IR 05000327/1987021

Insp Repts 50-327/87-21 & 50-328/87-21 on 870323-25 & 0401-03.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters & Followup Items

ML20214V722
Person / Time
Site:	Sequoyah
Issue date:	05/01/1987
From:	Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214V717	List: IR 05000327/1987021 ML20214V714
References
50-327-87-21, 50-328-87-21, NUDOCS 8706120258
Download: ML20214V722 (21)

Text

F paf(To UNITE 3 STATES

. yf q NUCLEAR REIULATORY COMMISSION 3 o REG 40N il

$ $ 101 MARIETTA STREET, N.W., SUITE 2900

o ATLANTA, CEORGIA 30323

%, + . . . . p Report Nos.: 50-327/87-21 and 50-328/87-21 Licensee: Tennessee Valley Authority 6N/38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: March 23-2 and April 1-3, 1987 Inspector: .[ taf7 <- 30 7)

B. R. Crowley Date Signed'

{ i Accompanying Personnel: T. K. McLellan, Reactor Construction Engineer IE, DI, RCPB Approved by: L / 7 J/ . Blake, Section Chief Date Signed n ineering Branch i

[DvisionofReactorSafety SUMMARY Scope: This routine, announced inspection was conducted in the areas of licensee action on previous enforcement matters (Units 1 and 2) and inspector followup items -(IFI) (Units 1 and 2).

Results: No violations or deviations were identifie PDR 870519ADOCK 05000327 PDRf G

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REPORT DETAILS Persons Contacted Licensee Employees

• L. M. Nobles, Plant Manager

• P. R. Wallace, Site Directors Office

• M. R. Harding, Site Licensing Manager

• G. B. Kirk, Compliance Licensing Manager

• G. A. Lundin, Weld Project Manager

• H. Mackay, Mechanical Test Supervisor

• C. W. Hatmaker, Assistant Project Engineer - Welding Project

• R. A. Montgomery, Lead Engineer - Welding Project

• J. L. Adams, Lead Welding Engineer

• R. O. Barnett, Chief, Civil Engineer

• R. N. Thompson, Licensing Engineer

• M. A. Cooper, Compliance Licensing Engineer

• B. Hall, Regulatory Licensing Engineer D. F. Goetcheus, Steam Generator Project Manager J. Galbreth, Employee Concerns Other licensee employees contacted included engineers, technicians, security force members, and office personne NRC Resident Inspectors

• K. Jenison, Senior Resident Inspector P. Harmon, Resident Inspector D. Loveless, Resident Inspector K. Poertner. Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on April 3,1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item 327,328/86-13-03, Resolution of NRC NDE Van Inspection Findings. See RII Reports 50-327, 328/86-33 and 50-327, 328/86-59 for previous inspections of this ite After RII Report

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86-59, the only issues remaining to be resolved were relative to TVA Items 2, 15 and 2 These issues have been resolved as summarized belo (1) (Closed) TVA Drawing 47A055-170 (TVA Item 2) - In addition to the problems identified by TVA and the NRC Van inspections, additional discrepancies were the NRC team inspection documented in RII Reportidentified by(See IFI 327, 86-33 328/86-33-05).

TVA re-inspected this item and documented and resolved all discrepancies. In addition to performing calculations where needed to resolve discrepant conditions, the original calculations for the support were regenerated (See paragraph 3.b. below) . Where needed, drawings will be revised (See Significant Condition Report (SCR) SQNCEB8606).

i This item is closed based on review of TVA inspection documentation, SCR SQNCEB8606 and Engineering Calculations (See paragraph 5.a. below relative to review of calculations).

(2) (Closed) TVA Item 15, Weld 1-46 - Welds were different from that shown on drawing Drawings reviewed by the NRC were TVA field drawings, which should not show vendor weld Per SCR SQNCEB8606, TVA drawings will be revised (See paragraph below).

(3) (Closed) TVA Item 21, Welds C1, C2, C3 and C4. This item is closed based on review of calculations for undersized welds (See paragraph 5.d. below).

b. (Closed) Violation 327/86-65-01, Inadequate Design Control of the HVAC Seismic Support TVA's letter of response, dated February 27, 1987, has been reviewed and determined to be acceptable by RII. The inspector held discussions with responsible personnel and examined corrective actions as stated in the letter of respons The violation pertained to the inability of TVA to retrieve the original design calculations for a Unit 1 HVAC duct support (TVA Item 2 - See paragraph 3.a.(1) above). As part of the corrective action, TVA i regenerated the calculations for the suppor The inspectors

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reviewed the regenerated calculations (See paragraph 5.a. below).

In addition, as part of an ongoing Design Basis Verification Program,

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TVA issued Policy Memorandum (PM) 86-02 to establish a program for

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achieving a consistent, continuous approach in development and maintenance of civil discipline calculation The PM identifies the calculations which are essential and also requires a project specific Implementation Pla The Sequoyah Implementation Plan contains criteria to categorize essential calculations as pre-start or post-star NRC's ongoing inspections of the Design Basis J

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Verification Program will satisfy verification of this portion of the corrective action for this violatio TVA's letter of response stated that calculations designated as required for restart by the Sequoyah Implementation Plan would be verified for retrievability, or regenerated if necessary, by April 1, 1987 for Unit 2. The April 1, 1987 date was not met. TVA stated that the April 1,1987 date was based on an earlier restart date than is now feasible. At the time of the current NRC inspection, a letter was in preparation to change the April 1,1987 date to be more compatible with the current projected restart date. Closure of this item is based on the understanding that the new date will be prior to restar (0 pen) Violation 327, 328/86-59-01, Failure to Meet Test Frequency Requirements for Category A and B Valves. TVA's letter of response, dated January 23, 1987, has been reviewed and determined to be acceptable by RII. The inspector held discussions with responsible personnel and examined corrective actions as stated in the letter of respons At the time of the current NRC inspection, revised procedures were in the review cycle and scheduled for issue prior to restart of Unit This item remains open pending review of the revised procedure . Unresolved Items Unresolved items were not identified during the inspectio . Review of Engineering Calculations (Units 1 and 2)

The inspector reviewed engineering calculations, as detailed below, relative to problems identified in RII Reports 50-327, 328/86-13, 86-33, and 86-6 See RII Report Nos. 50-327, 328/86-13, 86-33 and 86-59 for previous inspections in this area. The additionally supplied calculations were reviewed for completeness, consistency of documentation, engineering evaluations and mathematical accuracy of calculations. The accuracy of the design loads used in the calculations were not reviewed since such a review is considered to be outside the scope of this inspectio TVA Item 2, HVAC Support - In addition to the welding discrepancies identified in RII Reports 50-327, 328/86-13 and 86-33, TVA was unable to provide the original design calculations when requested by the NRC inspector. This inability to retrieve calculations was identified as Violation 327/86-65-01 (See paragraph 3.b. above). As a result of the violation, TVA has regenerated the original calculations for typical HVAC duct support 47A055-144 which includes HVAC seismic supports 1030 HDABHVAC - 0820, 0822 and 796 In addition, calculations were provided relative to welding discrepancies identified by TVA during their reinspection (See paragraph 3.a.(1)

above).

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The HVAC calculations were reviewed by the NRC inspector and found to be acceptable, TVA Item 6A, Instrument Support - The support was constructed in accordance with Support Variance Sheet 51-19-221 which allowed a gusset to be added so that the support could be installed at an angle to the baseplate. Calculations for this variance were not found and new calculations were requeste The NRC inspector reviewed the new calculations as reflected in Support Variance Sheet 51-19-221 and found them to be acceptabl TVA Item 15, Instrument Support - The NRC van inspection found that .

the welds were different from that shown on the drawing. The weld l details were missing for some welds and the location and length were not per the drawing for other welds. TVA's investigation revealed that the drawing used by the NRC was a TVA field drawing and that the support was a vendor furnished item. Therefore, the vendor weld details should not have appeared on the TVA field drawing. The welds appeared on the field drawing because of a drafting error. TVA's investigation determined that the welds in place were satisfactor The TVA drawing is being revised in accordance with SCR SQNCEB8606 to identify which welds are vendor welds. In addition to review of TVA's evaluation, the NRC inspector reviewed the " Summary" of the

" Seismic Simulation Test Program on Instrumentation Rack" and found the test to be acceptable, TVA Item 21, Cable Tray Support - Calculations were missing for undersized welds C1, C2, C3 and C4 on detail During this inspection, TVA personnel informed the NRC inspectors, that Detail

"D" was mislabeled and the welds should have been labeled "A", "B" and "N" on Detail "D". Subsequently, the NRC inspector reviewed the related documentation to mislabeling of Detail "D" and concurs with TVA's finding and resolution. Calculations for unacceptable welds on Item 21 were reviewed by the NRC inspectors and found to be acceptabl TVA Group 1, Mechanical Welds - A number of piping welds were rejected for underfill, undercut, or inadequate leg length. The TVA package of engineering calculations supporting the discrepant conditions were reviewed and found to be acceptabl Within the areas inspected, no violations or deviations were identifie l l

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5 Employees Concerns The inspector evaluated the following employee concerns, Case No. RII 85-A-0144, Weir Walls May Not Have Been Installed Properly This concern questioned whether reactor coolant pump weir plates were installed at Sequoyah and Watts Ba The concern was referred to TVA for investigation and was investigated for Sequoyah under TVA Concern No. ECP-86-SQ-252-0 TVA's investigation, as documented in TVA report approved January 12, 1987, revealed the following:

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Westinghouse initiated ECN's TVA-10524 and TEN-10515, dated August 22, 1973, to install weir plates in the reactor coolant pumps at Sequoya TVA's letter 3973, dated August 23, 1974, provided engineering justification for not installing the weir plate Westinghouse cancelled the ECN's by memorandum, dated August 28, 197 On July 9,1986, the SQN Project Engineer confirmed that the weir plates had not been installed at Sequoya This concern is being investigated at Watts Bar under Employee Concern ECP-86-WB-4601-0 Based on TVA's investigation, Case No. RII-85-A-0144 can be close Case No. RII-86-A-0117, IE-86-A-019, Technical Concerns Expressed by a TVA employee at Sequoyah Relative to CCW Heat Exchangers As a result of this employee concern, technical questions have been raised relative to the Component Cooling Water (CCW) Heat Exchanger at Sequoya The first question related to substandard shell material for the heat exchanger TVA has determined that the questions relate to laminations identified in the shell material during opening the shells for internal modifications during 1980 and 198 TVA's investigation determined that laminations were acceptable for the material in question. This concern was not pursued during the current inspection other than to review the following documents:

- Memorandum to C. E. Curigton from D. F. Goetcheus, dated August 14, 1986 - Sequoyah Nuclear Plant (SQN) Units 1 and 2 -

Investigation of Component Cooling Heat Exchanger Concern -

Technical Evaluation, l

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- SQN Work Plan 8588, Original, R1 and R2 - This work plan was issued in April of 1980 for modification to the heat exchanger and required cutting windows in the shells for the modificatio Review of the records copy of the Work Plan revealed that the modifications were performed and the windows welded in the shells as follows:

Unit A (Unit 1) - May and June, 1980 Unit B (Unit 2) - July and August, 1980 UnitC(Common)- May and June, 1981

- Maintenance Requests (MRs) 051677, 051678, and 051679 including associated Magnetic Particle (MT) inspection reports where the window welds were stripped of paint and MT inspected in September of 1982 - The MT reports indicate that linear indications were removed during the MT inspection. There are no records as to the location or nature of the linear indication The second concern related to porosity in the heat exchanger support to foot pad welds. As noted in the August 14, 1986 memo identified above. TVA has investigated this concern and determined that some minor repairs are needed. An MR had been issued for the repair. The ,

following summarizes the inspector's examination of this concern: )

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The inspector visually observed the support and noted that significant porosity is present in the support to foot pad welds. Also, some welds contain minor overlaps. Other than the porosity and minor overlaps, the welds are uniform with good appearance (The welds are painted).

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No specific receiving inspection documentation could be identified relative to the support The heat exchangers were inspected in the vendor's (Industrial Process Engineers) plant under TVA Inspection and Test (I&T) program. A sample of I&T reports was reviewed. There was no specific reference to the support weld The TVA Contract No, is 71C33-92691, Specification No. 133 In accordance with the contract, the applicable code isSection VIII of the ASME Boiler and Pressure Vessel Code. The contract specifies that welding be in accordance with ASME Section IX but does not specify any NDE or acceptance criteria for the support welds. The supports are outside the Section VIII boundary and Section VIII only specifies that the vessel be supported in such a way as to provide for the maximum imposed loadin Nonmandatory Appendix G to Section VIII contains suggested rules for supports. Appendix G states that the details of supports should conform to good structural practice. Also reference is

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made to the AISC Manua Therefore, there are no contractual requirements, other than good structural practice, for the support welds. Since AISC is referenced in the nonmandatory Appendix G to Section VIII, TVA considered using AWS D1.1 for inspection of the supports. At the close of the inspection TVA was considering using NCIG-01, Visual Weld Acceptance Criteria for Structural Welding at Nuclear Power Plants, for reinspection of the support to foot pad weld TVA also aointed out to the NRC inspector that plans have been made to clange out the heat exchangers with a new design. New heat exchangers have been procured and are on site. The following is the tentative schedule for the change out:

A - Unit 1, cycle 5 11/02/90 B - Unit 2, cycle 3 02/12/88 C - Unit 1, cycle 4 04/07/89 Case No. RII-86-A-0117, IE-86-A-019 will remain open pending further evaluation by the NR . Inspector Followup Items (92701) (Units 1 and 2) (Closed) Inspector Followup Item 327,328/86-09-03, Clarification of Terms " Adequate for Service" and " Meets all Requirements" Relative to TVA Welding Progra This item pertained to the fact that the TVA Secuoyah Phase I Welding Action Plan appeared to use the terms

"Acequate for Service" and " Meets all Requirements" interchangeabl The NRC pointed out that the first step should be to determine if commitments / requirements were met and the second step to determine adequacy for servic Review of TVA activities during the welding inspection program at Sequoyah revealed that in actual practice, TVA did perform the two separate steps. Section 1.0 of the TVA Phase II Welding Pro Report states that the purpose of the welding noject is ".. ject .to assure that installed weldments... meet TVA Coce, and regulatory requirements and are adequate for servic In addition, TVA is going to revise the paragraph at the bottom of page 12 of Section of the Phase II Report to further clarify that the two separate steps were used in the welding inspection progra Inspector Followup Items in RII Report 50-317, 328/86-33 are identified in notes to tables in the report. Each item number may be defined by several parts, each part being described by a note in the table. Therefore, closecut action is addressed by table number and note number for each individual part of each ite A number of items aertain to areas where welds or configuration deviate from that slown on applicable design drawing. The drawing requires one type of weld when, in fact, the actual weld was found to be some other type. TVA has shown that even though welds were not in accordance with drawings in some cases, the welds were satisfactory J

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based on engineering calculations. For the cases where welds were found to deviate from drawings, by TVA inspection or NRC inspection, TVA has issued Significant Condition Report (SCR) SQNCEB8606 to revise the drawings to reflect the "as-built" weld The SCR also addresses specification of the Quality Level on the drawings. For drawings not covered by the SCR, Section 3 of Volume II of TVA's revised Nuclear Performance Plan for Sequoyah provides an action plan that includes reconciliation of "as constructed" and "as designed" drawings to achieve a single set of plant drawings and improvement in the design control program for Sequoyah when implemented (See Executive Summary to RII Report 50-327,328/86-33).

(1) (Closed) Inspector Followup Item 327, 328/86-33-01, Pipe Weld Deficiencie l

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Table 1 Note 4 - The Weld documentation showed that a single weld material verification was performed by the quality control inspector. Dual process welding procedure was required by the weld data shee Welds 2 - AFDF-25AA and 2-AFDF-25BB: Resolution of this problem for these two welds is addressed in TVA Discrepancy Report (DR) 86-03-065 Weld 1 - AFDF-38: This weld was on original construction weld, welded and accepted October 29, 197 TVA Justification (Summary)

Field evaluation has been made to determine the welding process utilized for the cap pas The evaluation shows that the cap pass was made with shielded metal arc weld process with the stringer bead techniqu *

Weld 1-AFDF-38 is in agreement with its recorded documentation. The weld material identified on the fitup and cleanliness record (E70S3) is in agreement with the weld process specified for the root pass and field inspection has verified that the cap pass is in agreement with the specific process. The program in effect at the time the work was performed required that the inspector record the filler material in the welder's possession. The records indicates the welder had the proper material for the root pas The program did not explicitly require the identification of additional material. The weld was re-inspected by TVA (See TVA Welding Project Phase II Report) and by NRC and found to be acceptabl I

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This item is closed based on:

TVA Justification Even though the weld record does not identify the weld material for the SMA portion of weld, it appears that the procedure in effect at the time was met and that the correct welding material was use Table 1, Note 5 - Visual inspection of the weld revealed that the SMAW process was use Weld data record shows incorrectly that the GTAW process was use TVA Justiff t.ation (Summary)

The weld in question was an original construction weld, welded and accepted October 22, 197 The records for weld 1-AFDF-40 identify the GTAW process as being used for the complete weld. A field inspection has determined that the cap pass was made by the shielded metal arc process. The fitup and cleanliness record shows that the proper material (70S3) for the specified procedure was in the welders possession at the time of the fitup inspection. Since this weld is adjacent to a valve, TVA disassembled the valve and verified the GTAW process was used for the root pas *

An extensive records search has been made to determine if any modification or maintenance changes to the welds have been made that would cause the weld to not agree with the original record. Evidence to indicate rework for this weld has not been foun *

The weld has been reinspected by TVA and the NRC and

!. is acceptable as reported in the Phase II Report (Welding Project Vol. 3). The documentation discrepancy for weld 1-AFDF-40 is considered to be nonsignificant and of no consequence to the weld quality since acceptable SMAW procedures were available for use and visually, the weld cap appears

to have been welded with an acceptable (carbon steel)

SMAW material.

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This item is closed based on:

TVA Justification The problem appears to be a paper problem onl Approved SMAW procedures were available for the weld and the weld cap appears to have been welded with a SMAW carbon steel materia Table 1, Note 6 - Underfilled Wel This item is closed based on review of Appendix 4.4 of TVA Welding Project Sequoyah Phase II Report and review of calculations (See Paragraph 5.e above).

- Table 1, Note 7 - One of the eight inspected hanger pads was found to have a missing hard stamped material heat number. The heat number verification sign off was noted on the weld data record with no notation as to the number of pads checke TVAJustification-(Summary)

Applicable procedure SQN Proc. M-7, required traceability of heat numbers of attachments only until installed. The weld history record indicates that the " Material Release" hold point was specified and signed off by the inspector; heat number 7469628 was listed for component 1-CCH-67 This indicates that the inspector did identify the eight lugs prior to assembly to the process line. The most likely explanation for the one lug not having visible marking is that the inspector verified the component identification and heat numbers on the lug prior to fitup on the process line. After this verification, the lugs were fitup to the process line with the die stamped surface against the process line for the one lu The inspector visually observed the lugs and the one lug without marking appears visually to be identical to the other seven lugs. The paint was scraped from the lug and the painted mark number appeared on the lu This item is closed based on TVA's justification and visual inspection of the lug )

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(2) (Closed) Inspector Followup Item 327,328/86-33-02, Pipe Support Weld Deficiencies Table 2, Note 6 - Vertical location of Support in error by 3'-6" when compared with drawin This item is closed based on SCR SQNCEB860 (3) (Closed) Inspector Followup Item 327, 328/86-33-03, Instrument Tubing Support Weld Deficiencies

- Table 4, Note 1 - The weld contained undercut, slag, '

overlap and incomplete fusio This item is closed based on review of TVA Welding Project Sequoyah Nuclear Plant Phase II Review and Program Results (Phase II Welding Report) and review of TVA calculations (See RII Report 50-327,328/86-59).

- Table 4, Note 2 - The weld was underfilled or undersize This item is closed based on review of TVA calculations (See RII Report 50-327,328/86-59).

- Table 4, Note 3 - The drawings specified in two places that the connection between pieces of square tubing be full-penetration square groove butt welds. This type of joint is defined as a K, Y, or T connection by the AWS D structural welding code. The AWS D1.1 Code requires a special qualification test for welders who weld on T, Y,

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and K connection The review of a sample of welder qualifications indicated that some welders were qualified

on a plate using backing strap which does not qualify them i to weld on a T, Y, and K connections in structural steel

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i T. K and Y connections involve intersecting elements

! of tubular structure Design and fabrication requirements for such structures are addressed in Chapter 10 of the AWS D1.1 Code. This chapter currently contains requirements for both complete and

partial penetration groove welds in tubular members.

l Complete penetration T, K and Y connections are unique j among the prequalified joints of the D1.1 Code in that they permit design credit for a complete penetration a

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weld without the use of a backing strap or backgouging and back-welding. Because of the difficulty of making such . welds, the code requires a special rigorous welder performance tes ~

TVA does not design for complete penetration T, K and Y connections and, therefore, does not give the special welder performance qualification test for these weld TVA does design for partial penetration groove welds and fillet welds in square and recta'ngular (box section) tubing for which welders are qualified by standard plate qualification test In accordance with TVA SCR SQNCEB8606, TVA is revising weld symbols on drawings to clearly show the type weld required and that full penetration welds were not intende '

This item is closed based on:

TVA Justification For the editions of AWS applicable to Sequoyah (1969 and 1972), the qualification requirements for the type welds at Sequoyah, i.e. welds between square tubing of the same size where two sides of the weld are fillets and the other two sides a partial penetration weld similar to a partial penetration flare bevel weld, are not clear. In later editions of AWS, some clarification has been made, but it is still not clear that the restrictive T, K, .Y qualification test applies to the type welds at Sequoya a

Welders at Sequoyah were qualified on full penetration grove welds in plates. Practically, this appears to be adequate for the type welds at Sequoya ^ - Table 4. Note 4 - The support was constructed in accordance with Support Variance Sheet 51-19-221 which allowed a gusset to be added so that the support could be installed at an angle to the baseplat Calculations for this variance were not found and new calculations have been requeste This item is closed based on review of calculations (See paragraph 5.b.above).

- Table 4, Note 5 - The weld had an unacceptable crater and clustered porosit This item is closed based on review of calculations (See RII Report 50-327,328/86-59).

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- Table.4, Note 6 - The support was constructed in accordance with drawing 47A053-10A. The drawing specified that the

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connection between the unistrut and the supporting steel be a a full penetration square butt weld. The drawing symbol is Y incorrect because in this case it is not possible to make a square butt wel A This item is closed based on TVA SCR SQNCEB860 \\

- Table 4, Note 7 - The length of intermittent welds were too m short, but the welds were closely space $

T This item is closed based on review of calculations (See RII Report 50-327,328/86-59).

(4) (Closed) Inspector Followup Item 327, 328/86-33-04, Electrical Support Weld Deficiencies

- Table 5, Note 1 - The drawing did not specify which material and weld quality level requirements appl '

This item is closed based on:

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There was no evidence of the incorrect quality level being use TVA SCR SQNCEB8606 requires that the quality level be added to the drawing in questio " TVA's letter, dated January 30, 1987, in response to NRC draft Safety Evaluation Report, states that

.s quality levels will be specified on all new or revised drawing Table 5, Note 2 - The stitch weld was deficient with respect to the requirements stated on the drawing. Drawing required 2 on 6 weld, while the actual weld was 2 inches long on 8-inch center No calculations were made to evaluate the deficient stitch wel This item is closed based on review of calculations made after report 86-33 (See RII Report 50-327,328/86-59).

- Table 5, flote 3 - The drawing symbols do not match the actual weld configuratio This item is closed based on TVA SCR SQNCEB860 )

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- Table 5, Note 4 - No weld details were found for the dust Cover This item is closed based on TVA SCR SQNCEB850 Table 5, Note 6 - Undersized weld found on floor connection. No calculations have been made to evaluate the undersized wel This item is closed based on review of calculations (See paragraph 5.d. above).

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Table 5, Note 7 - Variance drawing does not show one cross member in side vie This item is closed based on review of calculations (See RII Report 50-327,328/86-59) and TVA SCR SQNCEB860 (5) (Closed) Inspector Followup Item 327,328/86-33-05, HVAC Support Weld Deficiencies

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Table 6, Note 1 - TVA's reinspection rejected a number of welds for being undersized fillets or underfilled flare welds. Also, a number of welds were identified as missin In some cases the weld specified on the drawing could not have been made because of the joint desig Some weld symbols on the drawing did not show weld sizes. The NRC NDE van inspection identified similar problems. A number of welds were considered to be inaccessible by TVA. The structure was inspected by the NRC NDE van team and many of the welds identified as inaccessible were inspected by the NRC. Weld surface problems such as craters, weld profiles, undercut, weld surface slag, and one missing weld were identified in addition to the problems identified by TV During the current inspection (86-33), the NRC inspectors noted that the drawing and variance were not clear as to the weld size required for weld "A". The weld size was accepted by TVA inspectors with a note that no weld size was specified on the drawing. Engineering accepted the weld by calculations based on the fact that only a 0.050 inch weld size is needed. The fitup gap for one weld was greater than the maximum allowed 3/16-inch ga This item is closed based on a review of calculations (See paragraph 5.a. above and RII Report 50-327,328/86-59)and TVA SCR SQNCEB860 Table 6, Note 2 - TVA's reinspection rejected a number of fillet welds for being undersize The NRC NDE van inspection team did not inspect this suppor During the

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current- inspection (86-33), the NRC team noted that for pad-to-beam welds, the variance drawing was poor and did not specify where the 3/16 inch fillet was to be welde The pads are 4" wide welded on 4" wide beam Therefore, the 3/16 inch fillet welds must be welded across the beam even though the variance drawing was not clear. Those welds were undersize The seams between the edges of the pads and the beams were seal welded even though the variance drawing did not show the weld This item is closed based on review of calculations (See RII Report 50-327,328/86-59) and TVA SCR SQNCEB860 Table 6, Note 3 - TVA's reinspection rejected a number of fillet welds for being undersiz The NRC NDE van team inspection identified similar problems. During the current inspection (86-33), the NRC team noted that the variance drawing was very poor and did not detail the full-penetration weld for weld "A-10."

This item is closed based on review of calculations (See NRC Report 50-327,328/86-33) and TVA SCR SQNCEB860 Table 6, Note 4 - This support was not a part of TVA's reinspection sample. The NRC NDE van inspection identified that the spacing on skip fillet welds did not meet drawing requirements. During the current inspection (86-33), the NRC team noted that the welding symbols on the variance drawings for the square-tube-to-square-tube welds did not agree with the type of welds that are in place. The drawings are not clear whether fillet welds or flare bevel welds are require The variance drawings also were found to be of poor qualit Only support number 824 was inspecte This item is closed based on review of calculations (see RII Report 50-327,328/86-59) and TVA SCR SQNCEB860 Table 6, Note 5 - This was not a part of TVA's reinspection sampl This item was inspected by the NRC NDE van tea During the current inspection (86-33), the NRC inspectors noted that the drawing welding symbol for the corner joints connecting the square tubing is incorrect. The symbol shows a flare bevel all around. It appears that a partial penetration weld was used on top and bottom, a fillet weld on the inside, and a seal weld on the en This item is closed based on TVA SCR SQNCEB8606.

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(6) (Closed) Inspector Followup Item 327, 328/86-33-06, Welder Qualification Deficiencies

- Table 7, Note 1 - Welder qualification test record showed that a dual process GTAW/SMAW was used to weld a 7" diameter A-106,1" thick test coupo The record also showed that this test was used to qualify the welder to weld from 3/16 inch to unlimited thickness. There is no record of deposit thickness. Above is not in compliance with Section IX of the ASME Cod TVA Justification -

G-29M Process Specification 1.M.1.2 (General Welding Procedure Specification), paragraph 17.1, defines the gas tungsten arc root pass of dual process walds as being a minimum of two layers and a maximum of 3/8". This definition is applicable to qualification testing and production weldin A nominal value of 3/16" may reasonably be assigned for the thickness of the gas tungsten arc process; the remaining thickness would be that of the other proces Note that all dual process Performance Qualification Tests were deleted from G-29M in General Revision No. 18, dated June 12, 198 This item is closed based on:

TVA justification An interview by the inspector of a previous weld test shop supervisor (supervisor in the 1970s) revealed that the common practice for dual process qualification was to weld two layers with the GTA process. Therefore, TVA's assignment of 3/16" for the GTA process is reasonabl Assuming 3/16" thickness for the GTA process, for the 1" test coupon in question, 13/16" thickness would remain for the SMA process for unlimited thickness qualification for that proces Practically, whether the thickness of the SMA portion of the test coupon was 5/8" (allowed by TVA procedures) or 3/4" (required by code for unlimited thickness qualification), is of little significance in determining a welders abilit As noted in the TVA justification, as of June 12, 1981, dual process qualification were no longer allowed by Process Specification G29 )

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- Table 7, Note 2 - The required visual examination of the test coupon was not recorded on the qualification test recor This item is closed based on:

The applicable editions (1969 and 1972 per the FSAR) of AWS Welding Standard did not require visual inspection of plate test Based on an interview with a previous TVA Weld Test Supervisor (Supervisor in 1970's), standard practice in the test shop was for the test shop supervisor to visually inspect the welder qualification test coupon during welding and in the completed condition. Certification on the test record that test welds were prepared, welded, and tested in accordance with the requirements of AWS D1.0 code, serve as documentation for satisfactory completion of activities mandated by the cod (7) (Closed) Inspector Follow Item 327, 328/86-33-07, Welding Procedure Deficiencie Table 8, Note 2 - WPS qualification for impact tested application is not in compliance with ASME Section IX of the Code concerning separate qualification requirements for P-1 Group 1 and P-1 Group 2 material TVA Justification -

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Procedure GT-SM11-0-38, prior to Revision 8, was supported by qualification tests performed on P-No.1, Group 1 base materials. Revision 8 of the procedure incorporated, by reference, procedure qualification test GT-SM11-0-3C which was performed on P-No. 1, Group 2 material. With Revision 8, Procedure GT-SM11-0-3B was, therefore, qualified to weld P-No. 1, Groups 1 and 2 material on impact tested application Similarly, procedure SM11-B-3, was originally supported by qualification tests performed on P-NO.1, Group 2 material and was later revised (R7) to reference qualification tests performed on P-No. 1, Group 1 materia It should be noted that during SQN construction, assignment of welding procedures for components / piping under the jurisdiction of the B31.7 Code was made by Engineering (Knoxville) via controlled drawings. Assignment of welding procedures for specific weld joints was based upon l

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18 l applicable requirements for preheat, post-weld heat treatment, material type, thickness, impact test requirements et This system effectively assured that appropriately qualified procedures were utilize It should also be noted that the mechanical component / piping codes of record for SQN (831.7 1969 + 1970 Addenda and B31.1 1967 ed.) predate the subdivision of P-No.1 materials into sub-groups which occurred in the 1974 edition of Section I There is no requirement in Section IX or the Codes of record that would require backfit/requalification of procedures to accommodate this particular change in Section I This item is closed based on TVA's justificatio (8) (Closed) Inspector Followup Item 327, 328/86-33-08, Weld Filler Material Certification Deficiencie Table 9, Note 1 - The TVA PF-1019, Revision 2, specification requires mechanical test data after post-weld heat treatment (PWHT). The record shows no test data for yield strength and reduction of area of the materia TVA Justification - The requirement of ASME Section III is that the tensile strength of the test specimen (when tensile tests are required) meet the requirements of the SFA Specification. Although yield strength, percentage elongation, and percentage reduction of area are commonly reported, the omission of these latter properties is not considered a technical or code compliance issu This item is closed based on:

TVA Justification - ASME Section III is not clear relative to requirements for reporting yield strength, elongation, and reduction in area when testing for tensile strength. Code interpretation 111-1-78-151 tends to support TVA's interpretatio The SQN piping Codes of record (B 31.7, 1969 plus 1970 addenda and 831.1,1967) only require material to the SFA specifications. Specific test are not specified to certify the welding materia Based on review in the past of numerous test reports for heats of E70S-3 materials with chemistry and tensile strength similar to that of the material in question, it is unlikely that the yield strength, elongation and reduction in area do not meet SFA value ]

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- Table 9, Note 3 - The record shows tensile test values to be less than those specified by the ASME SFA 5.18 specificatio This note applies to two heats (422C3841 and 432C1271) of E-70S-3 Welding Materia TVA Justification -

The CMTR for Ht. No. 422C3841 is annotated and initialed to indicate that material was not received at SQ (The inspector noted that if notes to Table 3 in SFA 5.18 (1971 Ed.) are considered, the results for this material meet SFA 5.18).

For Ht. No. 432C1271 -

Physical test data from an all weld metal tensile specimen made from the subject material and tested after post-weld heat treatment (PWHT) of 1150 F for six hours indicates a tensile strength of 67900 ps No test data is available for this material in the as-welded conditio The mechanical component / piping codes of record for SQN (B31.7.1969 with 1970 addenda and B31.1 1967 Ed.)

require that welding materials comply with ASME Section IX. They do not require physical test data for each heat and lot of welding materia Section IX, in turn, references standard SFA filler metal specification For the subject material (E70S-3, Ht. No 432C1271) the applicable specification is SFA5.1 This specification does not require or provide criteria values for weld metal tensile tests in other than the as-welded condition. Murex letter to TVA, dated September 24, 1974, states that the subject material meets the requirements of SFA5.1 On the basis of this letter, the material is considered to meet code requirements applicable to SQ To address the probable minimum tensile strength in the as-welded condition, a review of other test reports giving both as-welded and PWHT values for other heats of similar material was performed. Tensile test results of nine heats of Murex E70S-3 (Murex Type 1316) were compared in the as-welded and PWHT conditio Results indicate a reduction in the tensile strength of 6000 to 10,000 psi for the PWHT J

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sample Therefore, it can be reasonable assumed that the tensile strength (67,900 psi after PWHT) of the subject material would equal or exceed 70,000 psi in the as welded conditio This item is closed based on:

TVA's justification

The codes and material specifications applicable at the time of material procurement do not provide PWHT acceptance criteri It appears that if results were available, material would meet as welded tensile strength requirements of SFA 5.1 (9) (Closed) Inspector Followup Item 327, 328/86-33-09, Base Material Certification Deficiencie Table 10, Note 1 - The recorded tensile strength was below the required minimum for the materia For Mk/Ht. No. 72C54-76081 Structural Shape, the vendor material test report recorded an ultimate tensile strength of 57,640 psi versus a specification requirement of 58,000 psi. TVA retrieved a memorandum dated February 24, 1972, from R. C. Miles to files with Engineering justification for the use of the material in items the material was procured fo This item is closed based on TVA Engineering justification, dated February 24, 197 (0 pen) Inspector Followup Item 327, 328/86-59-02, Clarification of Pump Testing Requirement This item questioned the method of insuring that paragraphs IWP-4220 (pressure tap construction)

and IWP-4520 (instruments to measure vibration) of ASME Section XI are met. TVA reviewed Typical drawings 47A7, 47A6 and 47A5 covering pressure taps designs and found that all pressure taps meet IWP-422 Therefore, this portion of the item has been resolve Procedure TI-96.1, Vibration Observation - Pumps and Motors, which identifies vibration instruments consistent with paragraph IWP-4520, had been written and was in the TVA review cycle. This item is open pending review of the procedur