IR 05000335/1980035
| ML17209A587 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/19/1980 |
| From: | Elrod S, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17209A586 | List: |
| References | |
| 50-335-80-35, NUDOCS 8101290361 | |
| Download: ML17209A587 (65) | |
Text
~g REGS (4
0 UNITED STATES NUCLEAR REGULATORY COMIVIISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report No. 50-335/80-35 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name:
St. Lucie Unit 1 Docket No. 50-335 License No. DPR-67 Inspection at St. Lucie site near Ft. Pierce, Florida Inspector:
S. A. E d
Approved by:
R. D.
M tin, Sec on Chief, RONS Branch Date Signed 1-IF~8'z.'ate Signed SUMMARY Inspection on September 28, 1980 - November 7, 1980 Areas Inspected This routine, unannounced inspection involved 108 (resident)
inspector-hours on site in the areas of IE Bulletins and Circulars, Licensee action on NUREG 0578/0660, Reactor Trip of October 21, 1980 and Plant operations.
Results Of the four areas inspected, no items of noncompliance or deviations were identified.
>>0>2903(o(
DETAILS Persons Contacted Licensee Employees C.
J J
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A.
P.
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R.
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J.
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A.
L.
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M.
T.
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J.
M. Wethy, Plant Manager H. Barrow, Operation Superintendent E. Bowers, Maintenance Superintendent A Wells, Operations Supervisor M. Vaux, Quality Control Supervisor J. Frechette, Chemistry Supervisor J. Collier, Instrument and Control Supervisor L. Fincher, Training Supervisor R. Jennings, Technical Department Supervisor W. Mikell, Outage Coordinator K. Ryall, Reactor Engineering Supervisor F. Buchanan, Health Physics Supervisor H. Ruby, Administrative Supervisor G. West, Security Supervisor D. Hayes, Nuclear Plant Supervisor W. Marvin, Nuclear Plant Supervisor W. Pearce, Nuclear Plant Supervisor D. West, Nuclear Plant Supervisor L. Burton, Nuclear Plant Supervisor B. Vincent, Assistant Plant Superintendent-Electrical A. Dillard, Assistant Plant Superintendent-Mechanical W. Bailey, Quality Assurance Supervisor Krumins, Engineer Other licensee employees included technicians, operators, shift technical advisors, security force members, and office personnel.
-Attended one or more management interviews Management Interview The inspection scope and findings were summarized on October 17 and November 7, 1980 with those persons indicated in Paragraph 1 above. Specifically the unresolved and Inspector Followup Items related to commitments so cataloged.
Licensee Action on Previous Inspection Findings Not Inspecte ;
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 7.e, 7.g, 7.j.
5.
IE Bulletins The following IE Bulletins were reviewed to determine whether they had been received and reviewed by appropriate management, responses, where necessary, were accurate and complete, and that action taken, if required, was complete.
a.
(Closed)
IEB-79-03 and 79-03A - Longitudinal Weld Defects in ASME SA-312, TYPE-304 Stainless Steel Pipe (Fusion Welded).
This IEB is closed based on the licensees response L-80-260, dated August 6, 1980, that St.
Lucie Unit 1 has no such pipe in use or planned for use.
b.
(Closed)
- Possible Loss of the Emergency Notification System (ENS) With Ioss of Offsite Power.
The inspector reviewed the licensees response, L-80-288 date4 September 2,
1980, Letter of Instruction T-10, "Duties and Responsibilities of the Shift Technical Advisor", Plant Changes 112-80, and 131-80 and inter-viewed the asstant maintenance Superintendent-Electrical.
The licensee has provided emergency power for the ENS, the plant
"dimension" Bell System, the NRC HP Phones (except at the environmental monitoring tower)
and the intercom between the control room, Technical Support Center and Near Site Response Center.
The Shift Technical Advisor is charged with notifying the NRC if the ENS fails.
6.
IE Circulars The following IE Circular was reviewed to determine whether it had been received by station management, reviewed for applicability and appropriate action had been taken.
(Closed)
IEC 80-09 - Problems with Plant Internal Communications Systems The action required by this IEC was taken in conjunction with IE Bulletin 80.-15.
7.
Actions Taken to Implement The Three Mile Island Action Plan, NUREG 0660 r
a.
The inspector reviewed Licensee actions taken to implement certain portions of NUREG 0660, a
comprehensive action plan based on various
investigations and studies made following the Three Mile Island Accident.
The actions reviewed were originally part of a program referred to as
"TMI-2 Lessons Learned
- Short Term Requirements".
The reference material used as a basis for this review included the following corre-spondence and literature.
(1)
"TMI-2 Lessons Learned Task Force Report and Short term Recommendations" and NRC letter of September 13, 1979 (Eisenhut-licensees).
(2)
NRC letter of October 30, 1979 (Eisenhut-licensees)
Discussion of lessons learned short term requirements (3)
Florida Power and Light Company (FPL) letter L-80-17 of January ll, 1980.
(4)
NRC letter of March 27, 1980 (Reid-Uhrig)
(5)
FPL letter L-80-113 of April 3, 1980.
(6)
NRC Staff evaluation of St.
Lucie actions taken dated April 17, 1980.
(7)
Three Mile Island Action Plan.
(8)
NRC letter of September 5,
1980 (Eisenhut-licensees)
with September 14, 1980 addendum.
The results of this review are detailed in the following paragraphs.
TAP numbers refer to TMI Action Plan; numbers in parentheses refer to references (1) and (2).
b.
(Open)
TAP 1.A.1.1 (2.2.l.b) Shift Technical Advisor On Duty.
The basic requirement is to have personnel with Engineering or scientific degrees (or equivalent)
on shift as Shift Technical Advisors (STAs) by January 1,
1980; To establish their advisory function and to commence a training program leading to qualification by January 1,
1981.
The licensee has assigned such people to shifts since January 1,
1980.
The licensee currently has nine STAs, Seven have prior nuclear reactor operating experience-two have extensive technical experience within FPL.
The duties and responsibilities of STAs appear to be adequately delineated in letter of Instruction (LOI) T-10 approved March 3,, 1980 and revised (rev.
1) September 2,
1980.
Correspondence from the Vice President for Power Resources to plant managers dated March 7, 1980 also addresses the functions of the STA. This correspon-dence is not referenced in LOI T-10.
Though the early STA program was evaluated in reference (6) as meeting NRC requirements, further clari-
fication of duties included in reference (6) combined with increased program maturity and Technical Specification amendments being proposed by FPL indicate the need to upgrade IOI T-10 to a Plant Instruction.
Plant Management has committed to do this.
(IFI 335/80-35-01).
A formal STA training program was commenced on February 5, 1980 (Tech-nical Letter No.
31 dated January 24, 1980).
The inspector has no adverse comment on the content of the training program.
Though the Training Supervisor's signature did not appear on the implementing letter, discussions with several members of the technical staff and plant management made it clear that the program was developed with intense involvement of members of the training staff and Facility Review Group.
The licensee is currently coordinating with several other licensees to define the mechanism of final qualification required prior to January 1,
1981.
The licensee agreed that the STA training program is now mature enough that it should be formalized as a Plant Instruction (IFI 335/80-35-02).
TAP 1.A.1.1 remains open pending completion of the commitments mentioned above and pending assignment of fully qualified STAs to shifts commencing January 1, 1981.
No items of noncompliance or deviations were identified in this area.
(Open)
TAP 1.A.1.2 and 1.C.3 (2.2.1.a) Shift Supervisor Responsibilities These TAP items refer to subsections of position 2.2.l.a of references (1) and (2) and are therefore inspected as one item.
Administrative procedure 0010120 Rev.
11, "Duties and Responsibilities of Operators on Shift"; A letter dated December 29, 1979 and revised March 7, 1980 from the Vice President-Power Resources, FPSL, to Nuclear Plant Managers entitled "Duties and Responsibilities of Nuclear Plant Supervisors and Shift Technical Advisors; and Operations Supervisor letter No.
116 dated March 13, 1980 to operations personnel were reviewed in addition to listed references.
AP 0010120 defines the duti'es responsibilities, and authority of watchstanders including the Nuclear Plant Supervisor and also defines that the prime function of operators on shift is to assure the health and safety of the public.
With respect to paragraph 2.c of (2.2.1.a),
the Nuclear Plant Supervisor (NPS) is relieved by a
SRO qualified person entitled Nuclear Watch Engineer when the NPS is absent from the control room under normal conditions.
This exceeds present. Technical Specification requirements.
AP 0010120 was accepted by NRC staff following a site visit on 24-25 March 1980 - reference (b).
Administrative duties are presently in operations supervisor letter No.
161.
Reference (5) states the intent to limit a portion of those duties to approximately thirty minutes per shift, to revise plant procedures to provide for both the annual review of administrative duties by the senior (FPL) person responsible for plant operations, and annual re-issuance of the corporate directive
"5-emphasizing responsibility of the shift supervisor for the sa'fe operation of the plant.
AP 0010120 is currently under revision to incorporate the various commitments made and temporary measures.
The inspector will review this revision when issued.
(IFI 335/80-35-03).
With respect to position 3 of (2.2.l.a),
no formal training program for Nuclear Plant Supervisors could be identified, nor is the licensee presently committed to -one.
License actions such as night orders, reading file, etc.,
appear to have emphasized the NPS responsibility for safe operation in the past.
Much of the substance of NPS training proposed in ANS 3.1 draft of December 1979 is normally covered by company management training programs.
The concern here is not compliance with references (1) and (2) to date but rather the program for future compliance.
The licensee has committed to review this area.
(IFI 335/80-35-04).
'AP 1.A.1.2 and 1.C.3 remain open pending completion of commitments listed in paragraphs above.
No items of noncompliance or deviations were identified in this area.
(Closed)
TAP 1.C.2 (2'.lee) Shift and relief turnover Procedures Shift turnover and relief procedures're specified in Administrative procedure 0100120 for opeiators and for Techn'ical Staff in Letter of Instruction T-10, "Duties and Responsibilities of the Shift Technical Advisor" for STAs.
The inspector has observed frequent Quality Control Department Surveillance of Shift turnovers as committed to in reference (5).
Several discussions with plant operators and reivew of Shift turnover checklists, which were added in response to references 1 and 2, indicate that the checklists are well recieved by the operators.
While the inspector has no further questions on TAP 1.C.2, two related subjects were identified for inspector followup:
The first is that no shift overlap is specified.
Shift relief or turnover implies some sort of overlap.
Plant Management said that they do, on a case basis, hold the entire shift to complete a
more critcal plant procedure or action but that during normal steady--state operations, operators informally overlap a few minutes.
The inspector informed plant manage-ment that this would be referred to NRC management for review of acceptability.
(IFI 50-335/80-35-05).
The second subject is procedures for review of logs and turnover checklists.
It is not clear to the inspector that procedures were adequate to control this function.
This willbe followed up by the inspector.
(IFI 335/80-35-06).
(Closed) T.A.P. I.C.4 (2.2.2a) Control Room Access.
The basis requirements are to establish the authority and responsi-bilities of the person in charge of the control room, to limit access and to establish clear lines of authority and lines of succession and communication in case of an acciden Administrative Procedure AP-0010120; Operating Procedure 0010019; Emergency Plan Implementing Procedure 310021E, Rev.
7, Letter of Instruction T-10, Rev.
1, and the Emergency Plan, Rev.
6 dated May 1978 were reviewed by the inspector, who had no further questions in this area.
No items of noncompliance or deviations were identified in this area.
(Open) T.A.P. II.D.3 (2.1.3.a)
Valve Position Indicator for Safety and Relief valves.
In addition to reference materials previously listed, the inspector reviewed plant change/modification (PC/M) package 644-79, Off Normal Operating Procedure 0120036, and several control wiring diagrams.
An acoustic flow monitoring device is, installed with audible/visual alarms in the control room at the post accident panel.
The device is powered from a vital bus.
The licensee has contracted with the vendor to obtain component seismic and environmental qualification for the system.
The specified delivery date of this data has slipped from October 1980, Ref (6), and appears to
-
now be December 1980. It is not clear from review of PC/M 644-79 that the installation is made in a
manner that can be seismically qualified and can be termed single channel safety grade; specifical'ly the cable runs.
The licensee is conducting an investigation.
(Unresolved Item 335/80-35-07).
TAP II.D.3 remains open pending receipt of seismic and environmental qualification of the system and resolution of the unresolved item above.
(Open) T.A.P. II.E.1.2 (2.1.7.a, 2.1.7.b) Auxiliary Feed System Initia-tion and Flow.
This item was previously inspected (Reports 335/80-17, 335/80-25)
and referenced here to correlate the new TAP number.
A control grade system is installed.
During this inspection, Emergency Operating Procedures 0700040, Rev.
8,
"Loss of Feedwater or Steam Generator Level" and 0030140
"Blackout" were examined to verify that automatic initiation of auxiliary feedwater was addressed.
The inspector has no further questions at this time.
TAP II.E.1.2 remains open pending completion of upgrading the auto-start'nd indication portions of the auxiliary feed system to safety grade.
(Closed)
T.A.P. ICE.3..1 and II.G.1 (2.1.1)
Emergency power for Pres-surizer Heaters, Pressurizer level, Power Operated Relief Valves, and Block valves.
I Review of plant drawings shows that pressurizer heaters are powered from vital sources and deenergize upon transfer to the emergency
generator.
They may be manually re-energized from the control room.
Emergency Operating Procedures 0030140, "Blackout" and 0120040 "Natural Circulation" address use of pressurizer heaters under emergency condi-tions.'eview of plant drawings also shows that power operated relief valve solenoids are powered from vital 125 V.switchgear, motor operated block valves from 480V vital motor control centers lA5 and 1B5; and pressurizer level indication from vital instrument busses.
During this inspection, a plant work order was found that indicated that power operated relief Valve 1402 was powered from 125V DC Bus 1A via Non-class lE power panel 118 until July 21, 1980.
PCM 120-80 spliced this relief valve power cable directly to a spare breaker in 125VDC Bus 1A at that time.
The cause of this will be followed up during a future inspection (Unresolved Noncompliance 335/80-35-08).
No items of noncompliance or deviations were identified in this area.
(Closed)
NUREG 0578 item (2.1.5.c) Recombiner Procedure Upgrade I
The inspector reviewed Emergency Procedure 0120042, Rev.15.
The procedure for operation of hydrogen recombiners is included in Appendix B.
Plant drawings also show that 'electrical power is provided from vital sources.
The inspector has no further questions at this time.
TAP II.F.2 (2.1.3.b) Instrumentation to Detect Inadequate Core Cooling This item was previously inspected for short term r'equirements and is included here for correlation purposes.
See inspection reports 335/80-3, 335/80-12.
Additionally, Administrative procedure 0010125, Rev.
31,
"Schedule of Periodic Tests, Checks and Calibrations",
was reviewed.
Weekly surveillance is scheduled on the subcooling monitor.
Data Sheet No.
26 Emergency Procedures 0120042, Rev.
15, "Loss of Reactor Coolant";, "Steam Generator Tube Leak Failure";
and 0120040, Rev.
7,
"Loss of Reactor Coolant Flow" discuss operating procedures and actions to take when the subcooling monitor is unavailable.
The inspector had no further questions at this time.
T.A.P II.F.2 remains open pending upgrading in accordance with longterm actions required by reference (8).
(Open)
T.A.P. III.A.1.2 (2.2.2.b, 2.2.2.c)
Interim Technical and Operational Support Centers.
The inspector reviewed Operating Procedure 0010019, Rev. 2; Administra-tive Procedure 0010020, Rev.
and letter of Instruction (LOI) T-10.
Technical and Operational Support Centers are defined in OP 0010019.
Responsibility for staffing. is established in AP 0010020 and LOI T-10.
The licensees policy is to have the Nuclear Plant Supervisor and Shift
~ <
Technical Advisor (STA) decide who they need, then the Shift Technical Advisor contacts those persons.
The licensee was informed by the inspector that this policy did not appear to meet the intent of NUREG 0578 and would greatly interfere with the STAs function of accident.
analysis and that this would be referred to NRC management for review.
(Unresolved Item 335/80-35-09).
The computer to be used for direct display of plant parameters has arrived on site but is not installed as was scheduled (FPL letter L-80-113).
The installation has been rescheduled for April 1, 1981 (FPL letter L-80-353, Uhrig-Eisenhut, October 23, 1980).
I T.A.P. III.A.1.2 remains open pending resolution of the unresolved item and installation discussed above.
(Closed) IFI 80-17-03 The above inspection closes this item.
Reactor Trip of October 21, 1980 At 3:16 p.m., October 21, 1980, the turbine and reactor tripped, caused by a high water level in the steam generators.
Review by the inspector of the control center operators log and interviews with the operations staff indicated a
normal plant response.
A failed solenoid coil in the air supply to the "A" feed water regulating valve positioner was repa'ired and the plant returned to power by the next morning.
Plant personnel were unable to identify the specific cause of the coil failure; however, water was found in the coil housing which is exposed to the weather.
As the electrical conduit enters the top of the, housing, this and five similar solenoid valves were rotated to place the conduit entrance on the bottom, as a precaution.
No items of noncompliance or deviations were identified in this area.
Plant Operations The inspector monitored control room operations frequently during the inspection.
Areas monitored included shift staffing, operational para-meters, surveillance testing and alarm indications.
Discussions with the operating staff and plant management were held frequently.
Significant areas discussed included planned activities, plant status, and technical responses to IE Headquarters information requests.
The inspector conducted tours of plant areas.
Observations were made of work in progress, of plant house keeping and vital area controls.
No items of noncompliance or deviations were identified in this are 'I II I
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Ij PILQ COPY',
In Reply Refer To:
RII:JJ 0-33 80"34 50-389/80-15 Florida Power and Light Company ATTN:
R. E. Uhrig, Vice President Advanced Systems and Technology P.
O. Box 529100 Miami, FL 33152 Gentlemen:
This refers to the inspection conducted by J. Blake of this office on October 27-31, 1980 of activities authorized by NRC Operating License No. DPR-67 and NRC Construc-tion Permit No.
CPPR-144 for the St. Lucie facility, and to the discussion of our findings held with B. J.
Escue at the conclusion of the inspection.
Areas examined, during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.
We have examined actions you have taken with regard to previously 'identified enforcement matters.
These are discussed in the enclosed inspection report.
Four new unresolved items resulted from this inspection and are discussed in the enclosed report.
These items willbe examined during subsequent inspections.
During the inspection, it was found that certain activities under your license
.appear to be in noncompliance with NRC requirements.
These items and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's
"Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within 20 days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which willbe taken to avoid further noncompliance; and (3) the date when full compliance 'will be achieved.
In accordance with Section 2.790 of the NRC's
"Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a
copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor)
believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure.
Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part, of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Roo ~
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Florida Power and Light Company I
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, C. E. Murphy, Chief Reactor Construction and Engineering Support Branch
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report Nos. 50-335/80-34 and 50-389/80-15
REGION I I 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 50-389/80-15 and 50-335/80-34 Licensee:
Florida Power 8 Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name:
St.
Lucie Docket Nos.
50-389 and 50-335 License Nos.
CPPR-144 and DPR-67 Inspection at Inspectors:
J.
St.
Lucie site near Ft. Pierce, Florida 4c-
/
D te Signed l a sr Date Signed
/ M 8'/
W.
einsorge L
Z jac Accompanying Personnel:
A.
R. Herdt Approved by~~~
A.
R. Herdt, Section Chief, RCES Branch Date Signed
/z Si ate Signed
/-z- ~']
Date Signed SUMMARY Inspection on October 27-31, 1980 Areas Inspected This routine, announced inspection involved 146 inspector-hours onsite in the areas of in-depth gA inspection of performance in piping and structural welding; housekeeping and storage of materials; previously identified inspection findings; IE Bulletin 80-08 response; and alleged items of concern in the area of welding.
Results Of the 5 areas inspected, no items of noncompliance or deviations were identified in 3 areas; 5 apparent items of noncompliance were found in 2 areas (Deficiency -.
NDE certification program - Paragraph 6, Infraction-NDE performance
- Paragraph 6,
Infraction - Radiographic examination compliance - Paragraph 6, Infraction-Control of temporary attachments
- Paragraph 6; and Infraction Housekeeping-Paragraph 7).
DETAILS Persons Contacted Licensee Employees
- B. J.
Escue, Site Manager, PSL-2
- J. A. Thompson, Assistant Site Manager
- N. T. Weems, Assistant Manager gA Construction
- R. A. Garramore, Senior Resident Engineer
- W. M. Hayward, Supervising gA Engineer
- D. Cooper, Supervising gA Engineering
- K. N. Flanagan, Project Superintendent
- R. W. Zaist, Construction Superintendent
- L. V. Pelosi, Site Project Engineer
- W. F. Jackson, Welding Superintendent
- J. L. Parker, Project gC Supervisor
~J.
D. Behres, Area QC Supervisor Mechanical
- H. Averbach, qC Supervisor
"J.
W. Adams, guality Engineer
- J.
R. Luke, guality Engineer L. Drummond, guality Engineer
- L. T. Page, gA Engineer Records
- A. W. Bailey, Supervisor gA OPS
- T. C. Grozan, Nuclear Licensing (GO)
- W. M. Gaines, EPP
- G. Crowell, EPP
- R. C. Rasbury, CPL Other licensee employees contacted included several construction craftsmen, gC technicians, and office personnel.
- Attended exit interview.
2.
Exit Interview 3.
The inspection scope and findings were summarized on October 31, 1980 with those persons indicated in Paragraph
above.
The items of noncompliance and other new items were discussed in detail.
The licensee indicated that corrective actions were already under way on the majority of the findings.
Licensee Action on Previous.Inspection Findings (Open)
Repeat Infraction 389/80-13-02:
"Welding Fil 1 er Material Control".
This item concerns the licensee's failure to control used and unused welding filler materials.
Inspection of the work areas showed numerous examples which indicate that the licensee is in continued noncompliance.
The licensee indicated that their gA program has identified this problem on many occasions.
In view of the above it
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appears that the gA Department has not adequately exercised their pnerogative to take effective corrective action to prevent recurrence.
This item remains open.
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 6.a, 6.c.
and 6.d.
5.
Status of Previously Identified Inspector Follow-up Items (Unit 1)
(Open)
Inspector Fol 1 ow-up Item 335/80-31-01:
"Review of Welder qua 1 ificati on Audit".
This item involves an audit of welder qualification committed to by the licensee as the result of a concern reported to NRC:RII.
This item was discussed with the licensee, but the audit was not complete at the time of this inspection.
This item remains open.
6.
gA Inspection of Performance This inspection was performed to determine whether site work is being performed in accordance with NRC requirements and SAR commitments, the gA/QC program is functioning in a
manner to assure requirements and commitments are met, and that prompt and effective action is taken to achieve permanent corrective action on significant discrepancies.
The following areas were examined to verify the inspection objectives:
a.
Field Drawings and Work Procedures (1)
The inspectors reviewed the below listed documents to determine whether the most recent revisions of field drawings, construction specifications and work procedures are in agreement with the SAR and system drawings.
Number 2998-B-052, Rev.
(EBASCO)
2998-8-052, Rev.
8 (CE)
Tit'Lb
"Piping Line List"
"CE Portion of EBASCO Drawing 2998-B-052" CE-lOOEt1DRAC-2998-51 and -52, Rev.
2998-G199, Rev.
(EBASCO)
"Safety Injection System Diagram"
"Safety Injection System Piping Section and Details" SI-N-5, Rev.
(BF Shaw)
"Safety Injection Piping"
(2)
(3)
The inspectors reviewed the below listed documents to determine whether design changes have been properly provided, reviewed, approved and processed.
DCN-513. 898 DCN-513. 480 DCN-513. 451 The inspectors reviewed the below listed documents to determine whether work procedures adequately describe critical points and methods of installation as well as inspection and test hold points - to properly reflect design intent.
Numbers EBASCO Specification 62-72, Rev.
Title
"General Power Piping" QI 9.1, Rev.
"Visual Inspection of Welds" With regard to the above inspection, the inspectors questioned the licensee regarding the adequacy of his requirements for cold spring in piping.
In response, the licensee stated cold spring requirements are contained in Construction Quality Control Quality Instruction manual, Procedure, QI 9.1, Rev.
3, Attachment 1,
Paragraph 1.2.6.
Paragraph 1.2.6 states
"Cold Spring is not allowed in the fit-up of piping joint.
The fit-up shall be made without an excessive amount of mechanical force."
The inspectors stated that the above requirement does not seem to provide adequate guidance for cold spring control.
b.
Fiel d The licensee indicated that they would examine the requirements further.
The inspectors stated that the above would be an unresolved item identified as 389/80-15-08:
"Cold Spring Control Requirements".
Inspection The inspectors made a detailed inspection, including physical measurements, of a
porti on of the safety injecti on pi ping system as indicated below to determine whether equipment or systems are installed/erected as described by field drawings and construction specifications.
From Weld No.
SI-410-FW-1 S I-417-FH-1 To Weld No.
SI-410-FW-2 SI-417-FW-3 Drawin No S I-N-5 S I-N-5
I
SI-417-FW-3 SI-410-FW-1 SI-N-5
16 I-12-SI-410-1 c ~
'(2)
The inspectors interviewed craftsmen and foremen associated with safety-related piping fabrication and installation to determine whether their level of knowledge is adequate to provide the required quality of, workmanship.
guality Control (1)
gC Inspection Reports The inspectors reviewed nondestructive examination reports for the below listed welded joints to determine adequacy; whether deficiencies submitted by gC inspectors received proper corrective action where applicable; and if work controls were adequate.
Weld No.
B.
F Shaw
15 Weld No.
FPSL 2-SI-475-FW-1 2-S I-410- FW-1 2-SI-410-FW-3 2-S I-417-Rl-3 Drawin No.
I-10-SI-417-1 I-10-SI-417-1 I-10-SI-417-2 I-10-SI-417-2 I-12-SI-410-1 I-12-SI-410-1 I-12-SI-410-2 I-12-SI-410-2 SI-N-5 SI-N-5 SI-N-5 S I-N-5
r s
D
(2)
equality Control Inspection (a)
Liquid Penetrant Examination (PT)
The inspectors observed liquid penetrant examination of four items identified below, to determine whether or not the examination was performed per Code requirements and licensee's written procedures.
The applicable Code for nondestructive examinations is ASME Boiler and Pressure Vessel Code,Section V,
1977 edition with addenda thru sumer 1977.
Item Examined Weld Identification Class Electrical Penetration P/N 2F-2-P-OE6-003 P-OE6 Completed Butt Weld, Mat'1 Pl to PS El ectrical Penetration P/N 2F-2-P-OE7-003 P-OE7 Completed Butt Weld Mat'1 Pl to PS Reinspection After Grinding 2F-2-P-OE7-003 Electrical 'Penetration P/N P-OE7
2F-2-SI-0515-001 Pipe Weld Mat'1 P8 to PS Spool Pc. I-6-SI-515-1 to Spool Pc.
I-12-SI-149-1 Final Weld
The following discrepancies were noted during observa-tions of these examinations:
The inspectors observed a
Level I examiner PT on ASME Code Class 2 weld joint No. 2F-2-P-OE7-003 on electrical penetration No.
P-OE7.
The results of the examiner's evaluation was that the weld joint was acceptable without additional surface condi-tioning and he so indicated his acceptance on the weld traveler record.
The inspectors, however, pointed out to the examiner, and a
Certified guality Control Supervisor, 9 linear indications from 3/16-inch to 4-inch in length.
These indications were located in the weld and one indication located in the 4-inch adjacent base material.
Within the 3;-inch adjacent base material required grinding to approximately 1/32-inch deep before the indication was removed.
The equality Control Supervisor who was also a
Certified Level II examiner concurred with the inspectors
that this weld joint should have been rejected and all the linear indications removed.
In addition the liquid penetrant re-inspection of the
rejected areas by a
Level II examiner after grinding revealed additional rejectable indications.
The inspectors also observed a
Level II examiner evaluated weld joint 2F-2-P-OE6-003 this is an ASHE Class 2 weld.
The examiner rejected the weld joint and had marked the areas requiring repair.
The inspectors reviewed the PT indications'marked and concurred with the examiner's evaluation in these areas, however, the inspector also pointed out
linear indications, one a
heavy bleedout and the other not as profound, within 4-inch of the weld.
These were not marked for removal.
These are examples of inadequate NDE examiner performance and as such are a
part of Infraction No. 50-389/80-15-02
"NDE Performance".
As a result of this examiner's failure to reject the
linear indications noted on weld joint 2F-2-P-OE7-003 the licensee informed the inspectors during the exit interview on October 31, 1980, that this individual will be recertified and all inspections previously performed by this individual will be reinspected.
This item will be reported as an inspector follow-up item No. 50-389/
80-15-10, "Certification of Level I PT examiner - Training and Experience."
(b)
Magnetic Particle Examination (MT).
The inspectors observed magnetic particle examinations (MT)
of one production pipe weld, weld joint No.
2F-2-CC-0050-002, which i a ASME Class 3, 8-inch diameter, component cooling water system weld.
In addition the inspectors observed the HT of an AWS seismic qualified structural weld, joint No.
2F-2-STL-G803-015.
The inspectors observed these HT examinations to determine whether HT was being performed in accordance with Code requirements and the licensee's written procedures.
The applicable Code is the same as indicated above for liquid penetrant examination.
The following discrepancies were noted during the obser-vation of the HT examination of weld joint No.
2F-2-STL-G803-015:
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The inspectors noted that at times during the MT inspection, the application of powder by the examiner was extremely heavy and that the blow bulb used to remove the powder was held between the MT coil legs at a distance of approximately >;inch and squeezed rigously to remove this heavy concentration of powder.
"Standard Method for Dry Powder Magnetic Particle Inspection" which is invoked by Article 7,
"Magnetic Particle Examination" of ASME Code,Section V and Paragraph 4.3.2 of the licensee's Magnetic Particle Inspection Procedure gI 9.4, Revision 1 states in part:
"The powder shall be applied by lightly dusting a
small quantity over the magnetized surfaces, and then removing the excess with a gentle air stream.
The air stream shall be controlled so that it does not disturb or remove powder patterns indicative of discontinuities."
In addition, the inspectors noted that the red iron powder used during the inspection did not contrast with some of the as-welded background surface, and the examiner was forced to use a flashlight to get better definition even though the lighting in the area was more than adequate.
The inspector's.
observation was that a
black powder should have been used for contrast with the weld surface background.
This matter was discussed with the certified gC supervisor and he also concurred that black powder should have been used.
Paragraph 5 of SE-109 and Paragraph 4.3.1 of the licensee's procedure states in part:
"The color of dry particles shall provide adequate contrast with the background surface being examined."
It should be noted that the areas in question above were reinspected by the inspectors and only the examiner's technique and not the acceptances of this weld is of concern.
These are examples of inadequate NDE examiner performance as it relates to magnetic particle testing and are a
part of Infraction No. 50-389/80-15-02.
(c)
Visual Examination The inspectors visually examined final weld No.
MS-0029-007 and noted that the transition between the weld and adjacent tee fitting was sharp, i.e., it did not have the smooth transition as described by ASME,Section III, Article 4000, Figure 4250-1.
This joint had already been accepted visuall ~I
This is another example of Infraction No.
50-389/80-15-02
"NDE Performance."
Pi e Size and Mat'1
~Sstem (d)
Radiographic Examination I
The inspectors reviewed radiographic films for the pipe welds, identified below, to determine whether Code requirements and licensee procedures were being met.
The applicable Code is ASME Boiler and Pressure Vessel Code,Section V, 1977 edition with addenda thru summer 1977.
Joint Identification SI-0110-008 SI-0417-002 SI-0110-002 MS-0029-007 P-15 FW-3 Hain Steam Penetration thr u Containment wall 34" Carbon Steel 8" Carbon Steel Safety Injection 6" Stainless Steel Safety Injection 10" Stainless Steel Safety Injection 6" Stainless Steel P-17 FW-3 P-19 FW-3 Penetrati on thru Containment wal l Penetration thru Containment wall 8" Carbon Steel 8" Carbon Steel
. P-26 FW-3 Penetration thru Containment wall 12" Carbon Steel P-29 FW-3 P-30 FW-3 Penetration thru Containment-wall s
Penetration thru Containment wall 6" Carbon Steel 6" Carbon Steel P-32 FW-3 Penetration thru Containment wall 34" Carbon Steel P-43 FW-3 Penetration thru Containment wall 8" Carbon Steel P-70 FW-3 Penetration thru Containment wall 10" Carbon Steel P-24 FW-3 Penetration thru Containment wall 8" Carbon Steel
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- P-64
- Unit FW-3 Penetration thru 24" Carbon Steel Containment wal 1 1 penetration; all others are for Unit 2.
The following discrepancies were noted during this review:
Radiographs for penetration No.
showed several pene-trameters with a lead letter "F" positioned in the weld area on each exposure rather than on the adjacent base metal as required.
Although a note on the reader's sheet stated that due to configuration, the penetrameters were placed on the weld, this statement proved to be erroneous based that one additional exposure was taken after weld repair with the penetrameters properly placed on the adjacent base metal.
This joint should be re-radiographed with the penetrameters and lead letter "F" positioned on the base metal as specified in the ASHE Code.
Paragraph T-263.1 of Article 2 of Section V states in part,
"For welds, a
source side penetrameter shall be placed adjacent to the weld seam except in instances where...
the geometric configuration makes it impractical...."
3 ~
4.
A set of radiographs for penetration No.
were not dated.
These films were in a film packet dated 1/1/80.
Paragraph T-236 of Article 2 of Section V requires the date of the radiograph to be plainly and permanently included on the radiograph.
Radiographs of penetration
.
No.
for weld areas identified on the film reader'
sheet as 15-22)
and (22-29),
had no location marker at the (22 position.
Measurements could be made to verify adequate coverage, but location markers are required.
Paragraph T-237 of Article 2 of Section V states in part,
"Location markers, which are to appear as radiographic images on the film, shall be placed on the part...
providing evidence on the radiograph that the required coverage of the region being examined has been obtained."
The radiographs of penetration No. 32, weld area (105-0),
show a >;inch blob of metal (could be an arc strike)
on the base metal approximately 3/4-inch from the weld edge.
This indication was not reported on the film reader'
sheet.
This discontinuity, as viewed on the radiographs, could result in serious problems.
In addition to the blob, there is, what appears to be remnants of weld metal
from a temporary attachment.
This was not reported on the film reader's sheet either.
It is located about
inches from the weld edge and is about 3" long.
Paragraph T-292 of Article 2 of Section V requires the manufacturer to examine and interpret the radiographs and to record on a review form accompanying the radio-graphs the interpretation of each radiograph and disposition of the material examined.
The film reader's sheet for penetration No.
26 indicates a
radiographic technique other than what was actually used.
The reader's sheet states technique No.
3 when in fact technique No.
4 was used.
Paragraph T-293 of Article 2 of Section V requires detailed radiographic setup information to aid in the interpretation of radiographs.
The film reader's sheet for penetration No.
24 indicates that 2T sensitivity is required, but only 4T sensitivity i s displ ayed on the radi ographi c films.
The reader '
sheet is in error, since 4T sensitivity is required by the AStiE Code.
Errors of this type point out a lack of attention to details which can result in more significant items being overlooked.
As noted above the applicable standard is ASME B and PV Code,Section V,
1977 edition thur summer 1977 addenda.
The above examples are indicative of noncompliance with
CFR 50.55a.
This item is Infraction No. 389/80-15-03
"Failure of Radiographic Examination to Comply With ASNE Code Requirements."
The radiographs of SI-0417-002, exposure (0 - 8), indicate what appears to be unacceptable incomplete fusion (IF)
and incomplete penetration (IP).
This area was repaired once for IP, but it appears not all of the areas intended to be repaired, were actually repaired.
An indication of IF at station marker "0" appears to have been overlooked on the original radiographs as this area was not repaired. It is noted that the the IF indication is not as prominent on the second set of radiographs as it was on the original films.
Also, an indication of IP at station marker "7" appears to have been overlooked.
The licensee agreed to re-evaluate these radiographs and initiate action necessary to verify acceptability of the subject weld.
This will be carried as Unresolved Item No. 389/80-15-09 "Potential Unacceptable Safety Injection Pipe Weld."
8.
The inspectors observed radiographic examination of main steam joint MS-0029-007 during the backshift.
(This weld was discussed earlier in the paragraph on visual examination performance.)
(e)
Ultrasonic Examination The inspectors observed ultrasonic examination of a seismic qualified AWS structural weld No.
2F-2-STL-G838-2-128 to determine whether the examination was performed in accordance'ith Code requirements and licensee s written procedures.
The applicable Code is the same as that indicated above.
d.
equality Control Inspectors (1)
Discussions with Nondestructive Examiners (a)
The inspectors held discussions with four liquid penetrant examiners, two magnetic particle examiners, one ultrasonic examiner and two certified NDE supervisors.
The discussions centered on:
How they carry out procedural requirements;
Whether they had the necessary qualifications for the level of work being performed; and
Whether they felt their findings received proper attention.
One examiner indicated that one of the ultrasonic indica-tions which he reported to be in a structural weld had been called a
base metal indication and accepted by Engineering.
The weld in question was Ho.
2F-2-STL-G838-275 in the main steam tressel safety-related steel work.
The inspectors reviewed the UT report and the disposition of the weld repair request (WRR) after having visually inspected the weld in question.
The WRR No.
1726 had been dispositioned by referring to an Engineering memo No. FM-2-80-2456 which states that base metal indications should only be considered if they are within 3/16-inch of the weld zone.
Indications beyond the 3/16-inch zone are acceptable.
After reviewing the documentation for this weld the inspectors could not ascertain how it was determined that the indication was beyond the 3/16-inch zone.
At the request of the inspectors, the engineers showed how the indication was located by plotting the UT report dimensions on a
scale drawing of the weld joint.
The inspectors noted that the scale drawing of the weld had
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(b)
a weld groove which measured approximately 7/8-inch at its widest spot.
(This did not compare favorably with the weld which measured approximately 1-3/8-inch wide at that same location.)
When asked about this, the engineers were apparently not aware of this weld size.
After viewing the weld with the inspectors, the licensee's engineers immediately began examinations trying to determine the exact size of the weld, in order to determine whether, in fact, the reported indication was outside the 3/16-inch area of interest.
(The apparently wider than expected weld gap would tend to indicate that the indication is in fact in the heat affected zone.)
The status of this weld was still in question and will be carried as Unresolved Item No. 50-389/80-15-06
"Evaluation of Repair Requests."
During the examination of this weld the inspectors noted that the bolt holes in the plate containing the weld had been elongated.
When asked whether the holes were acceptable the licensee's engineers were not able to make a determination.
This question will be carried as Unresolved Item No.
50-389/80-15-07
"Unfairness of Bolt Holes."
Review of gualification Records The inspectors reviewed the qualification records for individuals qualified to perform visual, liquid penetrant, magnetic particle, ultrasonic and radiographic examinations.
The following discrepancy in qualification records was noted:
The inspectors reviewed the qualification folder for the Level I liquid penetrant examiner who had accepted the weld joint which had 9 rejectable linear indications as noted in Paragraph 6c above.
His certification records indicated that he was certified as a Level I examiner in visual inspection, liquid penetrant and magnetic particles examination.
However, a review of his previous employment records did not indicate he had sufficient documented practical experiences or classroom.training to be certified as a
Level I examiner as required by Table 6.2. 1A of SNT-TC-1A 1975 Edition of Attachment 1, page 1 of the, licensee s
procedure gI 2.7, Revision 5.
In addition,
'ive records of qualification in this examiner's quali-fication folder indicated that he held a Level II certifi-cation.
The five records consisted of the following:
Inspection Personnel Eye Exam
Indoctrination Training Record
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3 Inspection gual ificati on Sheet
Position Description Sheet
Construction guality Control Training Record (c)
Review of gualification Test and Practical Examination Test Specimens
The inspectors reviewed visual examination as it related to training and qualification test specimens.
Numerous test specimens (hardware)
were reviewed to determine whether the defects and surface conditions, required to be evaluated by the licensee's written Procedure, 9. 1, Revision 3, and by ASME Code were adequately illustrated.
The following discrepancies were noted:
a 'he test specimens, shown to the inspectors, are not formally included in the training program.
The one test specimen, currently being used for a qualification test specimen, is considered inadequate to verify the examiner candidate's proficiency in visual examination.
The qualification examination needs to include specimens representative of the type of welds and joint fitups the examiner is expected to evaluate in production, as required by Paragraph NB-5521 of Section III.
For example, the test should consist of pipe joints to be fitup, which tests the examiner candidate's.ability to use measuring devices as well as his knowledge of fitup requirements; at least the majority of the weld defects listed in the licensee's procedure should be included; socket or fillet welds should be included in addition to the pipe joint already in use.
Several defects/surface conditions are not included in'he hardware samples, i.e.,
burn thru, cracks, blow holes, 3 to 1 taper at the end of counterbores, the land on a weld prep.
The inspectors also reviewed magnetic particle and liquid penetrant examinations, only as it related to training and qualification test specimens.
The following test specimen deficiencies were noted:
0
MT test specimen No.
6 which is one of the two currently used test plates for testing MT candi-dates for examiner certification is not typical of MT welding defects and does not adequately appraise the examiner's ability to actually identify common welding defects.
The defects in the test sample are chisel marks that could be seen visually and which an examiner would be expected to have removed prior to MT.
In addition the number of indications are not recorded on the evaluation sheet, so determining if the examiner has identified 905 of the known indications as required by Paragraph 8.6.4 of SNT-TC-1A and Paragraph 5.4.2 of the licensee's Procedure gI 2.7 is a matter of opinion in lieu of established fact.
Test specimen No. 10, which is exclusively used for testing PT examinees, is also so grossly defective that it is not typical of PT indications that an examiner would normally be expected to encounter.
All indications described on the evaluation sheet for this test specimen can also be seen visually.
In addition, the number of rejectable indications are not noted.
However, the equality Control Supervisor who administers the test indicated that there were in the neighborhood of around 40 to 50 rejectable indications.
This weld would also be expected to be rejected visually by any qualified. examiners.
The inspectors concern that test specimens which are not typical of normal weld defects and are so gross that it does not test the ability of the examinee in the specific discipline that he is certifying in, appears to be one factor that may have resulted in the examiner's failure to identify tight linear indications as discussed in Infraction 50-389/80-15-02..
As noted previously, failure to establish the number of known indications in test specimens and also failure to have adequate test specimens for the intended certification of an examinee, in a specific discipline, is in noncompliance with SNT-TC-1A, the licensee's Procedure gI 2.7, Revision
and
CFR, Appendix 8, Criterion IX.
This item will be identified as a Deficiency item No. 50-389/80-15-01,
"NDE Certification Program Discrepancies".
e.
Qual ity Control Procedures Tttl e The inspectors reviewed FPSL's Nondestructive Examination Procedures listed below to determine whether the procedures meet Code requirements, are adequate to properly control the work, and are detailed to instruct the QC inspector on exactly what he should be looking for (especially acceptance criteria) when making inspections or observing a test.
Procedure No.
QI 9.1, Revision
QI 9.2, Revision
QI 9.3, Revision
QI 9.4, Revision
QI 9.5, Revision
QI 9.9, Revision
QI 2.7, Revision
Visual Inspection of Welds Inspection of Field Welding Radiographic Inspection Magnetic Particle Inspection Liquid Penetrant Inspection Ultrasonic Inspection of Struc-tural Welds NDE Personnel Qualification and.
Certification f.
Nonconforming Items Report (NCR)
The inspectors reviewed the licensee's program for the documentation and control of nonconforming items.
The program includes Nonconformance Reports (NCRs), Deficiency Reports (DRs)
and Weld Repair Requests (WRRs).
The inspectors selected a
number of NCRs, DRs, and WRRs for review.
g.
Materials and Equipment (1)
The inspectors examined/reviewed the items and certification documentation for the below listed components to determine whether meaningful inspections were made to verify that material meets specifications and to what degree the licensee/
contractor had inspected or verified performance by the vendor; item meets design and purchase order requirements; and the documentation is adequate; and the item meets design inten ~Com onent Tube 12.750 x 0.330 ECC.
Reducer 12" x 10" Elbow 10",
90'on.
Reducer 10" x 8" Elbow 12",
90'eat or Control No.
19222 JFVL JHJZ JGOE JFVM (2)
Welding material purchasing and receiving records for the following material s were reviewed for conformance with appl icable procedures and Code requirements:
~Te Process Size Heat No.
ER-308 GTAW 3/32 27516 308-16 SMAW 308-16 SMAW 3/32" 0328 1/8" 56724 ER308L GTAW
'.045" Y3189T308L 308-16
'HAW 3/32" 56493 ER-308L GMAW 1/16" 8900 ER-308 Sub Arc H5300 Sub Arc 3/32" 462317 Lot 16 (3)
The inspectors reviewed the purchase documents and certification records for the liquid penetrant materials listed below to ensure they met the Code requirements concerning total amounts of sulfur and halogens permitted.
Material Liquid Penetrant Liquid Penetrant Liquid Penetrant Penetrant Cleaner
~Te SKL-NF/S K017 SKL-NF/S SKC/NF Batch No 80-E-005 54-E803 79-H063 80-E116
L
Penetrant Cleaner Liquid Penetrant Developer Developer Developer K019 SKL-NF/S SKD-NF I
SKD-NF SKD-NF 56-H829 80-F006 80-E116 78-E125 80>>B048 h.
Control of Temporary Attachments and Their Removal (1)
During the inspectors inprocess inspection of welding and NDE, the inspectors noted that weld travelers at fit-up inspection did not indicate that temporary attachments were installed, nor was the immediate area around the temporary attachment marked.
Paragraphs NB-4231.2, NC-4231.2 and in part Paragraph ND-4435 of Section III of the ASME Code, 1977 edition thru summer 1977 addenda permits the use of attachments which are welded to the component during construction but which are not incorporated into the final component, such as alignment lugs or straps, tie straps, braces, preheat equipment, postweld heat treatment equipment provided the following requirements are met:
(a)
The material is identified and is suitable for welding but need not be certified material.
(b)
The material is compatible for welding to the component material to which it is attached.
(c)
The welding material is compatible with the base material and is certified in accordance with NB-2130, and NC-2130.
(d)
The welder and welding procedure are qualified in accordance with NB-4320, NC-4300 or ND-4321.
(e)
The immediate area around the temporary attachment is marked in a suitable manner so that after removal the area can be identified until after it has been examined in accordance with (g)
belo (f)
The temporary attachment is completely removed in accordance with the procedures of NB-4211, or NC-4211.
(g)
After the temporary attachment has been removed, the mar ked area is examined by a magnetic particle or liquid penetrant method in accordance with the requirements of NB-5110, or NC-5710 and meets the acceptance standards of NB-5340, NB-5350, NC-5340 or 5350 whichever is applicable.
(h)
The attachment weld or the area after removal of the attachment is postweld heat treated in accordance with NB-4620, NC-4600 or ND-4620.
Specific examples noted
- during this surveillance inspection consisted of the following:
Item Weld Number Class Spool pc.
CC-37-4 TO 2F-CC-0037-005 Spool pc.
CC-37-5 Preheat E ui ment P/N P-OE7 2F-2-P-OE7-003
P/N P-OE6 2F-2-P-OE6-003
A review of the licensee's
'procedure gI 9.1 and discussions with Florida Power and Light Company (FPLL)
equality Control Supervisor revealed that temporary attachments are inspected on the final weld in accordance with gI 9. 1 only when the area where the temporary attachment was removed can be identified.
The licensee agreed that procedural controls to insure FPSL verification and/or reinspection of all temporary attachments as required by Section III of the ASME Code was an oversight in the gC program.
Failure to establish adequate measures for the control of temporary attachments and their removal is in noncompliance with 10 CFR 50, Appendix B, Criterion IX.
This is an infraction and will be identified as item number 50-389/80-15-04,
"Inadequate Controls for Temporary Attachments."
i.
Audits The inspectors reviewed the following audits in the area of welding and NDE:
OAC-PSL2-80-08 Wel ding Control (AC-PSL2-80-21 Special Processes OAC-PSL2-80-24 HVAC Contractor (AC-PSL2-80-30 Weld Filler Material The audits appear to be predominately documentation oriented.
The inspector stated that the subject of auditing work as well as documentation was an area of concern and would be listed as Inspector Follow-up Item 50-389/80-15-11,
"Audits."
Within the areas examined no items of noncompliance or deviations were identified except for the. following:
Infraction Infraction Deficiency Infraction 7.
Independent Inspection Paragraph 6c(2)(a)2 Paragraph 6c(2)(d)6 Paragraph 6d(1)(c)2 Paragraph 6h(1) (h)
The inspectors conducted walk-through inspections of the reactor building, auxiliary building, material storage facilities and fabrication shops.
During the inspection of the reactor and auxiliary buildings, the inspectors noted an inordinate amount of garbage accumulating in all areas of these structures.
There was also a fair amount of construc-tion debris in the areas but the inspectors were primarily concerned with the following indicators of poor housekeeping:
a.
On Monday, October 27, 1980, the inspectors found a large number of cans of liquid penetrant materials, PVC adhesive materials, and insecticide sprays laying around the lower level of the containment.
(Some of the liquid penetrant materials and the PVC adhesive materials were labelled as highly inflammable.)
b.
On the same day food remnants, food wrappers and containers, as well as beverage cans were found throughout the 'containment and
'uxiliary building c.
On Monday through Thursday, uncontrolled welding electrodes were found throughout the reactor, auxiliary, turbine and diesel generator buildings.
The conditions noted during these inspections indicate that the requirements for housekeeping during the construction phase of nuclear power plants ANSI N45.2.3-1973 are not being met.
In fact, the inspectors found no evidence that any of the requirements of ANSI N45.2.3 for the establishment of and surveillance of housekeeping zones are being adhered to.
The inspectors informed the licensee that the status of the housekeeping would be categorized as an Infractin No.
50-389/80-15-05,
"Housekeeping" in that adequate measures in the form of procedures, etc.,
have not been implemented to provide adequate housekeeping.
Review of IE Bulletin No.
80-08, Examination of Containment Liner Penetration Melds IE Bulletin 80-08 was issued on April 7, 1980, and requested licensees to determine whether their facility contained the flued head design for penetration connections, or other designs with containment boundary butt welds between the penetration sleeve and process piping as illustrated in Figure NE 1120-1, winter 1975 addenda to the 1974 edition and later editions of the ASME Boiler
Pressure Vessel Code.
If the licensee's facility does contain this design then the licensee was requested to determine whether welds were made with a backing r ing and whether or not volumetric examination was conducted by radiography.
The Bulletin indicates that weld joints with a backing ring that have not been radiographed, are of particular interest as they are potentially defective.
In response to the Bulletin, Florida Power 5 Light Company (FPEL)
forwarded letter L-80-323 dated September 29, 1980, which provided a
listing 'of all Unit 2 penetration welds.
This letter indicates that all joints were, or will be, radiographed and that backing rings were not used.
During the visit to St. Lucie, the inspectors requested the radiogr aphs and records for several of the welds listed in the FPLL letter in order to review the films for compliance to Code requirements.
The films were retrieved, but it was subsequently determined that these radio-graphs were not for.the type of joints referenced in the Bulletin.
In discussions with the licensee it appears that the joints described in the Bulletin were fabricated by the vendor, thus the radiographs and records would not be available at the St. Lucie Site.
r Now that there is a clearer u'nderstanding of what joints the Bulletin refers to, the licensee has agreed to review their letter for Unit 2 and either modify it or revise it such that it reflects the information asked for in the Bulletin.
It should be noted that the licensee's response to the Bulletin for Unit 1 penetrations was obtained by the
inspectors while at the site.
Thus, the contents of this letter (L-80-215)
have not yet been reviewed by Region II.
In view of the misunderstanding regarding Unit 2 joints, the licensee agreed to also review the information provided for Unit 1 to determine if it is what the Bulletin requested.
9.
Concern Regarding Welding Practices The Region II office was contacted by an individual who expressed the following concerns in substance:
a ~
Welding procedures for work on the primary cooling loop were not followed.
Specifically, QC Inspection Report M80-1713 addresses a
practice where 0.045" wire is being twisted together. to make tack welds.
The one weld specifically identified was RC-112005.
The FPKL'elding superintendent was aware of the practice described above and did nothing about it.
The inspectors reviewed FPSL Inspection Report F80-1713, Weld Material Requisition Report SL-87111 (welding filler material for Weld Joint No. RC-112005),
Weld Traveler for Weld Joint RC-112005, Weld Data Change Request for Weld Joint No.
RC 112005 dated October 10, 1980 and Welding Procedure Specification 50, Revision 7.
The inspectors determined that the use of 0.045" diameter filler wire was properly authorized and documented consistent with the licensee's QA/QC program and the ASME BSPV Code prior to the start of welding.
The linear volume of two twisted 0.045" diameter welding filler wires is greater than that (one
.045" diameter rod) authorized by the October 10, 1980 note to the traveler and less than that authorized by the Welding Procedure Specification (one 0.093" diameter rod).
Therefore the use of two twisted 0.045" diameter welding filler wires for tacking Joint RC-112005 is consistent with the requirements of the ASNE Code, and the licensee's QA/QC program.
The licensee indicated that the use of two twisted 0.045" diameter welding filler rods was necessary because the 0.045" diameter filler material authorized (Code No.
088)
was the only material on site that conformed to the chemistry requirements of the CE specification covering welding filler material for the reactor coolant system.
b.
Weld rod and filler material control is not maintained during the night shifts.
Weld rods and filler material have been observed on the floor of the auxiliary building on numerous occasions.
FP&L takes the position that QA is responsible for all weld rod/filler material control.
There is no QA/QC inspector surveillance of welding during the night shifts.
The above was identified by NRC Inspection Report RII:WPK 50-389/80-13 as an infraction identified as
"Welding Filler Material Control".
The licensee stated that there was 'only
I
infrequent QA surveillance of welding during the night shift.
This item is further discussed in Paragraph 3.
The Project QC Supervisor (FPSL night shift supervisor)
destroyed an NCR which was initiated because a
QC/ANI hold point had been bypassed.
The NCR, M80-1764, dealt with weld CS-26-001 in the containment spray system and was dated October 17, 1980.
When destroying the NCR, the supervisor stated that the hold point was not required by the Code.
The individual also indicated that the weld was subsequently ground out and rewelded, but failed inspec-tion and a second NCR was generated.
The inspectors reviewed General Inspection Report
'880-1764, the traveler for Meld Joint CS-26-001 and WRR-1889.
The inspectors determined that the repair welding and the actions taken as a
result of the missed ASNE required hold point to the date of this inspection were consistent with the licensee's QA/QC program and the ASME BSPV Code.
By the licensee's QA/QC program, the super-visor was justified in destroying the NCR coupled to N80-1764 because repairs could be accomplished using existing procedures.
The inspectors have no further questions as the licensee's program identified and corrected the proble h
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