ML20154E434

Insp Rept 50-267/88-15 on 880711-0805.Violation & Deviation Noted.Major Areas Inspected:Previous Insp Findings,Ler Followup,Control of Design Changes & Mods & Activities Re Refurbishment of Reactor Helium Circulators

ML20154E434
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/08/1988
From:	Barnes I, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154E416	List: ML20154E413 ML20154E418 ML20154E426 ML20154E434
References
50-267-88-15, NUDOCS 8809160326
Download: ML20154E434 (15)

See also: IR 05000267/1988015

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APPENDIX C

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/88-15 License: DPR-34

' Docket: 50-267

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Licensee: Public Service Company of Colorado (PSC)

P.O. Box 840

Denver, Colorado 80201-0840 ,

Facility Name: Fort St. Vrain Nuclear Generating Station (FSV) t

Insp?ction At: FSV, Platteville, Colorado

Inspection Conducted: July 11 through August 5, 1988

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Inspectors: 8W 7- P- Pr ,.

I. Barnes, Chief, Materials and Quality Date

Programs Section, Division of Reactor Safety

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g R. G. Taylor, Reactor Inspector, Materials and Date

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Quality Programs Section, Division of Reactor

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Safety

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Accompanying Personnel: K. L. Heitner, Project Manager, NRR

Approved: /8%

I. Barnes, Chief, Materials and Quality

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Programs Section, Division of Reactor Safety ,

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Inspection Summary

Inspection Conducted July 11 through August 5, 1988 (Report 50-267/88-15)

Areas Inspected: Routine, unannounced inspection of licensee actions on

e previous inspection findings, licensee event report (LER) followup, control of

design changes and modifications, and activities related to the refurbishment

of the reactor helium circulators.

Results: Within the four areas inspected, one violation (failure to store

records at location required by procedure, paragraph 2.e) was identified in the

area of previous inspecticn findings. Two violations (feilure to obtain

authorization for helium circulator installation, paragraph 5.c; and failure to

appropriately control special processes, paragraphs 5.c and 5.d) and one

deviation (failure to comply with commitments made to the NRC relative to

procurement of helium circulator fasteners, paragraph 5.c) were identified in

the area of refurbishment of reactor helium circulators.

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DETAILS

1. Persons Contacted

PSC

• R. O. Williams, Jr., Vice President, Nuclear Operatica

• #D. Warembourg, Manager, Nuclear Engineering Division (NED)

1. M. E. Miehoff, Nuclear Design Manager

1. F. J. Novachek, Nuclear Support Manager

1. P. F. Tomlinson, Manager, Quality Assurance, (QA) Division

1. C. H. Fuller, Manager, Nuclear Production

• G. Redmond, Circulator Program Manager

• P. F. Moore, Supervisor, QA Technical Services

• J. P. Hak, Superintendent, Maintenance

• J. K. Jackson, Supervisor, QA/ Quality Control (QC)

• M. Lehr, Supervisor, QA Engineering

• L. R. Sutton, Supervisor, QA Auditing

• M. J. Raymond, Program Manager, Simulator-Training

• T. E. Schleiger, Superintendent. Chemistry and Radiation Protection

• L. D. Scott, QA Services Manager

• R. L. Hellner, Supervisor, QA Materials Engineering

• M. L. Block, Systems Engineering Manager

• M. W. Coppello, Central Planning & Scheduling Manager

• H. O. Hagan, Outage Manager

• #R. L. Craun, NED Site Manager

• J. M. Gramling, Supervisor, Nuclear I,1 censing-Operations

• M. H. Holmes, Nuclear Licensing Manager

The NRC inspectors also interviewed other licensee persennel during the

course of the inspection.

1. Denotes those persons attending the exit interview on July 14, 1988.

• Denotes those persons attending the exit interview on August 5,

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2. Licensee Action on Previous Inspection Findings (92702,92701)

a. (Closed) Violation (267/8507-05): This finding involved (1) failure

to include architect-engineer / nuclear steam system supplier (AE/NSSS)

drawing technical notes in a work instruction for the control rod

drives, and (2) failure to properly identify and establish material

traceability for slack cable bushing caps. Relative to item (1), the

licensee documented a detailed review of the specific work

instructions involved. While a number of discrepancies were noted,

none required rework of the control rod drives. The licensee further

committed to rewrite all equipment maintenance procedures by January 1,

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1987, and that the rewritten procedures would reference

appropriate AE/NSSS information. The NRC inspector reviewed selected

maintenance procedures and found that they did reference vendor data

and in many instances had attachments extracted from vendor provided

information. In regard to item (2), the NRC inspector reviewed

Change Notice 1994 dated March 26, 1985, which provided a new bearing

bushing retaining cap not included in the original design of the

control rod drives. The engineer selected aluminum as the material

for the cap since it was similar to that in the housing to which the

cap would be bolted and thus would prevent thermal expansion stresses

from developing. The engineer prescribed aluminum type 2011-T3 for

the application, apparently believing that aluminum rod then in stock

was of that type. Subsequent inspection could not establish the

grade and type of aluminum as documented in Nonconfonnance

Report (NCR)85-935. The material was uitimately traced to purchase

order documentation that revealed that the material was type 2024-T4.

Engineering accepted that material "use-as-is" based on the somewhat

superior qualities of 2024-T4 versus 2011-T3 in the area of strength.

The NRC inspector determined that the thermal behavior of the two

grades are essentially the same and had no further questions. The

above identified violation is considered closed,

b. (0 pen) Violation (267/8619-03): This item involved a finding that

the licensee's corrective action program was flawed in several areas.

The NRC inspector reviewed Audit Reports CARP 87-01 (April 1987),

CARP 87-02 (October 1987), and CARP 88-01 (March 1988) which present

the licensee's audit findings relative to their corrective action

program. The audit reports reflect that progress has been made to

improve the program but as of CARP 88-01, the program is still less

than fully satisfactory. The NRC inspector also reviewed a computerized

tracking system report that lists all unresolved deficiency reports,

of which there are several types intended for different areas of

endeavor. The report indicates that a Corrective Action Request

(CAR) issued in January 1986, CAR 86-003, is still unresolved after

numerous date extensions. In addition, an NCR issued in 1980 remains

open as of this time and there are also 35 open NCRs from 1986 and

earlier that are unresolved for a variety of reasons. The NRC

inspector concurs with the licensee's audit report conclusion, as

indicated above, and recomends that licensee management direct

renewed emphasis toward further improvement in the program. This

item remains open,

c. (Closed) Open Item (267/8619-02): This item expressed an observation

that the licensee's QA audit group was chronically understaffed and

that the personnel generally were lacking in experience. The NRC

inspector reviewed the current audit schedule. The schedule appears

to require frequent audits in appropriate areas and full compliance

with the Technical Specification mandated frequencies in .,ther areas.

The audits performed during the first half of 1988 were commensurate

with the schedule, indicating a sufficiently sized staff. The

qualification records for five of the current eight persons cssigned

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to the audit group were reviewed and all were found to equal or

exceed the recomendations of ANSI N45.2.23 "Auditor Qualifications." ,

Based on the review of the audit reports referenced in the previous  !

item, the audits are considered thorough with adequate coverage of l

the activity areas under audit. This item is considered closed,

d. (Closed)OpenItem(267/8636-01): This item was an observation that

a long-term walkdown of non-EQ safety-related systems and components

internally comitted to by the licensee in CAR 86-105 had not yet

been initiated. This CAR has been closed on the basis that the

walkdowns have been proceduralized and a project team has been

organized. At the time of this inspection, approximately 25 percent

of the overall projected effort has been completed. The NRC i

inspector reviewed selected records of the walkdown observations and

interviewed the project team manager. Based on the review of

recently generated records and the interview, the NRC inspector had

no further question and this item is closed,

e. (Closed) Unresolved Item (267/8623-06): This item concerned an

observation that no audit had been perfonned of an offsite commercial

records facility utilized by the licensee to store quality records.

An audit was performed in early 1987 with a conclusion that the .

facility met the requirements of ANSI N45.2.9. The audit report also

stated that the audit would be the first and last audit of the

facility since it was not being used to store quality records based

on the licensee's records program. This program requires that all

quality records be microfilmed prior to being forwarded to the

storage facility. The microfilms are stored in the onsite Records

Center and are considered to be the quality records. Administrative

Procedures Manual (APM) Procedure Q-17, Issue 11, "Quality Records,"

while not going into specific detail, does require that all quality

records be stored in the onsite Records Center. The records to be

stored and the duration of the storage are defined in a Records

Retention Schedule. In order to provide some confirmation of the

written conclusion of the audit report, the NRC inspector interviewed

the supervisor of the personnel working in the Records Center. In

response to a statement requesting confirmation that there were no

exceptions to all quality records being stored onsite, the supervisor

offered that there was one proceduralized exception. The supervisor

offered the current Records Retention Schedule which indicated that

charts made by control room stri) chart recorders were stored onsite

for a period up to 2 years and tien were sent to the offsite facility

for lifetime storage. The supervisor stated that the microfilming

equipment could not handle the charts and the records center building

was not large enough to permanently house the volume of records

involved. It appears that the licensee has violated APM Procedure

Q-17

10 CFRandPart thereby(the requirenents of Criterion XVII of Appendix B to

50. 267/8815-01)

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3. LER Followup

(Closed) LER 84-05: This LER was submitted to the NRC on April 26, 1984,

and involved a finding made during a surveillance test of the prestressed

concrete reactor vessel tendons. The initial finding was that individual

wires in some tendons had failed With the initial apparent cause of

failure being a corrosion mechanism. Liftoff tests, which verify presence

of adequate preload in the tendon, indicated that the reactor vessel

remained within its oesign basis even though some wires had failed.

Supplemental reports were submitted frequently as new information became

available with a final (revised) report submitted June 16, 1986. The NRC

inspector reviewed several correspondences between NRR and the licensee

which indicated that there had been no significant continuing degradation

of the tendons based on the results of additional surveillance tests

conducted at 6-month intervals since the initial finding. Based on >

discussions with the NRR Project Manager and on review of the reports of ,

the test, this LER is considered closed from an inspection standpoint. '

4. Control of Design Chsnges and Modifications (37700)

The purpose of this area of the inspection was to verify continued  ;

adherence by the licensee to NRC' requirements and to commitments made to

the NRC in the area of design changes and modifications that are not

considered tc require NRC approval under 10 CFR 50.59. The NRC inspector

reviewed the following documents and procedures germane to the control of

design changes and modifications:

o Updated Final Safety Analysis, Revision 5, paragraph B.5.3, "Design

Controls"

o Procedure Q-3, Issue 12, dated June 17, 1988, "Design Control System"

o Procedure G-2, Issue 22, dated February 10, 1988, "Fort St. Vrain ,

Pror.edure Systems"

o Procedure G-3, Issue 8, dated May 27,1987, "Action Request-Preparation

and Processing"

o Procedure G-9, Issue 9, dated April 6, 1988, "Controlled Work

Procedures"

o Procedure ENG-1, Issue 13, dated February 25, 1988, "Design Change

Control"

o Procedure ED-100, Issue 4 February 25, 1988, "Change Notice '

Preparation and Document Control"

o Procedure SEMAP-12, Issue 2, dated June 16, 1988, "CWP Preparer's

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Instructions"

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o Procedure SEMAP-11, Issue 2, dated February 10, 1987, "Controlled

Work Procedure (CWP) NED Instructions"

o Procedure SEMAP-18. Issue 4, dated November 19, 1987, "Process'ng of

Temporary Configuration Reports"

o Procedure TASMAP-7, Issue 6, dated September 20, 10R7, "Work Review

Committee Guidelines"

The procedures essentially describe a program for design change and

modification control in which nearly any person in any organization can

request consideration of a proposed design change. Once approved, the

request generally goes forward to the NED for action. The NED can

originate changes as well as persons on the plant staff. Changes take on

one of two forms. One form is of an essentially permanent nature and is

documented in a Change Notice (CN) and is usually prepared within the NED

under their procedural direction. The other form is a temporary change

generally having an effect for a relatively short period of time and is

documented on a Temporary Configuration Report (TCR). The CN package,

when complete, contains a description of the change and an evaluation of

the chango at the 10 CFR 50.59 level and for environmental considerations.

Equipment qualifications are also considered and documented. Changes are

design reviewed by a person other than the originating engineer. After

completion of review and approval of basic engineering, a Procurement,

Installation, and Test Requirements document is prepared which includes a

Bill of Materials, installation sequencing, and pertinent information to

aid the users. Test requirements are included where required. When the

complete package is ready, the package is forwarded to the plant staff

which then develops a Controlled Work Package (CWP) that is reviewed and

approved by the Work Review Committee and scheduled for implementation.

The TCR packages are subject to plant manager and Plant Operations Review

Connittee (PORC) approval prior to implementation and are reviewed after

the fact by engineering. The same considerations outlined above for the

CN are applied to these changes.

To verify implementation of the above program, the NRC inspector selected

the following four CNs from a group of approximately four dozen scheduled

for partial or complete implementation during the plant outage period of

July 5 through October 15, 1988.

o CN-2559 and CWP 88-157: Approves the use of elastometer "0"-ring

seals in the helium circulators in lieu of the present metallic

rings. This is a nonmandatory change that can be implemented as

necessary,

o CN-2715 and CWPs 88-0167 through -0174, and 88-0177: This package

provides for a substantial number of bolting and antiseize material

changes in the helium circulators. In all, approximately 46 detailed

changes are documented.

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o CN-1878 and CWPs88-086 through -094: Moves certain stripchart type

recorders from the main control board to an auxiliary panel.

o CN-2747 and CWPs88-073 and -074: Replaces two existing valves with

different model valves from the same vendor since the original valves 1

are no longer available. Components for the old valves can no longer j

be obtained.

The NRC inspector reviewed each package in detail and found that all I

trocedural requirements had been satisfied. The level of engineering

detail was considered to be excellent as were the work instructions given

for installation. The results of additional NRC inspection of design

changes and controls implemented on the helium circulators are documented

in paragraph 5 of this report.

In regard to implerantation of the temporary changes, the NRC inspector

obtained the following four TCRs from the Records Center that had been

fully completed:

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o TCR 87-10-01: Authorized installation of a temporary

electrical cable to replace a cable that had been damaged.

o TCR 87-10-02: Authorized installation of a temporary

electrical cable to replace a cable that had been damaged.

o TCR 87-09-01: Authorized the removal of one cell from battery N9243 ,

in order to use the cell in another battery bank. ,

o TCR 87-09-02: Authorized connecting a temporary line to provide

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makeup water to the bearing water surge tank when reactor is at low

pressure.

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The above TCRs were all closed with restoration of normal service in

approximately 2 months af ter initiation. The technical and safety basis ,

for each of the changes was well documented and each had received PORC  !

approval.

No violations or deviations were identified in this area of the

inspection. l

S. Refurbishment of Reactor Helium Circulators [

The purpose of this area of the inspection was to verify that design

changes and repair activities addressed 1.. PSC engineering report "Report i

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2 of Helium Circulator S/N C-2101 and Inlet Piping S/N 2001 Repair and

Modification Activities," Attachment 1 of PSC Letter P-88019 to the NRC

dated January 22, 1988, were being implemented in accordance with licensee  !

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coninitments and regulatory requirements.

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a. Review of Fastener Installation Criteria (37700)

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The NRC inspector reviewed Procedure MP-2229, "Removal and

Installation of Pelton Wheel and Turbine Stator / Rotor Assemblies,"

Issue 2, effective date July 8,1988, with respect to the coninitments

contained in the engineering report referenced above. During this

review, the NRC inspector noted that the procedure did not address:

(1)chamferingoftheedgeoftheC-2101-431 counterbores

(paragraph 5.5 of Attachment 1 to P-88019), and (2) cleaning of bolt

! holes to remove previous thread lubricants (paragraph 5.6 of

Attachment 1 to /-88019). The NRC inspector also noted that the

procedure torquing criteria for the C-2101-300-52 3/4-inch bolt

created higher preload stresses as a result of the bolt being center ,

drilled. In response to observations (1) and (2) above, the licensee  !

furnished CWP No. 880170. The NRC inspector verified by review of

this document that the requirements for chamfering of counterbores

and cleaning of bolt holes had been specified. The NRC inspector

also verified that the question of increased stress levels in t.1e -52

bolts had been evaluated with a conclusion made that the small stress

increase from the drilled hole still left the overall stress levels

significantly below yield levels.

The NRC inspector additionally reviewed Procedure QCIM-33, "Control

of Bolt Elongation Using the Stress-Mike Stress Control Computer,"

Issue 1, effective date July 8, 1988, which is utilized for

measurement of C-2101 ',00-45 bolt elonpation, and hence preload

i stress. The procedure was found to be satisfactory and consistent

with conunitments.

During the inspection, the NRC inspector questioned licensee

personnel concerning the results of the GA Technologies inspection of

the primary side of the S/N 0-2101 helium circulator. Licensee

personnel stated that they had not yet received the results of this

inspection from GA Technologies. This subject is considered to be an

open item pending the licensee obtaining the inspection results and

NRC review. (267/8815-02)

No violations or deviations were identified in this area of the

inspection,

b. Circulator Wobble Monitoring System (37700)

< The NRC inspector reviewed the proposed operation of the circulator

wobble monitoring system. Circulator shaft wobble is currently '

monitored by dedicated oscilloscopes and recorded daily per

Test T-369. A surveillance procedure, now in draft fann, will be

implemented frr monitoring of this parameter. The circulator shaft

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wobble data dvectly reflects sideways (radial) movement of the shaf t ,

at the probe location. Based on the limited clearances of the lower (

, bearing (about 2 nils), the licensee has decided that a maximum

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wobble of 0.5 mils will be allowed. (The plant operations staff will

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be alerted at 0.3 mils of wobble.) The NRC inspector had no further

questions or comments concerning this system.

No violations or deviations were identified in this area of the

inspection.

c. Receipt Inspection of Fasteners (38702)

(1) Installation of Helium Circulator S/N 0-2101: As a result of a

prior observation that the 5/N C-2101 helium circulator, which

had been received from GA Technologies following refurbishment, *

was in the process of being installed, the NRC inspector decided

to commence inspection in this subject area relative to

fasteners installed by GA Technologies. At the start of the

review, the NRC inspector requested verification that all PSC

receipt inspection activities were complete for this circulator.

QA/QC personnel informed the NRC inspector that a hold tag had '

been placed on the circulator on receipt as a result of the

physical inability to place the circulator in the receiving

area. This hold tag was placed to alert plant personnel that  !

receipt inspection had not been completed and had not been  ;

removed as of the time of this discussion. The QA/QC supervisor ,

ascertained that the circulator had been installed and initiated '

a stop work action.

Paragraoh 4.8 of APM Procedure Q-8, "Identification and Control

of Materials, Parts, and components," Issue 7, effective date

September 30, 1986, provides for conditional release of

materials, which have not been accepted by QA/QC, for the

purpose of alleviating del.tys in performance of construction or

plant maintenance. A conditional release requires the approval

of the NED Site Engineering Manager / Designee and the QA Services

Manager / Designee. The NRC inspector ascertained from the NED

Site Engineering Manager that a request had not been made for i

conditional release of the circulator. The failure to obtain

appropriate authorization for installation of the S/N C-2101

helium circulator is an apparent violation of Criterion VIII of

Appendix B to 10 CFR Part 50 and the licenset's approved QA

program. (267/8815-03)

The NRC inspector additionally ascertained on August 2, 1988,

that NCR 88-199 had been initiated on July 19, 1988, relative to

materials documentation furnished by GA Technologies. This NCR ,

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was not dispositioned until after installation of the S/N C-2101

helium circulator. As a result of this status, the NRC

inspector reviewed APM Q-15. "Nonconfonnance Reports," Issue 7,

effective date March 15, 1988, with respect to the nature of

work activities permitted on a component affected by an open

NCR. Paragraph 3.7 of this procedure was found to prohibit work

on the nonconforming part of an item until the NCR has been ,

dispositioned and approved. While this requirement can be

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construed as not prohibiting circulator installation, the

circumstances bring into potential question the effectiveness of

existing controls relative to Criterion XV of Appendix B to

10 CFR Part 50.

(2) Review of Fastener Certifications: The NRC inspector reviewed

materiali documentation which was furnished by GA Technologies

with repbcement circulator fasteners. This review was

performed relative to the comitments and criteria contained in

Table 3 and paragraphs 5.2 and 6.0 of Attachment 1 to P-88019,

with the emphasis placed on fastener part numbers which had

exhibited prior stress corrosion cracking. The NRC inspector

noted no discrepancies relative to the certified material test

report data and heat treat charts furnished for fasteners which

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had been changed to Inconel X-750 materials.

During this review, it was noted, however, that no vendor

certification had been received for 16 spring plungers (Item 37

Purchase Order (P0) N8446 through Supplement 02 dated June 6

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1988) which were changed by Table 3 of Attachment 1 to P-88019

from carbon steel to Inconel X-750. As a result of NRC

inspector questions on the absence of documentation, PSC

personnel contacted GA Technologies and were infonned that a

certified material test report was available which would be sent

to PSC. This contact also e.stablished, however, that the

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modified Inconel X-750 heat treatment comitted to by ,

paragraph 5.2 of Attachment 1 to P-88019 had not been used for

the spring plungers. It would appear from the available

information that the spring plungers were not considered to be

fasteners and thereby falling in the scope of comitments made ,

for fastener procurement by Attachment 1 to P-88019. The items  !

were, however, included in the Table 3 of Attachment 1 to  ;

i P-88019 list of fasteners and lockwashers, without any

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modification of comitments subsequently being mede. The

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failure to comply with the comitments made by Attachment 1 of

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P-88019 relative to procurement of spring plungers is an

i apparent deviation. (267/8815-04)

No discrepancies were noted by the NRC inspector with respect to

' tht certification applicable to the 3/4-inch C-2101-300-104 and

-105 A286 steam ducting to bearing assembly bolts (original part

i numbers were, respectively, C-2101-300-52 and -45). The NRC '

! inspector did observe that only tensile strength values had been

! obtained by the vendor by tensile test of a completed fastener, .

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but had no further questions as a result of Table 2 of

l Attachment 1 to P-88019 showing the minimum yield strength for 1

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the material was an estimated value. l

I The NRC inspector noted from review of P0 N8446 that PSC had ,

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required only a certificate of conformance from GA Technologies

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in regard to many of the detailed QA requirements for fastener

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procurement committed to by paragraph 6.0 of Attachment I to

P-88019. The NRC inspector was thus unable to specifically

verify implementation of these comitments by GA Technologies in

the procorement process. This subject is considered an open

item pending completion of a planned NRC inspection at GA

Technologies. (267/8815-05)

The NRC inspector additionally reviewed a PSC procurement for

steam inlet piping stud material (Part No. FP-91-M-19-4-42),

which was indicated by paragraph 5.2 of Attachment 1 to P-88019

to have been changed from SA-193 Grade B5 to'SA-193 Grade B7

material because of material availability reasons. It was noted

that the stud material was ordered as bar stock from two

separate vendors with no heat treat charts obtained, required

threads rolled by another vendor, and fluorescent magnetic

particle examination of the threads performed by PSC QA/QC

personnel.

Paragraph 6.0 of Attachment 1 to P-88019 comitted, however, for

fastener procurement to require furnace charts for all heat

treating. This paragraph additionally comitted to fluorescent

penetrant examination of completed fasteners per ASME Code

Section V, Article 6, with no linear indications permitted in

the shanks or threads. In response to a question on why the

comitted nondestructive examination method was not used, the

NRC inspector was shown NCR 88-142. This NCR identified that

fluorescent magnetic particle examination had been used and was

dispositioned as acceptable based on equal sensitivity of the

method and that the method was preferred by QA.

The NRC inspector additionally questioned why the shanks of

these long studs (approximately 17 feet) had not been examined

as comttted. The rationale provided by PSC personnel was that

only the threaded portions of the studs were actually loaded

after installation. The NRC inspector did not disagree with the

technical accuracy of this information after examination of an

assembly. No information was provided to the NRC inspector,

however, which would indicate that any modifications had been

made to commitments contained in Attachment I to P-88019. The

f ailure to fully implement these comitments with respect to

steam inlet piping studs is an additional example of the

apparent deviation described above. (267/8815-04)

While reviewing the PSC fluorescent magnetic particle

examination report for the threads on the steam inlet piping

studs, the NRC inspector noted that the record indicated only

one direction of examination was performed; i.e., only a three

turn coil was denoted as being used. The NRC inspector then

reviewed the applicable Procedure QCIM-24 "Fluorescent Magnetic

Particle Inspection," Issue 4, effective date September 22,

1987. litis review confirmed that the procedure was consistent

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with ASME Code Section V requirements relative to two directions

of examination being required, with the lines of magnetic flux

for the second examination being perpendicular to the flux ,

direction in the first examination. The NRC inspector questioned

the adequacy of the magnetizing current used for the coil

examination with respect to the equation specified by ASME

Code Section V and the procedure for determining this parameter.

PSC personnel informed the NRC inspector that a magnetic particle

field indicator had been used to assure the adequacy of the

magnetizing field. Use of this device is permitted as an

alternate to the equation for assuring adequacy of magnetizing i

field. The failure of PSC personnel to perform the required two

directions of magnetic particle examination is an apparent '

violation of Criterion IX of Appendix B to 10 CFR Part 50 and

the licensee's approved QA program. (267/8815-06)

d. Repair Welding and Examination of Steam Ducting Struts (55050,57060)

The NRC inspecter requested a repeat liquid penetrant examination of

a sample of upper strut to scroll plate weld repairs in the "A"

S/N C-2102 helium circulator. The NRC insSector selected Struts 4

and 11 for this examination and examined t1e results. No relevant '

indications were noted. The NRC inspector reviewed the applicable

Procedure QCIM-20. "Liquid Penetrant Tt:st Procedure," Issue 6,

effective date June 70, 1987, and found it to be consistent with the

requirements of ASME Code Sections III and V.

The NRC inspector examined the weld data sheets, filler material i

certified material test reports, and liquid penetrant examination

reports which were applicable to PSC repair welding of the upper

strut to scroll plate welds in the S/N C-2102 and C-2105 helium

circulators. A verification was also performed that the welders j

documented on the weld data sheets as performing the weld repairs -

were included ir the welders qualification status listing for the

applicable Welding Procedure Specification (WPS).

During the review, the NRC inspector noted that different WPSs were

indicated by the weld data sheets as being used for the repairs made l

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to the two helium circulators. In following up the reasons why this

< happened, the NRC inspector ascertained the following information.

- NCR 88-186 was initiated on July 13, 1988, as a result of the liquid

penetrant examination identification of linear indications in all 16  ;

i upper strut to scroll plate welds in the S/N C-2105 helium

circulator. On the same date, NCR 88-190 was initiated relative to

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the WPS to be used for repair welding, WPS SA/B-3, being incorrectly

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qualified for ASME Code Section IX P-5 to P-5 material rather than

the re;uired P-4 to P-4 material qualification. This NCR was

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dispositioned "ws-as-is," with the instruction given to perform

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welding on the circulator using WPS SA/B-3 and to perform a P-4

material procedure qualification prior to operation of the

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circulator. The disposition additionally permitted use of a

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different welding process (i.e., shielded metal arc) to the gas

tungsten arc welding (GTAW) process specified by WPS 5A/B-3, again on

the premise of qualification prior to circulator operation. This

approach fails to recognize that special processes are required by

Criterion IX of Appendix B to 10 CFR Part 50 and APM Procedure Q-9,

"Control of Special Processes," Issue 8, effective date December 1,

1986, to be performed using qualified procedures. The failure to

qualify a WPS for P-4 material application prior to use is considered

an additional example of the apparent violation described in  !

paragraph 5.c above. (267/8815-06)

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The NRC inspector noted that the GTAW WPS for P-4 material, ,

WPS 4-A/B-3, was qualified prior to use for repairs made to the upper

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strut to scroll plate welds in the "A" helium circulator

(S/N C-2102). This WPS reduced the oermissible maximum interpass

temperature to 400*F from the 600*F permitted by WPS 5A/B-3 and also l

slightly increased the permissible amperage range, neither of which

parameters are ASME Code Section IX essential variables for the -

application.

The NRC inspector additionally reviewed welding and nondestructive

examination records which were applicable to repair welding by GA

Technologies of the upper strut to scroll plate welds in the

S/N 0-2101 helium circulator. During the review, the NRC inspector

noted that the record package furnished to him by PSC included a

welding procedure qualification record (PQR) but not a WPS. A copy l

of the GA Technologies WPS used for the repair welding was requested  ;

from PSC. The NRC inspector was subsequently informed by PSC  ;

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personnel that GA Technologies personnel had stated to PSC that the

same parameters documented on the PQR were used for the repair {

welding. In response to a direct question on the existence of a WPS,

the NRC inspector was informed that GA Technologies had not prepared

a WPS for this activity. This subject is considered unresolved i

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pending performance of a planned NRC inspection at GA Technologies.

(267/8815-07)

6. Unresolved Item

Unresolved items are matters about which more information is required in

order to ascertain whether or not the items are acceptable, violations, or

deviations. The following unresolved item was discussed in this report:

Pa ragraph Item Subject

5.d 267/8815-07 Performance of repair .

l welding without a WPS l

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7. Exit Interview

Exit interviews were conducted en July 14 and August 5, 1988, with the

licensee personnel denoted in paragraph 1. During these interviews, the

NRC inspectors reviewed the scope and findings of the inspection.

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