IR 05000324/1992047

Insp Repts 50-324/92-47 & 50-325/92-47 on 921228-31.No Violations Noted.Major Areas Inspected:Welding Program & Observe in Process Welding Activities

ML20127K076
Person / Time
Site:	Brunswick
Issue date:	01/15/1993
From:	Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K057	List: IR 05000324/1992047 ML20127K056
References
50-324-92-47, 50-325-92-47, NUDOCS 9301260033
Download: ML20127K076 (8)

Text

,

-

f UNITED ST ATES

/e?"*'% g%,

.

_

NUCLEAR REGULATORY COWAlsslON

. [- n HEClON 8 S

• [$

'*

101 M AlllEYT A slit [ET.'N, AT L ANT A, GE0nGt A 30323

%y* . . . + j$

siAN I 9 m Report Nos.: 50-325/92-47 and 50-324/92-47 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50 324 License Nos.: DPR-71 and DPR-62 facility Name: Brunswick 1 and 2 Inspection Conducted: December 28-31, 1992 Inspector: 8 - f6 bi /r / h f3 J . L . CB ey , 'Jr . U

// ' ~D i e Signed-Accompanying Personnel: M. L. Marshall Approved by: [g8 L M Io / /h'/l

'

J . J . fi e,ChieC ' Date HTgned~

MaterialsandProcessesSection/

Engineering Branch Division of Reactor Safety SUMMARY Scope:

This special, announced inspection _was conducted to independently evaluate the licensee's welding program, observe in process welding activities,'and revie corrective actions taken by the licensee as a result of their " work stoppage" of welding activities on December 17 and 18,1992, because of repetitive programmatic welding discrepancie .

9301260033 930119 PDR ADOCK 05000324 0- PDR' .

.

-.

!

'

Results:

The inspector's review of welding activities and inspection findings identified by the licensee revealed that programmatic weaknesses in welding are apparently due to inadequate supervision of the welding processes, weaknesses in material control procedures, failure to follow procedures, and lack of formai training on procedure requirements for welders. Welder training at Brunswick is entirely based on performance. No training on the procedures which control materials and processes is given. The licensee is in the process of identifying the scope of their problem in the area of weldin Adequate controls have been taken by the licensee to prevent in-process welding errors. The inspector also discovered that immediate corrective actions and management emphasis on the reported fi.idings appear to have __

improved overall welding activities. No in process welding was found deficient by the inspectors. One Unresolved item No. 50-325, 324/92-47-01,

" Material Control Weaknesses in Welding Test Shop Issue Room", was reporte No violation or deviation was identifie F

-

_ _ _ _ _ _ . . . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ __ _ _

, .

--

__ _

REPORT DETAILS Persons Contacted Licensee Employees

• Alicn, Sup(rvisor, Storeroom issut H. Beane, Manager, Quality Control M. Bradley, Manager, Nuclear Assessment Separtment

• J. Brown, Unit 2, Plant Manager

• S. Callis, Licensing Engineer

• T. Eason, Quality Control Supervisor

• H. Guthrie, Materials Engineer, Nuclear Engineering Department

• J. Kelly, Manager, Podifications and Support R. Morgan, Vice President (Acting), Brunswick Nuclear Plant

• P. Macser, Manager, Nuclear Assessment Department

• Spry, Project Welding Engineer

• S. Tabor, Regulatory Compliance

• E. Willett, Manager, Outage Managerment and Modifications NRC Resident inspector (s)

/. Byron, Resident lnspettor

• Nelson, Resident inspector

• Attended exit interview Review of Welding Activities Units 1 & 2 (55050)

Background:

In the second quarter of 1992, the licensee's Quality Control organization developed a quality verification procedure entitled

" Support of Self-Assessment and Field Surveillance Prograr..s" and started to perfor;n surveillances of field activities. The surveillances were successful in identifying discrepancies in the welding program. The deficiencies included welders working to verbal instructions, inadequate welding controls, improper welding techniques being used, and inadequate contru of welding rod materials. On August 17, 1992, the problem was observed to effect in process work in that; a welder improperly used stainless steel rods on a copper - nickel 2B Residual Heat Removal Service Water Booster Pump Discharge flange and immediately observed the weld crac The NRC resident inspector held discussions with the corporate quality control manager and expressed his concern for the findings identified in the welding area. The quality control manager subsequently obtained the services of an outside consultant to independently assess Brunswick's site welding program. The assessment identified weaknesses in the areas of welder training on procedural requirements, improper brazing procedure qualification, weaknesses in material control procedures, control of welding materials, iniproperly filling out of Weld Requisition i

_ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _

.

l

Reports, and welders not qualified for the process or Welding Procedure Specification which they were assigned. Many of the findings were similar to those previously identified by the Quality Control surveillance ;

On December 15, 1992, a Brunswick welder used a carbon steel weld rod to weld a stainless steel clip to a carbon steel support tube. This was .

done in the welding shop. The error was caught by the welder when he noted a " golden tint" to the base metal. The welder's foreman also recalled two such clips had already been installed in the Unit 1

,

drywell. These clips had been inspected and accepted by quality control. The error was discovered to be that engineering _had

incorrectly called for-the use of the carbon steel rod. On December 17, 1992, the licensee issued a "stop work" order on all welding activities until in-process work packages could be reviewed to ,

insure that the packages contained the correct instructions, correct

'

materials were being assigned to be used, and that the welders were qualified for the Welding Procedure Specification assigne On December 28, 1992, the inspector arrived on site to evaluate the licensee's corrective measures taken in response to their "stop work" order of welding activities which was initiated on December 17 and then  ;

concluded on December 18, 1992. The inspector's objective was to determine, by review of the welding program procedures, interviews with I cognizant managers, examination of welder training activities, audit of weld material issue stations, direct observation of in-process welding activities, verification of production equipment adequacy, and review of corrective measures taken by the licensee for the reported discrepancies, that established quality control systems are adequate for the production of sound welds, Review of welding program The inspector's first step in examining the implementation of the licensee's welding program was to review the findings addressed in the consultant's October 2, 1992, Assessment Report and his

followup report dated December 3, 1992; review quality control surveillance reports; and review licensee Adverse Condition Reports on welding from 1990 to the present. The inspector then reviewed the welding program instructions which are contained in

!

CPal.'s " Corporate Welding Manual". This manual contains the requirements and guidelines for qualification of welders and the generic welding program procedures necessary for compliance with the ASME Boiler and-Pressure Vessel Code; ANSI B31.1, Power

, Piping and AWS D1.1, Structural Welding Code-steel. The i l inspector limited the review of the Corporate Welding Manual .to L

the procedures listed below:

,

-

-

<

-

i I

'- _ . - - . . .- .-.-;_------.--- - _ _ _ _ _ - - _ _ - - - - - - - - - - - - - _ - - - - - - - - - - -

.

Procedure Not 11th NW-01 Qualification of Welding and Brazing Procedures NW-02 Qualification of Welders and Welding Operators NW 03 Welding Material Control NW 04 Permanent Marking of Plant Materials, Components, and Weld Joints NW-05 General Welding Procedure for Structural Welding NW 06 General Welding Procedure for Carbon and Low Alloy Steels, Stainless Steels, and-Nonferrous Alloys The inspector then held discussions and reviewed applicable data with managers cognizant over specific welding issues in order to determine what corrective actions had been taken on the consultant's discrepant items, what actions were bning taken by the licensee to ensure that in process welding was now conducted in accordance with approved procedures and that actions were being taken by the licensee to determine the extent of the welding problems on previous wor The above discussions and reviews revealed the following:

Welding engineering has taken action to correct the discrepancies identified by the consultant. In addi_ tion the m m ger of welding engineering has hired another consultant to independently review the findings and to offer solutions for correction of the causes of the discrepancies,

• In order to assess in process welding activities management

,

has issued instructions that all welding packages be

. reviewed that were previously processed but not completed or l

'

closed.out to ensure that welding; instructions are correct and that material is correctly identified (this review also included-packages that have not been worked to date). Afte a review of approximately 168 of 308 weld packages no problems have been found that would have allowed the -

i incorrect weld material or an unqualified welder to-be use Other documentation problems were discovered however.

'

l The Manager of Outage Management and Modifications stated l

that structural drawings will be reviewed, from August 1, 1992, through the present, in order to investigate welding engineering instructions on completed installations. The L

t

---_______ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ - _ - _ _ _ _ _ - _ - - _ _ _ _ - _ _ _ _ _

!

t

basis for only examining structural drawings is dependent on not finding any pipe drawings with incorrect Weld Procedure Specifications assigned. piping drawings receive a more vigorous material scrutiny than structural drawings due to piping specification drawing criteri i

A draft letter was also reviewed by the inspector addressed .

',

from the project engineer which formally requested that maintenance staff personnel perform a review of Work Requests and Job Order he pur > ose of this review is to determine if a problem exists wit 1 the material identity of catalog items. These items may be used in pipe or structural components. Due to the use of a catalog part without the base material being identified on the drawing an incorrect Welding Procedure Specification was assigned in Modifications and Suppor *

CP&L's Nuclear Assessment Department has scheduled a eight man two week audit of welding starting January 4th thru 15th,1992, to determine the extent of the welding problems at Brunswick. The inspectors held discussions with the audit team leader and reviewed the inspections attributes for this audi ,

• The Manager of Outage Management and'Hodifications stated '

'

that, a manager in welding from the Harris facility was also being assigned to the' Brunswick site to assess programmatic welding issues for the next three months and to implement corrective actions on findings obtained from the Nuclear Assessment Team's audi The above reviews and discussions revealed that management at Brunswick recognized the seriousness of the reported findings and are activitely involved in identifying the scope of their problems and taking appropriate action to prevent there recurrence. Long term corrective action such as welder training and revision of procedures will be addressed when the audits are completed.

, Observation of in process welding and material control at weld I issue stations As a result of the holidays there was no-welding being performe in the weld test shop and field welding activities were also some what curtailed. However, the inspector did audit the following ,

in-process welding in the outside fabrication shop, the motor operated valve shop, and the hot machine shop:

,

-~r v. -----+ - n-.,=v,-rv..-+%,-e-, + <,c.~ ow e t- - ---'-*-e w-*uv-- v---=- e w e- w-e v - ~ ~e* - - *

. <

&

[omponent Audited Weldina Instructio2 Welder Conduit Support Modification 92073 D-18 j Low Range Monitor field Traveler Document D 28 Support for llWV 92 073-f015 Valve Bonnet Repair Work Request No. BGNB2 Vendor j ISV 821 f0280 MSIV for the above welding activities, welder qualification, materials,

'

equipment, and instructions were verified to be satisfactory by the inspecto '

In addition to the above audits of work activities the inspector also examined rod issue stations in the welding test shop, the '

fabrication shop, and the central tool room. Welding materials -l were found to be satisfactory in the fabrication shop and the central tool room. However, wire brushes, grinding wheels,-

flaaper sanders, deburring tools, and files were found not to be .'

mar (ed with white paint for use on stainless steel as required by procedure NW 06, paragraph 4.5.5 in the weld test shop issue roo The inspectors also discovered that spools of weld wire with different heat numbers (llt# A11969 and Ht# 412S7231, and Ht#

569828 and Ht# 58A2688)were mixed together in the weld test shop issue room. Although, this finding was not specifically prohibited by Procedure NW 03, labels on the wire spools were deteriorating and could subsequently become mixed. The above >

findings were reported as unresolved item 50-325,324/92-47-01, '

" Material Control Weaknesses in Welding Test Shop Issue Room".

Discussions with the welding supervisor of the weld test shop also revealed that, welders received no training on material control procedures or any other procedure in the corporate welding manual, i Their training consists only of a performance test on the weld

'

procedure specification for which they are qualifying. This l weakness had also been identified by the consultant hired by CP&L.

l The inspectors discussed this finding with management who indicated that it would be addressed as part of the long term corrective actio Within the areas examined, no violation or deviation was identified

! Exit Interview The inspection scope and results were summarized on December 31, 1992, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection result Since the licensee is presently in the process of performing audits of i records and _ welding activities to identify the. scope of the weldin problem and taking the appropriate corrective action on findings as they I

l i______._____ __ _ _ _ _ _ _ _ _ . _ . .

. _ _ _ _ _ - _ - _ _ _ _ _

,

.

i Carolina Power & Light Co.

'

are found, the inspectors informed CP&L management that the inspector would perform a followup inspection the week of February 1, 1993, to ensure corrective actions are complete and effective. Proprietary information is not contained in this repor Dissenting comments were not received from the license (0 pen) Unresolved item fio. 50 325,324/92-47-01, " Material Control Weaknesses in Welding Test Shop Issue Room" paragraph _

-

-- . - - - - _ - _ _ _ . _ . _