IR 05000335/1981020

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IE Insp Repts 50-335/81-20 & 50-389/81-16,on 810818-21. Noncompliance Noted:Inadequate Measures to Control Welding
ML17212A980
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 09/04/1981
From: Herdt A, Kleinsorge W, York J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17212A974 List:
References
50-335-81-20, 50-389-81-16, NUDOCS 8111050766
Download: ML17212A980 (23)


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UNITED STATES UCLEAR REGULATORY COMMISSIO

REGION II

101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report Nos.

50-335/81-20 and 50-389/81-16 Licensee:

Florida Power and Light 9250 West Flagler Street Miami, FL 33101 Facility Name:

St. Lucie License Nos.

DPR-67 and CPPR-144 Inspection at i

s',

near Fort Pierce, FL r

Inspectors:

. P.

Kl insorge J.

W.

r Approved by:

//lM A. R. Herdt, Section Chief Engineering Inspection Branch Engineering and Technical Inspection Division L~3 fF/

Date Signed

Dat Signed D te Signed SUMMARY Inspection on August 18-21, 1981 Areas Inspected This routine, unannounced inspection involved 58 inspector-hours onsite in the areas of welding filler material control (Unit 2), safety related piping (Unit 2),

reactor coolant pressure boundary piping (Unit 2), containment structures (Unit 2), safety related structures (Unit 2), concern regarding improper radiog-raphy practices (Unit 2), concern regarding inadequate QC practices (Unit 2), IE Bulletin 79-02 (Units 1 and 2) and IE Bulletin 79-14 (Units 1 and 2).

Results Of the nine areas inspected, no violations or deviations were identified in six areas; one violation found in three areas (Violation - Inadequate Measures to Control Welding - paragraphs S.b, 6.a, 6.d, and 8.c).

Ho deviations were found.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

"B. J.

Escue, Site Manager

  • A. E. Siebe, QA'Manager

"G. Crowell, Engineering Site Supervisor

~W.

F. Jackson, Welding Superintendent

~J.

L. Parker, Project QC Supervisor J.

W. Adams, QA Engineer

~R. A. Symes, Sr.,

QA Engineer

~D.

R. Cooper, Supervisor, QA Engineer Other licensee employees contacted included construction craftsmen, QC inspectors, security force members, and office personnel.

Other Organizations

~K. N. Flanagan, Assistant Site Manager - Ebasco Services, Inc.

"R. W. Zaist, Project Superintendent - Ebasco Services, Inc.

NRC Resident Inspector S. A. Elrod

  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on August 21, 1981 with those persons indicated in paragraph 1 above.

The inspectors described the areas inspected and discussed in detail the inspection findings listed below.

No dissenting comments were received from the licensee.

(Open)

Violation 389/81-16-01:

'"Inadequate Measures to Control Welding" Paragraph Nos. S.b, 6.a, 6.d.,

and 8.c.

(Open)

Unresolved Item 389/81-16-02:

"Lead Letter B" Paragraph No. 10.

(Open)

Unresolved Item 389/81-16-03:

"Bend Specimen Removal Order" Paragraph No. 6.b.(3).

3.

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 violations or devia-tions.

New unresolved items identified during this inspection are discussed in paragraph nos. 6.b.(3) and 10.

5.

Independent Inspection Effort a.

Construction Activities The inspectors conducted a general inspection of the reactor building, auxiliary building and stainless steel pipe fabrication shop to observe construction activities such as welding, welding filler material control, material controls, housekeeping and storage.

b.

Welding Filler Material Control (Unit 2)

During the general inspection above, the inspectors, on August 20, 1981, noted twenty-two unused 3/32-inch diameter type E-7018 electrodes abandoned in the auxiliary building.

The above is contrary to Site Quality Procedure SQP-8, Revision 3,

"Storage and Distribution of Welding Filler Materials", 'which requires all unused welding filler material to be returned to the Weld Rod Control Room.

The above condition indicates inadequate measures for the control special processes a'nd is an example of violation 389/81-16-01 as discussed further in paragraph 8.c.

Within the areas examined no violations or deviations were identified except as described in paragraph 5b.

6.

Safety Related Piping The inspectors observed welding work activities for safety related piping as described below to determine whether applicable code and procedure require-ments were being met.

The applicable code for safety related piping is the ASME B&PV Code,Section III, Subsections NC and ND, 1977 Edition with addenda through summer 1977.

The inspectors observed in-process welding activities of safety related piping field welds as described below to determine whether applicable code and procedure requirements were being met.

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Welding The below l i sted welds were examined in process to determine work conducted in accordance with traveler; welder identification and location; welding procedure; WPS assignment; welding technique and

sequence; materials identity; wel'd geometry; fit-up; temporary attach-ments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment condition; interpass temperature; interpass cleaning; process control systems; identity of welders; qualification of inspec-tion personnel; and weld history records.

Joint Number SI-0110-011 Size 6" x 0.719"

~Setem Safety Injection b.

Welder gualifications The inspectors reviewed the FPAL program for qualification of welders and welding operators for compliance with gA procedures and ASME Code requirements.

( 1)

The following welder qualification status records and "Records of Performance gualification Test" were reviewed relative to the weld joints listed in paragraph Nos. 6.a, 6.d., 7.a., 8.a., 8.b., 9.a.,

and 9.b.

Welder S mbol A

lication FAR PSU FHG ICF FFM PYC FDU PTE PSH PUO PSW FBB FAA FED PVW FCS pzQ Safety Related Piping Safety Related Piping (Re Structures and Supports Structures and Supports Structures and Supports Structures and Supports Structures and Supports Structures and Supports Structures and Supports Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Repair)

Reactor Coolant Pressure Piping (Cladding)

pair)

r Boundary Boundary Boundary Boundary Boundary Boundary Boundary Boundary

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PZH FAA d

Reactor Coolant Pressure Boundary Piping (Cladding)

Reactor Coolant Pressure Boundary Piping (Cladding)

(2)

The inspectors observed in process performance qualification testing for the below listed welders:

Welder S mbol Weldin Procedure S ecification FHX FHX G66 FCB 13-662 68A 89A

24

(3)

The inspectors observed the removal, preparation, and testing of root and face bend specimens from qualification test assemblies for the below listed welders:

d~ld Weldin Procedure S ecification FII FII 68A 89A With regard to the above inspection, the inspectors noted, on August 18, 1981, that the above bend specimens were removed from the test assemblies without marking.

The absence of mar king makes it impossible to determine the order of removal of specimens from the test assembly.

The preceeding appears to be in conflict with ASME B&PV Code Section IX, Paragraph Nos. QW-463.2(d),

QW-452.3 and QW-302.

This will be examined in a subsequent inspection, and will be identified as unresolved item 389/81-16-03:

"Bend Speci-men Removal Order".

Welding Filler Material Control The inspectors reviewed the FP&L program for control of welding materials to determine whether materials are being purchased, accepted, stored and handled in accordance with QA procedures and applicable code requirements.

The following specific areas were examined:

Purchasing procedures, receiving, storing, distributing and handling procedures, material identification, inspection of welding material issuing stations Welding material purchasing and receiving records for the following materials were reviewed for conformance with applicable procedures and code requirements:

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Size Materi al ID Code E-7018 E-7018 E-308-16 E-308-16 ER-316 E-316-16 1/8" 3/32" 1/8" 3/32 1/8ll 3/32'I 185 194 027 031 047 043 d.

Special Welding Activities The inspectors examined special welding activities including weld repair as described below to determine whether applicable code and procedure requirements were being met.

Repair Welding The following repair weld was examined inprogress relative to the following:

welding procedure used; repair welding procedure includes all pertinent requirements; repair welding procedure qualification; repair welder performance qualification; ANI witnesses performance qualification; repair area does not exceed limits; base and filler material as specified; base material repairs documented; NDE performed, and records complete.

Joint No.

SI-0103-902

~Sstem Safety Injection With regard to the above inspection the inspectors noted on August 19, 1981, that the single bead cover pass on safety injection weld repair no. SI-0103-902, deposited 1/8-inch diameter type E-308-16 electrode, in accordance with Welding Procedure Specification 50, revision 4,

was 7/8-inch wide.

Welding Procedure Specification

revision 4, requires bead width for 1/8-inch diameter type E-308-16 electrode, not to exceed 5/8-inch maximum.

Therefore the welder did not follow the Welding Procedure Specification requirements.

The above condition indicates inadequate measures for the control of special processes and is an example of violation 389/

81-16-01 as discussed further in paragraph 8.c.

e.

Weld Heat Treatment The inspectors reviewed the FP&L program for weld heat treatment for compliance with gA procedure and Code requirements.

The welds listed in paragraph 6.a and 6.d were examined inprocess relative to weld joint

~ ~

preheating to determine; if procedures were -available; procedures specified acceptable preheating method; procedures provided monitoring and recording requirements and procedure compliance.

Within the areas examined, no violations or deviation were identified except as described in paragraph nos.

6a and 6d.

7.

Reactor Coolant Pressure Boundary Piping Il The inspectors observed welding work activities for reactor coolant pressure boundary (RCPB) piping.

The applicable code for the installation of RCPB piping is the ASME BEPV Code,Section III, Subsection NB, 1977 Edition through the summer 1977 addenda.

Special Welding Activities The inspectors examined special welding activities including weld repair as described below to determine whether applicable code and procedure requirements were being met.

(1)

Repair Welding Records of the following repair welds were examined relative to the following:

welding procedure used; repair welding procedure includes all pertinent requirements; repair welding procedure qualification; repair welder performance qualification; ANI witnesses performance qualification; repair area does not exceed limits; base and filler material as specified; base material repairs documents; NDE performed, and records complete.

Weld Joint No.

Weld Re air Re ort No.

RC-114-010 SI-150-001 SI-151-001 RC-112-004 RC-112-060 RC-112-060 RC-157-002 RC-115-001 RC-115-001 RC-115-030 RC-121-003 1910 1635 1652 2048 1919 2098 1267 3580 2229 3177 4282 (2)

Clad Welding Records of the below listed welds were examined to determine whether work was conducted in accordance with travelers; welder identification and location; welding procedure; WPS assignment;

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welding technique and sequence; materials identity; weld geometry; fit-up; temporary attachments; gas purging; preheat; electrical characteristics; shielding gas; welding equipment'ondition; interpass temperature; interpass cleaning; process contro'I system; identity of welders; and weld history records.

'RC-112-60 RC-114-10 RC-123-20 b.

Welder gualification Welder qualification is discussed in paragraph 6b.

c.

Melding.Material Control Melding material control is discussed in paragraph 6c.

Within the areas examined, no violations or deviation were identified.

8.

Containment Structures (Unit 2)

The inspectors observed field welding activities associated with steel containment structures and steel supports for major equipment within the containment at various stages of weld completion.

The applicable code for the welding indicated below is AWS D1.1-75.

a.

The inspectors observed v~lding activities where joint fitup and align-ment were complete (but welding had not been started)

to determine conformance with applicable specifications and procedures in the areas of-; weld identification, joint fitup and alignment and evidence of gC verification.

The welds listed below were examined:

Structural Supports Drawin /Weld No.

Structure CC-2079-0038 2998"G"797 Sh2 STL-G"799"049 Component Cooling Water Pipe Support Main"Steam Restraint Main Steam Restraint b.

The inspectors observed welding activities where welding was in progress to determine conformance with specifications and procedures in the areas of; weld identification, specified weld procedures, qualified welders, specified weld materials, specified purge (if applicable);

repair procedures, specified NDE being performed and periodic checks of welding variables.

The welds listed below were examined:

Structural Suppor ts Drawin /Weld No.

Structure CC-2079-0038 2998-G-797-Sh2 STL-G-799-049 STL-G-799-110 STL-G-799-061 CCW Pipe Support Main Steam Restraint Main Steam Restraint Main Steam Restraint Main Steam Restraint With regard to the inspections of paragraphs a and b above, the inspec-tors accompanied by a representative of the licensee, on August 18-19, 1981, noted the following conditions:

(2)

(3)

(4)

The welders of record for CC-2079-0038 and STL-G-799-110 did not have a properly annotated and approved

"Weld Material Requisition Report".

The above is contrary to FP&L Site Quality Procedure SQP-8 Revision 3,"Storage and Distribution of Welding Filler Materials" which requires

"Weld Material Requisition Reports" to be properly annotated and approved.

Therefore welding was accom-plished without proper authorization.

The single bead cover pass on Weld No STL-G799-110 deposited with an 1/8-inch diameter type E-7018 electrode, in accordance with Welding Procedure Specification 15 revision 0, was one inch wide.

Welding Procedure Specification 15, revision 0 requires bead width for 1/8-inch diameter, type E-7018, electrodes not to exceed 3/4-inch maximum.

Therefore the welder did not follow the Welding Procedure Specification requirements.

The welder of record for weld joint no.

STL-G-799-049 did not know the preheat requirements for that weld joint, or have the means to measure the specified preheat temperature.

The above is contrary to FP&L Site Quality Procedure SQP 39, Revision 3, "Field Welding Control", which requires preheat temperature to be controlled.

Four portable rod ovens, containing type E-7018 electrodes were unplugged, inoperative or abandoned contrary to FP&L Site Quality Procedure SQP-8, Revision 3, "Storage and Distribution of Welding Filler Materials" and FP&L ASME Quality Assurance Manual, AQR 9.2 PSL-2, Revision 3,"Storage and Distribution of Welding Materials" which requires heated portable rod ovens to be used for covered electrodes.

The above combined with the examples as discussed in paragraphs 5b, 6a, and 6d indicate that the licensee does not have adequate measures for the control of special processes.

Failure to establish adequate measures to control special processes including welding i s in violation of

CFR 50, Appendix 8; Criterion IX.

This violation will be identified as 389/81-16-01:

"Inadequate Measures to Control Welding".

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Observation of weld material control included; identification, segregation, oven temperatures, issue slips and control of unused material at issue stations and work areas.

e.

During observation of welding activities there was a sufficient number of qualified inspection personnel at the work site.

Within the area examined no violations or deviations were identified except as in paragraph 8c.

9.

Safety Related Structures (Unit 2)

The inspector observed field welding activities associated with safety related structures and supports outside containment during various stages of weld completion.

Observations were made in order to determine whether the requirements of applicable specifications, standards, work and/or inspection procedures were being met for activities involved and in the following stages of weld completion.

The applicable code for the welding indicated below is AWS 01.1-75.

a.

The inspector examined weld joint fitup, prior to welding, to determine whether weld identification/location, joint prepration and alignment and gC verification are in conformance with existing 'requirements.

The welds listed below were examined.

Drawing Number CW-14-R2 CW-14-R8 CM-(I)-27-R6 Support Circulating

& Intake Cooling Water Seismic Restraint Circulating

& Intake Cooling Water Seismic Restraint Circulating

& Intake Cooling Water Seismic Restraint b.

The inspector examined weld joints where welding was in progress to determine whether weld identification, weld procedures, welder quali-fication, weld material, defect removal (if applicable),

specified NDE and periodic checks of welding variables are in conformance with existing requirements.

The welds listed below were examined.

, Drawing Number Support CW-14-R2 Circul,ating

& Intake Cooling Mater Seismic Restraint CW-14-R8 Circulating

& Intake Cooling Water Seismic Restraint

Drawing Number CW-( I)-27-R6 Support Circulating 5 Intake Cooling Mater Seismic Restraint s

c.

Observation of weld material control included; identification, segre-gation, oven temperatures, issue slips and control of unused material at issue stations and work areas.

During observation of welding activities there was a sufficient number of qualified inspection personnel at the work site.

Within the areas examined, there were no violations or deviations identi-fied.

10.

Concern Regarding Improper Radiography Practices (Unit 2)

The NRC was contacted by an individual who expressed the following concern in substance:

Concern:

X-ray cassettes do not have the letter "B" on the back of the cassette as required for backscatter.

~Ins ection:

The inspectors made an unannounced inspection during the third shift to observe radiogrpahy in progress and to determine whether the lead letter

",B" was on the back of cassettes as required.

The inspector noted that for all radiography observed the lead letter "B" was in place as required by the licensee's procedures.

With regard to the above inspection the inspectors observed that the lead letter "B" was positioned at the edge of the film outside of the area of interest.

The inspectors indicated that if the lead letter "B" was outside the normal viewing area, or in an area on the film where the density is beyond that required by the code the lead letter "B" might not be seen and thus unacceptable back scatter not be identified.

The licensee indicated that they would look further into the matters The inspectors stated that the above would be 'n unresolved item identified as 389/81-16-02:

"Lead letter "B".

Within'the areas contained no violations or deviation were identified.

ll.

Concern Regarding Inadequate gC Practices.(Unit 2)

The NRC was contacted by an individual who expressed the following concerns in substance:

r

Concern:

Fitup inspection, at tacking, is not being performed on safety-related socket welds, such as assuring proper withdrawal of pipe.

~ins ection:

Fitup inspection is not required by the ASME B, & PV Code for socket welds.

The licensee's procedures require socket welds to be marked such that pipe end clearance (pipe withdrawal) can be verified at the time of final visual inspection of welded socket joint.

The existance of the above pipe end clearance was verified by the inspectors on completed and accepted socket joints'he inspectors determined that the licensee is inspecting, socket welded pipe joints consistent with the accepted QA/QC program and the ASME Code.

Concern:

In some areas heat numbers are not being transferred to safety-related pipe sections which are cut to assure traceabi lity of the cut portions.

When reported to supervision, heat numbers from properly identified safety-related pipe found in storage were transferred to the "unidenti-fied" (no heat number identification) piping.

There does not appear to be adequate assurance that the correct heat numbers are being applied.

Examples of pipe without proper traceability have been seen in safety-related piping in work in the stainless steel pipe fabrication shop.

When the pipe is not properly identified the identification numbers cannot and are not being recorded on weld travelers as specified by site Procedure QI 9.1.

NCR's such as those addressing the heat traceabi lity number problem have been "held" in the desk of the QC supervisor for approximately two months with no action.

These NCR's are not being processed and are prevented from being reported.

Specific examples of failure to identify piping in the field may be found on the travlers for welds 2F-A-BF-S-l, 3, and 5.

This pipe is believed to be safety related.

~ins ection:

The inspectors inspected the stainless steel fabrication shop, reviewed the licensee's material control program, reviewed the below listed Nonconformance Reports (NCRs) concerning traceabi lity problems, and discussed the above concern with the licensee to verify the above concern.

The inspectors could find no,indication of willful falsifi-cation of material identification or traceabi lity.

The inspectors could find no evidence of failure to report traceabi lity problems.

The NCRs listed below indicate that the licensee has had problems in the area of traceabi lity, but has resolved those problems consistent with the accepted QA program and regulatory requirements.

The inspectors could not identify welds 2F-A-BF-S-1, 3 and 5 as those numbers do not conform with the licensee's weld number forma '

NCR No.

Status 1301M 1424M 1659M 1672M 1673M 1865M 1880M 1881M 1921M 1923M 2053M Closed Closed Closed Closed Cl osed Closed Closed Closed Closed Open Open Within the areas examined no violations or deviations were identified.

12.

(Open)

IE Bulletin 79-02:

Pipe Support Base Plate Design Using Concrete Expansion Anchors (Units 1 and 2).

Only the Phillips externally threaded wedge expansion bolt anchors (split ring) are being used in the construction of St.

Lucie Unit 2.

The craft personnel installing the concrete expansion anchors are required to pass a

qualification test before installing any of the anchors.

The test consists of installation of two anchors of the size and position most frequently installed by the applicants craft and the installation of an additional anchor of a different size and position specified by the qualifier.

The three installed anchors receive the normal construction quality control inspection plus a tension or pull test.

If this person passes all of the requirements, his name is placed on a qualification list for use by the construction and quality control inspection personnel.

The quality control inspection for the concrete anchors is performed by U.S.

Testing under contract to Florida Power and Light.

The following specifi-cations were reviewed:

(a)

SQP-5 Rev.

1, "Installation of Concrete Expansion Anchors" (FP@L)

(b)

QI 10.23 Rev. 1, "Inspection and Testing of Expansion Anchors" (FP8 L)

(c)

FL0-2998.469, "Drilled-In Expansion Anchors" (EBASCO)

All anchor s are tested for torque and one in fifty of all size anchors is tension tested.

e The inspectors examined the following:

(a)

Training curriculum for quality control inspectors for concrete anchors (b)

The training records for 3 concrete anchor inspectors (c)

Expansion Anchor Release Nos. 338, 346 and 347 (d)

Installed anchors on one of the base plates in Expansion Anchor Release

¹338

The inspectors discussed the status of IEB 79-02 for Unit 1 with the licensee.

Within the areas examined, no violations or deviations were identified.

(Open)

IE Bulletin 79-14:.

Seismic Analysis for As-Built Safety-Related Piping Systems (Units 1 and 2)

A review of specification QI 10. 18, "Piping System Configuration Inspec-tion", reveals that the Unit 2 program is divided into two phases.

Phase I

inspections are used to verify that individual hangers, supports and restraints are installed in accordance with the applicable design documents.

The Phase II inspections will document the as-built configuration of the installed piping system and will check the final configuration, settings and adjustments of individual components.

The quality control group conducting the inspection for IEB 79-02 is a

separate group from the group conducting the inspection for IEB 79-14.

This group started anew to reinspect all hangers that had been previously inspected and started with a new specification, QI 10. 18 (previous inspec-tions used specification QI 10. 14).

This effort began in mid June, 1981 with the first inspections being performed on non safety related systems (non 79-14 systems).

The licensee estimated that 500 hangers out of approx-imately 8,000 safety related hangers had been inspected (Phase I inspected).

The licensee is inspecting approximately 60 hangers per day.

The quality control inspectors are qualified to make decisions on the weld quality of the hangers, but if a dimension on a hanger etc. varies from the drawing, the judgement must be made by the EBASCO site engineer or EBASCO design (N.Y.) If a dimension is outside the construction tolerances, instructions are sent to the IEB 79-14 quality control group to write a

Deficiency Report (DP)

so that a repair may be made or a

Nonconformance Report (NCR)

so that a justification for using the component

"as is" may be written by the EBASCO Design group.

The following specifications for welds inspections on hangers, supports and restraints were reviewed:

(a)

QI 9.2 Rev. 3, "Inspection of Field Welding (b)

QI 9 '

Rev. 4, "Visual Inspection of Welds", Technique

Inspection of the following hangers was observed:

(a)

Hanger No. PD.-17-R-19 in the Radioactive Waste Plumbing and Draining System (b)

Hanger No. OCBH-64 in the Open and Closed Blowdown Cooling System

Hanger PD-17-R-19 had not been previously inspected.

Hanger No. OCBH-64 had been inspected and this reinspection by the quality control inspector produced the same results.

The inspectors reviewed the training procedure for the quality control personnel conducting the inspection program.

This training program lasts approximately 3 weeks.

During the time of this inspection, there were

certified gC inspectors, 3 in the process of being certified and 6 in training.

The licensee's goal is to have 22 certified quality control inspectors in this group.

Currently the inspectors are working on two shifts, ten hours a day and six days a week.

The inspector discussed the status of IEB 79-14 for Unit 1 with the licensee.

Mithin the areas examined, no violations or deviation were identifie I 1