review of Revised PT Procedure - paragraph 5.c.(2)(a).
(0 pen) Violation 321/85-26-03, Failure to Follow Inspection Program For Class'2TubingWelds-paragraphs 5.b(4)(a)and5.c.(1)(b).
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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 This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items were not identified during the inspection.
5.
Maintenance Welding and NDE (Units 1 and 2)
The inspector examined the welding and NDE activities described below relative to maintenance (including retrofit) to determine whether applicable code and regulatory requirements were being met.
In general, the governing code is ASME Boiler and Pressure Vessel Code (B&PV)Section XI,1980 Edition, W81 Addenda.
In addition, various editions and addenda of the following codes are being used:
ASME B&PV Code Section III ASME B&PV Code Section V ASME B&PV Code Section IX ANSI Standard 831.7 AWS Structural Welding Code 01.1 a.
Welding and NDE Program - General The inspector reviewed the welding and NDE program in general as defined by site Administrative ' Control (AC), General Maintenance (GM),
Inspection and Test (IT), and Quality Control (QC) procedures.
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At the beginning of the inspection, the licensee pointed out that as a i
result of site QA Audit Finding 85-TR-1/51, numerous problems with the l
welding program were identified. As part of the corrective action, the
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licensee decided to write and issue a new welding program.
The milestones for corrective action completion indicate that the program is to be developed by January 30, 1986, and implemented by March 31,
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1986.
At the time of the inspection, a group had been designated to i
develop the new program.
The group was in the process of getting organized.
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The inspector reviewed the existing welding control procedures and NDE i
procedures as described in paragraphs b. and c. below.
A number of areas where procedures are weak and/or need clarifying were identified.
These areas are discussed in this paragraph and in paragraphs b. and c.
below.
Discussions with licensee personnel revealed that the problem
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areas identified by the inspector were the type of problems that would l
be corrected in the new welding program.
The licensee further agreed l
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that problem areas iden'tified by the inspector would be evaluated and addressed as necessary in the new welding program.
Based on the fact that the licensee had identified problems with the welding program and
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corrective actions were in process, Inspector Followup Item (IFI) 321,
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366/85-26-01, Examination of New Welding Program, is identified.
The IFI encompasses the general problems areas listed below as well as the
problems listed in paragraphs b. and c. below.
The following general problem areas were identified:
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(1) There does not appear to be consistency in applying codes and/or specific editions / addenda of. codes (identified as part of QA audit
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finding). Examples are:
(a) Visual (VT) procedure 52IT-MNT-001-0 references ASME B&PV Section III, ASME B&PV Section V, and AWS D1.1 without
listing edition and addenda.
The procedure references
specific paragraphs in ASME Section III. However, acceptance
for socket weld size refers to requirements from ANSI B31.7.
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(b) Procedure 51GM-PQL-001-0 references ASME B&PV Section IX
without edition and addenda for qualification of welders. A i
statement in the procedure indicates that the latest edition and addenda apply.
However, in examination of qualification
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f activities, there is no evidence the latest edition and addenda are being used.
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(c) Procedure 51GM-MTL-002-0S for control of welding material references ASME Section III,1974 Edition, winter Addenda and AWS D1.1-75.
(d) NDE procedures reference codes as follows:
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ASME Section V, Latest Edition
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ASME Section III, 1974 Edition i
ASME Sections III and V. No
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Edition
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AWS D1.1, No. Edition 52IT-MNT-007-0 (MT)
ASME Section III, 1974 Edition-
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ASME Section V, 1974 Edition
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ANS1 B31.7, 1969 Edition
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ASME Section XI,1974 Edition,
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S75 Addenda
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i AWS D1.1.-72 i
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(e) The inspector tried to: establish the applicable code for the Analog Transmitter Trip System (ATTS) where welding was in process. The Design Change Request (DCR) references drawings which reference the original construction piping specifi-cation.
The piping specification references ANSI-831.7 as
.the applicable code. __ Other drawings refer to ASME Section III, Class 2 for the system.
Bechtel verbally indicated that the applicable code was the ASME B&PV Code Section III, 1980 Edition.
(2) The welding program does not detail how to obtain proper fitup for socket welds or how to inspect fitup of socket welds. The piping specification refers to the use of scribe lines.
(3) The drawings and welding procedures for the ATTS system do' not indicate the required weld size for the tubing socket welds.
The only way to obtain the required size is to refer to the VT procedure.
b.
Welding (55050 and 55100)
-(1) Welding Material Control (a) The inspector verified that the filler materials used for the welds observed (see paragraph (4) below) were the correct materials specified by the Welding Procedure Specification (WPS) and that in general filler materials specified on WPSs were compatible with specified base materials.
(b) The inspector performed the following verifications related to control and handling of welding material:
That the contractor had established procedures for
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purchasing, receiving, storing, disbursing, and handling of welding materials. The applicable procedures are:
GM procedure 51GM-MTL-002-05, R0, " Control of Welding Materials" AC procedure 50AC-MTLO3-0, R1,
" Warehouse Preservation, Handling, Shipping and' Storage of Materials and Equipment" AC Procedure 50AC-MTLO4-0, R0," Procurement of Materials and Services" QC Procedures 45QC-QCX0L-0, R1,
" Materials Receiving Inspection" l
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AC Procedure 50AC-MTL01-0, R1, " Control of Purchased Material"
i AC Procedure 50AC-MTLO2-0,R0, " Identification and Control of Materials and Equipment" That purchasing and receiving operations were conducted
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in accordance with applicable procedures.
Purchasing I
and receiving records for the welding materials listed below were reviewed.
That welding material storage and handling procedures
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contained requirements for environmental control and that actual practice followed these requirements.
The T&B rod room and the maintenance tool room were inspected ~ and weld material control observed during observation of welding (see paragraph (O below).
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That there were effective procedures for maintaining
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identification of welding materials and that procedures are enforced.
Identification control was inspected during observation ~ of welding (see paragraph (4) below).
That the welding material control system met the
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requirements. for the most restrictive application and personnel involved were knowledgeable of the system.
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That the method of disbursement of welding materials was
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effective and controlled in accordance with approved procedures.
l That required ASME Code tests were performed on each lot
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of welding material.
The procurement, receiving inspection and material certification documentation were i
reviewed for the following welding materials used for
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the welds listed is paragraph'(4) below.
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3/32" E7018 i
Ht. 422x7061 l
P. O. M54318 MIR 84-607
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1/8" E7018 Ht. 421L0131 P. O. E53530 i
MIR 80-736 1/16" ER308L Ht. 03064 L
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MIR 79-364
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(c) During review of procedure 51GM-MTL-002-0S, the inspector noted that paragraphs 4.3.6, 4.3.8, 7.2.2, 7.2.2.1 and 7.2.3 are not clear as to the moisture control requirements for each type of electrode.
This is part of IFI 321, 366/85-26-01 (see paragraph 5.a. above).
(2) Welding Procedures The inspector reviewed procedures to verify that the licensee had established procedures for preparation, qualification, approval, certification and issue of welding procedure specifications (WPSs).
The applicable procedure for qualification of welding procedures is GM procedure 51GM-MNT-011-0, RO, " Welding Procedure Qualifi-cation".
(3) Welder Performance Qualification (a) The inspector verified that the licensee had established procedures for qualification of welders and welding r
operators. The applicable procedure is:
GM procedure 51GM-PQL-001-0, R0, " Welder Performance Qualification" During review of the procedure, the inspector noted the following weaknesses:
More detail is needed for maintaining status of
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qualifications.
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The informal system for conveying to the foreman the
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current status of qualification needs to be formalized in a procedure.
The program does not clearly define how qualification
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limitations such as thickness are handled.
Under the present system, welders are qualified to a
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procedure (WPS) rather than to a test which would qualify for several WPSs.
However, the welders are not qualified to the full thickness of the WPS used for the qualification.
Records in the foreman's office, which are used to approve rod tickets, do not indicate
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qualification limits.
For qualifications using a combination of processes,
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welder qualification records do not indicate the
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l thickness welded with each process.
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The weld test shop does not have enough detailed
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instructions in plant procedures to qualify welders.. He
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must rely on his review of code requirements to obtain much of the detail he needs.
These problems are a part of IFI 321, 366/85-26-01 (see
paragraph 5.a. above).
(b) The inspector reviewed the system for maintaining welder qualification status.
This process is covered in the l
proceduresofparagraph(a)above.
(c) The inspector reviewed the qualification records and status records for the below listed welders relative to the field
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welds listed in paragraph (4) below.
BFP-41,
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BPF-1, BPF-7, NPF-14, BPF-5, and BPF-4 (4) Production Welding (Unit 1)
(a) The inspector observed in-process welding and reviewed in-process records on the following ATTS welds covered by'
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j DCR-81-138, MWO 1-84-4884:
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F 6711 F 6710 F 6715
'F 6716 F 6713 F 6718
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F 6709 F 6712 The welding was observed and the records reviewed to determine whether:
Work was conducted in accordance with a document which
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coordinates and sequences operations, references procedures, establishes hold points, and provides for production and inspection approval.
Weld identification and location were as specified.
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Procedures, drawings, and other instructions were at the work
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station and readily available.
WPS assignment was in accordance with applicable code
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requirements.
I Welding technique and sequence were specified and adhered to.
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Welding filler materials. were the specified type and
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traceable to certifications.
Weld joint geometry was in accordance with applicable
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procedure and was inspected.
Alignment of parts was as specified.
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Preheat and interpass temperatures were in accordance with
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procedures.
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Electrodes were used in positions and with electrical characteristics specified.
Shielding gas was in accordance with the welding procedure.
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Welding equipment was in good condition.
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Interpass cleaning was in accordance with applicable
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procedures.
Temporary attachments were removed in accordance with
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applicable procedures.
Gas put ging, if specified, was used in accordance with
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applicable procedures.
Process control system had provisions for repairs.
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Welders were qualified.
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No peening performed on root and surface layers.
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During observation of the above welding, the inspector noted that the root passes had been welded on all eight welds but the fitup inspection hold point had not been signed off on welds F 6709 and F 6718.
This is in violation of procedures 40AC-QCX01-0, Revision 0, Quality Control Inspection Program, and 50 AC-MNT01-0, Revision 2 Maintenance Program.
Paragraphs 5.3.2 and 8.6.1 of procedure 40AC-QCX01-0 require that work not proceed beyond inspection hold points and that completed inspections be documented in applicable procedures, inspection plans and QC inspection hold point sheets.
The violation is ider.tified as 321/85-26-03, Failure to Follow Inspection Program for Class 2 Tubing Welds.
See paragraph 5.c.(1)(b) below for another example of this violation.
l It should be noted that evidence (examiner's notes plus the fact j
that all eight welds were welded at one time on 2 very small assemblies) indicates that the inspections were made. The failure was to document the inspections.
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(b) Selected completed welds listed below were examined to verify by visual inspection that the following characteristics conformed to ASME Code and AWS Standard, as applicable, and applicable procedures.
-Weld surface finish and appearance.
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Transition between components of different diameter and
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thicknesses.
Weld reinforcement.
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Shape and size of fillet and socket welds.
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Weld' reinforcement.
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Removal of temporary attachments, arc strikes and weld spatter.
Finish grinding - absence of wall thinning.
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Absence of surface defects.
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Welds examined (DCR 81-138, MWO 1-84-4884):
Tubing Welds - F6703, F6704, F6705, F6706, F5884, F5883, F5882, F5881, F5844, F5847, F5832A Support welds - Supports A-18042-001, 002, 003, 004, 005, and 006 (Note:
These welds were painted.
There-fore, inspection was to the extent possible.)
In addition, to examination of the welds, the inspector reviewed the completed weld records including qualification /
certificatic, records for inspection personnel.
The inspector verified that approved NDE procedures in accordance with applicable codes were available and being used.
(See paragraph c. below).
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NDE (57050, 57060 and 57070)
(1) Visual (VT) Examination The inspector examined the VT activities described below relative to repair and replacement activities.
(a) The following procedure was reviewed to determine wnether the procedure had been approved and issued in accordance with the QA program:
IT procedure 521T-MNT-001-0, R0, " Visual Examination"
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In addition, the procedure was reviewed to determine whether the following parameters were specified and controlled in accordance with applicable requirements:
Method - direct visual, remote visual or translucent
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visual.
hydrostatic testing, fabrication Application
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procedure, visual examination-of welds, leak testing, etc.
How visual examination is to be perfomed.
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Type of surface condition available.
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Method of surface preparation, if any.
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Whether direct or remote viewing is used.
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i Special illumination, instruments, or equipment to be
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used, if any.
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Sequence of performing, examination, when applicable.
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Data to be tabulated, if any.
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Acceptance criteria are specified consistent with the
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applicable code and specific contract requirement.
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Reporting requirements.
During review of the procedure, the inspector noted the
following areas where clarification is needed and terminology
needs upgrading ar.d/or clarifying.
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Paragraph G.1 refers to " sufficient accuracy" relative
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to joint edge preparation.
The meaning of this term is i
not defined.
Paragraph G.2 refers to ASME NB-4232.1 for maximum
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allowable offset rather than 'specify the required offset.
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Paragraph G.3 requires that the joint geometry conform
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i to the welding procedure, when in fact drawings specify the joint geometry in many cases.
The meaning of paragraph G.4 is not clear.
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-Paragraph I.1 refers to " indications - that may be
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injurious to the part". The meaning of this term is not
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defined.
Paragraphs I.2 and J.1 give acceptance criteria which
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appear to be PT acceptance criteria.
Some of these
criteria are not applicable to VT acceptance.
Paragraph J.4.a refers to ASME NB-4426.2 for reinforce-l
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ment requirements rather than specify the required
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i reinforcement.
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Figure 2 only covers fillet weld sizes for socket welds.
Fillet weld sizes for structural fillets are covered on
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j-drawings.
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l The above procedural problems are a part of IFI 321,
366/85-26-01 (see paragraph 5.a. above).
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(b) The inspector observed in-process final VT inspection for the j
welds listed in paragraph 5.b.(4)(a) above. The inspections l
were observed to determine whether:
l Applicable drawing, instruc'tions or travelers clearly
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specified the test procedure to be used.
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Required tools and examination aids were available.
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Areas, locations and extent of examination were clearly
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defined.
Test attributes were as specified in the applicable i
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procedure.
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Defects were evaluated in accordance with procedure
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requirements, correct acceptance criteria were used and the inspection results properly reported.
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Relative to the above examination, the inspector questioned
the examiner relative to the required fillet weld size for
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the tubing socket welds.
The examiner stated that the
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requirements were to have the fillet weld legs approximately
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equal with lengths equal to the height of the fitting t
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The examiner was not aware of the requirement in
j procedure 521T-MNT-001-0 that the fillet leg size be 1 1/4t i
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minimum.
Paragraphs 8.5.2 of procedure 40AC-QCX01-0, requires that QC examiners perform inspections in accordance with approved procedures.
This failure to inspect in accordance with the approved procedure is another example of Violation 321/85-26-03 identified in paragraph 5.b.(4) above.
It should be noted that, although the examiner was not aware
of the procedure acceptance criteria, the acceptance criteria being used would insure the correct weld size for the subject welds.
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(c) The inspector reviewed VT inspection records and performed VT inspection of the welds listed in paragraphs 5.b.(4)(a) and
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5.b.(4)(b) above.
(d) VT qualification records for the examiners who inspected the welds identified in paragraph (c) above were reviewed.
(2) Liquid Penetrant (PT) Examination The inspector examined the PT activities described below relative to maintenance activities.
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(a) IT procedure 52IT-MNT-003-0, R0,
Examination Procedure" was reviewed to determine whether the procedure had been approved and issued in accordance with the QA program.
In addition, the procedure was reviewed to j
determine whether the following parameters were specified and controlled in accordance with applicable requirements:
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Method consistent with applicable codes
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Specification of brand names and types of penetrant
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materials Specification of limits of sulfur and total halogens for
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materials
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Pre-examination surface preparation and cleaning
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Minimum drying time following surface cleaning
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Penetrant application and penetration time
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Temperature requirements -
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Solvent removal
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Method and time of surface drying prior to developing
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Type of developer and method of application
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Examination technique
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Required Lighting
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Technique for evaluation
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Acceptance standards Reporting requirements
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Requalification Requirements During the above review, the inspector noted the following areas where the PT procedure needs clarifying:
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The procedure allows grit blasting _for surface preparation. ASME section V cautions that grit blasting should not be used.
The procedure does not clearly state that the
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temperature requirement is 60 F to 125 F.
The procedure does not address lighting requirements for
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the examination.
The licensee anreed that the procedure needed to be clarified in the above areas and that the procedure would be revised.
Pending review.of the revised procedure, IFI 321, 366/85-26-02, Review of Revised PT Procedure, is opened.
(b) The inspector observed PT inspection of the eight welds listed in paragraph 5.b.(4)(a) above to verify that:
Applicable instructions or travelers clearly specified
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the procedure to be used and that a copy of the procedure was available for the inspection.
. Sequencing of examinations relative to other operations
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was specified and in accordance with applicable Code and procedures.
Personnel performing the examinations were qualified.
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Materials use for the examinations were certified and
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the certifications met applicable requirements.
Areas, locations and extent of examinations were clearly
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defined.
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The following attributes were as specified in the
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applicable procedure and consistent with applicable code:
t Surface preparation / cleaning method, type, time,
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Penetrant type Penetrant application method
Penetrant time
Temperature of surfaces
Penetrant Removal Drying
Developer, application, type
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Developing time
Evaluation technique
Acceptance criteria
Reporting of results
s (c) The inspector reviewed PT inspection records for the tubing welds listed in paragraphs 5.b.(4)(a) and 5.b.(4)(b).
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(d) Personnel qualification / certification records for NDE personnel who performed the PT inspections of the welds
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identifiedinparagraph(c)abovewerereviewed.
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(e) Certification records for penetrant materials used to PT the
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welds identified in paragraph (c) above were reviewed.
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(3) Magnetic Particle (MT) Examination
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The following procedures were reviewed to determine whether the i
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program:
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IT procedure 521T-MNT-006-0, R0, " Magnetic Particle
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Inspection, Yoke Method" l
IT procedure 521T-MNT-007-0, R0, " Magnetic Particle
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Procedure, Prod Method"
Within the areas examined, no violations, except as noted in paragraphs j
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5.b.(4)(a) and 5.c.(1)(b), or deviations were identified.
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