ML17207A332

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IE Insp Rept 50-389/79-07 on 790515-18 Noncompliance: Failure to Include All Info in Qualification Records of Weld Procedure Specs & Failure to Follow Radiographic Procedure & Code Requirements for Welder Qualifications
ML17207A332
Person / Time
Site: Saint Lucie NextEra Energy icon.png
Issue date: 06/14/1979
From: Economos N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17207A329 List:
References
50-389-79-07, 50-389-79-7, NUDOCS 7909040043
Download: ML17207A332 (6)


See also: IR 05000389/1979007

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTAST., N.W., SUITE 3100

ATLANTA,GEORGIA 30303

Report No. 50-389/79-07

Licensee:

Florida Power and Light Company

9250 West Flagler Street

Miami, Florida 33101

Facility Name: St. Iucie Unit 2

Docket No. 50-389

License No. CPPR-144

Inspection at St. Lucie Unit 2 near Hutchinson Island, Florida

+~1

Inspector:

N. Economos

7

Date

igned

Approved b

T.

.

onion, Section Chief,

RCES Branch

ate

igned

SUMMARY

Inspection

on May 15-18,

1979

Areas Inspected

This routine,

unannounced

inspection involved 25 inspector-hours

onsite in the

areas

of reactor

coolant loop piping and other safety-related

piping - welding

procedure specifications

and quality assurance

procedures

review; welder perform-

ance qualification procedure

and record review; welder qualification and training

facilities; control of preheat practices.

Results

Of the five areas

inspected,

no apparent

items of noncompliance

or deviations

were identified in two areas;

two apparent

items of noncompliance

were found in

three

areas

(Deficiency - Documentation

of Specific Variables

Used to Qualify

Weld Procedure Specifications,

paragraph

6; Infraction - Failure to Follow Radio-

graphic Procedure

and Code Requirements for welder Qualifications, paragraph 5.c.

No apparent deviations were found in the areas

inspected.

'0

V999 040

f ~

DETAILS

Persons

Contacted

Licensee

Employees

B. J. Escue,

Site Manager

  • J. D. Kirk, Assistant Site Manager
  • W. J. Taylor, Project Superintendent

-W. M. Hayward,

QA Supervisor

  • W. F. Jackson,

Welding Superintendent

J.

R. Behris,

QC Supervisor

-J.

W. Adams,

QA Engineer

(Mechanical)

  • B. M. Parks,

QA Engineer

Other licensee

employees

contacted

included construction craftsmen

and

technicians.

-Attended exit interview

Exit Interview

The inspection

scope

and findings were summarized

on March 18,

1979, with

those persons

indicated in Paragraph

1 above.

The inspector identified the

areas inspected which i'ncluded weld procedure specifications

and qualification

records; welder performance qualifications; welder training and qualification

facilities;

control of weld joint preheat.

Two items of noncompliance

were discussed

in detail.

No dissenting

comments

were received

from the

licensee.

Licensee Action on Previous Inspection Findings

(Closed)

389/78-11-01

Inadequate

procedure

for control of heat treatment.

Construction Site Procedure

(CSP) - 41, "Control of Heat Treatment"

has

been

revised

and is

now identified as

SQP-42.

With regards to the appli-

cable

code edition covering heat treatment of welds, the revised procedures

requires that,

"The proper

code edition and addenda

of the applicable

codes

shall apply" and that,

"the postweld heat treat

(PHT) procedure

must have

been prequalified through the PQR and approved by the welding superintendent".

Section IX 1977 Edition of the ASME Code with Summer 78 addenda

was indicated

as applicable

on WPSs involving thermal treatment.

The inspector stated that this action was sufficient to close the question

concerning the applicable

code edition.

The inspector stated

however, that

the question

concerning control of preheat

had not been adequately

addressed

and would therefore

be identified as unresolved

item 389/79-07-04.

This

matter is discussed

in paragraph 5.d of this report.

-2-

4.

Unresolved Items

Unresolved

items

are matters

about which more information is required in

order to ascertain whether they are acceptable

items, items of noncompliance,

or deviations.

Unresolved

items identified during this inspection

are

discussed in paragraphs

5.b and 5.d.

5.

Independent Inspection Effort

a ~

Welder Training and Qualification Facilities

An inspection of the welder qualification shop

was conducted in order

to observe the craft working on performance tests

and to discuss with

those

taking tests

specifics

of this activity.

At this

time the

inspector witnessed efforts to qualify procedure

WPS-71C to be used

on

certain primary coolant welds.

b.

Review of Welder Performance Qualification Procedures

The licensee

has revised the current welder/welder operator qualifica-

tion procedure

CSP-6, which is now superseeded

by site quality procedure

(SQP),

SQP-10.

A review of this procedure for technical content

and

adequacy,

disclosed that the it was lacking specific information with

respect to supervision,

indoctrination, training (formal/informal) and

related documentation of welders/welder operators.

I

In discussing this matter with the licensee's

cognizant representative

the inspector

noted that requirements

for establishing

a

documented

comprehensive

training and testing program for welding personnel

was

contained

in sections

QP 9.1

and

QP 2.5 of the site

QA manual.

The

licensee's

representatives

stated

that although

the training program

was not documented in a formal procedure,

such

a program did exist and

was being implemented.

However the licensee

agreed

to look further

into this matter

and the inspector stated that this would be identified

as

unresolved

item 389/79-07-03 until RII has

the opportunity to

review the licensee's

documented program in this area.

c ~

Welder Performance Qualification Record Review

Randomly selected

welder performance qualifiication test records

were

reviewed in order to ascertain

whether they (records)

were complete,

accurate

and consistent

with code

requirements.

The qualification

records selected

were as follows:

Welder Stencil No.

Test Method

0

PD

PQS

PSI

PSS

PQK

"13-512

106

5

89

24

43F(Fillet)

15

Mechanical

(bend)

Radiography

Radiography

Radiography

Fracture

Only

Radiograph

-3"

  • The radiograph of this weld test was reviewed by the inspector.

Within the areas the inspector noted the following:

Radiography

of welders

qualification tests

was

performed

in

accordance

with procedure

$1-9.3 revision

1,

which references

Section

V of the

ASME

Code.

Acceptance

standards

for these

radiographs

are

as specified in Section IX of the

ASME Code

1977

Edition thru

S78

addenda.

As

a result of the film review and

disucssion

with NDE personnel,

the inspector

noted that certain

code

and procedural

requirements for the identification of radio-

graphs

were

not being followed.

Instead,

each

radiograph

was

given

a generic type number e.g.

), 2,

3 etc which corresponded

with that on

a log maintained by the radiographer.

The inspector

stated that this method of film identification was not consistant

with procedural and/or code requirements.

The matter was discussed

at length with the licensee's

representative

who agreed to provide

a more definitive indentification method.

2)

Also, the inspector noted that even though the "Radiographic Test

and Interpretation Report" (reader sheet)

had provisions (blanks)

for listing the type of acceptable/rejectable

indications that

were found in the weld test;

the reader

sheets

were not being

marked except for a notation indicating whether or not the welder

has

passed

the test.

Moreover, this notation

appeared

on the

welder's

PgR form without any specific reference

to the reader

sheet

which was kept in a seperate file by the welding superinten-

dent.

Also the inspector

noted that

gA did not appear

to have

any control over this phase

of the welder qualification program

as

evidenced

by the fact that they did not review welder test

radiographs,

reader

sheets

nor did they

do

any surveillance

and/or

audits in this

area.

Instead quality control

(gC)

and

construction

appear

to have

sole control over this phase of the

program, e.g.,

(}C approves the NDE results

an construction certifies

the welder's qualifications.

The review of the welder performance qualification records disclosed

that,

welder

PgK

was

required to take

a fillet weld test for

WPS-43F

on

a one half-inch pipe with a 0.109 inch wall thickness.

Paragraph

gW-303.6,

Section

IX of the

ASME

Code

states

that

welders

who make fillet welds

on

a pipe or tube less than 2.875

inch outside

diameter

must pass

the pipe fillet weld test per

gW-452.4 which requires

both macro

and fracture test to be per-

formed.

The

inspector

noted

however,

that

the qualification

records

showed results for the fracture test only and the macro

tests protion of the test

had been omitted and marked "N/A'.

The

inspector discussed this matter with the licensee's

representative

who stated that the welder had previously taken

an open butt test

on WPS-43 which qualified him for fillet welds under this

WPS and

that the fillet weld test

was

a site imposed requirement.

However

the inspector stated that their decision to require the welder to

-4-

take the fillet weld test

on

a one-half inch pipe size invokes

the test

requirements

presribed

by gW-452.4 which are fracture

and

macro tests.

The inspector

stated

that in this

case,

the

code contains

no provisions for selecting or taking exceptions

to

one of the

two tests listed in table

gW-452.4.

Consequently,

failure to perform both tests

appeared

to be contrary to code

requirements.

These findings were discussed

with the licensee

who concurred

and

agreed

to take the necessary

corrective action to rectify this

problem.

These findings represent

two (2) examples of failure to

follow code and/or procedural requirements,

which is in noncompli-

ance with Criterion V of Appendix B, to 10 CFR 50.

This apparent

noncompliance

was assigned

item number 389/79-07-01.

d.

Control on Preheat

and Interpass

Temperatures

As stated in paragraph

3 above the inspector

reviewed procedure

SgP-42

"Control of Heat Treatment"

and discussed its contents with the licensee

representative.

'

With regards

to preheat

methods,

controls

and interpass

temperature

checks.

The inspector noted that the aforementioned

procedure did not

address

these

areas.

The inspector

stated

that

such

areas

as

(1)

frequency of interpass

temperature

checks

and methods to be used,

(2)

application of preheat

(3) control and maintenance

during interrupted

welding needed to be addressed

either in the new procedure or elsewhere.

The licensee

agreed

to look into this matter further.

The inspector

stated that this would be identified as unresolved item 389/79-07-04.

6.

Reactor

Coolant

I,oop Piping - Welding Procedure Specification

and equality

Assurance

Procedures

n'0

The licensee's

"equality Procedures"

and

gP 2.4 "Preparation

and Revision of

equality Instructions",

establish

methods

to be followed for the approval,

development,

distribution

and control of quality procedures

(gP)s

and

quality instructions

(gl)s.

gP 9.1 "Control of Special

Processes

for

Construction", delineates

the requirement for the control of special processes

which include welding, heat treatment

and

NDE during plant construction.

In addition, this document assigns

specific areas of responsibility at the

various levels of site management

with regards to the aforementioned special

processes.

Requirements

control, qualification and documentation

of weld

procedure

specification

(WPS)

and other special

processes

are established

thru procedure

ASP-6 Rev.

0 "Control of Special Processes".

Section IX of

the ASME Code 1977 Edition with Summer 1978 addenda controls the qualification

of WPS applicable to reactor coolant loop (RC) piping.

Four randomly selected

WPS involving shielded

metal arc,

(S11AW)

and

gas

tungsten

arc

(GTA) processes,

or

a combination of both, were selected for

review.

These were identified as follows:

WPS-6 Rev

1

WPS-24

WPS-50

WPS-68

Process(es)

GTA/SHAM

GTA/SHAM

GTA/SHAW

GTA

Performance Quality

Records

(P R)

88-4.2-6

11-2.4-24"1

88-4.2-50

18-.75-68

Each of the above WPS(s)

and their supporting PQR's were reviewed to ascertain

whether essential,

supplementary

and/or nonessential

variables

including

thermal treatment

were consistent with code requirements;

whether

WPSs were

properly qualified and their supporting

PQRs were accurate

and retrievable;

whether all required

mechanical

tests

had

been

performed

and the results

met minimum requirements;

whether the

PQRs

had been reviewed

and certified

by appropriate

personnel

and,

whether

any revisions

and/or

changes

to

nonessential

variables were noted.

Within the areas,

the inspector noted that in certain instances

the recorded

information concerning essential/nonessential

variables

on the

PQRs

was not

consistent

with paragraph

QW-201.2 of ASHE section IX.

This requires that

specific facts

involved in qualifying a

WPS be recorded

on

a

PQR.

The

inspector

stated

that in several

instances

PQRs did not show variables

as

specific quantities but rather

as ranges, e.g., volts, amps, preheat temper-

ature

and,

in other

cases

some

variables

(nonessential)

were

omitted.

These

included

amps/volts

QW-404.6,

shield

gas

flow QW-408.3,

preheat

QW-406.1 and .2, shield gas

cup size QW-410.3, joint design and the thickness

of weld metal deposited

by each process

when

a combination of processes

were involved QW-201.2,

and

3.

In discussing this matter,

the licensee's

representative

stated that in the case

where variables

were given in terms

of ranges

on the

PQR, both ends of the range

had been

used for the qualifi-

cation of the procedure

and that records

were available for varification

purposes.

The inspector stated that since the PQR is the supporting document

for qualification of the

WPS, it should contain all the specific details

used in the

WPS qualification as stated in the code.

This would preclude

the

need to retrieve supporting

records

whose retrievability could not be

assured

over the time span these

records

must be retained.

The licensee's

representative

agreed to take appropriate corrective action on the matter.

Failure to include all pertinent information in the qualification records

of VPSs is in nonconformance with Criterion XVII of Appendix B, to

10 CFR 50.

This apparent

noncompliance

was assigned

item number 389/79-07-02.

Other Safety Related

Piping,

Welding Procedure

Specifications

and Quality

Assurance

Procedures

The procedure

review and inspection results of paragraph

6 above also apply

to safety-related

pipe welding in that safety related piping will be welded

under the

same control procedures

as the procedures

used for reactor coolant

pressure

boundary piping.

The welding

code

referenced

in paragraph

6

applies,

except that subsections

NC and

ND are applicable in lieu of subsec-

tion NB.