ML17341A859

Responds to NRC 811202 Ltr Re Violations Noted in IE Insp Repts 50-250/81-26 & 50-251/81-26.Corrective Actions: Superintendent & Welders Reminded to Plug Warmers in

ML17341A859
Person / Time
Site:	Turkey Point
Issue date:	01/11/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17341A858	List: ML17341A859
References
L-82-10, NUDOCS 8202050358
Download: ML17341A859 (18)

Text

P.O. BOX 529IOO MIAMI,FL 33152 USNRG. P.,E,GION:~

ATLANTA, GEQRIgtA ~iri,A~

FLORIDA POWER & LIGHT COMPANY IIp JIINlo P l:- 5 January 11, 1982 L-82-10 Mr. James P. O'Reilly Regional Administrator, Region I I U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Re: Turkey Point Units 3 8I 4 Docket Nos. 50-250, 50-251

~IE Inn ection Report 81-26 Florida Power 8I Light Company has reviewed the subject inspection report and a response is attached.

There is no proprietary information in the report.

Very truly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/PLP/ras cc: Harold F. Reis, Esqui re

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ATTACHMENT RE: TURKEY POINT UNITS 3 5 4 DOCKET NO. 50-250, 50-251 IE INSPECTION REPORT 81-26 FINDING N:

'1 10 CFR 50, Appendix B, Criterion IX, as implemented by paragraph 9.1 of the accepted guality Assurance Program, requires measures be established to assure that special processes including welding are controlled'nd accomplished in accordance with procedures. CBSI procedure RTl, revision 4, "Radiographic Examination Procedure", paragraph 5.5. 1, requires the lead letter "B" to be placed on the back of the film holders during radiography. CB8I Nuclear guality Manual for ASME Section III Products, Revision 4, Construction, Section 8 Welding, paragraph 8.2.2. 1, requires all welding materials to be stored in locked storage areas or locked electrode ovens. BPC Welding Standard WFMC-l, dated April 15, 1981, paragraph 4.5.6, requires portable rod warmers to be continuously heated or energized during use except duri ng transit time.. BPC Welding Standard WFMC-l, paragraph 4.5.6, further requires low hydrogen'ow alloy electrodes to be used di rectl'y from portable rod

- warmer s.

Contrary to the above, on November 4-5, 1981, adequate measures had not been established to assure that special processes were controlled in that:

1. The Lead Letter "B" was not attached to the backr of the film holders during radiography of welder qualification test assemblies.

2. Type E8018 wel-ding el ectrodes were stored in an unguarded un I ocked el ectrode oven.

3. Cold flux covered welding electrodes were left for approximately eight hours in an unenergized portable rod warmer. j

4. Type E7018 low hydrogen, low alloy electrodes were used from an open bucket adjacent to an energized rod warmer.

RESPONSE

Item l.

1. FPL concurs with the finding.

2. The lead lined box was being used for x-ray shots of welder qualification sampl es and i t had been f proven to be ef i ci ent in el iminati ng backscatter. The box is completely lead lined especially for this use.

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3. No corrective action was taken. Several test "shots" were performed for review by the NRC representative, which had been loaded with lead letter "B". No backscatter was detected.

4. Al 1 code x-rays of wel ded seams and wel der qual i ficati on x-rays, are "shot" with the lead letter "B" attached to the backside of the cassette. FPSL g.A. has witnessed several of these shots to verify this.

5. The program was in full compliance on 12/4/81.

Item 2

1. FPL concurs with the finding.

2. Personnel had removed the lock on the storage oven in order to put it on a storage oven in the contai nment building. The attendant was in the process of obtaining a replacement lock from the gA office when the

'bservation was made.

3. Personnel were informed to pay more attention to lost locks. No further i nstances of such lack of control have occurred.

4. Additional locks were purchased and stored inside the containment for use if a lock gets misplaced or damaged.

5. The program was in complete compliance by the afternoon of ll/5/81.

Item 3

1. FPL concurs with the finding.

2. The reason for the violation is that when the welder arrived at his work station, he neglected to plug his rod warmer in. He was called out of the containment to do other work and did not return, leaving the rod can unplugged the entire shift.

3. The responsible superintendent and welder were reinstructed on weld rod control requirements.

4. All welders are reminded to plug their warmers in. When the situation warrants further action, the welder's qualification will be rescinded and he will be terminated from the job.

5. We consider that the program is in full compliance, and that this was an isolated incident.

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Item 4

1. We agree that Type E-7018 electrodes were found as described, however, we do not agree that it is a violation. The electrode under consideration is Type E-7018. This electrode is a low hydrogen rod, but it low alloy rod; therefore, this requirement does not app'ly because low is not a

~yrogen rods are not required to be issued in a rod warmer, as are low hydrogen, low alloy rods.

Secondly, Bechtel Specification WFNC-l, Rev. 0, Table 1, required 'low hydrogen Type E-7018 electrodes to be issued in a container in accordance with Note 1 of Table 1. The maximum time out of the holding oven is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

We issue all covered rods in a portable rod warmer even though this is not a specification requirement. It is an acceptable practice for a welder to transfer a portion of his rod to a container, other than a rod warmer, and use the rod from that container during welding. Since our working shifts are less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each and the welder returns his rod and rod can at the end of his shift, it is not likely that the rod would be out of an oven for greater than the specification limit of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2.~ Response is not required since we do not agree that Part 1 of the finding is a vi ol ati on.

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3. No action is considered necessary for correction.

4. No corrective action is considered necessary to prevent recurrence.

5. The program is considered to be in full compliance.

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FINDING B 10 CFR 50, Appendix B, Criterion XIII, as implemented by paragraph 13.1 of the accepted guality Assurance Program, requires measures be established to control the handling, storage and preservation of materials and equipment in accordance with work and inspection procedures to prevent damage or deterioration.

Contrary to the above, on November 3-6, 1981, measures were not established to control the storage and preservation of materials and equipment in that the following were noted:

1. Approximately five examples of riggi ng fr om or scaffolding supported by installed safety related cable trays or piping.

2. The licensee has no documented procedures to control rigging from or scaffolding on safety related materials or equipment.

3. Numerous examples of extraneous markings and various types of tape applied to the surfaces of safety related components, tanks and piping.

4. The licensee has no documented .procedure to control surface applied substances for safety related stainless steel applications to prevent deterioration.

Items 1 and 2

1. FPL concurs with the finding.

2. At the time of the NRC visit, scaffolding was being installed without contacti ng the contractors Field Engineering group. There was no set policy or procedure for review of exi sti ng systems used to rig from or scaffold off of installed components to insure they were adequate to support the additional load.

3. A wal kdown of scaf folding and rigging was performed by the Field Engineering group to insure equipment, piping and cable trays were not overloaded. Field Engineering has judged that no equi pment, piping or cable trays were over loaded.

4~ Supervision was instructed to review any scaffolding attachments to existi ng equipment, piping and cable trays with Field Engineering prior to rigging and scaffolding. Periodic walkdowns will be done by Field Engineering to insure that any scaffolding attachments to existing equipment, piping and cable trays does not overload the equipment, piping and cable tray

5. With the implementation of Item 4 above, the program is now in full compliance.

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Items 3 and 4

1. FPL concurs with the finding

2. Uncontrolled tape and marking pen ink used during construction/maintenance were not properly removed after use.

3. Construction supervi sion will be instructed at the end of each outage to remove all such tape/marking pen ink from stainless steel surfaces as per Engineering direction.

4. A site procedure ASP-15, "Control of Expendable Products", was in the review stage during the NRC visit. As of the date of this letter, in the final signature cycle.

it is

5. The program will be in full compliance as of February 12, 1982. Existing tape/ink will be removed as per Engineering di rection before the start up of Unit 3.

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Par agraph (a) (1) of 10 CFR 50.55a requi res structures and components be fabricated and inspected to quality standards commensurate with the importance of the safety function. ASME B and PV Code Section IX has been identified as the applicable code for welding procedure specifications. Paragraph gW.201.1 of ASME Section IX requires that welding procedure specifications list specific facts involved in qualifying a procedure specification.

Contrary to the above, on November 4, 1981, structures and components were not fabricated to quality standards commensurate with the importance of the safety functions in that the code required specific facts (non-essential variables),

gW-410. 5 method of initial interpass cleaning; gW-410. 10 single electrode or mul ti pl e el ect rode; gW-410.15 el ect rode spaci ng; gW-410. 25 manual, semi-automatic or machine-atomatic wel ding; and gW-410.26 peening; were not addressed in welding procedure specifications.

RESPONSE

1. FPL does not agree with the finding: the non-essential variables delinated in the finding are either incorporated by refer ence in the procedures reviewed by NRC or not applicable as explained below.

1. ASME Section IX, paragraph gW-410.5-a change in the method of initial and interpass cleaning (brushing, grindi ng, etc.) affected Welding Procedure Specifications - Pl-AT-Lh(CVN), P3(G3) Pl-AT-Lh(CVN) and P 1-A-LH.

Response

The welding procedure specifications contain the statement, "This welding procedure specification must be used in conjunction with the General Welding Standard GWS-FM". By means of this statement, the referenced general welding standard becomes a part of the welding procedure specification. This results in many non-essential variables being found in the general welding standards. GWS-FM, Revision 4, paragraph 4.1.3 requires that filing, brushing or grinding be performed prior to fit-up (initial cleaning) and welding (in-process cleaning); additionally this paragraph is supplemented by paragraph 4.4.8 of GllS-FM, which states, "Each completed weld head shall be cleaned essentailly free of slag, heavy oxide, glassy silicate deposits, or other foreign material before depositi ng successive beads.

Conclusion The non-essential variable listed in ASME Section IX, paragraph gW-410.5 ~ is addressed in General Welding Standard GWS-FM.

2.~ ASME Section IX, paragraph gW-410.10 - A change from single electrode to multiple electrode, or vice versa, for machine or automatic welding only.

4 ASME Section IX, paragraph gW-410e15 - A change in the electrode spacing for machine or automati c wel di ng only. Affected Wel ding Procedures Specifications - Pl-AT-Lh(CVN) and P3(G3) Pl-AT-Lh(CVN).

~Res onse The inspection report quotes the paragraph from ASME Section IX out of content. Paragraphs gW-410e10 and gW-410e15 do not apply to the manual wel ding process, only to machine or automati c wel ding; therefore, the variables are not applicable to these welding procedures.

3. ASME Section IX, paragraph gW-410.25 - A change from manual to semi-automatic to machine automatic welding and vice versa.

Affected Welding Procedure Specifications - Pl-AT-Lh(CVN), P3 (G3) Pl-AT-Lh(CVN) P43A and Pl-A-Lh.

~Res onse The four referenced welding procedure specifications concern the use of the manual shielded metal arc process and the manual gas tungsten arc process. This is evident from the date on the WPS's. The inspection report therefore, quoted the referenced paragraph from ASME Section IX out of context, since semi -automatic or machine automatic welding are not applicable.

4. ASME Section IX, paragraph gW-410.25 addition or deletion of peening.

Affected Welding Procedures Specifications -Pl-AT-Lh(CVN), P3 (G3) Pl-AT-Lh(CVN), P-43A and Pl-A-Lh.

~Res onse The use of peening i s not used on Bechtal pr ojects. In the event that peeni ng was needed, then the applicable wel di ng procedure specification or general welding standard would be revised to permit peening. If peening had been used to qualify the welding procedures, it would have been included in the procedure qualification records and the welding procedure specification.

Based on the above, we consider that there are no deficiencies in the referenced welding procedure specifications with respect to inclusion of non-essential variables. These welding procedure speci fications in combination with the applicable general welding standards are in full compliance with ASME Section IX requi rements.

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STATE OF FLORIDA )

) st COUNTY OF DADE )

Robert E. Uhri, being first. duly sworn, deposes and says:

That. he is Vice President ~

of Florida Power 6 Light. Company, the herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct, to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Robert E. Uhrig Subscribed and sworn to before me this I/ day of 19~/

,,NOTARY .PUBLIC, State of Florida

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My COmmiSSiOn

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'y in nd eXpireS:

for the County of Dade, Notary Public, State of Porida ct Large CommL+alon Expiroa October 30, 1SS3 Goiidad tbru Mayiiard aoiiding Agency

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