ML20141J989

Insp Repts 50-361/97-08 & 50-362/97-08 on 970421-25. Violations Noted.Major Areas Inspected:Review of Licensee Implementation of Welding,Boric Acid Corrosion Prevention & ISI Programs

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: ML20141J950 ML20141J976 ML20141J989
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

Text

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ENCLOSURE 2

- U.S. NUCLEAR REGULATORY COMMISSION

REGION IV  !

Docket Nos.: 50-361

50-362

License Nos.: NPF-10

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 l

C. J. Paulk, Reactor inspector, Maintenance Branch

J. E. Whittemore, Reactor Inspector, Maintenance Branch

Approved By: Dr. Dale A. Powers, Chief, Maintenance Branch '

Division of Reactor Safetv

ATTACHMENT: Supplemental Information

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9705280279 970523

PDR 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). j

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• Welders employed a poor welding practice when they used the actual components l

to be welded, rather than a " strike" plate, to determine if sufficient amperage I

existed prior to production welding (Section M1.1). l

• 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

Summarv of Plant Status

Unit 2 was operating in Mode 1, and Unit 3 was in a refueling outage for the entire t

inspection period.

ll. Maintenance

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, M1 Conduct of Maintenance

M 1.1 Nuclear Weldina General Insoection Procedure (55060)

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a. Insoection Scope

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The inspectors observed welding on two replacement pressure measurement -

nozzles being fabricated under Maintenance Order MO 97041119, and Repair  !

] 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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l The inspectors also reviewed the certified material test reports applicable to the

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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. >

j E-7018, 3/32", Heat Number 105221

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E-7018,1/8", Heat Number 63187

E-7018, 5/32", Heat Number T22316

E-7918, 3/16", Heat Number 73598

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. Inconel UNS N06052,3/32", Heat Number NX9579JK

Inconel UNS N06052,1/8", Heat Number NX9277JK

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The inspectors performed followup for a previously identified issue related to a ,

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

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 l

60,000 joules per inch. Only amperage / travel speed combinations under this limit, j

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 I

on amperage and travel speed, and the acceptable / unacceptable limits. Note 4, in j

the welding procedure specification, stated, "[t]he following measures shall be l

taken to minimize welding-induced sensitization: Adhere strictly to the specified I

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 I

address the subject. The inspectors observed that all other essential and

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 j

to be welded, rather than a " strike" plate, to determine if sufficient amperage <

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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b. 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.

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c. Conclusions l

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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 i

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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  !

Ultrasonic B9.11 03-18-150 12" Pipe Weld

Liquid Penetrant B10.10 03-18-640 upper 12" Pipe Support

Integral

Attachment

Liquid Penetrant 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

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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

routinely spent time in the field observing examinations.

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l 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 j

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 l

adequate performance of the examination contractor. ]

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M3 Maintenance Procedures and Documentation j

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a. Insoection Scope (55050. 73753)

The inspectors reviewed the procedures, and inspection reports listed in the

attachment to verify adequate program implementation.  ;

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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 ,

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 l

as SA-105 Cl.2 and the main steam piping was SA-333 GR6. i

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 I

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 l

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 j

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. 1

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

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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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M4 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 ,

were certified. Those personnel involved in testing activities observed by the l

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

X1 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 l

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 VIO failure to assure welding-induced sensitization of

< stainless steel would be minimized (Section M1.1)

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50-361,-362/9501-01 IFl implementation of boric acid corrosion prevention

program (Section M1.2)

50-361,-362/9605-03 IFl 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

l SO23-XXVil-20.54 1 Ultrasonic Examination of Nuclear System Austenitic

Piping

Nondestructive Examination Reports

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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 ,

397-091VT-002 l

397-091 VT-004

397-091 VT-006

. Weld 03-049-300 UT, March 5,1979

l Weld 03-052-450 UT, June 6,1990

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Weld 03-052-460 UT, June 6,1990

j . Weld 03-052-470 UT, June 6,1990

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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 ]

Weldina Procedure Specifications and Acolicable Procedure Qualification Records l

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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

. 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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