IR 05000498/1989036
| ML20247H542 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/08/1989 |
| From: | Barnes I, Ellershaw L, Gilbert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247H533 | List: |
| References | |
| 50-498-89-36, 50-499-89-36, NUDOCS 8909200012 | |
| Download: ML20247H542 (10) | |
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APPENDIX B 0.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-498/89-36 Oper6 ting Licenses: NPF-76 50-499/89-36 NPF-80 Dockets: 50-498 50-499 Licensee: Houston Lighting and Power Company (HL&P)
P.O. Box 289 Wadsworth, TX 77483 Facility Name: South Texas Project (STP), Units 1 and 2
' Inspection At: STP, Matagorda County, Texas Inspection Conducted: August 21-25, 1989 Inspectors: ['
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L. D. failbert, Reactor Inspector, Materials Date and Quality Programs Section, Division of Reactor Safety
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L1 E. Ellershaw, Reactor Inspector, Materials Date '
and Quality Programs Section Division of Reactor Safety
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Approved:
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1. Barnes, Chief, Materials and Quality Date Programs Section, Division of Reactor Safety
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-2-Inspection Summary Inspectian Conducted August 21-25, 1989 (Report 50-498/89-36; 50-499/89-36)
Areas Inspected: Routine, unannounced inspection of the control of welding activities.
Results: A progr:m for the control of welding activities has been developed by the licensee but program implementation was weak as evidenced by weaknesses identified in the areas of monitorir.g of welding parameters, and control of filler materials.
It was also noted that the actual QC involvement in welding activities during the inspection was minimal. An apparent violation (paragraph 2.b) was identified for f ailure to monitor welding parameters during welding. A secord apparent violation (paragraph 2.c) was identified in the area of filler material control for commingling of welding materials in the storage ovens.
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-3-DETAILS 1.
Persons Contacted HL8P
- G. E. Vaughn, Vice President, Nuclear Operations
- J. E. Geiger, General Manager, Nuclear Assurance
- D. N. Brown, Manager, Support Construction Department
- T.'J.. Jordan,-Manager, Plant Engineering
- J. D.-Green, Manager, Inspection and Surveillance
- S. M. Dew, Manager, Nuclear Purchasing Material Management
- S..W. Loesch, Plant Operations. Manager
- J. T. Minor,lb.usar, Construction Engineering
- M. R. Wisenburg, General Manager, Nuclear Safety Review Board
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- S. Timmaraju.. Senior Consulting-Engineer
' *C.. A. Ayala, Supe.rvisor Licensing Engineer
- P. L. Walker, Senior. Licensing Engineer
- A. K. Khosla, Senior Licensing Engineer
- K. Silverthorne, Construction Welding Engineer W. Jones, Construction Welding Supervisor S. Jerrick, Maintenance Support Group Lead'
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- J. E. Bess. Senior Resident Inspector
- J. I. Tapia, Senior Resident Inspector
- D.,L'. Garrison, Resident Inspector
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- R. J. Evans, Resident Inspector
- I. Barnes, Chief, Materials and Quality Programs Section The inspectors also interviewed other licensee employees during the
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- Denotes attendance at exit interview conducted on August 25, 1989.
2.
' Welding Activities (55050 and 55100)
The objective of this inspection was to verify that the licensee has developed and implemented a program relating to control of welding activities that is in confomance with Design Specifications and comitments in the Final Safety Analysit Report (FSAR).
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Review of Procedures
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The inspectors reviewed the licensee's program for controlling l
safety-related welding activities to assure that welding is controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards,
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L-4-specifications, criteria, and other special requirements. The licensee documents for controlling the welding program are listed in Attachment 1.
These documents provide the instructions for: general welding requirements; welding procedure specification (WPS) preparation and qualification; welder qualification and certification; control of filler materials; and control of post weld heat treatnent. The licensee's welding specification index consisted of 24 welding procedure specifications. The WPSs and their supporting procedure qualification reports (PQRs) that were reviewed by the inspector, are listed.in Attachment 2.
In reviewing the WPSs for welding austenitic stainless steels, the inspectors noted that the qualification records did not indicate the travel speed or heat input used during qualification.
The requirements for establishing heat input during welding procedure qualification for welding austenitic stainless steels are discussed in Sections 6.1.1.1, 5.2.3.4, and 5.3.2.3.6 of the FSAR. This issue was discussed with the NRR Materials Engineering Branch and determined not to be'a safety. issue for pressurized water reactors. The heat input controls specified in the FSAR for welding austenitic stainless steels are considered as good welding practice and not regulatory requirements. The discrepancy between the FSAR and the WPS qualification records is considered a technical issue and not a safety issue.
Therefore, no citation will be issued; however, the licensee is requested to resolve the discrepancy between the FSAR and the WPS qualifications concerning heat input controls.
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Observation of In-Process Welding The inspectors observed in-process welding associated with two Modification Design Change Notices (MDCNs); MDCNs 88-0246-04 and 88-0246-01. MDCN 88-0246-04 pertained to modifications being made to Unit 1 chemical and volume control system, Line CV-1214, which was designated as being ASME Class 2.
The particular weld which was observed being made was identified as FS-0028, and was part of Work Package 005393-EP05. This involved gas tungsten arc welding (GTAW)
of a stainless steel pipe and reducer using WP5 P8-T-Ag. The inspectors noted the identity of the welder and the welding material in his possession. Review of the Filler Material Issue Slip (FMIS)
indicated that the welder had been issued 3/32 and 1/8-inch ER308L bare electrodes, Heat Codes 264 and 337, respectively. However, review of the applicable Weld Inspection Checklist (WIC), which becomes the permanent documentation record, revealed that the identity of the welding material had been recorded as Heat Codes 264 and 237. Review of the Weld Filler Material Matrix revealed that
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Heat Code 237 had been assigned to E7018 electrodes (coated, low hydrogen). The inspectors' questions to the cognizant personnel resulted in the determination that during the transfer of information from the FMIS to the WIC, a transposition error occurred. Upon identification of this error, the licensee took immediate corrective action cnd made the necessary correction. The inspector noted during i
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-5-the review of Station Procedure OPMP02-ZK-0004, that Field Change 88-2141 dated November 29, 1988, had deleted the requirement for retention of FMISs as permanent records. The inspectors expressed concern that the deletion of the requirement coupled with the failure to verify the accuracy of information transfer could lead to further errors in the future. The inspectors also observed the rate of argon gas flow, gas cup size, travel speed, and amperage, and compared this to the welding parameters specified in the WPS.
It should also be noted that the welding power sources are not equipped with voltmeters or ammeters. Therefore, in order to observe the amperage, the inspectors had to requert that a tong meter (ameter) be provided.
MDCN 88-0246-01 pertained to modifications being made to Unit I safety injection system, Line SI-1101, which was designated as ASME Class 2.
The particular weld which was observed being made was identified as FW-0031, and was part of Work Package 005393-EP02.
This involved the welding of a stainless steel weldolet to a pipe with the GTAW process using WPS P8-AT-Ag. This is actually a two processWPSusingbothGTAWandtheshieldedmetalarcwelding(SMAW)
process; however, the inspectors did not observe the SMAW portion of the weld. The inspectors noted that the FMIS and WIC were in agreement with respect to the identity of the issued welding materials; i.e.,
3/32 and 1/8-inch ER308L electrodes, Heat Codes 264 and 337, respectively.
The amperage, travel speed, and argon gas flow characteristics were noted, compared, and found to be within the parameters specified by the WPS.
The inspectors verified by review of Certified Material Test Reports (CMTRs), welder qualification records, and procedure qualification records, that the welding filler material, welders and WPSs were properly certified for the in-process welding that the inspectors observed.
During the inspection of the in-process welding activities, the inspectors determined that a program was not in place to ensure that welders were complying with the welding parameters of the welding procedure specification by monitoring the initial welding setup or performing in-process monitoring. The Support Construction Department indicated that they were not monitoring welding parameters of its welders. The Quality Control (0C) Department has a hold point for in-process inspections in Procedure NDEP 3.0, "il:ual Examination of Welds", Revision 1.
However, QC supervision indicated that this hold point was rarely used and that none of the QC inspection personnel had verified welding parameters for any welding performed in support of the outage. The Nuclear Assurance (QA) Department has a surveillance checklist for the surveillance category of general welding requirements. However, the last QA surveillance report for this category was performed in January 1989 and none were scheduled because of a manpower shortage. The licensee has, as part of their corrective action to this finding, initiated monitoring of welding parameters by the Support Construction Department and the QC
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-6-Department. This is an apparent violation for failure to provide q
in-process monitoring of welding parameters.
(498/8936-01;499/8936-01)
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Welding Material Control The inspectors conducted a review to determine that a procedure had been established with respect to storing, disbursing, and handling of welding materials. Station Procedure OPHP02-ZW-0004. Revision 4, including Field Change No. 88-2141, is the procedure which delineates the requirements and responsibilities associated with weld material control. The procedure appears to be comprehensive and addresses all of the elements necessary for the control of welding materials.
In order to verify implementation of the procedure, the inspectors observed the storage, issuance, and use of welding materials. The inspectors were informed that three filler material issue areas (FMIAs) existed: two controlled by Support Construction (SC),
and one controlled by Nuclear Plant Operations Department (NPOD).
While a limited amount of welding was being performed during this inspection, nnae was being performed with material issued from the SC FMIA located '
the fabrication Shop. However, the inspectors did observe the identification and storage of welding materials, including those electrodes required to be stored in ovens. This also included a review of oven temperature control and calibration of the oven thermometers. The inspectors reviewed the CMTRs associated with the covered electrodes stored in the ovens in order to verify that the applicable ASME Code requirements were addressed.
It was also verified that the required Authorized Filler Material Issue Slip Approval Roster and the Authorized Personnel Access List had been established, maintained, and posted.
The next FMIA that the inspectort observed was located in the Maintenance Shop and was under the control of NP0D. The inspectors performed a similer observation and review of welding materials ard CMTRs, as described above.
In addition, while not observed by the inspectors, welding material had been issued for a temper bead weld repair on a secondary manway in the Unit 1 Steam Generator lA. The ASME Code allnws this type of weld repair to be made on P-3 material (low alloy steel) without postweld heat treatment provided specific requirements are met with respect to conditioning of the welding materials to be used. These requirements pertain to the baking of low hydrogen covered electrodes at specific times and temperatures with emphasis on heating and cooling rates. They also require the subsequent storage of the electrodes in controlled ovens within a specific temperature range. Documentation and other data was availeble to substantiate that the licensee had implemented these ASME Code requirements.
The final FMIA to be observed was the Unit 1 FMIA, controlled by SC.
This area contained eight holding ovens, seven of which were in use.
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-7-Station. Procedure OPMP02-ZW-0004 requires that all covered, low hydrogen and stainless steel electrodes, once removed from their l
hermetically sealed containers, be stored in holding. ovens which are
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clearly marked to identify the contents.
It: further requires that the ovens shall contain no more'than one classification of covered electrodes or more than one heat code of the same size. 'The inspection' identified that three of the seven ovens: contained either more than one classification of covered electrodes or more than one heat' code of the same size, none of which were identified as being in-the ovens.
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1. ' Oven OSC 101, which was identified as containing 3/32'and 1/8-inch E9018-B3 electrodes, also contained 1/8-irch E7018 electrodes mixed in with the 1/8-inch E9018 electrodes.
2.. Oven OSC 102,'which was identified as containing 3/32-inch and 1/8-inch E308L-16 electrodes, Lot Nos. 2849816 and-2449256 respectively, also contained 3/32-inch E308L-16 electrodes, Lot No. 2549410 mixed in with the identified 3/22-inch E308L-16 electrodes.
3; Oven OSC 108, which was identified as containing 3/32 and
- 1/8-inch E7018. electrodes, also contained 3/32-inch E309-16 electrodes mixeo in with the 3/32-inch E7018 electrodes, and one 1/8-inch E8018-B2 electrode mixed in with the 1/8-inch E7018 electrodes.
This failure to maintain welding material control is an apparent violation (498/8936-02; 499/8936-02).
It should be noted that upon notification by the inspectors, the licensee issued Problem Report No. 89-0631, which addressed the condition description, imediate corrective actions taken, and which-will cause an evaluation to be performed in terms of impact on previous work and measures to preclude recurrence.
In addition,'the Plant Manager issued a Stop Work Order with respect to the issuance of welding naterials from the Unit 1 FMIA.
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The inspectors reviewed FMISs for welding materials issued on August 23, 1989.from the Unit 1 FM1A. One FMIS had been initieted in order to obtain welding electrodes necessary to make Weld No. FW 0031 on the Unit 1 safety injection system required by MDCN 88-0246-01. The FMIS specified the use of 3/32-inch E308L-16 coated electrodes. The FMIA attendant issued the welding material and completed the FMIS, which included entering the heat code number (HC 264) of the issued material. The inspectors reviewed the Weld Filler Material Matrix, which is a description, by heat code, of all filler material used et the STP. This matrix showed HC 264 to be 3/32-inch ER308L bare rod.
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The inspectors questioned the FMIA attendant to determine if the incorrect heat code had been entered or if welding material had been
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-8-issued which was different from that which had been requested. From what could be ascertained, it would appear that the attendant did, in-fact, issue material different from what was requested, and he recorded the heat code number of the issued material. Further discussion with other cognizant personnel. indicated that.the FMIS had actually been filled out incorrectly and the attendant recognized this and took it upon himself-to issue the correct material. The inspectors expressed concern over the attendant's failure to reject the FMIS request and his subsequent actions of issuing a different material. The licensee took imediate corrective action by correcting the FMIS and initiating training sessions for the FMIA attendants.
d.
Welder Qualification The. inspectors toured the welder qualification testing area, however, no welders.were being tested. ~The inspectors selectively sampled and reviewed 14 welder certifications and compared each certification to the welder qualification matrix for the Support Construction Department that was dated August _16, 1989. It was noted that the standard welder qualification test for pipe butt welds used the more stringent radiographic examination which is optional in lieu of bend testing for acceptance of welder qualification testing.
There were no violations or deviations identified during this part of the inspection.
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Exit Interview An exit interview was conducted on August 25, 1989, with those personnel denoted in paragraph 1.
At the exit interview, the inspectors sumarized i-the inspection findings. The licensee committed to discontinue welding on austenitic stainless steel which has a carbon content in excess of 0.03 percent until the'FSAR requirements concerning heat input controls were
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addressed for the welding procedures. This restriction was subsequently I
lifted after clarification by the licensee of its FSAR requirements and supporting technical basis..No information was presented to the inspectors that was identified by the licensee as proprietary.
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ATTACHMENT 1 LIST OF WELDING PROGRAM DOCUMENTS REVIEWED j
Procedure OPMP02-ZW-0001 Revision 02, " General Welding Requirements" i
Procedure OPMP02-ZW-0002, Revision 02, " Welding Procedure Specification i
Preparation and Qualification" Procedure OPMP02-2W-0003, Revision 03, " Welder Qualification and Certification" Procedure OPMP02-ZW-0004, Revision 04, "Centrol of Filler Materials," and fCR 88-2141 Procedure OPMP02-ZW-0005, Revision 00, " Control of Post Weld Heat Treatment" I
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ATTACHMENT.2 y
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l; LIST OF WELDING PROCEDURE SPECIFICATIONS REVIEWED
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i WPS P1-T _Revisioni1 and; supporting PQR 003
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. WPS'P4-AT-Revision 0.aad supporting PQRs 014A and 14B
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- WPS P4-T Revision 0.and supporting PQR'13'
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wps_P4,PI-AT Revision 0 and supporting PQRs 014A and'14B
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-WPS P5-AT-Ag. Revision 1 and supporting PQR 012A and 12B
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WPS PS.P1-AT-Ag~ Revision'l-:end supporting PQR 012A and 12B
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. WPS'P8-A Revision 1-and~ supporting PQR 005
WPS P8-AT-Ag Revision,I'and supporting PQR 005
. WPS P8-T-Ag: Revision 0 and supporting.PQR'002-WPS P8-T-Ag-1 Revision 0 and supporting PQR 016
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WPS P8,PI-A Revision.0 and supporting PQR 006
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WPS.P8,P1-AT-Ag Revision 0 and supporting PQR 006
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WPS.P35,P1-T, Revision 0 and' supporting PQR 010
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._ WPS P35.PS-T. Revision 0 and supporting PQR 090
- WPS P35-T-Revision.0 and supporting PQR 007 WPS P3-A(TB) Revision 0 and' supporting PQR 024
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