ML20128K297
| ML20128K297 | |
| Person / Time | |
|---|---|
| Site: | Crystal River |
| Issue date: | 05/30/1985 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20128K270 | List: |
| References | |
| 50-302-85-23, NUDOCS 8507100538 | |
| Download: ML20128K297 (12) | |
See also: IR 05000302/1985023
Text
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. UNITED STATES
NUCLEAR REGULATORY COMMISSION
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REGION 11
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5
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101 MARIETTA STREET,N.W.
ATLANTA, GEORGIA 3030:1
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- Report No.:
50-302/85-23'
' Licen'see:
Florida Power Corporation
- 3201 34th Street, South
St. Petersburg, FL 33733
Docket'No.:
50-302
License No.:
Facility Name:
Crystal River
Inspection Co d
Sd:-
3 - 17
Inspector: Y-
' //*
41M/M6
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K.' P P
sor
D3te 5igned
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Approved by
J.
lake, Sec'; ion Chief
D' ate Signed
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Eg eering Division
iv sion of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection entailed 37 inspector-hours on site
- in the areas of licensee action on previous enforcement matters, modification
progress, welding (55050), and nondestructive examination.
' Results:
One violation was identified
" Failure to Follow WPS Requirements" -
paragraph 6e.
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8507100538 850606
DR
ADOCK 050
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
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- K. F. Lancaster, Manager, Site Quality Assurance (QA)
- J. G. Bradley, Manager, Site Quality Control (QC)
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- W. L. Rossfield, Manager, Site Nuclear Compliance
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- J. May, Welding Engineer
Other licensee employees contacted included construction craftsmen,
engineers, technicians, and office personnel.
OtherOrganizatio$
Fluor
- J. Warren, Project Engineer
- B. E. Drake, Engineer
NRC Resident Inspectors
- T. Stetka, Senior Resident Inspector
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- J. E. Tedrow, Resident Inspector
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- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized on May 17,1985, with
those persons indicated in paragraph 1 above.
The inspector described the
- are'as ' inspected and discussed in detail the inspection findings listed
below'; No dissenting comments were received from the licensee.
F
(0 pen) Inspector Followup Item 50-302/85-23-01:
" Weld Undercut Acceptance
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Criteria" - paragraph 6a
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'(Open) Unresolved Item 50-302/85-23-02:
"WPS Validity" - paragraph 6c(1)
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(0 pen) Inspector Followup Item 50-302/85-23-03:
"WPS Thickness Range" -
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paragraph 6c(2).
e
(0 pen) Violation 50-302/85-23-04:
" Failure to Follow WPS Requirements" -
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paragraph 6e
(0 pen) Inspector Followup Item 50-302/85-23-05:
" Post Weld Heat Treatment
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Program Inconsistencies" - paragraph 6f
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The licensee did not identify as proprietary any of the materials provided
-to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
(0 pen)UnresolvedItem 302/85-17-02:
" Control of Filler Material".
This item involves the staff's concern over the adequacy of the licensee's
welding filler material control program.
The welding filler material is
controlled by two procedures, M0P-412, " Control of Welding Consumables",
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Rev. O, dated March 27,1985, and MP524, " Control and Issue of Welding
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. Materials". MPS24 controls welding materials to the point of issue from the
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welding material issue station; M0P-412 controls welding materials in the
field from the point of issue from the welding material issue station to
deposition or. return to the welding material issue station where MP-524
takes over control.
The inspector reviewed both procedures, inspected the
welding material issue station, and observed field welding for compliance
with both procedures in the applicable areas.
The inspector found the
following areas of weakness in addition to these identified in IE Report
302/85-17:
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a.
The licensee has no documented program to control welding filler
material stubs.
b.
There is no statement defining what the authorizing signature on the
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welding material withdrawal order (WEW0) signifies.
c.
The procedures permit welding filler material issued to one welder to
be used by other welders not listed on the WEW0.
This is an open
invitation for the loss of control of materials.
d.
The procedures permit the WEW0s to be kept with the document packages
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and not with the material thus providing an additional area of possible
loss of control and identification of the material.
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The licensee agreed to address these issues in their review of both
procedures. This matter remains open.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions. New unresolved items identified during this inspection are discussed
in paragraph 6c(1).
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5..
Independent Inspection Effort
Modification Progress
The inspector ~ conducted a general inspection of protected area, auxiliary
-building turbine building and the containment to observe modification
progress and activities such as welding, material handling and control,
housekeeping and storage.
Within the areas examined no violations.or deviations were identified.
6.
Welding (55050)
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' The - inspector observed welding work activities as described below, to
determine whether applicable code and procedure requirements were being met.
The applicable codes standards and specifications are listed below:
The Final Safety Analysis Report (FSAR) indicates the -following codes as
applicable:
Reactor Coolant Pressure Boundary (RCPB? Piping United States of
America Standard (USAS) B31.7 February :.968 Draft
Power Pi)ing USAS B31.1.0 - 1967 (But Fabricated, tested and inspected
to USAS 331.7 - February 1968)
Structures American Institute for Steel Construction (AISC) 1963,
" Specification for Design, Fabrication, and Erection of Structural
-Steel for Buildings"
" Requirement Outline for Fabrication of. Steel Structures" R.0. - 2968 of
March 9, 1970, specifies that welding shall be performed in accordance with
American Welding Society (AWS) D1.1-69.
R0-2968 is the FPC document.that
provides requirements for fabrication of structures during construction at
- the Crystal River Unit 3 site.
The licensee indicated that the latest
edition of AISC code was used to write R0-2968, that revision of the AISC
code referenced AWS D1.1-69.
The licensee indicated the below listed codes are applicable for the present
outage:
P_ower Piping'- USAS B31.1.0-67
Structures - AWS D1.1-1980
Welder / Procedure Qualification -
American Society of Mechanical
Engineers Boiler and Pressure Vessel
(ASME B&PV) Code Section IX -- The
latest at the time of qualification
Section XI - 1980 Edition
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a.
Review of Quality Program
The inspector reviewed the below listed documents to ascertain whether
these documents had been approved by the licensee and whether adequate
plans and procedures had been established to assure that the specified
activities would be controlled and accomplished consistent with
commitments and regulatory requirements.
No.
Title
" Nuclear Quality Assurance Plan"
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" Crystal River Unit 3 Final Safety Analysis
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Report"
FPC-M0P-411, Rev. 1
" Control of Welding"
FPC-M0P-412, Rev. 0
" Control of Welding Consumables"
FPC-MP-525, Rev. 0
" Control of Welding"
FPC-MP-524, Rev. 0
" Control of Issue of Welding Material"
FPC-MTAP-W-010, Rev. 2
" Welding Procedure Specification Supplement"
FPC-MTAP-W-020, Rev. 2
" Qualification of Welding Procedures"
FPC-MTAP-W-030, Rev. 3
" Qualification of Welders"
FPC-MTAP-W-040, Rev. 2
" Storage Handling and Control of Welding
Consumables"
FPC-MTAP-W~041, Rev. 2
" Purchase of Welding Consumables"
FPC-MTAP-W-050, Rev. 2
" Control of Preheat, Interpass and Post Weld
Heat Treatment"
With regard to the inspection above, the inspector noted that M0P-411,
Section III, D60, and Section III, Table 1, require the user of the
procedure to know the direction of " primary tensile stress, shear,
compression" strettes to evaluate undercut.
The inspector discussed
this matter with the licensee and indicated that this type of
determination is beyond the abilities of the expected users of the
procedure. The licensee indicated they will reevaluate this matter and
provide undercut acceptance criteria definitive and determinable at the
user level.
This matter will be identified as inspector followup item
302/85-23-01:
" Weld Undercut Acceptance Criteria."
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b.
Base Material and Filler Material Compatibility for Welding
(1) The inspector reviewed the base and filler material combinations
employed to evaluate the suitability of application.
(2) The inspector reviewed the licensee's program for control of
welding materials to determine whether materials are being
purchased, accepted, stored, and handled in accordance with QA
procedures and applicable code requirements.
The following
specific areas were examined:
Purchasing, receiving, storing, distributing and handling
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procedures, material identification, and inspection of
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welding material issuing stations
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Welding material purchasing and receiving records for the
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following materials were reviewed for conformance with
applicable procedures and code requirements.
Type
Size
Heat / Batch No.
E-316
Insert
14548
ER-316
3/22"
40560
ER-316
1/8
51156
ER-308
1/8
98520
E-7052
Insert
421N3602
ER-70S2
3/32
065433
E-7018
3/32
33043
c.
Welding Procedure Specification
The following Welding Procedure Specifications (WPS) were selected for
review and comparison with the ASME Code:
WPS
PROCESS *
8/8-TT-022
76-003
8/8-TT-019
76-002
1/1-TS-Q
GTAW/SMAW
1/1-SS-022
76-008,76-006
- GTAW-Gas Tungsten Arc Welding
SMAW-Shielded Metal Arc Welding
The above WPSs and their supporting Procedure Qualification Records
(PQRs) were reviewed to ascertain whether essential supplementary
and/or nonessential variables including thermal treatment were
consistent with code requirements; whether the WPSs were properly
qualified and their supporting PQRs were accurate and retrievable;
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whether all required mechanical tests had been performed and the
results met the 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.
WPSs
are qualified in accordance with ASME Section IX, the latest edition
and addenda at the time of qualification.
(1) With regard to the examination above, a representative of the
licensee informed the inspector that some WPSs (specific WPS Nos.
not specified) were qualified by Catalytic, Inc. (CI) while they
had the contract for welding work at the Crystal River site.
Those procedures were not qualified by FPC.
Section XI, paragraph IWA-4500, requires that all welding be
performed in accordance witn WPS, which have been qualified by the
owner (FPC) or the repair organization.
It has not been
determined whether FPC or CI was the repair organization as
defined in IWA-4300(c)(1)-(3).
As FPC is the repair organization
for the currect outage, it remains undetermined whether those
unidentified WPSs are consistent with IWA-4300 and therefore valid
for this outage.
If FPC is determined to be the repair organi-
zation during the contract period with CI, then the procedures
were qualified consistent with IWA-4300 and are valid for this
outage.
Conversely, if CI is determined to be the repair
organization then the procedures would not have been qualified by
the owner (FPC) or the current repair organization (FPC) and
therefore not valid for this outage.
Once the issue of repair
organization during the CI contract period is resolved, the
validity of the CI qualified WPSs will be determined by the NRC
staff.
This matter will be identified as unresolved item 302/85-
23-02:
"WPS Validity"_.
(2) With regard to the examination above, the inspector noted that the
supporting PQRs listed on the below listed WPSs do not support the
full thickness range listed on these WPSs.
WPS
Section IX
Qualified
WPS
Thickness
PQR
Maximum
No.
Range
No.
Thickness
Thickness
1/1-SS-022 0.062"-1.500"76-008 &
0.562"
1.124"76-006
0.280"
0.560"
8/8-TT-022 1/16"-0.562"76-003
0.280"
0.560"
8/8-TT-019 0,062-0.562"76-002
0.280"
0.560"
The licensee indicated that they had other PQRs to support
1/1-SS-022, and they would amend all three WPSs to reflect
thickness ranges consistent with ASME B&PV Code Section III. This
matter will be identified as inspector followup item 302/85-23-03:
"WPS Thickness Range."
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d.
Welder Performance Qualification
(1) The inspector reviewed the licensee's program for qualification of
welders and welding operators for compliance with QA procedures
and applicable code requirements.
(2) The following welder qualification status records and " Records of
Performance Qualification Test" were reviewed:
Welder Symbol
PF-4
PF-13
PF-46
PF-362
e.
Production Welding
The inspector surveyed ongoing welding activities and selected typical
in-process operations representing different welding processes,
procedures and joint configurations for detailed review.
The weld
joints selected are listed below.
The review was conducted to
determine the following:
work conducted in accordance with a
" traveler"; welding procedures and drawings available; WPS assigned in
accordance with applicable code; technique and sequence are specified;
materials as specified; geometry as specified; fitup and alignment as
specified; temporary attachments consistent with applicable code; gas
shielding and purging as specified; preheat is as specified; technique
is as specified; welding electrodes are as specified and consistent
with the code; gas flow is controlled as specified; welding equipment
is as specified; interpass temperature is controlled and consistent
with the applicable codes; interpass cleaning and backgouging are
performed as specified; process control system has provision for
repairs consistent with applicable codes; weld re9 airs are conducted in
accordance with specified procedures; base metal repairs are properly
documented; welder identification; peening not done on root or final
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weld surface layer; and contractor / licensee has periodic welding
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equipment preventative maintenance program.
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Welds Examined
Wold Numbers
System
MU-85-128
Makeup
MU-85-129
Makeup
MU-85-42
Makeup
EF-85-110
Emergency Feedwater
With regard to the inspection above, the inspector noted the follcwing
on May 15, 1985, while observing inprocess welding on Field Weld
No. MU-85-128 being welded with WPS 8/8-TT-022.
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The torch. shielding gas was 12 cfh and the maximum bead width was
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7/16-inch; this is contrary to WPS 8/8-TT-022 which requires torch
shielding gas flow of 15 to 25 CFH and bead width for the filler
material size used of 3/8-inch maximum.
- The inspector- discussed- the above with the welder concerned and his
supervisor.
This discussion. concerned the importance of verbatim
compliance to procedures controlling activities affecting quality. On
May 16, 1985, the inspector observed the same welder, welding field
weld MU-85-129 welding with WPS 8/8-TT-022.
The inspector made the
following observations:
The bead width was consistent with the procedure requirements;
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however, torch shielding gas flow was now less than ten CFH.
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The above are clear examples of failure to follow procedure for
activities affecting quality, which is in direct violation of Title 10
-Code of Federal Regulations, Appendix B, Criterion V.
This violation
will be identified as 302/85-23-04:
" Failure to Follow WPS Require-
ments."
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f.
Preheat and Post Weld Heat Treatment-
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-(1) Preheat
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(a) The inspector reviewed the licensee's programs for weld
preheating to determine whether procedures were available
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when specified; procedures specify acceptable methods and
provide requirements for ~ monitoring and recording preheat
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before, during, and if specified after welding, until post
-weld stress relief.
(b) The inspector observed preheat controls in process to
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~ determine whether procedures were being followed, and
temperatures were within specified limits. The welds listed
in paragraph 6e were examined.
(2) Post Weld Heat Treatment (PWHT)
(a) The inspector reviewed the licensee's program for PWHT to
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determine whether procedures were available; had a system
capable of meeting of the heating and cooling rates, metal
temperature, temperature uniformity and control limits were
specified and consistent with the applicable codes; procedure
covered both local and furnace heating if used; and furnace
atmosphere controlled if used.
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With regard to the examination above, the inspector noted the following
. inconsistencies:
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W-050 specifies heating and cooling rate maximums for temperatures
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above 800 F; AWS D1.1 specifies maximum heating and cooling rates
for temperatures over 600'F.
The preheat temperatures listed in W-050 are not consistent with
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the preheat temperatures listed in USAS B31.1.0.
The post weld treatment temperature ranges specified in W-050 are
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not consistent with the preheat temperatures listed in USAS
B31.1.0.
The inspector discussed the above with the licensee, who indicated that
they would reevaluate W-050 and provide engineering justification for
all deviations from committed code requirements or ammend W-050 to
comply with the committed codes.
This matter will be identified as
inspector followup item 302/85-23-05:
" Post Weld Heat Treatment
Program Inconsistencies."
g.
Examination of Welds
The inspector visually examined completed and accepted welds as
described below to determine whether applicable code and procedure
requirements were being met.
(1) The below listed welds were examined relative to the following:
location, length, size and shape; weld surface finish and
appearance (including inside diameter of pipe welds when
accessible); transitions between different wall thickness; weld
reinforcement -- height and appearance; joint configuration of
permanent attachments and structural supports; removal of
temporary attachments; arc strikes and weld spatter; finish-
grindioq or machining of weld surface -- surface finish and
absence of wall thinning; surface defects -- cracks, laps, and
lack of penetration, lack of fusion, porosity, slag, oxide film
and undercut exceeding prescribed limits.
Weld No.
System
MU-85-115
Makeup
MU-85-116
Makeup
MU-85-30
Makeup
MU-85-37
Makeup
MU-85-38
Makeup
MU-85-49
Makeup
MU-85-56
Makeup
MU-85-57
Makeup
MU-85-58
Makeup
Within the areas examined no deviations or violations were
identified except as noted in paragraph 6e.
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7.
The inspector reviewed procedures, observed in-process examinations and
reviewed' quality records as described below to determine whether applicable
code, procedure and regulatory requirements were being met. The applicable
code for nondestructive examination (NDE) is ASME B&PV Code,Section V,1974
Edition with Addenda through Summer 1975.
a.
Review of Quality Program
The inspector reviewed the below listed documents to ascertain whether
the NDE program has been approved by the licensee and whether
adequate plans and procedures had been established to assure that the
modification project would be controlled and accomplished consistent
with commitments and regulatory requirements.
Procedure No.
Title
FPC-SPS-PT-002, R4
" Visible Dye Liquid Penetrant
Examination Specification
FPC-SPS-PA-002, R1
" Liquid Penetrant Acceptance
Standard (AWS)"
FPC-SPS-PA-001, R4
" Liquid Penetrant Acceptance
Standard (ASME & ANSI)
b.
Liquid Penetrant (570608)
(1) Procedure Review
The inspector reviewed Procedure Nos. FPC-SPS-PT-002, FPC-SPS-
PA-001 and FPC-SPS-PA-002 to ascertain whether it has been
reviewed and approved in accordance with the licensee's
established QA procedures. The above procedures were reviewed for
technical adequacy and conformance with ASME,Section V, Article 6,
and other licensee commitments / requirements in the below listed
areas:
specified method; penetrant materials identified;
penetrant materials analyzed for sulfur; penetrant materials
analyzed for total halogens; acceptable pre-examination surface;
drying time; method of penetrant application; surface temperature;
solvent removal / water washable; dry surface prior to developing;
type of developing; examination technique; and eva'Jation
technique.
(2) Work Observation
The inspector observed the liquid penetrant examination of weld
joints indicated below:
to determine whether procedure clearly
specified the applicable test; procedure was available; sequencing
and timing of examination in accordance with applicable code /and
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contract; materials available and properly identified; examiner
identification; location and extent of examination clearly
defined; and procedure compliance in the following areas; surface
preparation; penetrant type; application method; penetration time;
surface temperature; penetrant removal; drying; developed type and
application; developing time; evaluation in accordance with
procedure and with correct acceptance criteria; and surfaces
cleaned at conclusion of examination.
Weld No.
MU-85-115
MU-85-116
(3) Records Review
(a) The inspector reviewed the qualification documentation for
the below listed examiners in the following areas:
employer's name; person certified; activity qualified to
perform; effective period of certification; signature of
employer's designated representative; basis used for
certification; annual visual acuity; and color vision
examination.
RUV PT-LII
AJU PT-LII
JA
PT-LII
(b) 'The inspector reviewed the below listed liquid penetrant
,
examination reports for compliance with procedure record
requirements.
Weld No.
60-85-38
MU-85-49
MU-85-56
MU-85-57
MU-85-58
(c) The inspector reviewed the " certification of contaminent
content" for the below listed liquid penetrant materials to
determine whether the analysis for halogen and sulfur is
consistent with applicable requirements.
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M
Batch No.
Penetrant
85C025
Cleaner
84K065
Developer
84M040
Within the areas examined no violations or deviations were identified.