ML20011A589

Final Deficiency Rept Re Rejectable Indications on Essential Cooling Water Sys Welds,Initially Reported 800312.All Welds Will Be re-examined,repaired or Replaced,As Required by Piping Acceptance Criteria

ML20011A589
Person / Time
Site:	South Texas
Issue date:	10/23/1981
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
10CFR-050.55E, 10CFR-50.55E, ST-HL-AE-733, NUDOCS 8110290150
Download: ML20011A589 (4)

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The Light COIIIpMy llouston 1.igining & Power I 0. Ihn 1700 llouston.'lexas e soul (713)228-9211 October 23, 1981 ST-HL-AE-733 SFN: V-0530 ._

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l v' OCT?6\98I U Hr. Karl Seyfrit Director, Region IV fb J"~

ff' Nuclear Regulatory Commission -a

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Dear Mr. Seyfrit:

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South Texas Project -

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'o Units 1&2 _

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Docket Hos. STN 50-498, STN 50-499 ca , ,,f 'O ISS; .

Final Report Concerning Welds in the :4'$fjgug,,

Essential Coe)ing Water System On March 12, 1980, pursuanc to 10CFR50.55(e), Houston Lighting'a, Pgwer\

Company notified your office of an item concerning rejectable indications'on the radiographs of the girth welds in the Essential Cooling Water System oiping.

Our final report regarding this item is attached.

If there are any questions concerning this item, olease contact Mr. Michael E. Powell at (713) 676-8592.

Very truly yours, Y Y,

. ,Jr.'

Execu ve Vice resident ,

RRH/amj Attachment C of[Ohhg m &

II nnton 1.ighting & Power Company ec: J. H. Goldberg October 23, 1981 J. G. Dewease ST-HL-AE-733 D. G. Barker SFN: V-0530 C. G. Robertson Page 2 Howard Pyle R. L. Waldrop H. R. Dean R. A. Frazar D. R. Beeth J. D. Parsons J. W. Williams J. W. Briskin J. E. Geiger STP RMS H. S. Phillips (NRC)

J. O. Read (Read-Poland, Inc.)

M. D. Schwarz (Baker & Botts)

R. Gordon Cooch (Baker & Botts)

J. R. Newman (Lowenstein, Newman, Reis, & Axelrad)

Director, Office of Inspection & Enforcement Nuclear Regulatory Commission Washington, D. C. 20555 R. L. Range /G. W. Muench Charles Bechhoefer, Esquire Central Power & Light Company Chairman, Atomic Safety & Licensing Board P. O. Box 2121 U. S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D. C. 20555 R. L. IIancock/G. Pokorny Dr. James C. Lamb, III City of Austin 313 Woodhaven Road P. O. Box 1088 Chapel Hill, North Carolina 27514 Austin, Texas 7876/

J. B. Poston/A. c.onRostnberg Mr. Ernest E. Hill City Public Service Beard Lawrence Livermore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P. O. Box 808, L-46 Livermore, California 94550 Brian E. Berwick, Esquire William S. Jordan, III Assistant Attorney General Harmon & Weiss for the State of Texas 1725 I Street, N. W.

P. O. 7:ox 12S43 Suite 506 Capitol Station Washinton, D. C. 20006 Austin, Texas 78711 Lanny Sinkin Citizens for Equitable Utilities, Inc.

Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn 5106 Casa Oro Route 1, Box 1684 San Antonio, Texas 78233 Brazoria, Texas 77422 Jay Gutierrez, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Revision Date 10-20-81

FINAL REPORT CONCERNING WELDS IN THE ESSENTIAL COOLING WATER SYSTEM.

OCTOBER 21, 1981 i

Summary [

On March 12, 1980, Houston Lighting'& Power Company (HL&P) under the requirements of 10CFR50.55(e) notified your office of an item concerning rejectionable indications on radiographs for the Essential Cooling Water  ;

System (ECW) piping. A review of the radiographs had identified rejectable indications for ECW piping which had been previously accepted. All accessible ECW piping welds will be subjected to a 100% visual, liquid penetrant and radiographic examination. Welds identified as being rejectable will be replaced or repaired as required.

Description of the Incident Aluminum-bronze ECW piping has been designed and fabricated to meet the  :

provisions of American Society of Mechanical Engineers (ASME) Boiler and i Pressure Vessel Code,Section III, Division 1, Subsection ND,' Class 3  :

Components, which specifies final examination of welds by the liquid - '

penetrant method (PT examination). During the initial stages of construction a decision was made to perform supplemental weld inspection beyond PT examination through weld radiography (RT) as a tool for evaluating welder t proficiency and weld quality. The requirements for weld inspection are t contained in a field construction procedure which also established acceptance criteria and the frequency of RT examination per welder. The acceptance criteria utilized was based upon ASME Subsection ND-5321.except that porosity restrictions were made more stringent.

Based upon a surveillance of radiographic testing it was determined that the radiographers did not fully understand the RT acceptance criteria. A.

re-review of previously inspected RT films was initiated which resulted in a determination that saany of the previously accepted films contained code-rejectable indications. This condition was identified through the issuance of a non-conformance report and on March 12, 1981, HL&P notified your office of this item of concern in accordance with the requirements of '

10CFR50.55(e).

Corrective Action ,

As previously identified a re-review of the RT film was conducted of the  !

ECW piping welds. This re-review included an examination by a NDE Level III of all RT film previously reviewed and accepted by NDE Level II interpreters.

The film was 61so reviewed by an independent welding task force under the NRC.

Order to Show Cause Item 3(a). The film re-evaluation resulted in the identification of various generic problems such as poor film quality, rejectable indications, improper surface conditions and the use of incorrect i radiographic techniques.

1 Earlier interim reports had identified twelve (12) ECW pipe welds which were considered to be inaccessible for purposes of re-;xamination. These welds were located as:

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1) Six (6) welds - buried approximately six (6) feet in the ground under the Unit 1 Diesel Generator Building. These welds are located approximately three (3) feet in from the edge of the Diesel Generator Building;

2) Six (6) welds - buried ap.roximately six (6) feet beneath the Essential Cooling Pond embankment near the Intake and Discharge Structures.

A decision has been reached on the project to excavate these welds and re-examine them. Procedures have been prepared by Engineering and issued to Construction for the excavation of thase welds without compromising the integrity of the Essential Cooling Wt, 3r embankment.

All ECW piping welds will be re-examined and repaired or replaced as required by the project's ECW piping acceptance criteria. The schedule for completion of this program remains consistent with that which was provided in our transmittal of November 19, 1980 concerning " Restart of Safety-related ASME yelding."

Corrective Action In order to prevent a recurrence of this deficiency, establishment and implementation of the following actions has been initiated and completed:

1) An NDE Level III examiner ,%s assigned to the South Texas Project site to evaluate radiograph er, radiographic techniques, and the radiographic NDE procedure.

2) All NDE Level 11 examiners were given additional training and were recertified consistent with Society of Nondestructive Testing requirements.

3) The radiographic examination procedure was revised to clarify RT acceptance criteria and to require NDE Level III examiner review of RT film interpretation results until a high level of confidence is l established in NDE Level 11 performance. This latter requirement l was met in February,1981.

4) A procedure to control the handling and processing of RT film was issued by Quality Assurance.

5) The overall training program was revised to further define tra'ning and certification criteria for NDE personnel.

6) An NDE Superintendent, fully certified, has been assigned to direct NDE activities and NDE personnel.

Safety Evaluation The code rejectable indications are not anendable to an evaluation relative to a significant safety hazard. Corrective action assures that the final configuration is in conformance with code requirements prior to use.

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