IR 05000389/1982007
| ML20051C366 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/25/1982 |
| From: | Crowley B, Herdt A, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20051B743 | List: |
| References | |
| 50-389-82-07, 50-389-82-7, NUDOCS 8205140536 | |
| Download: ML20051C366 (17) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION o
a REGION il
Id1 MARIETTA ST., N.W., SulTE 3100 o
ATLANTA, GEORGIA 30303 o
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Report No. 50-389/82-07 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33101 Facility Name:
St. Lucie 2 Docket No. 50-389 License No. CPPR-144 Inspection at St. Lucie site near Ft. Pierce, FL
1 Inspectors:
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erdt, Section Chiaf Date' Signed Engineering Inspection Branch Division of Engineering and Technical Programs SUMMARY Inspection on February 16-19, 1982 Areas Inspected This routine, unannounced inspection involved 49 inspector-hours on site in the areas of reactor coolant pressure boundary piping, safety related piping, pre-service inspection (PSI), and licensee action on previous inspection findings.
Results
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Of the four areas inspected, no violations or deviations were identified in
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three areas; one violation was found in one area (Violation - Failure to follow NDE procedures paragraphs 10.b and 10.e).
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REPORT DETAILS I.
Persons Contacted Licensee Employees
- B. J. Escue, Site Manager N. T. Weems, Assistant Manager QA-PSL G. Gotch, Nuclear Section Supervisor for Codes and Inspections - NED
- J. L. Parker, Project QC Supervisor
- G. E. Crowell, Site Engineering Supervisor G. J. Boissy, Startup Superintendent
- R. A. Symes, Supervising QA Engineer
- E. W. Sherman, QA Engineer
- J. R. Luke, QA Engineer Other licensee employees contacted included construction craftsmen, QC inspectors, security force members, and office personnel.
Other Organizations
- D. L. Jones, NDE Engineering Consultants B. E. Mather, Site Supervisor (NES)
J. T. Smith, Shif t Leader (SwRI)
NRC Resident Inspector
- S. A. Elrod
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 19, 1982, 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.
(0 pen) Inspector Followup Item 389/82-07-01; Clarification of Qualification Requirements for PSI Site Supervisor paragraph 8.b.
(0 pen) Violation 389/82-07-02; Failure to Follow NDE Procedures paragraphs 10.b. and 10.e.
(0 pen) Inspector Followup Item 389/82-07-03; Review of Code Data Report Review Prccess paragraph 6.c.(2)(b)
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(0 pen) Unresolved Item 389/82-07-04, Undersized Socket Welds paragraph 6.c.(2)(a).
3.
Licensee Action on Previous Inspection Findings (Closed) Violation 389/81-07-07, Failure to follow ultrasonic procedure for_ PSI.. Florida Power and Light Company's (FP&L) letter of response dated July 8,1981, has been reviewed and determined to be acceptable by Region II.
Based on examination of corrective actions as stated in the letter of response, the inspectors concluded that FP&L had determined the full extent of the subject violation, performed the necessary survey and followup actions to correct the present conditions and developed the neces-sary corrective actions to preclude recurrence of similar circumstances.
The corrective actions identified in the letter of response have been implemented.
4.
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 6.c.(2)(a).
5.
Independent Inspection Effort Construction Activitics 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.
Within the areas examined, no violations or deviations were identified.
6.
Reactor' Coolant Pressure 3oundary (RCPB)
a.
Review of Welding and Non-Welding Related Quality Assurance Procedures The inspectors reviewed the licensee's Quality Assurance Manual,
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Quality Instruction Manual and Procedures Manual to determine whether adequate procedures had been established for welding and non-welding related RCPB piping act'vities such that proper controls and require-ments in compliance with NRC requirements, SAR commitments and the -
applicable code could be assured. The applicable code for this piping is ASME Section III, Subsection NB, 1977 edition with addenda through summer 1977.
The specific activity control and requirement areas addressed by the NRC inspectors and the procedures identified and reviewed relative to these areas are as follows:
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(1) Activity Control and Requirement Areas (a)' General quality requirements and controls for procurement and design documents and their review (including deviations and design changes); preparation and maintenance of quality documentation; and identification and control of components, structures and systems.
(b) Review, approval, and control-of work and inspection proce-dures.
(c) Control of material and equipment. including traceability, handling, shipping, stcrage, and identification of noncon-forming material.
. (d) Control of processes including requirements for properly qualified procedures and personnel and proper work and inspection conditions.
(e) Controls on tests and test equipment
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(f) Requirements and controls for work on and inspections of
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piping and related appurtenances and materials relative to:
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Location-Clearances
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- Type, size, location and' adjustment of hangers, bellows, q,
restraints, snubbers
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t Nondestructive examination and inspections (where
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applicable)
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Hydrostatic testing
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Cold spring
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Installation recerjs generated during work performance
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. Cleaning and cleanliness
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FPL _Qu'al'ity Procedures (QPs): 2.3RS, 2.4R2, 2.7R1, 2.8R3. 2.9R4,
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3.1R2, 3.2R2, 3.5R3, 3.6R3, 4.1R10, 4.4R10, 6.1R1, 6.2R3, 6.4R1, 7.2R4, 7.6R2, 7.8RO, 8.2.R1, 9.1R2, 10.2R2, 11.1R2, - 11.4R4,
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12.1 R3, 13.1 R 3, 14. 2 RO, 15.1 R 3, 17.1 R7, 18.1 R5.
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FPL Quality Instructions (_QI's):
2.1R4, 2.4R2, 2.7R5. 6.1R2, 6.2R3, 6.6R1, 7.1R4, 9.1R4, 9.2R3, 9.3P2, 9.4R1, 9.5R5, 9.11R0 9.12RO, 9.13 R 1, 10.1 R2, 10. 4 R 1, 10. 23 R 1, 10. 78R1, 10. 79 R0, 12.1 R3, 15.1R4.
FPL Site Quality _ Procedure (SQP's):
3R7, 4R4, SR1, 8RS, 9R1, 10R4,11R2,14R7,16Ra,17R3,18R1, 21R5, 41R2, 42R3, 47RS, 52RI.
EBASCO Quality Control Procedure:
QC-4R4.
(3) Welding Procedure Specification (WPS) control The inspectors also reviewed the licensee's procedures (SQP-4R4 and SQP-9RI) for preparation, qualification and control of WPS's to verify that requirements for WPS preparation, qualification, approval / certification, distribution and revision were adequately specified.
b.
Observation of Non-welding Activities Observation of specific work activities were conducted to determine conformance, where applicable, with the following; inspection and/or work procedures, record keeping requirements, installation specifica-tion requirements, specified material and qualified inspection per-sonnel.
Reactor Coolant System Activity Component Procedure Handling Various SQP-23, R0 SQP-47, R4 Protection Various SQP-3, R7
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SQP-23, R0 Receiving Inspection Various SQP-3, R7 CLP-QI 7.1 Cleanliness Various SQP-23,R0 SQP-30,R2 SQP-47, R4 l
Identification Various SQP-3,R7
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Installation Various SQP-47, R4 Documentation Various SQP-39, R4 SQP-47, R4 l
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Safety Injection System Activity Component Procedure
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Handling Various SQP-23,R0 SQP-47,R4 Protection Various SQP-3, R7 SQP-23,R0 Receiving Inspection Various SQP-3, R7 CLP-QI 7.1 Cleanliness Various SQP-23, R0 SQP-30, R2 SQP-47, R4 Identification Various SQP-3, R7 Installation Various SQP-47,R4 Documentation Various SQP-39,R4 SQP-47, R4 c.
Ol>servation of Welding Activities The inspectors observed in process welding activities of RCP8 piping field welds as described below to determine whether applicable code and procedure requirements were being met.
(1) 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:
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Purchasing, receiving, storing, distributing and handling procedures, material identification, inspection of welding material issuing station.
(2) Visual Inspection of Welds
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The inspectors visually examined completed and accepted reactor coolant pressure boundary welds as described below to determine whether applicable code and procedure requirements were being met.
(a) The below listed welds were examined relative to the following:
location, length, size and shape; weld surface finish and appearance, including inside diameter of pipe welds when accessible; transitions between different wall thicknesses; weld reinforcement -- height and appearance; joint configuration of permanent attachments and structura:
supports; removal of temporary attachments; arc strikes and
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weld spatter; finish grinding or machining of weld -surface -
surface finish and absence of wall thinning; surface defects -- cracks, laps, and lack of penetration, lack of fusion, porosity, slag, oxide film and undercut exceeding prescribed limits.
Weld No.
System Application RC-103FW903 Reactor Coolant RCPB
RC-103FW901 Reactor Coolant RCPB
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RC-109FW913 Reactor Coolant RCPB RC-141FW913 Reactor Coolant RCPB RC-125SW002 Reactor Coclant RCPB RC-125SW003 Reactor Coolant RCPB RC-125SWOO4 Reactor Coolant RCPB i
RC-125SW005 Reactor Coolant RCPB RC-125SW006 Reactor Coolant RCPB SI-457FW001 Safety Injection SR SI-457FW002 Safety Injection SR SI-508FW001 Safety Injection SR CS-007FW001 Containment Spray SR SI-511FW001 Safety Injection SR CS-041FW001 Containment Spray SR BF SHAW WELD JOINTS Weld ISO No.
System No.
-Application j
1-12-SI-457-1 Safety Injection
SR 1-12-SI-457-1 Safety Injection
SR 1-12-SI-457-1 Safety Injection
SR 1-12-SI-457-1 Safety Injection
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With regard to the inspection above, on February 18, 1982,
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the inspectors noted three, two-inch schedule 160, reactor i
coolant system socket welds RC-0125-FW002, FW-004 and FW-005, with leg sizes of 0.342 to 0.359 inches in lieu of the.374
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inches minimum leg size required by Attachment 1, Figure (b)
to procedure QI 9.1.
At the time of the inspection, the extent of this problem could not be determined. Depending
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on determination of whether or not this is an isolated case, this item is considered unresolved and is identified as item number 389/82-07-04, Undersized Socket Welds.
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(b) Quality records for the weld listed in paragraph 6.c(2)(a)
were examined relative to-the following:
records covering
visual and dimensional inspections indicate that the speci-l fled inspections were completed; the records reflect ade-quate quality; history records are adequate.
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With regard to the above inspection on February 19; 1982, the inspectors noted the following:
The weld traveler' for ' weld joint No. SI-0508-FW-001 incor-
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rectly ~ identified -one of the spools as I-24-CS-14-1 vice I-24-CS-41-1.
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The weld traveler for weld joint CS-0041-FW-001 indicated that the above joint was a_ pipe spool to an elbow-weld, when in fact the above weld joins a pipe spool to a pipe.
The licensee stated that the records are being reviewed as part of the program to document Code Data Reports. This review would identify and correct the type of records errors identified by the inspector. The errors identified will be. corrected. A review of the above records and the Code Data Report documentation review process will be identified as inspector followup item = 389/82-07-03, Review of Code Data Report review process.
(3) Welder Qualifications-The inspectors reviewed the FP&L program for qualification of welders and welding operators for compliance with QA procedures and ASME Code requirements.
(a) The following welder qualification ' status records and
" Records of Performance Qualification Test" were reviewed relative to the weld joints listed in paragraph Nos. 6.c(2)
and 7.c(5).
Welder Symbol Application PUI SR PVP SR PTZ SR POK SR FAR RCPB FYI RCPB (b) The following repair welder's qualification status ' records, and " Records of Performance Qualification Test"'were reviewed to determine whether they meet applicable qualification requirements, a
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Welder Symbol WPS Application PVM
SR PQW
SR PWH
SR PSU
SR PRZ
SR PQW
SR PSK
SR FDE
SR PSR
SR PTV
SR FCM
SR PST 68F SR PVO
SR FBP
SR (c) The following in progress performance qualification testing was observed:
Welder Symbol WPS PQZ 89A FFF 89A PXU 68A (d) The inspectors observed the removal and testing of the below listed test assemblies:
Welder Symbol Specimen Type FFF Root and Face Bends PXV Root and Face Bends (4) Weld Heat Treatment (a) Weld Joint Preheating
The inspectors reviewed the below listed procedure to
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determine whether approved procedures are available for l
weld joint preheating when required by a welding proce-dure specification and whether these procedures properly specify acceptable preheating methods, provide require-ments for monitoring and recording preheat temperature before, during, and if specified, after welding.
SQP-39, R4, " Field Welding r.. trol"
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Records for the below listed weld joints were reviewed
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to determine whether preheat control procedures were followed during field welding activities.
Weld Number
RC-112 FWOO6 RC-114 FWOO2 RC-11E WOO 6 RC-124 FW002
(b) Post Weld Heat Treatment
The inspectors reviewed the below listed procedure to -
y determine whether approved and adequate procedures are available for the conduct of postweld heat treatment and whether the licensee / contractor has a system capable of meeting the heating and cooling rates, metal tempera-
ture, temperature uniformity and control limits speci-fied in the ASME B&PV Code, as applicable SQP-42, R3, " Control of Heat Treatment"
Records for the below listed weld joints were reviewed.
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to determine the following:
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Weld area is instrumented to provide time-tempera-ture recordings for the duration of the entire heat
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treatment cycle.
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The temperature monitoring instruments are properly calibrated as required by the applicable procedure.
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Sufficient thermocouples or other - appropriate
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temperature measuring devices are used to measure
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The PWHT temperature and holding time is specified,
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is 6dhered to, and is consistent with applicable Code requirements based on the material type' and thickness.
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The maximum -initial temperature, heat-up and l
.cooldown rates are specified, are adhered to, and I
are consistent with applicable Code requirements.
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The temperature records being generated reflect adherence to the above requirements.
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Weld Number RC-112-006 RC-114-002 RC-115-006 RC-124-002
Records for the weld joints listed in paragraph 6.c(4)-
(b)2 were reviewed to determine whether specified temperature control is utilized on in process welds which are required to be maintained at pre-heat for extended time periods.
(c) Stress Relief Records for the weld joints listed in paragraph 6.c(4)(b)2 were reviewed to determine whether the total time at temper-ature did not exceed that permitted by applicable Code requirements based on the welding procedure qualification record.
Within the area inspected, no violations or deviations were identified.
7.
Safety-Related Piping The inspectors reviewed procedures and observed non-welding and welding work activities for safety-related piping as described below to determine whether applicable code and procedure requirements were being met.
The applicable code for safety-related piping is the ASME B and PV Code,Section III, Subsection NC and ND,1977 edition with addenda through summer 1977.
a.
Review of Welding and Non-Welding Related Quality Assurance Procedures.
The review of welding and non welding related quality assurance proce-dures is discussed in paragraph 6.a.
b.
Observation of Non-Welding Activities Observation of specific work activities was conducted to determine conformance, where applicable, with the following:
inspection and/or work procedures, record keeping, installation specifications or plans, specified materials, specified NDE, calibration and use of proper test equipment and qualified inspection and NDE personnel,
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Activity System or Component Procedure Handling Various SQP-23,R0 SQP-47, R4 Protection Various SQP-3,R7 SQF-23, R0 Receiving Inspection Various SQP-3,R7 CLP-QI 7.1 Cleanliness Various SQP-23, R0 SQP-30,R2 SQP-47,R4 Identification Various SQP-3, R7 Installation Various SQP-47, R4 Documentation Various SQP-39, R4 SQP-47, R4 c.
Observation of Welding Activities The inspectors observed in process welding activities of safety-related piping field welds as described bel'w to determine whether applicable code and procedure requirements were being met, i
(1) Welding Material Control Welding material control is discussed in pargraph 6.c.(1).
(2) Visual Inspection of Welds Visual inspection of welds is discussed in paragraph 6.c(2).
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(3) Welder Qualification Welder qualification is discussed in paragraph 6.c.(3).
(4) Weld Heat Treatment Weld heat treatment is discussed in paragraph 6.c.(4).
(5) Special Welding Activities i
The inspectors examined special welding activities including weld l
repair as described below to determine whether applicable code and procedure requirements were being met.
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l Repair Welding l
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 i
qualification; repair welder performance qualification; ANI witnesses performance qualification; repair area does not exceed limits; base and filler material as specified; base
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material repairs documents; NDE performed, and records complet.
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Weld Joint No.
Weld Repair Report No.
'CH-0947-901 4567 BF-0019-005 3886 SF-0019-007 4091 BF-0052-003 4039 CC-0040-001 3509 CC-0041-905 3956 INS-F020-042 4334 INS-F020-006 3333 CS-0027-006 4817 CS-0034-901 1672, 3608, 4464 SI-0361-005 126 SI-0407-904 2228 MS-0029-005 3331 CH-0967-003 3579 CC-0041-904 3957 CC-0302-007 3453 CC-0355-012 2152 CH-0555-001 1355, 3561, 3789 Within the areas examined, no violations or deviations were identified.
8.
Preservice Inspection - Review e f Program The inspectors reviewed the licensee's preservice inspection (PSI) program as described below to determine whether regulatory requirements were being met. The PSI is being performeo in accordance with the ASME Boiler and Pressure Vessel Code,Section XI, 1977 edition with addenda through S78 as modified by 10 CFR 50.55a.(g).
As noted in RII report 50-389/81-07, Combustion Engineering (CE) had been contracted for the PSI. However, after inspection of the reactor coolant loops, FP&L decided to issue their own insoection program and perform the inspection themselves. Therefore, the inspection is being performed using FP&L program and procedures with Nuclear Energy Services (NES) furnishing the examination personnel.
The program description, inspection plan description and the inspection plan are still in the process of being changed from CE documents to FP&L. The inspection plan is being formally approved and issued by individual " zones" rather than issue of the entire inspection plan.
a.
The inspectors reviewed the following documents:
(1) FP&L QI 10 PR/PSL-2, Revision 1, "Preservice Inspection (PSI)"
(2) FP&L PSI Implementing Instructions -
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" Preparation and Approval of PSI Implementing Instructions"
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" Control and Distribution of PSI Procedures, Instructions, Plans and Drawings"
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" Approval and Revision of PSI Inspection Plan"
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" Receipt Inspection and Control of Nonconforming Materials During PSI"
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" Field Changes to NDE Procedures"
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" Corrective Action" (3) CE PPB-ISI-001, Revision 2, " Program Description, FP&L St. Lucie, Unit No. 2" (4)
FP&L "St. Lucie, Unit No. 2 Preservice Inspection - Inspection Plan" - Zone 2, Zone 6 and Zone 8" (5)
FP&L "Preservice Inspection Plan Description", Rough Draft.
The documents were reviewed in the areas of:
Program Approval Organizational Structure General QA requirements including documentation, deviations from PSI program and identification of components to be inspected.
Work and quality inspection procedures.
b.
During review of the above documents, the inspector noted that the qualification requirements for the PSI Site Supervisor are not defined in the program and procedures at the site. Discussions with licensee personnel revealed that qualification requirements exist for the site supervisor position, but not necessarily in a PSI procedure.
The licensee agreed to review the documents covering the site supervisor position and determine the need for any clarification to PSI proce-dures.
This matter will be identified as inspector followup item 389/92-07-01, Clarification of Qualification Requirements for PSI Site Supervisor.
Within the areas inspected, no violations or deviations were identified.
9.
Preservice Inspection - Review of Procedures The inspectors reviewed the PSI procedures as described below to determine whether the procedures were consistent with regulatory requirements. See paragraph 8. above for the applicable Code.
a.
The following procedures were reviewed in the areas of procedure approval, qualification of NDE personnel and compilation of records:
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(1) NDE 5.1, Revision OB, FCN00028, " Ultrasonic Examination of Pres-sure Vessel Welds 22-1/2 inches in thickness".
(2) NDE 3.1, Revision IA, FCN0005, " Liquid Penetrant Examination Visible Dye Technique".
3) NDE 2.1, Revision 0A, FCN00012, " Magnetic Particle Examination".
(4) %DE 5.2, Revision 0A, FCN00017, " Ultrasonic Examination Procedure For Ferritic Piping Welds" (5) NDE 5.4, Revision 0,
" Ultrasonic Examination Procedure for Austenitic Piping Welds" b.
In addition to the review above, procedure NDE 5.1 was reviewed for technical content relative to:
(1) Type of apparatus (2) Extent of coverage including beam angles and scanning technique (3) Calibration requirements (4) Search units (5) DAC curves (6) Reference level for monitoring discontinuities (7) Method of demonstrating penetration (8)
Levels for evaluating and recording indications (9) Acceptance standards Within the areas inspected, no violations or deviations were identified.
10.
Preservice Inspection - Observation of Work and Work Activities The inspectors observed the PSI activities described below to determine
whether these activities were being performed in accordance with regulatory I
requirements and licensee procedures.
See paragraph 8.
above for the applicable code.
a.
Personnel qualification records for four Level II and four Level I NDE examiners were reviewed.
b.
In process ultrasonic (UT) inspection including calibration on appli-cable calibration blocks, was observed to the extent indicated for the following welds:
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Component Weld Examination Steam Generator 2A 106-201 0 (base and weld)
Zone 41 RV Closure Head 101-104C 0 (base and weld)
Zone 2 101-104D 0 (base and weld)
101-104A 0 (base and weld)
101-1048 0 (base and weld)
102-101 0 (base and weld)
101-101 0 (base and weld)
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Loop A2 Reactor 103-722-A 45 Angle Beam Coolant Cold Leg Zone 8 The inspections were compared with applicable procedures in the following areas:
(1) Availability of and compliance with approved NDE procedures (2) Use of knowledgeable NDE personnel (3) Use of NDE personnel qualified to the proper level (4) Recording of inspection results (5) Type of apparatus used (6) Extent of coverage of weldment (7) Calibration requirments (8) Search Units (9) Beam Angles (10) DAC Curves (11) Reference level for monitoring discontinuities (12) Method for demonstration penetration (13)
Limits for evaluating and recording indications (14) Recc-ding significant indications (15) Acceptance limits During observation of UT inspection of steam generator 2A weld 106-201 on February 18, 1982, the inspectors noted that the UT instrument sweep distance was set up such that the full CRT screen width represented approximately the full thickness of the material being inspected.
Paragraph 5.2.1 of the applicable procedure, NDE 5.1, requires that the sweep distance be set up such that at least 1/4t beyond the nominal production material thickness be included on the CRT screen.
This failure to follow NDE procedure is an example of violation 389/82-07-02 discussed further in paragraph 10.e.
c.
In addition to observation of calibration for the RV closure head welds above, the inspector observed photographing of the initial pulse shape as required by Regulatory Guide 1.150, paragraph C.1.5.
The loaded and unloaded pulse shapes were photographed.
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The inspectors observed the automatic equipment used for UT inspec-tion of reactor vessel welds.
At the time of the observation, no inspections were in process.
Preparations were being made to cali-brate, and perform additional scans on weld 201-141 in accordance with SwRI procedure 700-6, Revision 10.
The inspector discussed
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set up and operation of the equipment with examination personnel.
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On February 17, 1982, the inspectors observed liquid penetrant (PT)
inspection of weld 05 on line RC-0116 (2" diameter stainless steel socket weld). The inspector noted that the examiner did not apply penetrant to the base material on the valve side of the weld.
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graph 5.3.1 of OI 9.5, the applicable procedure, requires that at least the adjacent 1/2-inch area on each side of the weld be thoroughly and uniformly coated with penetrant.
A+. the time the PT inspection was observed it was assumed to be a construction inspection.
However, later investigation revealed that construction surface examination results for Class 1 welds are used to satisfy PSI inspection require-ments if certain conditions are met.
The determination to use con-struction PT inspections to satisfy PSI requirements was based on a review of the construction PT procedure (QI 9.5) to determine that the procedure met ASME Section XI, which requires PT inspection of 1/2-inch base material on each side of the weld.
The above failure to follow procedure and that discussed in paragraph 10.b. are in violation of 10 CFR 50, Appendix B, Criterion V.
This violation is identified as 389/82-07-02, " Failure to Follow NDE Proce-dures".
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Within the areas inspected, no violations or deviations were identified except as noted in paragraphs 10.b and 10.e.