ML20154E434
| 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: |
| 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:
' Docket:
50-267
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Licensee:
Public Service Company of Colorado (PSC)
P.O. Box 840
Denver, Colorado 80201-0840
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Facility Name:
Fort St. Vrain Nuclear Generating Station (FSV)
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Insp?ction At:
FSV, Platteville, Colorado
Inspection Conducted: July 11 through August 5, 1988
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Inspectors:
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7- P- Pr
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I. Barnes, Chief, Materials and Quality
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Programs Section, Division of Reactor Safety
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g R. G. Taylor, Reactor Inspector, Materials and
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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:
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F-p-pp
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
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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
R. O. Williams, Jr., Vice President, Nuclear Operatica
- #D. Warembourg, Manager, Nuclear Engineering Division (NED)
- M. E. Miehoff, Nuclear Design Manager
- F. J. Novachek, Nuclear Support Manager
- P. F. Tomlinson, Manager, Quality Assurance, (QA) Division
- 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.
Denotes those persons attending the exit interview on July 14, 1988.
Denotes those persons attending the exit interview on August 5,
1988.
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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
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."
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Based on the review of the audit reports referenced in the previous
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item, the audits are considered thorough with adequate coverage of
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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
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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
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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 and thereby(the requirenents of Criterion XVII of Appendix B to
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.
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discussions with the NRR Project Manager and on review of the reports of
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the test, this LER is considered closed from an inspection standpoint.
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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:
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Updated Final Safety Analysis, Revision 5, paragraph B.5.3, "Design
Controls"
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Procedure Q-3, Issue 12, dated June 17, 1988, "Design Control System"
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Procedure G-2, Issue 22, dated February 10, 1988, "Fort St. Vrain
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Pror.edure Systems"
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Procedure G-3, Issue 8, dated May 27,1987, "Action Request-Preparation
and Processing"
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Procedure G-9, Issue 9, dated April 6, 1988, "Controlled Work
Procedures"
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Procedure ENG-1, Issue 13, dated February 25, 1988, "Design Change
Control"
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Procedure ED-100, Issue 4 February 25, 1988, "Change Notice
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Preparation and Document Control"
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Procedure SEMAP-12, Issue 2, dated June 16, 1988, "CWP Preparer's
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Instructions"
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Procedure SEMAP-11, Issue 2, dated February 10, 1987, "Controlled
Work Procedure (CWP) NED Instructions"
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Procedure SEMAP-18. Issue 4, dated November 19, 1987, "Process'ng of
Temporary Configuration Reports"
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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.
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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,
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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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CN-1878 and CWPs88-086 through -094: Moves certain stripchart type
recorders from the main control board to an auxiliary panel.
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CN-2747 and CWPs88-073 and -074:
Replaces two existing valves with
different model valves from the same vendor since the original valves
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are no longer available. Components for the old valves can no longer
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be obtained.
The NRC inspector reviewed each package in detail and found that all
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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TCR 87-10-01:
Authorized installation of a temporary
electrical cable to replace a cable that had been damaged.
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TCR 87-10-02:
Authorized installation of a temporary
electrical cable to replace a cable that had been damaged.
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TCR 87-09-01:
Authorized the removal of one cell from battery N9243
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in order to use the cell in another battery bank.
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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
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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
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for each of the changes was well documented and each had received PORC
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approval.
No violations or deviations were identified in this area of the
inspection.
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S.
Refurbishment of Reactor Helium Circulators
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The purpose of this area of the inspection was to verify that design
changes and repair activities addressed 1.. PSC engineering report "Report
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of Helium Circulator S/N C-2101 and Inlet Piping S/N 2001 Repair and
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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
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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
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drilled.
In response to observations (1) and (2) above, the licensee
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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
stress.
The procedure was found to be satisfactory and consistent
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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
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wobble monitoring system. Circulator shaft wobble is currently
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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
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at the probe location.
Based on the limited clearances of the lower
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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
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physical inability to place the circulator in the receiving
area.
This hold tag was placed to alert plant personnel that
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receipt inspection had not been completed and had not been
removed as of the time of this discussion.
The QA/QC supervisor
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ascertained that the circulator had been installed and initiated
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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
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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
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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
(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
had been changed to Inconel X-750 materials.
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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
1988) which were changed by Table 3 of Attachment 1 to P-88019
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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
modified Inconel X-750 heat treatment comitted to by
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paragraph 5.2 of Attachment 1 to P-88019 had not been used for
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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
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for fastener procurement by Attachment 1 to P-88019. The items
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were, however, included in the Table 3 of Attachment 1 to
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P-88019 list of fasteners and lockwashers, without any
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
apparent deviation.
(267/8815-04)
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No discrepancies were noted by the NRC inspector with respect to
tht certification applicable to the 3/4-inch C-2101-300-104 and
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-105 A286 steam ducting to bearing assembly bolts (original part
numbers were, respectively, C-2101-300-52 and -45).
The NRC
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inspector did observe that only tensile strength values had been
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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
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Attachment 1 to P-88019 showing the minimum yield strength for
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the material was an estimated value.
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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
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
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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
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field.
The failure of PSC personnel to perform the required two
directions of magnetic particle examination is an apparent
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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
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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
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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
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documented on the weld data sheets as performing the weld repairs
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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
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to the two helium circulators.
In following up the reasons why this
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happened, the NRC inspector ascertained the following information.
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NCR 88-186 was initiated on July 13, 1988, as a result of the liquid
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penetrant examination identification of linear indications in all 16
upper strut to scroll plate welds in the S/N C-2105 helium
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circulator. On the same date, NCR 88-190 was initiated relative to
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
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the re;uired P-4 to P-4 material qualification. This NCR was
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
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material procedure qualification prior to operation of the
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
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paragraph 5.c above.
(267/8815-06)
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The NRC inspector noted that the GTAW WPS for P-4 material,
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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
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slightly increased the permissible amperage range, neither of which
parameters are ASME Code Section IX essential variables for the
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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
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of the GA Technologies WPS used for the repair welding was requested
from PSC. The NRC inspector was subsequently informed by PSC
personnel that GA Technologies personnel had stated to PSC that the
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same parameters documented on the PQR were used for the repair
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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
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pending performance of a planned NRC inspection at GA Technologies.
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(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
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welding without a WPS
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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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