IR 05000424/1986017
| ML20203N943 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/23/1986 |
| From: | Blake J, Newsome R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20203N918 | List: |
| References | |
| 50-424-86-17, 50-425-86-09, 50-425-86-9, NUDOCS 8605060234 | |
| Download: ML20203N943 (15) | |
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NUCLEAR REGULATORY COMMISSION
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,o Report Nos.:- 50-424/86-17 AND 50-425/86-09 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-424 and 50-425 License Nos.: CPPR-108 and CPPR-109 Facility Name: Vogtle 1 and 2 Inspection Conducted: Mar h 17-21, 1986 Inspector:
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Approved by:
3 80 J. J.
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'Date' Signed E gi ering Branch iv ion of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection involved 37 inspector-hours on site in the areas of construction Nondestructive Examination (NDE), welders qualifica-tion radiography and previously opened items.
Results: No violations or deviations were identified.
8605060234 860425 PDR ADDCK 05000424 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. E. Conway, Senior Vice President, Vogtle Project
- R. H. Pinson, Vice President, Vogtle Project
- E. D. Groover, Quality. Assurance (QA) Site Manager, Construction
- C W. Hayes, QA Manager
- M. H. Googe, Project Construction Manager, Construction
- G. A. McCarley, Project Compliance Coordinator, Construction Other licensee employees contacted. included construction cra ftsmen, engineers, technicians, operators, mechanics, security force members, and office personnel.
Other Organizations
- J. E. Miller, Quality Assurance / Quality Control (QA/QC) Manager, Pullman Power Products (PPP)
L. Fields, Project Manager, Chicago Bridge and Iron (CBI)
J. Abbott, Manager, Nuclear Installation Services Company (NISCO)
NRC Resident Inspectors
- H. H. Livermore, Senior Resident Inspector, Construction J. F. Rogge, Senior Resident Inspector, Operations R. Schepens, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and finlings were summarized on March 21, 1986, with those persons indicated in paragraph I above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters a.
(Closed) Violation 50-424, 425/84-36-01 - Failure to follow NDE precedures.
This violation cited 2 examples of failure to follow NDE pr@edures by PPP personnel:
(1) During the examination of welds using ma41 etic particle (MT) procedure IX-MT-5-AWS75, a magnetic field
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indicator was not used as required by the procedure.
PPP conducted a
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series of inspections on test pieces with known defects using the established techniques of yoke leg placements without the use of a magnetic field indicator and again with the use of a magnetic field indicator to determine that an adequate field was established. Results of the evaluation indicated that all known surface indications were detected using the various pole placements; (2) During the performance of ultrasonic thickness examinations using procedure X-2CB the examiner performing the examinations did not confirm the calibration accuracy of the ultrasonic instrument by the use of an intermediate thickness reading as required by procedure.
PPP randomly re-examined eight of the examinations conducted by the WDE ultrasonic technician.
Results of the re-examinations were found to be acceptable.
The inspector reviewed data associated with the above findings and has no further questions regarding these matters.
b.
(Closed) Unresolved Item 50-424, 425/84-36-06 - Certification date for GPC NDE examiners.
This item identified a potential for the GPC NDE examiners to exceed the three year recertification re-examination time limit imposed by controlling documents.
The inspector reviewed GPC procedure GEN-12750, Qualification and Certification of Nondestructive Testing (NDT) Personnel, revision dated July 10, 1984, and determined that recertification may be accomplished by continued satisfactory use of the NDE method.
The inspector has no further questions regarding this matter.
c.
(Closed) Unresolved Item 50-424, 425/84-36-07 - Reinspection by visual inspectors after grinding to explore indications discovered by NDE.
Review of NDE procedures revealed that grinding to remove surface roughness and to determine the relevance of indications in welds did not require that welding QC be informed whenever the final configura-tion of a weld is changed due to grinding, although the fabrication specifications require that visual inspections be conducted on welds in their final surface condition.
The inspector reviewed the NDE procedures in question with their latest revisions which directs the NDE examiner to contact welding QC for a final visual examination whenever grinding is performed on visually accepted welds.
The in-spector has no further questions regarding this matter, d.
(Closed) Unresolved Item 50-424/85-35-14 - Undersized /overground welds.
The welds in question were made and inspected by a vendor and are not normally reinspected by site personnel.
The condition noted has been addressed by initiation of deviation reports MD-8721 and MD-8723 which will be evaluated and dispositioned in accordance with project procedures.
The inspector has no further questions regarding this matter.
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Unresolved Items Unresolved items were not identified during the inspection.
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Construction Progress The inspector conducted a general inspection of Units 1 and 2 containments, auxiliary building, and fabrication areas to observe construction progress and construction activities such as welding, material handling and control, housekeeping, and storage.
Within the areas examined no violations or deviations were identified, 6.
Construction Nondestructive Examination (NDE)
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The inspector reviewed procedures, conducted examinations, observed examinations, and reviewed records for various NDE methods, as indicated in the following sub-paragraphs, to determine whether NDE activities were being accomplished in accordance with the applicable code and regulatory requirements.
The applicable code is the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME B&PV) Code,Section III,1977 Edition, Winter 1977 Addenda.
The nondestructive examinations were being conducted by Pullman Power Products (PPP), Nuclear Installation Services Company (NISCO), and Chicago Bridge and Iron (CBI).
a.
Visual Examination Procedure Review / Record Review (57050)
(1) Procedure Review (Units 1 and 2)
The inspector reviewed the below listed visual examination procedures to ascertain whether they were ~ issued and qualified in
accordance with the licensee's quality assurance program.
The procedures were also reviewed to determine whether they contained sufficient instructions to assure that the following parameters were specified and controlled within the limits permitted by the applicable code, standard, or any additional specification requirement; method - direct visual, remote visual or translucent visual; application - hydrostatic testing, fabrication procedure, visual examination of welds, leak testing, etc.; how visual examination is to be performed, type of surface condition avail-able; method or tool for surface preparation, if any, whether direct or remote viewing is used; special illumination, instru-ments, or equipment to be used, if any; sequence of performing examination, when applicable; data to be tabulated, if any; acceptance criteria is specified and consistent with the applicable code section or controlling specification; and report
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form completion.
Procedure Ti tle Revision (PPP) X-11 Visual Examination - General 5-31-82 (CBI) VT7X Visual Examination Procedure Rev. 1 (CBI) C76 Calibration of Dimensional Measuring Rev. 1 Equipment with Vernier Scales l
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(2) Records Review (a) The inspector reviewed the below listed CBI visual examina-tion personnel qualification records to ascertain whether these records properly reflect the employer's name, person certified, activity qualified to perform,. effective period of certification, signature of employer's designated representative, basis used for certification, and annual visual acuity,' color vision examination and periodic recertification.
Examiner Level CLF II LSS II (b) The inspector reviewed the QCI Final Visual Training Plan and Procedure Study List for QCI Final Inspection certification recently instituted by PPP for their NDE personnel.
This review was accomplished to determine the prerequisites for the NDE examiners prior to certification and the adequacy of the subject matter being addressed.
(c) The inspector reviewed the visual examination reports for the below listed welds to determine compliance with procedure requirements for examination records.
Examiner Drawing No.
Weld No.
NISCO 1X6AB08-33-8(SupportA)
BMIA-366 BMIA-367 BMIA-368 BMIA-369 BMIA-370 Contract No.
Seam No.
CBI 854491 (Quad. A)
P5-11 to Cl-2 P7-4 to Cl-8 P7-8 to Cl-8 CBI 854491(Quad.C)
B5-3 to Cl-3 P4-9 to Cl-7 CBI 854491 (Quad. D)
88-4 to P1-20 b.
Magnetic Particle Examination Procedure Review / Record Review (57070)
(1) Procedure Review Units 1 and 2 The below listed magnetic particle (MT) NDE procedures were reviewed by the inspector to ascertain whether essential
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examination variables are defined and whether these variables are controlled within the limits specified by the applicable code and other specification requirements.
Latest Procedure No.
Title Revision (PPP)1X-MT-3-W77 Magnetic Particle Examination 1-2-85 Procedure Dry Powder Continuous Method Yoke Technique (PPP)1X-MT-5-AWS75 Magnetic Particle Examination 1-2-85 Procedure for Structural Steel AWS D1.1-1-75, Section 6 and ASTM E709-80 (Formerly E109)
Prod Technique (CBI)MT13X Magnetic Particle Examination R-4 Procedure Continuous Yoke, Dry, Visible Particles In addition to the above review, the procedures were analyzed in the area of technical content relative to magnetizing method, surface preparation, magnetic particle contrast, surface temperature, light intensity, coverage, prod spacing, magnetizing current, yoke pole spacing and acceptance criteria.
(2) Record Review Units 1 and 2 (a) A review of qualification records, as listed below, for CBI magnetic particle examination personnel was accomplished to determine whether the qualification records properly reflect the employer's name, person certified, activity qualified to perform, level of qualification, effective period of certification, signature of employer's designated repre-sentative,. basis used for certification, annual visual acuity, color vision examination, and periodic recertifica-tion.
Examiner Level CLF II LSS II GLR II
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(b) The inspector reviewed the magnetic particle examination l
reports for the below listed welds to determine compliance
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with procedure requirements for examination records.
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Examiner Drawing No.
Weld ID PPP 2K3-1217-008-01 008-W-01A 008-W-01C PPP 1K4-1217-037-02 037-W-07 i
037-W-08 037-W-09 037-W-10 037-W-11 037-W-12 037-W-13 037-W-14 037-W-15 PPP IK4-1217-037-03 037-W-04 037-W-05 NISCO 21X6AB08-40 2BMIE-99 2BMIE-100 2BMIE-101 2BMIE-102 NISCO 1X6AB08-36-6 BMIA-1 BMIA-2 BMIA-9 BMIA-10
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(c) The above listed welds were MT examined using alternating current (AC) yokes.
The inspector reviewed documentation indicating that lift tests had been performed on AC yokes (PPP) B-7A-2, B-7A-7, and (NISCO) 76166.
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Ultrasonic Examination Procedure Review / Record Review (57080)
(1) The below listed ultrasonic examination procedures were reviewed to ascertain whether the procedure contains sufficient information
to assure that all essential parameters are specified and controlled within the limits permitted by the applicable code or specification requirements.
Latest Procedure No.
Title Revision PPP 1X-UT-1-W77 Ultrasonic Examination 4-2-82 of Weldments Winter 1977 Addenda
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NISCO C3 Calibration and Verification R-0 of Ultrasonic Thickness Gauges l
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In addition to the review above, the procedures were analyzed in the areas of technical content relative to type of apparatus to be used including frequency range as well as linearity and signal attenuation accuracy requirements; extent of coverage (beam angles, scanning surface, scanning rate and directions) as well as the scanning technique; calibration requirements, methods and frequency including the type, size, geometry, and material of calibration blocks as well as location and size of calibration reflectors within the block; the sizes and frequencies of search units specified and that they are consistent with applicable requirements; beam angle or angles are specified and that they are consistent with the applicable requirements; methods of compensation for the distance traversed by the ultrasonic beam as it passes through the material including distance - amplitude correction and transfer mechanism; reference reflectors for accomplishing transfer and the frequency of use of transfer mechanisms; examination reference level for monitoring discontinuities and the scanning gain setting is specified and that these values are in accordance with applicable requirements; the methods of demonstrating penetration and coverage are established; the levels or limits for evaluation and recording of indications are specified and are in accordance with applicable requirements; the method of recording significant indications and that the reporting requirements are in accordance with requirements; and the acceptance limits are in accordance with the applicable requirements.
(2) Records Review Units 1 and 2 (a) The inspector reviewed the below listed PPP weld examination reports to determine compliance with procedure requirements for examination records.
Drawing No.
Weld I.D.
109-S-09 Wald A 109-S-09 Weld B 1K4-1302-109-01 109-W-08 109-W-07 109-W-14 (b) The inspector reviewed the material certification records for ultrasonic couplant batch numbers 8114 and 044..
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Liquid Penetrant Examination Procedure Review / Records Review (57060)
(1) Procedure Review Units 1 and 2 The below listed liquid penetrant NDE procedures were reviewed by the inspector to ascertain whether essential examination variables are defined and whether these variab.les are controlled within the limits specified by the applicable Code and other specification requirements.
Latest Procedure No.
Title Revision PPP IX-PT-1-W77 Penetrant Examination 7-22-85 Procedure to ASME Section III Winter 1977 Addenda CBI PT10X Liquid Penetrant Examination R-2 Procedures Color Contrast; Water Washable, Wet Developer CBI PT11X Liquid Penetrant Examination R-1 Procedure Color Contrast; Solvent removable, Wet Developer In addition to the review above, the procedures were reviewed in the area of technical content relative to specified test method requirements; brand names and specific types (number or letter designation, if available) of penetrant, penetrant remover, emulsifier and developer; penetrant materials used are analyzed for sulfur and total halogens; methods for acceptable pre-examina-tion of surface preparation and surface area to be examined is consistent with applicable Code requirements; establishing a minimum drying time following surface cleaning, method of penetrant application and the penetration (dwell) time are specified; examination surface temperature is specified; methods for removal of solvent removable penetrant are specified; method and time of surface drying prior to developing are specified; type of developer is specified; method of developer application and the time interval between penetrant removal and developer application are specified; final interpretation is performed within the range of 7-30 minutes after developer application; minimum light intensity at the inspection site is prescribed; technique for evaluation of indications is specified, acceptance standards are included and these are consistent with applicable Code and specification requirements; reporting requirements are specified; and procedure requalification is required when critical element changes are necessar,
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(2) Records Review Units 1 and 2 (a) A review of qualification records for the CBI liquid penetrant examination personnel listed below was accomplished to determine whether the qualification records reflect the employee's name, person certified, activity qualified to perform, level of qualification, effective period of certification, signature of employee's designated representa-tive, basis used for certification, annual visual acuity, color vision examination, and periodic recertification.
Examiner Level CLF II LSS II GLR II TAC II (b) The inspector reviewed the liquid penetrant examination records for the below listed welds to determine compliance with procedure requirements for examination records.
Examined By CBI Seam No.
Contract No.
54-4-2 33723 Ring #1 51-B 52-A 50-2-2 50-2-3 A
33723 Ring #2 B
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E (c) The below listed liquid penetrant material certification records were reviewed to ascertain if the sulfur and halogen content of the materials were within acceptable content requirements.
Material Batch Nos.
Liquid Penetrant 85F071, 81L052 Developer 84H056, 84G028
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Radiographic Examination Procedure Review / Record Review (57090)
(1) Procedure Review Units 1 and 2 The below listed radiographic procedures were reviewed to ascertain whether they had been issued and approved in accordance with the licensee / contractor's QA program and to ascertain whether the examination variables were defined and whether these variables are controlled within the limits specified by the applicable Code or specification requirements.
Latest Procedure No.
Title Revision NISCO E.S.8.7 Radiographic Examination R-C of Production Welds and Welder / Welding Operator Qualifications CBI RTIN Spot Radiographic R-1 Examination Procedure for Welds PPP XII-2 Calibration of Tools 5-3-85 Measurement and Test Equipment In addition to the review above, the procedures were analyzed in the area of technical content relative to material and weld surface condition requirements, types of material to be radio-graphed, material thickness range, type of radiation source, film brand or type, minimum source to film distance, blocking or masking technique, type and _ thickness of intensifying screens and filters, exposure conditions for procedure qualification, radio-graphic film processing requirements, quality of radiographs, film density limits for single and composite viewing, system of radiograph identification, use of location markers, record for showing film and source location with reference to the part being radiographed, use of intensifying screens, methods of testing for backscatter, material type and thickness restric.tions for isotope radiography, geometrical unsharpness limitations, selection and use of penetrameters, radiographic technique requirements for double wall viewing, qualification of radio-graphic procedure, requirements for evaluation and dispostion of radiographs, and records requirement.
(2) Records Review Units 1 and 2 (a) A review of qualification records for the CBI radiographic examination personnel listed below was accomplished to determine whether the qualification records reflect the employer's name, person certified, activity qualified to perform, level of qualification, effective period of certification, signature of employer's designated representatives, basis used for certification, annual visual acuity, color vision examination and periodic recertification.
Examiner Level CLF II LSS I
GLR II TAC II (b) The inspector reviewed equipment and material certifications and calibration records for the items listed below in order to ascertain whether the documents are retrievable, complete, and accurate.
Penetrameters #17 and #40 on purchase order 14677.
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Stainless steel penetrameters on purchase order TAV-8477.
NISCO densitometer serial number C-2068 PPP t
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densitometer serial numbers TD 504 and TD 903 Within the areas examined, no violations or deviations were identified.
7.
On March 10, 1986, the licensee notified the USNRC Region II office that a deviation from PPP procedure IX-RT-1-77 and ASME Section IX, Para QW-191, relative to the radiographic technique used to qualify heavy wall welder test coupons, had occurred.
The following paragraphs describe the deviation, actions taken to substantiate the adequacy of the radiographic technique used, and conclusions reached relative to the affected hardware.
a.
Deviation Description Heavy wall welder test coupons qualified by RT in accordance with ASME Section IX, Paragraph QW-142 were radiographed using the wrong technique for code editions and addenda of ASME Section IX, Paragraph QW-191 from the 1980 edition, Winter 1980 addenda through the 1983 edition, Summer 1984 addenda.
In accordance with ASME Section IX,
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Paragraph QW-191 and Project Procedure IX-RT-1-W77 (all revs)
paragraphs 3.3.1 and 3.3.3, whenever the I.D. is accessible, both the source and the penetrameter are to be placed on the inside of the pipe (i.e., opposite wall / source side penetrameter technique). Contrary to this, in nearly every case between 1981 and 1985, the source and penetrameter have been placed outside the pipe (i.e., double wall exposure / single wall viewing with film side penetrameter technique); in several instances, the opposite wall technique was used but with a film side penetrameter placement.
This situation was noted and corrected (for the most part) in 1985.
The improper penetrameter placement was identified by the Authorized Nuclear Inspector (ANI) and documented on SIS Record of Monitoring QA/QC Programs dated January 4,1986.
The improper source placement was discovered upon review of radiograph reports in preparation for a response to the SIS.
b.
Justification of Radiographic Technique Used (1) Paragraph QW-191 of ASME Section IX, Winter 1984 addenda deleted the requirement for single wall radiography and the use of a source side penetrameter and referenced Article 2 of Section V for the radiographic technique without any exceptions. Use of double wall radiography is allowed by Paragraph T-270 of Article 2 of Section V, and the use of film side penetrameters is allowed by Paragraph T-263.1 of Article 2 of Section V.
Radiography of production welds in piping is generally accomplished using a double wall technique with film side penetrameters because of restricted access to the I.D.
Article 2 of Section V provides that the acceptability of the radiographic technique is based on the ability to see the specified hole in the image of the penetrameter.
In all cases, the welder performance qualification radiographs met the required sensitivity.
(2) PPP performed comparison radiographs of heavy wall coupons with source side and film side penetrameters in each exposure to demonstrate that the sensitivity of the radiograph is adequate for evaluation even though the required technique was not used.
Exposures were made to be worst case basis for each set up with the following variables:
(a) Use of #15 penetrameter on film side in each exposure regardles of allowable penetrameter per Table T-272 in ASME Section V, Article 2.
(b) Increased shim thickness in each exposure (0" to.187).
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(c) Use of largest available source size (.107" X.102").
(d) Source placed so that maximum focal spot size is used.
(e) Use of maximum offset of penetrameter from normal plane of radiation.
(3) Comparison radiographs were made at the request of Westinghouse and Bechtel, utilizing the proper radiographic technique and a radiographic technique utilizing double wall exposures with a film side penetrameter on 8" diameter coupons.
(4) Comparison radiographs were made at the request of Hartford Insurance, which used 6" coupons with man made 1/8" diameter holes having a depth of approximately 1/4".
(5) Technique radiographs exposed by Pullman Power Products to verify acceptable radiographic film quality were reviewed by qualified NDE personnel of Pullman, Westinghouse and Bechtel.
The radio-graphs provided the required film side and source side penetra-meter image and hole size which demonstrated acceptable sensitivity for the penetrameter locations, c.
Disposition of Affected Hardware PPP and the authorized inspection agency have determined that hardware is not affected and may be used as is.
Justification for this conclusion is based on criteria in ASTM E-142-72 which provides criteria for determining the appropriate film side penetrameter in cases where placement of the penetrameter on the source side is impractical (Ref. para. 6.4.2), ASME Section V, Article 2, has already provided for this and is reflected in Table T-272.
Had the proper radiographic technique been used (i.e., opposite wall with source side penetrameter) the proper penetrameter to use would be a #20 penetra-meter (per Table T-262.2).
Even though the incorrect technique was used, the penetrameters actually used are more restrictive in thickness and essential hole diameter and therefore indicate adequate sensitivity for the radiographs as allowed in ASTM E-142-72.
Comparison radio-graphy was performed using film side penetrameters versus source side penetrameters.
In addition, the documentation of the welds performed by these welders to date, has been reviewed and found to be in compliance with all applicable requirements.
d.
The NRC inspector reviewed all of the comparison radiographs made by PPP and has reviewed the supporting documentation.
The required film side and source side penetrameter image and hole was evident on the
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comparison radiographs which demonstrated acceptable exposure sensitivity for both penetrameter locations.
The inspector has no further' questions regarding this matter.
Within the areas inspected, no violations or deviations were identified.
8.
Inspector Followup Items (92701) Unit 1 (Closed) Inspector Followup Item 50-424/85-46-01 - Guidance for maintaining physical integrity of reference reflectors in UT Calibration Blocks. Vogtle Electric Generating Plant Procedure No. 00411-C has been revised to establish responsibility for control of the calibration blocks.
Southern Company Services, the preservice contractor for the licensee, has developed an administrative procedure, AUX-V-308, that establishes requirements for handling, storage and_ care of the calibration block while being used_in the field.
The inspector reviewed the above procedures and has no further questions regarding this matter, i