ML20141J989
| ML20141J989 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/23/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20141J955 | List: |
| References | |
| 50-361-97-08, 50-361-97-8, 50-362-97-08, 50-362-97-8, NUDOCS 9705280279 | |
| Download: ML20141J989 (14) | |
See also: IR 05000361/1997008
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ENCLOSURE 2
- U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-361
50-362
License Nos.:
NPF-15
Report No.:
50-361/97-08
50-362/97-08
Licensee:
Southern California Edison Co.
Facility:
San Onofre Nuclear Generating Station, Units 2 and 3
Location:
5000 S. Pacific Coast Hwy.
San Clemente, California
Dates:
April 21-25,1997, with in-office inspection through May 8,1997
Inspectors:
L. E. Ellershaw, Reactor inspector, Maintenance Branch
C. J. Paulk, Reactor inspector, Maintenance Branch
J. E. Whittemore, Reactor Inspector, Maintenance Branch
Approved By:
Dr. Dale A. Powers, Chief, Maintenance Branch
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Division of Reactor Safetv
ATTACHMENT:
Supplemental Information
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9705280279 970523
ADOCK 05000361
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EXECUTIVE SUMMARY
San Onofre Nuclear Generating Station, Units 2 and 3
NRC Inspection Report 50-361/97-08;50-362/97-08
This inspection consisted of a review of the licensee's implementation of its welding, boric
acid corrosion prevention, and inservice inspection programs. The inspection report covers
a 1-week period on site, with followup in the office by 3 region-based inspectors.
Maintenance
A violation was identified for the failure to adequately implement procedural
measures developed to perform welding activities in a manner to assure that
welding induced sensitization of stainless steel would be minimized (Section M1.1).
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Welders employed a poor welding practice when they used the actual components
to be welded, rather than a " strike" plate, to determine if sufficient amperage
existed prior to production welding (Section M1.1).
The administrative control of welding materials (i.e., identification, storage, and
issuance) was effective and wellimplemented and considered a program strength
(Section M1.1).
The boric acid corrosion prevention program at the San Onofre facility has been
implemented in accordance with licensee procedures and has been effective in
identifying and correcting boric acid leaks (Section M1.2).
Inservice examinations were performed correctly. The authorized nuclear inservice
inspector and the inservice inspection program engineer spent sufficient time in the
field to verify adequate contractor performance (Section M1.3).
Licensee and contractor procedures used within the inservice inspection program
met regulatory requirements. The documentation of inservice inspection activities
was in accordance with regulatory requirements (Section M3).
The welding procedure specifications were developed and qualified in accordance
with either Section IX of the ASME Code or the AWS D1.1, "St; Jctural Welding
Code - Steel." All mechanical tests required by Sections lll and IX of the ASME
Code had been properly documented in the procedure qualification records
(Section M3).
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REPORT DETAILS
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Summarv of Plant Status
Unit 2 was operating in Mode 1, and Unit 3 was in a refueling outage for the entire
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inspection period.
ll. Maintenance
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Conduct of Maintenance
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M 1.1 Nuclear Weldina General Insoection Procedure (55060)
a.
Insoection Scope
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The inspectors observed welding on two replacement pressure measurement
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nozzles being fabricated under Maintenance Order MO 97041119, and Repair
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Specification 046-97, Revision 1. The inspectors reviewed the controls established
by the licensee to assure proper identification, storage, and use of welding filler
materials. The inspectors reviewed Procedures SO123-1-11.1, " Welding Filler
Material Control," Revision 0, and SO123-V-7.30.5, " Technical Requirements for
Weld Filler Material, Field Storage, and Handling," Revision 5.
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The inspectors also reviewed the certified material test reports applicable to the
following heat / lots of welding filler material (listed below) to verify the material had
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been properly tested and qualified, and identification had been maintained.
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E-7018, 3/32", Heat Number 105221
E-7018,1/8", Heat Number 63187
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E-7018, 5/32", Heat Number T22316
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E-7918, 3/16", Heat Number 73598
Inconel UNS N06052,3/32", Heat Number NX9579JK
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Inconel UNS N06052,1/8", Heat Number NX9277JK
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The inspectors performed followup for a previously identified issue related to a
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discrepancy between the weld material used in the plant and the weld material
listed in the Updated Final Safety Analysis Report. This issue had been previously
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identified as inspection followup item (50-361;-362/9605-03).
b.
Observations and Findinas
On April 23,1997, the inspectors observed in-process gas tungsten arc welding
performed on two replacement pressure measurement nozzles identified as
RS-046-97-A and RS-046-97-B. The welding was performed by two licensee
welders. Both welders were documented in the current Welder Qualification
Record, dated April 21,1997, as being qualified to perform the gas tungsten arc
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welding. Repair Specification RS-046-97 classified the nozzles as ASME Code
Section lil, Class 1, components. Maintenance Order 97041119 specified that pre-
and post-weld nondestructive examinations, fitup, and welding were to be
performed on Nozzles RS-046-97-A and RS-046-97-8 in accordance with Weld
Records WR3-97-217 and WR3-97-218, respectively. The weld records were
essentially work packages that contained all pertinent instructions, drawings, and
the applicable welding procedure specification. These documents were also used to
record performance, completion, and verification of the specified activities.
While observing the welding, the inspectors noted that the welding procedure
specification established heat input limits to minimize welding-induced sensitization.
The welding procedure specification stated, in part, that "It]he most influential
process variables are travel speed and, to a lesser degree, amperage. Voltage, for
the purpose of heat input determination with this process, is conservatively
assumed to be constant at 14 volts. The upper limit for heat input in this WPS is
60,000 joules per inch. Only amperage / travel speed combinations under this limit,
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as determined by the graph in Figure 1 on page 3, shall be used." The graph in
Figure 1 provided an easy and convenient method for determining heat input based
on amperage and travel speed, and the acceptable / unacceptable limits. Note 4, in
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the welding procedure specification, stated, "[t]he following measures shall be
taken to minimize welding-induced sensitization: Adhere strictly to the specified
limits in this WPS for interpass and heat input."
The inspectors observed that the welding power source was set at a constant
voltage and the adjustable amperago dial was set by the welder at 60. To verify
accuracy of the power source, the inspectors requested that amperage and voltage
measurements be taken while welding was in-process. In response, the welder
determined that the voltage was approximately 10 volts. However, with the power
source amperage dial set at 60, actual current, as measured by a calibrated clamp-
on ammeter, was between 88 and 90 amperes. This approximately 50 percent
discrepancy did not exceed the welding procedure's allowable amperage range of
40-160 amperes. It did, however, demonstrate the need for assuring that specified
amperage was verified prior to welding.
Subsequent to taking these measurements, the welder increased the dial setting to
70 amperes. The inspectors requested that the measurements be taken again. This
time, the actual amperage fluctuated between 98 and 105 amperes, with an
average value of approximately 102 amperes. The inspectors also monitored the
travel speed of the welding process and determined that the speed was
approximately 1 inch per minute. This was based on the welder placing a half-
circumference weld bead on a weld build up with a diameter of approximately 0.75
inches in approximately 1 minute. By applying these measurements to the formula
provided in the welding procedure specification, the inspectors found that the heat
input would have been approximately 61,200 joules per inch. This value was in
excess of the allowable heat input specified in the procedure. Also, the inspectors
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found that, using the graph provided in the welding procedure specification, the
actual travel speed to current relationship fellin the unacceptable range.
Additionally, the inspectors were informed that the welders, based on their
experience and skill, established electrical characteristics at the time the
components were tack welded. However, while performing the welding no one
verified the electrical values at any time, until prompted by the inspectors. The
inspectors were not made aware of any licensee guidance or provisions for assuring
that electrical characteristics were established by use of a " strike" plate prior to
welding on the actual component, The inspectors determined the use of an actual
component, rather than a " strike" plate, to determine if sufficient amperage existed
as a poor practice. The inspectors also determined that there was no prohibition
regarding this practice, and the general welding procedures did not appear to
address the subject. The inspectors observed that all other essential and
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nonessential variables specified in Welding Procedure Specification 43-8-GT-1 were
being adhered to.
Based on observations, and discussions with the welders, the weld foreman, and
the quality control inspector, the inspectors noted that none of the heat input
variables had been measured or monitored. While requirements were established in
the welding procedure specification, responsibilities were not assigned to assure
implementation of those requirements. The inspectors found that the measures
established for minimizing welding-induced sensitization (i.e., assuring that the
specified limits in the welding procedure specification were adhered to), were not
implemented. The inspectors also found that welding-induced sensitization was not
a concern, in this instance, because of the low carbon content of the base metals.
The inspectors did not find a violation of the ASME code; however, the inspectors
found that the licensee's failure to adequately implement welding procedure
specification WPS 43-8-GT-1 was a violation (50-362/9708-01).
Upon completion of the welding, Maintenance Order MO 97041119 required final
visual and radiographic examinations of the welds prior to machining. The licensee
determined that the visual examination results were acceptable; however, the
radiographic examinations showed the welds in both nozzles were unacceptable
because of incomplete fusion. The welds were rejected and documented
accordingly in the nozzle's respective Weld Record on April 24,1997. The
inspectors reviewed the radiographs for each nozzle and noted that the weld in
Nozzle RS-046-97-B exhibited barely detectable indications; however, the weld in
Nozzle RS-046-97-A exhibited significant lack of fusion.
The inspectors noted that the welding filler material control procedures provided the
necessary guidance to assure that welding materials would be properly identified,
stored, and used. The inspectors also found that the licensee had established a
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single location for the issuance of all safety-related welding materials. O orage
areas and holding ovens were clearly marked, and access was limited to the
welding material crib attendant and the tool room supervisor. Holding oven
temperatures were set and being maintained in accordance with the procedure. The
welding material crib attendant exercised very good control over welding material
identification, storage conditions, issuance, and return of unused welding materials.
Violation 50-361;-362/9526-02 was issued for Updated Final Safety Analysis
Report discrepancies identified during an engineering inspection. Subsequent
to the engineering inspection, but prior to the liconsee's completion of the
corrective actions, the resident staff identified that the weld materials
listed in Table 5.2-4 of the Updated Final Safety Analysis Report were
not updated to reflect recent changes. This item was designated as
Unresolved item 50-361;-362/9602-05, although it was considered to be
another example of Violation 50-361;-363/9526-02. In the resident inspectors'
NRC Inspection Report 50-361;-362/96-05, dated July 8,1996, the unresolved
item was administratively closed and re-opened as inspection Followup
Item 50-361;-362/9605-03, " Weld Specification Material Not Updated in UFSAR."
On April 1,1997, the licensee initiated Change Request SAR23-442 to update
Table 5.2-4. The licensee also informed the NRC by letter dated April 22,1996,
of the corrective actions to be taken to address other Updated Final Safety
Analysis Report discrepancies. The licensee stated that the corrective actions
would be completed by December 1997. In addition to responding to this violation,
the licensee also responded to an NRC letter, transmitted in accordance with
10 CFR 50.54(f), as to the fidelity of the plant design and actual plant conditions
(including accuracy of the Updated Final Safety Analysis Report).
The inspectors found the licensee's planned actions for the violation to be adequate
to address the discrepancy between Table 5.2-4 of the Updated Final Safety
Analysis Report and the weld materialin the plant. Consequently, inspection
Followup item 50-361;-362/9605-03 is closed.
c.
Conclusions
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A violation was identified for the failure to adequately implement measures
oeveloped to perform welding activities in accordance with Welding Procedure
Specification 43-8-GT-1.
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Welders employed a poor welding practice when they used the actual components
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to be welded, rather than a " strike" plate, to determine if sufficient amperage
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existed prior to production welding.
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The administrative control of welding materials (i.e., identification, storage, and
issuance) was effective and wellimplemented and considered a program streng h.
M1.2 Boric Acid Corrosion Prevention Proaram (62001)
a.
Inspection Scope
The inspectors reviewed the boric acid walkdown binder for both units;
Procedure SO123-V-8.15, " Mode 3 Boric Acid Leak Inspection," Revision 1,
Temporary Change 1-1; and Procedure SO23-V-8.16, " Reactor Coolant System
inconel Nozzle inspection," Revision O. The inspectors also performed an
inspection of the containment building in response to address inspection Followup
Item 50-361;-362/9501-01, " Implementation of Boric Acid Corrosion Prevention
Program."
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Observations and Findinas
During a previous inspection, the NRC reviewed the boric acid corrosion prevention
program, but did not evaluate the implementation of the program, inspection of the
implementation of the program wa? n
'ified as an inspection followup item,
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(50-361;-362/9501-01).
The inspectors observed no boric acid leaks inside containment that had not been
previously identified by the licensee. Most of the leaks identified during walkdowns
by licensee personnel had been cleaned and documented in the " Boric Acid
Walkdown Binder." Those leaks that had not been cleaned were recently identified
by the licensee during inspection of the Inconel nozzles. The inspectors found that
the licensee had implemented the program in accordance with their procedures.
Accordingly, inspection Followup item 50-361;-362/9501-01 is closed.
c.
Conclusions
The boric acid corrosion prevention program at the San Onofre facility has been
implemented in accordance with licensee procedures and has been effective in
identifying and cor ecting boric acid leaks.
M1.3 Inservice insocction (73753)
The Unit 3 inservice inspection program was in the second 10-year interval, and the
current outage marked the end of the first 40-month period of the second interval.
The Unit 3 program adopted Section XI of the 1989 Edition of the ASME Code,
without addenda. The NRC had granted six requested exemptions to the code
requirements. Two requests for relief had been denied.
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a.
Inspection Scope
The inspectors observed nondestructive examinations on the following welds and
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supports.
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EXAMINATION
ASME ITEM
SYSTEM AND LOCATION
COMPONENT OR
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TYPE
CATEGORY
IDENTIFICATION
WELD TYPE
Ultrasonic
89.11
03-18-130
12" Pipe Weld
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Ultrasonic
B9.11
03-18-150
12" Pipe Weld
B10.10
03-18-640 upper
12" Pipe Support
Integral
Attachment
B10.10
03-18-640 lower
12" Pipe Support
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Integral
Attachment
Magnetic
C3.20
03-52-780-1
6" Pipe Support
Particle
Integral
Attachment
b.
Observations and Findinas
The inspectors found the examinations were performed as required by the
procedures. The inservice inspection nondestructive examination contractor's
procedures had been adequately reviewed and approved by the licensee's
organization. The licensee's inservice inspection engineer (coordinator)
accompanied the inspector during three of the examinations. The authorized
nuclear inservice inspector accompanied the inspector during two of the above
examinations. During followup discussions, it was determined that these individuals
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routinely spent time in the field observing examinations.
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The examiner identified an indication during tiie magnetic particle examination of
Pipe Support 03-52-780-1. The initial evaluation was that the area had not been
adequately prepared for examination by the lici,nsee preparation crew. The
examiner delayed reporting the indication to allow the licensee weld-preparation
crew to better prepare the area for re-examination. The re-examination had not
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been performed at the end of the inspection.
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c.
Conclusions
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The inservice inspection examinations were performed ir' iccordance with the
applicable procedures. Also, the authorized nuclear inse
.cc inspector and the
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inservice inspection program engineer spent sufficient time in the field to verify
adequate performance of the examination contractor.
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Maintenance Procedures and Documentation
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Insoection Scope (55050. 73753)
The inspectors reviewed the procedures, and inspection reports listed in the
attachment to verify adequate program implementation.
The inspectors reviewed the welding procedure specifications and the applicable
procedure qualification records listed in the attachment to assure that they had been
developed and qualified in accordance with Section IX of the ASME code and the
American Welding Society D1.1 " Structural Welding Code - Steel," as applicable.
The inspectors also reviewed the procedures for the conduct of post-weld heat
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treatment to ascertain whether or not the procedures provided adequate guidance
for the craft to conform to the required heating and cooling rates, metal
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temperature, temperature uniformity, and control limits specified in Section lli of the
ASME code.
b.
Observations and Findinas
The inspectors noted that the program description of an ultrasonic testing
calibration block didn't match the description of the main steam system material.
Main Steam System Weld 03-052-460 connected 6 inch intet piping for a main
steam safety valve to a main steam header. The program specified that Calibration
Block UT-68 should be used to calibrate and set up the search unit (i.e.,
components) for examining this weld. The calibration block material was identified
as SA-105 Cl.2 and the main steam piping was SA-333 GR6.
Licensee personnel obtained material certifications for the block and steam piping
that verified the program material descriptions were correct. Article 3411 of
Appendix !!! to ASME Section XI,1989, states that the calibration block material
can be different from the materialinspected provided the chemical, tensile, and
metallurgical properties of the two materials are similar'. A review of the material
specification tables for the two materials indicated that the material properties were
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similar. Therefore, the inspectors had no concerns in this area.
The inspectors noted that a Level lit examiner certified to perform VT3
examinations, had also signed for performing the review of three VT3 examinations
that he had actually performed. The inspectors questioned this practice and were
told the review was signed by the work performer because the contractor's
procedure required a signature in the review block and another Level 111 VT3
certified examiner was not available. The ASME Code does not prohibit this
practice. The inspectors asked what would be done if any visual examinations
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showed potential flaw / defect indications. Both licensee and contractor personnel
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indicated they would not allow this practice on any examination that yielded
indication of a potential flaw / defect. The inspectors discussed this poor practice
with the authorized nuclear inservice inspector and determined that no violation of
regulatory requirements had occurred.
The inspectors found that the licensee's inservice inspection program and
implementing procedures were clear and concise. The contractor's examination
procedures were of sufficient quality to perform the examinations with a minimum
of interpretation required by the user (examiner). The inspectors verified that ASME
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code requirements had been included in the current interval plan for the two relief
requests that had been denied.
The inspectors verified that all ASME code-required essential and nonessential
variables had been addressed in the welding procedure specifications, and that all
essential variables had been addressed in the procedure qualification records. Each
procedure qualification record contained the results of ASME Code required
qualification tests. Welding Procedure Specification 1-Il-SM-F4 had been
appropriately prequalified in accordance with the AWS D1.1, " Structural Welding
Code - Steel."
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The inspectors requested information on any recent post-weld heat treatment
activities. Tha welding engineering supervisor recalled that stress-relieving heat
treatment was performed on a Unit 2 steam generator nozzle in conjunction with
the removal and replacement of main feedwater piping and elbows in approximately
February 1995 (see discussion in NRC Inspection Report 50-361;-362/95-01). The
inspectors requested the documentation associated with that effort, with emphasis
on post-weld heat treatment / stress relieving operations performed on site, and the
impact on weld material qualifications.
On April 24,1997, licensee personnel provided documentation pertaining to steam
generator nozzle base metal qualifications, but not the associated weld ';ller
material. On May 6,1997, the inspectors received the additional information
related to the weld filler material and the base metal. The inspectors determined the
post-weld heat treatment that the materials had been subjected to was acceptable
and within the qualification range of the weld filler m;tterial and the base metal.
c.
Conclusions
Licensee and contractor procedures used in the inservice inspection program met
regulatory requirements. The documentation of inservice inspection activities was
in accordance with regulatory requirements.
The welding procedure spec + cations were developed and qualified in accordance
with either Section IX of the ASME code or the AWS D1.1, " Structural Welding
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Code - Steel." All mechanical tests required by Sections ill and IX of the ASME
code had been properly documented in the procedure qualification records.
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Maintenance Staff Knowledge and Performance (73753)
The inspectors reviewed copies of the certifications for the contractor examiners.
These records indicated that the contract personnel were physically qualified and
technically competent to perform the inservice inspection activities for which they
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were certified. Those personnel involved in testing activities observed by the
inspectors were considered to be proficient. The inspectors also considered the
licensee's inservice inspection engineer (program coordinator) to be knowledgeable
of the program and its requirements.
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V. Manaaement Meetinas
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Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management
at the conclusion of the onsite portion of the inspection on April 25,1997. The
licensee personnel acknowledged the findings presented.
On May 9,1997, a followup exit was held via telephone with Mr. G. Gibson and
other licensee representatives. The purpose of the followup was to inform the
licensee of a change to information provided at the onsite exit. At the onsite exit,
an unresolved item was identified that related to the qualification of weld filler
material used in steam generator nozzle welds. After in-office review of the
additional information, this item was satisfactorily resolved.
The inspectors asked the licensee personnel whether any materials examined during
the inspection should be considered proprietary. No proprietary information was
identified.
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
D. Axtine, Licensing Engineer
R. Clark, Manager, Quality Engineering
D. Cole, Supervisor, Non-Destructive Examination / Welding
J. Fee, Manager, Maintenance
G. Gibson, Manager, Compliance
D. Irvine, Manager, Technical Support
A. Mahindrakar, inservice inspection Engineer
A. Meichler, Supervisor, Welding Engineering
D. Nunn, Vice President, Engineering and Technical Services
G. Plumlee, Compliance Eny 9er
S. Shaw, Supervisor, Nuclear Services
K. Slagle, Manager, Nuclear Oversight
NRC
J. Sloan, Senior Resident inspector
INSPECTION PROCEDURES USED
IP 55050:
Nuclear Welding General inspection Procedure
IP 62001:
Boric Acid Corrosion Prevention Program
IP 73753:
Inservice inspection
ITEMS OPENED AND CLOSED
Opened
50-362/9708-01
failure to assure welding-induced sensitization of
stainless steel would be minimized (Section M1.1)
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Closed
50-361,-362/9501-01
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implementation of boric acid corrosion prevention
program (Section M1.2)
50-361,-362/9605-03
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discrepancy between weld materialidentified in
Updated Final Safety Analysis Report Table 5.2-4 and
weld materialinstalled in the plant (Section M1.1)
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DOCUMENTS REVIEWED
Procedures
Number
Revision
Title
SO123-IN-1
4
Inservice inspection Program
SO123-XVil
7
Inservice Inspection Program Implementation
SO123-XVll-1.1
3
Inservice inspection Program Maintenance
SO23-XXVll-20.47
1
Magnetic Particle Examination
SO23-XXVil-20.48
0
Liquid Penetrant Examination
SO23-XXVil-20.49
0
Visual Examination to Determine the Condition of
Nuclear Parts, Components or Surfaces
SO23-XXVil-20.51
0
Visual Examination Procedure for Operability of Nuclear
Components, Supports and Conditions Related to
Functional Adequacy
SO23-XXVil-20.54
1
Ultrasonic Examination of Ferritic Piping
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SO23-XXVil-20.54
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Ultrasonic Examination of Nuclear System Austenitic
Piping
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Nondestructive Examination Reports
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387-091 MT-OO3
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397-091 MT-001 -
397-091 MT-002
397-091 PT-001
397-091 UT-001
397-091 UT-005
397-091 UT-007
397-091 UT-010
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397-091VT-002
397-091 VT-004
397-091 VT-006
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Weld 03-049-300 UT, March 5,1979
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Weld 03-052-450 UT, June 6,1990
Weld 03-052-460 UT, June 6,1990
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. Weld 03-052-470 UT, June 6,1990
Weld 03-052-480 UT, June 6,1990
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Proaram Relief Reauests
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3.3.5, Exemption from Use of Certified Personnel for VT3 Examinations
3.3.6, Exemption from inspection of Specific Heat Exchanger Welds
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Weldina Procedure Specifications and Acolicable Procedure Qualification Records
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Weldina Procedure Soecification
Procedure Qualification Record
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WPS 43-8-GT-1, Revision 0
POR 25 and 34
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WPS 1-II-SM-F4, Revision 0
AWS Structural Welding Code D1.1:
Prequalified
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WPS 1-GT, Revision 1
POR 51,112, and 153
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WPS 8-GT, Revision 0
POR 5 and 68
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