IR 05000440/1985043

Insp Rept 50-440/85-43 on 850619-21.Violation Noted:Failure to Control Selection of Electrodes in Welding Procedures & Welding Procedures Did Not Control Fillet Weld Size & Heat Input

ML20129A793
Person / Time
Site:	Perry
Issue date:	07/10/1985
From:	Danielson D, Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20129A769	List: IR 05000440/1985043 ML20129A765 ML20129A771
References
50-440-85-43, NUDOCS 8507150388
Download: ML20129A793 (4)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-440/85043(DRS)

Docket No. 50-440 License No. CPPR-148 Licensee: Cieveland Electric Illuminating Company Post Office Box 5000 Cleveland, Ohio 44101-Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, Ohio '

Inspection Conducted: June 19-21, 1985 .

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Inspector: .

s 7/

Date d o[#

Approved By:

od7d D. H. Danielson, Chief b

7 /0 ff Materials & Processes Section Date'

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Inspection Suninary Inspection on Jun_e ~ 19_ _ _21_,1985_ _(R_epor_t No. 50-440/85043(DRSJJ Areas Ins)ected: Unnannounced, speciB inspection to review welding procedures

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used by tie electrical contractor for cable trays and supports. This inspection involved a total of 16 inspector-hours onsite by ane NRC inspecto Results : Within the areas inspected, one violation was identified (failure To control special processes - Paragraph 2.a and c).

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DETAILS 1. Persons Contacted Cleveland Electri_c Il_1_uminating Company _(CEI_)

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• K. Cimorelli, Lead Quality Engineer J. Wilcox, Welding Engineer S. Anzalone, Welding Engineer

• S. Tulk, Supervisor, Electrical Quality Unit

• D. Gallagher, Quality Assurance Level II Inspector

• G. Parker, Quality Assurance Supervisor

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• C. Shuster, Quality Assurance Manager

• K. Pech, General Supervising Engineer

• H. Walls, Senior NDE Aaministrator Comstock Engineering, In J. Hubbuch, Quality Assurance Engineer T. Vogt, Quality Assurance Engineer W. Gardner, Quality Control Manager C. Hart, Assistant Quality Control Manager Gilbert / Commonwealth C. Wright, Senior Welding Engineer B. Brown, Design Engineer

• Denotes those attendi.ng the exit meetin . Review of_L. K. Comstock Welding Procedures A comprehensive review of all welding procedures used for fabrication and i

installation of cable trays and supports was performed. This special l

review was conducted as a result of problems that were found with welding l

procedures utilized by this same contractor at another site. The procedures

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and revisions reviewed are as.follows:

Procedure 4.7.1, Revision C dated April 3, 1985, (For SMAW) permits i the use of.E6010, E7010, E6013, and E7018 electrodes. Three of i these electrodes were in stock and available for field.use. The design fcr electrical _ support attachment to building structure assumes weld material having 70 ksi minimum strength is used. As this procedure does not adequately control electrode selection, it

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is possible that E6010 or E6013 electrode having 60 ksi minimum strength could be used. Use of' these electrodes could result in welded connections of inadequate strength. It should be noted that-this deficiency existed in all revisions of this procedure. Failure to control the selection of electrodes is an example of a violation of 10 CFR 50, Appendix B, Criterion IX (440/85043-01(a)(DRS)).

Requirements per AWS D1.1-75 (the applicable welding code) require a 150 F pt cheat temperature for materials 3/4" .through 1 1/2" thick

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when using E6010 or E6013 e'iectrodes. All revisions of this procedure fail to address this requirement. When using E7018 electrode, a 150 F preheat is required for materials over 11/2" in thickness. All revisions of this procedure prior to revision C fail to address this requirement. Failure to observe preheat requirements may result in cracking of welds.' Failure to control the preheat requirements is an example of a violation of 10 CFR 50, AppendixB,CriterionIX,(440/85043-01(b)(DRS)).

The AWS D1.1-75 code allows the'use of certain welding procedures without having to perform a qualification test provided all stated requirements are met. The "prequalified" fillet weld procedure requires that a specific size fillet be applied dependent on material thickness, and that it be accomplished in a single pass thus controlling heat input. Failure to follow these heat input require-ments may result in weld cracking. All revisions of this procedure fail to incorporate this requirement. When a procedure fails to incorporate all requirements for "prequalified" status, a qualification test is required. The failure to control heat input requirements is an example of a violation of 10-CFR 50, AppendixB,CriterionIX,(440/85042-01(c)(DRS)).

The AWS D1.1-75 code requires that when a procedure is qualified, it be tested in all positions that will be encountered in the fiel All revisions of Procedure 4.7.1 state that all positions ar qualified, however, procedure qualification records do not support this. The qualification tests were not performed in all position The AWS code also requires that when materials not listed as

" approved" are used, a qualification test be performed. Some galvanized unistrut items were supplied as ASTM A446, which is not listed as an " approved" material, and were subsequently welded with Procedure 4.7.1. This procedure (all revisions) neither permits welding of A446 material; nor is qualifie Welding procedure qualification tests must contain. sufficient information to establish procedural limits. The qualification tests for stainless steel welding do not state the thickness of the test coupon. This thickness is used to establish the range of thickness to which the procedure is qualified. Furthermore, Procedure 4. (all revisions) does n't o state the required thickness limitatio Failure to control the qualification process as stated in thu two examples above are considered a violation of 10 CFR 50, Anpendix B, Criterion IX (440/85043-01(d)(DRS)).

Other revisions of Procedure 4.7.1 reviewed by the inspector were as follows:

3/16/84 3/1/83 2/14/83 11/2/82 9/22/82 8/26/82 5/24/82 11/4/80 Procedure 4.7.9 dated April 27,1984, (for GMAW) was reviewed and found to be acceptabl _ - - -__

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. Procedure 4.7.7 dated October 9,1981, for welding galvanized sheet and tube states that it is "prequalified" per the AWS D1.1 cod Galvanized materials are not "prequalified" and require qualification testing. This is another example of a violation concerning control of the qualification process (440/85043-01(d)(DRS)). Review of Piping Weld Repair

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Six documentation packages relating to weld repairs on RHR system piping were reviewed by the inspector. The following 5 packages were found to be complete and acceptable:

1E12-23, Weld 24 1E12-12, Weld 3 1E12-25, Weld 3 1E12-28, Weld 10 1E12-28, Weld 3 The documentation for 1E12-24 Weld 21 was found to be unacceptable. The radiograph of this repair for area 5-1 contained a questionable linear-like indication which had not been evaluated. The CEI Senior NDE Administrator agreed that the indication should have been evaluated.- The NDE Administrator, a qualified ASNT Level III, evaluated the indication as slag and added it to the documentation package. The NRC inspector reviewed and agreed with the evaluatio . Examination of L. K. Comstock Welding

.Approximately 300 welds located in the control complex at elevation 620'

and the cable spreading room at elevation 638' were visually examined by the inspector. The general workmanship and quality of all welds inspected appeared acceptable to the inspecto . Exit Interview The inspector met with representatives (denoted in Persons Contacted paragraph) at the conclusion of the inspection. The inspector summarized the scope and findings of the inspections noted in this report. The. inspector also discussed.the likely informational content of the inspection' report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar