IR 05000328/1980011
| ML19331C857 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/20/1980 |
| From: | Herdt A, Zajac L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19331C845 | List: |
| References | |
| 50-328-80-11, NUDOCS 8008190631 | |
| Download: ML19331C857 (7) | |
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k UNITED STATES P
"f, NUCLEAR REGULATORY COMMISSION
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.E REGION 11 d
101 MARIETTA ST N.W.. SUITE 3100 e
o ATLANTA, GEORGIA 30303
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Report No. 50-328/80-1 1 Licensee: Tennessee Valley Authority 500A Clestnut Street Tower 11 Chattanooga, TN 37401 Facility Name:
Sequoyah License No. CPPR-73 Inspection at Sequoyah gite near Chattanooga, TN
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Inspector:
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L. D. Zaja c,', /
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Approved by:
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A. R. Herdtfi-Date Signed g-SUMMARY Inspection on May 19-22, 1980 Areas Inspected This routine unannounced inspection involved 29 inspector-hours onsite in the areas of preservice inspection of piping welds including program review, ultrasonic procedure review, observation of ultrasonic examinations of piping welds and review of data and evaluation records.
Results Of the four areas inspected, one item of noncompliance was found in one area (Deficiency - Failure of Ultrasonic Procedure to adequately provide instructions and failure of the ultrasonic examiners to comply with the procedure.)
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DETAILS 1.
Persons Contacted Licensee Employees G. Stack, Project Manager
- T. Northern, Jr., Construction Engineer
- D. Mack, Assistant Construction Engineer
- D. McCloud, QA Supervisor
- W. Glasser, QA Representative
- R. Daniel, Supervisor Baseline and ISI
- J. Munns, Supervisor Construction QA Other licensee ~ employees contacted included five technicians.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 22, 1980 with those persons indicated in Paragraph 1 above. The one item of noncompliance described in Paragraph 6.b and the two unresolved items described in Paragraph 5 and 6.b(4) were discussed in detail.
3.
Licensee Action on Previous Inspection Findings Not Inspected.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations. New unresolved items identified during this inspection are discussed in Paragraphs 5 and 6.b(4).
5.
Preservice Inspection - Review of Program During the inspection at Sequoyah on March 31 to April 3, 1980, the inspec-tor conducted a partial review of the Preservice Inspection Program, SI-114, which esulted in noncompliances being noted and reported as Deficiency 328/80-08-01. Subsequent to this inspection the review of Preservice Inspection Program, SI-114, has been completed, except for a review of the actual welds to be examined for baseline, Appendix A of SI-114, and the inspection schedule, Tables 1, 2, A and B of SI-114. The program was reviewed to determine if it complied with NRC and ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition with addenda through summer 1975 requirements. The following specific areas do not appear to be adequately addressed in the program, SI-114.
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Indoctrination / training program for QA personnel responsible for a.
preservice and inservice inspection activities.
It was noted during the inspection, that there were no records to indicate the engineer, responsible for coordinating the nondestructive examination, had indoctrination training.
b.
Audit procedures such as:
(1) scope and purpose of audits to be performed including audits of status and adequacy of the perservice/ inservice program.
(2)
frequency of audits, audit criteria, basis for re-audit criteria, basis for re-audit, management review and assessment, corrective action and followup, documentation of results of audits and management review and followup of corrective actions.
(3) qualifications and responsibilities of auditors, including those of contractors.
c.
Quality documentation is generated and maintained to indicate whether preservice/ inservice inspection quality requirements have been met for
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such items as:
(1) material certifications (2) examination reports (3) evaluations (4) auditing results d.
Procedures for identification and correction of conditions adverse to quality as detected during examination, including provisions to preclude repetition of such adverse activities.
Control of documents related to preservice/ inservice inspection.
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Preservice/ inservice inspection related documents are reviewed by cognizant personnel for adequacy.
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Provisions to assure appropriate identification / listing and control of 04 instructions and procedures including future revisions.
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Provisions to assure periodic review of the adequacy of document control procedures.
i.
Procedures to assure that NDE documentation for Perservice/ inservice examinations have been reviewed by responsible personnel.
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Administration controls have been established for control of the generation approval and custody for the following records:
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(1) examination results, data sheets, film and tape records (2) NDE equipment used during examination such as the make, model, serial number
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e-3-(3) listing of calibration blocks by identification number and material (4) personnel qualification records and certifications (5) drawings, sketches and work orders k.
Responsibilities have been assigned for maintenance of NDE records and that storage controls are established which accomplish the following:
(1) define reccrd storage facility locations (2) designate a custodian in charge of storage facility (3) describe the filing system to be used to allow for retrieval of records and materials (4) provisions for governing access to files, records, materials and for maintaining accountability (5) establish method for filing supplemental informatica It should be noted that just prior to the exit interview, TVA provided the inspector with an unofficial written response to each of these items, indicating other documents where subject items are included. Thus, further review by the inspector will be made to ascertain if each item is adequately documented and addressed. This is Unresolved Item Number 328/80-11-01.
Potential Inadequate Preservice/ Inservice Inspection Program.
6.
Preservice Inspection - Observation of Work and Work Activities The inspector observed the ultrasonic examination of ten pressure a.
retaining piping welds, identified below, to determine compliance with ASME Boiler and Pressure Vessel Code,Section V, 1974 edition with addenda through summer of 1975.
Pipe Size Weld Identification System and Material Type Inspection SIS-247 Safety Injection 10" SS L&S wave SIS-248 Safety Injection 10" SS L&S wave SIS-275 Safety Injection 10" SS S wave only SIS-276 Safety Injection 10" SS S wave only SIS-277 Safety Injection 10" SS S wave only SIF-184 Safety Injection 10" SS S wave only
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SIF-142 Safety Injection 10" SS L wave only SIS-258 Safety Injection 10" SS L wave only RRRS-67 Residual Heat Removal 8" SS S wave only RHRS-65LS Residual Heat Removal 8" SS S wave only Specific areas observed / reviewed were:
(1) type of apparatus used and frequency range (2) extent of coverage including beam angles, scanning rate, transducer overlap and scanning directions
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(3) calibration of equipment, before and af ter each examination (4) size and frequency of search units (5) reference level for monitoring discontinuities (6) levels for evaluation and recording of indications (7) compliance with TVA's ultrasonic procedures N-UT-1 Rev. 3 and N-UT-6, Rev. 1 (8)
familiarity of inspection system and operation by examination personnel (9) couplant used (10) Recording of meaningful and reproducible data b.
During the observation / review, the following conditions were noted:
(1) During the ultrasonic (UT) longitudinal wave examination of piping welds SIS-247 and SIS-248, the inspector noted that sound transmission was not occurring through the pipe wall when scanning on the inner bend of the elbow side of the weld for about 120* of the circumference. The inspector also noted that the level II examiners did not record anything on the report form to indicate there was a scan limitation in this area. When the UT examiners were questioned by the inspector on this matter, they explained
that losing search unit contact in these areas was not unusual,
thus it was not considered necessary to record such scan limita-
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tion. However, during later conversations with two level III examiners (one which is the Baseline supervisor), it was estab-lished that these scan limitations were to be recorded, as indicated by Paragraphs 10.3.3 and 10.6 of ultrasonic procedures N-UT-1 and N-UT-6 respectively.
The inspector noted, however, that the report form TVA 6678 (DNP-12-79) which is Figure 5 of UT procedure N-UT-1 and Figure 2 of UT procedure N-UT-6 does not provide a specific space for record!.g scan limitations. As a result, the examiners record such conditions (when considered necessary) in the space titled,
" Descriptions of Indications."
Consequently, the reporting form appears to be inadequate for ensuring such information gets recorded.
It should be noted that the two subject pi;*ng welds were reinspected with the longitudinal wave technique and the scan limitations were appropriately recorded.
It should also be noted that the inspector observed shear wave examination of these two joints and the elbow's inner bend did not seem to affect the ability of the search unit to produce satisfactory sound transmission.
(2) The inspector questioned the intent of Figure 4 of UT Procedure N-UT-1 as it related to the volume and surface to be examined for piping welds. The figure is not clear on how much base material adjacent to the welds is required to be examined.
It should be noted that this discrepancy had recently been identified by TVA's QA personnel.
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5-(3) A review of completed report forms by the inspector, as indicated by Paragraph 7.b disclosed questionable and confusing annotations which were made in the space titled, " Description of Indications."
The discrepancies identified above represent inadequancies in the ultrasonic procedures N-UT-1 and N-UT-6, and a lack of compliance to the procedures by the UT examiners, which in both cases, are in noncompliance with 10 CFR 50, Appendix B, Criterion V as implemented by FSAP, paragraph 17.1A.S.
This item is Deficiency Number 328/80-11-02. Failure of ultrasonic procedure to provide adequate instructions and failure of personnel to comply with procedural requirements.
(4) During calibration of the UT equipment, the inspector noted that a notch was being used for calibrating the equipment rather than a side-drilled hole, as specified by Paragraph T-533.2(a) of Section V of the ASME Code. To support this position TVA provided the inspector a copy of a " Request For Relief ISI-2," dated January 10, 1979, which TVA stated they sent NRC Headquarters for approval. Although TVA has not yet received approval, they are currently using notches for calibration.
A review of the " Request for Relief" (RFR) by the inspector disclosed a major discrepancy, in that the notch does not represent more sensitivity than the side-drilled hole, as implied in the RFR.
In fact the notch would represent less sensitivity based on the information presented in the RFR and the attached graphical display of conducted tests. Furthermore, Paragraph T-533.2(b) of Section V of the ASME Code states, "However, other calibration reflectors may be used provided equivalent responses to that from the basic calibration hole are demonstrated." TVA's request for relief does not demonstrate equivalency.
It was also established that the demonstration tests presented in the RFR were not conducted by TVA, but rather by another activity. Thus, TVA is not know-ledgeable of the basis upon which the evaluation was made, e.g.
thickness of materials, location of notch with respect to the side-drilled hole, the metal path distance of the ultrasonic sound wave for the notch and the side-drilled hole, etc.
It should be noted that this discrepancy had also been recently disclosed by TVA's QA personnel.
In view of the above TVA agreed to revise or rescind the RFR and to conduct their own test and evaluation to determine equivalency of a notch to a side-drilled hole. This is Unresolved Item Number 328/80-11-03, apparent noncompliance of using notch for calibration of ultrasonic equipment.
Within the areas examined, no items of noncompliance or deviations were noted except for the deficiency noted above in Paragraph 6.b.(3).
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e-6-7.
Preservice Inspection - Data Review and Evaluation The inspector reviewed the completed records for two 14" stainless a.
steel pressure retaining piping welds, RHRF-26 and RHRS-23 of the Residual Heat Removal system. The specific areas reviewed were:
(1) Whether calibration data sheets showed major deviations between initial and final calibrations (2) Whether examination data and recordable indications were properly recorded to permit accurate evaluation and documentation (3) Whether evaluation of data is performed by a Level II ar Level III examiner (4) Whether evaluation of examination data complies with the procedure (5) Whether evaluation of indications complies with the criteria of the NDE procedure and the ASME Code,Section XI (6) Legibility and understandability of the data provided b.
As a result of the review, the inspector noted the following condition:
The report form for the longitudinal wave examination of piping weld RHRF-26 contained the annotations, " upstream.46" and "4L47", in the space titled, " Description of Indications." The UT examiner was questioned as to the meaning of these annotations and he advised that they were pipe wall thickness measurements.
It is noted that the report form has no space for recording thickness measurements even though Paragraph 10.3.3 of UT Procedure N-UT-6 requires such measure-ments to be recorded.
It was pointed out that such unexplained annota-tions are confusing and may cause even more confusion several years later when the record is used for baseline guidance during inservice inspections. This item is mentioned in Paragraph 6.b(3) herein, and as such, is part of the noncompliance identified in that paragraph.
Within the areas examined, no items of non:ompliance or deviations were noted except for the discrepancy noted above in Paragraph 7.b which is included as a deficiency in Paragraph 6.b.(3).