ML20138A448

Insp Repts 50-324/86-08 & 50-325/86-07 on 860203-07. Violation Noted:Inadequate Measures Established for Control of Welding to Design Base Specs

ML20138A448
Person / Time
Site:	Brunswick
Issue date:	03/05/1986
From:	Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138A437	List: ML20138A435 ML20138A441 ML20138A448
References
50-324-86-08, 50-324-86-8, 50-325-86-07, 50-325-86-7, NUDOCS 8603140237
Download: ML20138A448 (10)

See also: IR 05000324/1986008

Text

UNITED STATES

[A McLu'o,'n NUCLEAR REGULATORY COMMISSION

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REGION il

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• Ij 101 MARIETTA STREET,N.W.

2 ATLANTA, GEORGI A 30323

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Report Nos.: 50-325/86-07 and 50-324/86-08

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: February 3-7, 1986

Inspector: ( ,7 [ dim 3 - 4 - E /,

J. . ey ,g Date Si ned

Approved by: _

3 8d

J. U. aRe, Section Chief Date' Signed

E 1 ering Branch

D i ion of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection involved 33 inspector-hours on site

in the areas of nondestructive examination of recirculation and residual heat

removal system piping, overlay welding, and visual inspection of supports.

Results: One violation was identified-Inadequate measures established for

control of welding to design base specifications - paragraph 6.

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8603140237 860310

PDR

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G ADOCK 05000324

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. Howe, Vice President, Brunswick Nuclear Project (BNP)

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• J. Chase, Assistant to General Manager - BNP

• W. Pierce, Lead Engineer, Brunswick Engineering Support Unit (BESU)

• L. Wheatley Inservice Inspection (ISI) Project Specialist - BNP

• R. Poulk, Senior Regulatory Specialist - BNP

Other licensee employees contacted included construction craftsmen,

engineers, technicians, operators, and office personnel.

Other Organizations

T. Brinkman, General Electric (GE), Level III Examiner

R. Trude, Southwest Research Institute (SwRI), Team Leader

NRC Resident Inspector

• W. Ruland, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on February 7,1986, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the' inspection findings. No dis-

senting comments were received from the licensee.

The licensee did not idedntify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

(0 pen) Violation 324/86-08-01,325/86-07-01, Inadequate Measures Established

for Control of Welding to Design Base Specifications - paragraph 6.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items

Unresolved items were not identified during the inspection.

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5. Nondestructive Examination (NDE) of Recirculation (RECIRC) and Residual Heat

Removal (RHR) System Piping.

On April 19, 1984, NRC issued Generic Letter 84-11 to all licensees of

operating reactors, applicants for operating license, and holders of

construction permits for boiling water reactors. This letter addressed a

. problem that had been identified in inspections conducted at several boiling

water reactors (BWRs) wherein intergranular stress corrosion cracking

(IGSCC) in large diameter RECIRC and RHR piping had been revealed. These

inspections were conducted pursuant to IE Bulletins (IEB) 82-03, Revisioa 1,

and 83-02 and the NRC August 26, 1983 orders. The letter expressed to the

Comission's opinion that the results of the above inspections mandated an

ongoing program for similar reinspection at all operating BWRs. The Generic

Letter also described those actions which licensees should take to provide

an acceptable response to the IGSCC concern.

Carolina Power and Light Company's (CP&L) ' letters of response to Generic

Letter 84-11, Serial Nos. NLS-85-390 dated November 1, 1985, and NLS-85-423

dated November 27, 1985, were reviewed by Region II. In these letters, CP&L

identified their plans to perform IGSCC inspections and mitigative actions,

during the Brunswick 2 reload outage which started on December 1, 1985.

Ninety-four RECIRC and RHR welds were scheduled to be ultrasonically

examined prior to induction heat stress improvement (IHSI). Five welds that

had received weld overlays as a result of earlier IGSCC examinations were

scheduled for UT re-examination. CP&L also scheduled material replacement

for 24 IGSCC susceptible welds in the reactor water cleanup (RWCU) system

piping. The susceptible 304 stainless steel (SS) piping will be replaced

with nuclear grade, 316 SS which has low carbon content and high resistance

to IGSCC. In addition, the RWCU primary containment penetration will be

modified to eliminate the inaccessible weld of the original flued head

penetration design.

UT examinations for the detection of IGSCC were to be performed on these

welds immediately before and as soon as practical after the performance of

the IHSI measures. General Electric (GE) Apparatus and Engineering Services

were selected as the vendor to perform the UT examinations using the

enhanced ultra-image automated equipment commonly referred to as the " SMART"

System on inspections where physical clearances allow.  ;

The applicable codes, regulatory requirements and licensee comitments for

the examinations were the American Society of Mechanical Engineers (ASME) l

Boiler and Pressure Vessel Code (B&PV), Sections V and XI (77578), the l

Coordination Plan between NRC, the Electric Power Research Institute (EPRI),

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and the Boiling Water Reactors Owners Group (BWROG) for Training and Quali- 1

fication Activities of NDE Personnel, and Code Case N335. '

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I a. Review of Procedures (730528)

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The inspector reviewed GE procedures' pertaining to the UT examination

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.of stainless steel for IGSCC to ascertain whether these procedures were

consistent with-regulatory requirements and licensee commitments. The

following procedures were reviewed:

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, Procedure No. UT1.43 Rev. 5, Procedure for Ultrasonic Examination

of Pipe Welds Using Automatic Equipment

-- Procedure No. UT1.30, Rev.12, Procedure ~ for Ultrasonic Examina-

. tion'of Austenic Metal Welds for IGSCC

- Procedure No. UT1.35, Rev. 3 Procedure for Ultrasonic Planar Flaw

Sizing

- Procedure No. NDE-49, Rev. O, Zero Reference Location and- Data

Recording for Nondestructive Examination

The above procedures were reviewed to . determine if the following

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procedure elements' were properly implemented:

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- The type of ' apparatus to be used including frequency range,

, linearity, . and signal attenuation accuracy requirements were

specified.

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The extent of coverage (beam angles, scanning surface, scanning

rate and directions) and methods of scanning were specified and

consistent with the ASME Code.

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Calibration requirements, methods, and frequency including type,

size, geometry, and material of calibration blocks as well as

location and size of calibration reflectors within the block were

. clearly specified and consistent with the applicable ASME Code.

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The sizes and frequencies of search units were. specified and

4 consistent 'with the ASME Code, Code Case N335, and had been

demonstrated on qualification specimens at EPRI, NDE Center.

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Beam angle or angles were specified and consistent with the ASME

i Code, Code Case N335 and had been demonstrated on qualification

specimens at EPRI, NDE Center.

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Methods of compensation for the distance traversed by the ultra-

1 -sonic beam as it passes through the material were specified and

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consistent with the ASME Code.

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The reference level for monitoring discontinuities was defined and

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the scanning gain setting specified. These values met or exceeded

the ASME Code. .

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- Methods of demonstrating penetration were established.

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- L'evels or limits for evaluation and recording of indications were

specified. These values met or exceeded the ASME Code.

-- Methods of recording significant indications were established and

the reporting requirements were in accordance with requirements

. established by the licensee.

Acceptance limits were specified or referenced and were in

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accordance with the ASME Code,Section XI.

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l In addition to the meeting code requirements delineated above, GE's

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procedures incorporated inspection parameters described in EPRI's

I Module.17, Revision 1. " Generic Procedure for Detection and Discrimi-

nation of IGSCC." .This module was utilized for.GE's personnel quali-

[ fication at the EPRI NDE Center during September 1985.

j b. Observation of NDE Activities-(73753)

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The inspector observed work activities and reviewed documentation to

i ascertain whether personnel equipment and materials were properly

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qualified and/or certified; approved NDE procedures were available and

i were being followed; specified NDE equipment that had been qualified at

the EPRI NDE Center during personnel and procedure qualifications was

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being used; NDE personnel were knowledgeable of examination methods and

. operation of the NDE' equipment; NDE personnel with the proper level of

l qualification and certification were pe'rforming the various examination

activities including-designation of NDE method / technique to be used,

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equipment calibration, examination, and interpretation / evaluation /

i acceptance of test results. The following examinations / evaluations /

I calibrations were observed by the inspectors in the evaluation of the

examination processes:

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(1) . SMART System calibration and in-process examination of. weld No.

]' 2B32 '"l-28"-A3.

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!. (2) SMART System Post-IHSI examination of Weld No. 2832-RR-12" AR-D-3,

~ reviewed video tape of examinations and discussed evaluations with

GE Level III examiner during review process.

. -(3) SMART System Pre-IHSI examination of weld No. 2B32-RR-28"-B-5,

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reviewed video tape of examination and discussed evaluations with

GE Level III examiner during review process.

The calibrations / examinations / evaluations delineated above were

observed to determine if the examination activities were consistent

with the approved procedures in the following areas:

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The type of apparatus used, including frequency range as well as

l linearity and signal attenuation accuracy.

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- The extent of coverage (beam angles, scanning surface, scanning

+- rate and directions) as well as the scanning technique.

-- Calib' ration, methods and frequency including the type, size,

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georetry and material of identified calibration blocks as well as

location and. size of calibration reflectors within the block were

clearly determined and recorded.

- .The sizes and frequencies of search units.

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Beam angle ~or angles.

i - Methods of compensation for the distance traversed by the ultra-

sonic beam as it passes through the material including distance -

amplitude correction curves, electronic distance - amplitude

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correction.

- The reference level for monitoring discontinuities was as defined

and the scanning gain setting was as specified.

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Methods of demonstrating penetration.

- Levels or limits for evaluation and recording of indications.

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Method of recording significant indications.

- Acceptance limits were determined,

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The examination personnel were thoroughly familiar with the

inspection system, its application, operation and its limitations.

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Review of NDE Records (737558)

The inspector . reviewed records associated with the qualification and l

1 certification of personnel and equipment, examination results and data

sheets, calibration. data sheets, weld profile data, examination

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evaluation data, records on extent of examinations, records on dispo-

sition of findings, re-examination data after IHSI, and records

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identifying NDE materials such as couplant and certified marking

materials. The records were reviewed in part to determine if personnel

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and equipment utilized by GE to perform the examinations had been i

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qualified / certified in accordance with SNT-TC-1A and the most recent

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certification effort administered by the EPRI NDE Center-in accordance -

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with the " Coordination Plan for NRC/EPRI/BWROG Training and Qualifica-

tion Activities of NDE Personnel."- The records were also reviewed to .

determine if the data files were complete, technically adequate and

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within the previously established acceptance criteria.

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Records for the following welds were reviewed:

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Weld No. 2832-RR-12"-AR-D-3 Post-IHSI

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Weld No. 2832-RR-2E"-B-5 Pre-!HSI

Within the areas examined, no violation or deviation was identified.

6. Overlay Welding (55050) Units 1 and 2.

The inspector reviewed CP&L's welding specifications, work procedures, plant

modification 85-030 for overlay welding, welders qualification records,

filler material certifications, completed and in-processing overlay weld

records, and audited welding activities by direct observation, to determine

whether welding specifications, procedures, production equipment, personnel,

and the established licensee quality control systems are adequate for the

production of sound welds. The applicable codes and licensee commitments

are the ASME Boiler and Pressure Vessel (B&PV) Code Section IX,1980 Edition

with Addenda's through Winter 1981, the American National Standards

Institute B31.1,1967 Edition, and the Nutech Design Base Welding Speci-

fication No. CPL-21-101, Rev. 3, for Brunswick Steam Electric Plant, Units 1

and 2.

The inspector observed the following in-process overlay welding on the

Unit 2 RECIRC system piping:

Weld Joint Nos. Layer No. Position

2-B32-753-12BR-G-3 Layers IV & V SG

2-B32-751-12AR-E-3 Layers IV & V SG

2-832-748-12AR-C-3 Layers II & III SG

2-832-770-288-5 Layers I & II 2G

2-B32-744-12AR-A-3 Layer V SG

During the inspectors surveillance of the above work, welding parameters

identified in the Nutech Design Base Welding Specification No. CPL-21-101,

Rev. 3, were observed being followed by machine operator for each specified

welding position. Welding, however, was intended to be performed under CP&L

quality welding program using CP&L's Welding Procedure Specification

(WPS-88V12 Rev. 3). The inspector compared the two documents and found

that CP&L WPS document had broader welding parameters than the Nutech Design

Base document. As a result of this difference, the inspector held discus-

sions with CP&L's Lead Engineer in the Brunswick Engineering Support Unit

(BESU) to determine whether CP&L had justification for exceeding the design

base document. The licensee could not provide justification for the broader

parameters other than explanation that WPS-8BV12 was developed by CP&L as a

welding procedure with parameter broad enough to weld the design critical

overlay welding on the recirculation system piping and also as a possible ,

fix for the less critical service water system piping, which had suffered

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, material loss as a result of material erosion'. The licensee also provided

? the inspector with site memoranda for Units 1 and 2 which forwarded Nutech's '

specification to the field for information. CP&L, however, has committed to

weld the RECIRC system weld overlays under the Brunswick Construction Unit's

Quality Welding Program using Power Cutting Inc. Welders qualified to

l CP&L'.s Welding Procedure' Specification 88U12. Failure of CP&L to. assure i

l. that measures established in their welding procedure specification was i

! controlled within design base criteria is in . violation of 10 CFR 50,  ;

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Appendix B, Criterion IX . and was identified to the licensee as violations 2

324/86-08-01 and 326/86-07-01, Inadequate Measures Established for Control e

of Welding to Design Base Specifications.  !

As noted by the' inspector above, welding operators have apparently -been ,

instructed to follow the narrow parameters of the Nutech WPS, therefore;  !

this violation'specifically_ addresses a procedure discrepancy and not the ,

soundness of in-process or completed welding. j

Within the area examined, no violation or deviation was identified except as ,

noted above.  !

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7. Visual Examination of Supports - Unit 2 (57050) i

a. Procedure Review

The inspector reviewed CP&L's procedure for administrative control of i

inservice in operation activities (Engineering Procedure ENP-16), <

various visual examination procedures, periodic test procedures, audit  :

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procedures, and training procedures to determine whether the licensee's

l quality program for visual examination met the applicable ASME Code

requirements delineated in paragraph 5 above.

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The following procedures were reviewed:

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l Procedure No. Title  !

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NDEP-611 VT-1, Visual Examination of Nuclear Power Plant i

Components

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NDEP-612 VT-2, Visual Examination of Nuclear Power Plant  !

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- NDEP-613, VT-3, Visual Examination of Nuclear Power Plant l

l Components

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- NDEP-614, VT-4, Visual Examination -of Nuclear Power Plant l

Components

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- Periodic Test, PT-91.0.23, RHR (Ell), Class 2, Loop B. VT-3/VT-4

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Examination of Components Supports

- Procedure for Site Orientation Indoctrination / Training for Visual

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Examiners-

-: QAP-305, Inservice Inspection Surveillance Program

The above procedures were reviewed to determine whether the procedures

were approved in: accordance with the licensee's quality assurance

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program and contained information or referenced a general inspection

f . procedure or supplementary instruction sufficient to assure that the

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following : parameters were specified and controlled within ' the limits '

permitted by the ap* scable code-

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- - Examination Method - direct visual, remote visual or translucent  :

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visual  ;

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- Application - hydrostatic testing, fabrication procedure, visual

examination of welds, leak testing, etc.

] - Equipment - special illumination, instruments, optical aids, and t

i measuring devices l

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Surface Condition - type of surface condition acceptable and

method or tool for achieving proper surface

condition  ;

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Procedure Criteria - sequence of performing examination and

inspection criteria to be used in the

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! - Reporting - data to be tabulated l

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- Acceptance Criteria - review of data and evaluation of  ;

indications

i b _ .0bservation of the Effectiveness of Visual Examination Activities by ,

j. . Independent Re-examination of Completed Work 1

I The inspector re-examined eight representative component supports on '

4 the core spray _ system (PT-91.0.23), loop B to determine through direct

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observation whether the visual examinations conducted by CP&L have been l

performed by qualified personnel in accordance with approved pro- '

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cedures. The following component supports were re-examined and the

. Ldata taken by the inspection was later composed to the initial visual

examination data taken by CP&L:

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Support Nos. Type of Support

2E21-6PG22(19-130) Pipe Guide

2E21-40SS107(18A-901) Snubber

2E21-40SS106(18A-900) Snubber

2E21-40FS90(18A-11236) Fixed Support

2E21-40PG1(18A-55/400) Pipe Guide

Penx227B(18A-210) Link Seal Support Guide

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Penx223B Anchor Support

Core Spray Pump 2B Fix Support

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The above supports were examined to determine whether applicable

drawings and instructions clearly specify the test procedure to be used

and a copy of the procedure was available; personnel were qualified to i

perform the design task, test attribute were as specified in the

applicable test procedure and measurements taken by the licensee were '

consistent with those taken by the inspector, defects evaluated in ,

accordance with test procedure, correct acceptance criteria used, and '

inspection results were reported in the prescribed manner.

Within the areas examined, no violation or deviation was identified. i

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