ML20198A376
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UN:TED STATES 8"
NUCLEAR REGULATORY COMMISSION o
WASHINGTOM. D. C. 20555
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OCT e o 1985 MEMORANDUM FOR:
J. P. Knight, Acting Director Division of Engineering FROM:
Vincent S. Noonan, Director Comanche Peak Project Division of Licensing
SUBJECT:
SAFETY EVALUATION REPORT ON THE VISUAL INSPECTION OF WELDS THROUGH PAINT AT THE COMANCHE PEAK SITE.
Texas Utilities has provided the NRC staff with a copy of the proposed CPRT Project Procedure No. CPP-022, " Supplementary Evaluation of Visual Welding Inspection Techniques". Texas Utilities developed this procedure in accordance with NRC recomendations. These recommendations were presented in a memorandum from W. Johnston to V. Noonan, dated August 29, 1985,.in which the Materials Engineering Branch provided a position based on the information submitted to date. These recommendations were verbally supplied by the NRC staff in a public meeting with TUGC0 on September 17, 1985. This position, which will appear in the Comanche Peak Steam Electric Station Supplemental l
Safety Evaluation Report No. 12, is that one can visually inspect through paint for weld attributes such as location, presence, and length, but weld attributes related to quality present problems when using this method. Also suggested by the NRC staff in this meeting was a sampling program. Texas Utilities proposed a sampling program which was described in a September 26, 1985 conference call. Enclosed is the documentation of the applicant's proposed procedure. Please review this information and prepare a Supplemental Safety Evaluation Report, providing your coments on this program, no later than November 25, 1985. This date was agreed upon in a telephone conversation October 29, 1985, between A. Vietti-Cook, Project Manager and W. Hazelton.
If the NRC staff is satisfied with this proposed program, we will close this item out in a future SSER.
In addition, please advise us of the necessary follow up by Region IV on the implementation of this pro f
f W
an Director omanche ak roject Division of Licensing
Enclosure:
Letter from W. Counsil (TUGCO) to V. Noonan (NRC), dated October 3,1985 cc:
B. D. Liaw D. Smith S. Burwell b
h h p D *i g %
R. Ballard I. Barnes, Region IV e
T T. Westerman, Region IV L. Shao e
p W. Hazelton h-
Log i TXX-4580 TEXAS UTILITIES GENERATING COMPANY File # 10010 SKYWAY TOWER
- 400 NORTH OIJVE STREET. L.B. 81
- DAll.AS. TEXAS 75308 October 3, 1985 UNEL?2?h*h Director of Nuclear Reactor Regulation Attention: Mr. Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION DOCKET N05. 50-445 AND 50-446 VISUAL WELD INSPECTION
Dear Mr. Noonan:
As discussed in the September 26 conference call between members of Texas Utilities and the NRC staff, enclosed is a copy of the CPRT Project Procedure No. CPP-022, " Supplementary Evaluation of Visual Welding Inspection Techniques". This procedure was developed in accordance with NRC recommendations made in NRC memorandum from William V. Johnston to Vincent S. Noonan dated August 29, 1985 which was included as part of the transcript of the NRC/TUGC0 meeting of September 17, 1985. The procedure is oeing submitted for review and comments.
Should you have any questions in this matter, please contact this office.
Very truly yours,
((). h.
W. G. Counsil n
ure By:
Wohn S. Marshall Richard P. Denise - Region IV Licensing Supervisor c-Ian Barnes - Region IV Annette Vietti Cook QM A DnTSION OF TEXAS UTTLETTES ELECTRIC CDMPANY
l *' ' 5 Page 1 of 8 EVALUATION RESEARCH CORPORATION COMANCHE PEAK RESPONSE TEAM PROJECT PROCEDURE FOR QA/QC ISSUE-SPECIFIC ACTION PLANS VII.b.3, VII.b.5 and VII.c PROCEDURE NO.: CPP-022 REVISION: 0
(/27/86 ISSUE DATE:
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SUPPLEMENTARY EVALUATION OF VISUAL WELDING INSPECTION TECHNIQUES PreparedBy:(w 9!2787 u_
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CPP-022 Revision: 0 1.0 PURPOSE This procedure describes the methodology the QA/QC Review Team will utilize in gathering and evaluating information to supplement the conclusions previously reached regarding the reinspection of safety related non-pressure boundary welds through paint.
2.0 APPLICABILITY The information developed as a result of the implementation of this procedure is applicable to the visual reinspection of completed, inspected, and accepted safety related non-pressure boundary welds being conducted by the QA/QC Review Team in accordance with ISAPs VII.b.3, Pipe Support / Inspections, VII.b.5, Electrical Raceway Support Inspections, and VII.c.,
Construction Reinspection / Documentation Review Plan.
3.0 REFERENCES
3.1 ISAP VII.c., Construction Reinspection / Documentation Review a
Plan 3.2 ISAP VII.b.3, Pipe Support Inspections 3.3 ISAP VII.b.5, Electrical Raceway Support Inspections 3.4. Position Paper on Visual Inspection of Painted Support Welds prepared by C. F. Reeves and H.F. Feery, J. O.15297, dated June 17, 1985.
3.5 Quality Instruction QI (Later) 4.0 GENERAL 4.1 Responsibilities 4.1.1 The QA/QC Review Team Inspection Group is responsible for conducting the inspections of welds as required by this procedure and Reference 3.5.
4.1.2 The QA/QC Review Team Safety Significance Evaluation Group (SSEG) is responsible for conducting engineering evaluations of inspection results obtained as a result of implementation of this procedure which do not conform' to VWAC or ASME (an applicable) welding acceptance criteria.
4.1.3 The QA/QC Review Team Welding Engineer is responsible for the overall implementation of this procedure including the Phase II evaluation of results utilizing the results of the SSEC evaluations and the expertise of other welding, QC, and statistical consultants as required.
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CPP-022 Revision: 0 4.0 GENERAL (Cont'd) 4.1 Responsibilities (Cont'd)
The Welding Engineer is also responsible for identifying the portions of this procedure which are to be witnessed by USNRC representatives and for providing appropriate notification to the USNkC of such activities when they occur.
4.1.4 The QA/QC Review Team Leader has the responsibility for the final decision of the acceptability of the QA/QC Review Team reinspection of completed non-pressure boundary welds through paint.
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4.2 Policy 4.2.1 Personnel Qualification Requirements I
Personnel conducting inspections shall be i
a.
certified Level II or III in accordance with ANSI N45.2.6 and Regulatory Guide 1.58.
b.
All personnel participating in the implementation of this procedure shall be t
qualified in accordance with Para. III.H of CPRT Program Plan.
4.2.2 Procedures Development and implementation of this procedure shall be conducted in accordance with CPRT Program Plan and the ERC Management Program Plan.
4.3 Procedure Overview The development of supplementary information regarding inspection of non-pressure boundary velds through paint as specified by this procedure takes place in two phases as outlined below:
4.3.1 Phase I a.
Selection of Samples A random sample of 60 weld connections containing completed and QC accepted site welds is selected from the ISAP VII.c populations which in turn contain non-pressure. boundary welds which are to be inspected through paint by the QA/QC Review Team.
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CPP-022 Revision: 0 4.0 GENERAL (Cont'd) 4.3 Procedure Overview (Cont'd) b.
Inspection of Welds from Random Sample Welds coated with paint are inspected in accordance with Reference 3.5 prior to removal of paint. After completion of these inspections paint is removed and all of the 60 randomly selected weld connections are reinspected to VWAC or ASME weld inspection riteria as applicable. Results of the inspections are documented including any areas which are identified as not in compliance with weld acceptance criteria.
4.3.2 Phase II SSEG Evaluation of Deficient Welds a.
Weld connections if any, which contain welds.
not conforming to VWAC or ASME weld inspection criteria are analyzed by the SSEG to determine the impact of the nonconforming welds on the original design of the items.
The results of these analyses are documented.
b.
Overall Evaluation of Results The inspection results from 4.3.lb. and, if applicable, the engineering evaluations from 4.3.2a., are evaluated and compared with the conclusions of Reference 3.4.
Based on this evaluation a report is developed and submitted to the QA/QC Review Team Leader which recommends whether or not reinspection should be conducted through paint for the applicable Vll.c. populations and, if so, what attributes should be reinspected.
c.
Final Conclusion Based on 4.3.2b. above, the QA/QC Review Team Leader decides how to proceed with weld reinspections of the applicable VII.c populations.
5.0 PROCEDURE 5.1 Gene ral This procedure will be implemented in two phases.
Phase I activities include (1) definition of the population, (2) selection of the random sample..(3) inspection of selected weld connections, and (4) documentation of results.
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CPP-022 Revision: 0 5.0 PROCEDURE (Cont'd) 5.1 ceneral (Cont'd)
Phase II consist of (1) the collection, review, and evaluation of documented inspection results. (2) the analysis of data obtained. (3) determination of any further evaluation required, and (4) issuance of a final report with conclusions and recommendations, if appropriate.
5.2 Phase 1 - Reinspection 5.2.1 Safety related, non-pressure boundary welds subject to this inspection procedure include the following populations as identified in Reference 3.1:
LBSN (Large Bore Pipe Supports - Non-rigid)
LBSR (Large Bore Pipe Supports - Rigid)
SBPS (Small Bore Pipe Supports)
STEL (Structural Steel)
INSP (Instr. Pipe / Tube Supports)
HVDS (HVAC Duct Supports)
COSP (Cat. 1 Conduit Supports)
PWRE (Pipe Whip Restraints)
DUPL (HVAC Ducts / Plenums)
CATY (Cable Tray) i EEIN (Elect Equip Install)
NOTE:
The above populations from ISAP VII.c. were selected based on the homogeneity of the overall installation activities. However, because of the similarity of the welding processes utilized in the applicable VII.c.
populations, these populations may be grouped together into one homogeneous population for l
the purpose of the evaluation specified by this procedure.
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CPP-022 Revision: 0 5.0 PROCEDURE (Cont'd) 5.2 Phase 1 - Reinspection (Cont'd) 5.2.2 The combined population from which the inspection sample described herein is to be selected shall be those items previously selected in accordance with Reference 3.1.
(The initial sample of 60 (each) from the populations listed in Para. 5.2.1) 5.2.3 The items from each of the 11 populations shall be consecutively numbered 1 through 660 (11 groups x 60 each).
5.2.4 Random number tables provided by the CPRT Statistics Consultant shall be utilized to select the sample. The required sample size is 60 welded connections.
'l 5.2.5 If the item selected has no velded connections, that item shall be passed over, an'other random number selected, and another item selected until the required sample size is accumulated.
5.2.6 If the item selected has several welded connections, the connection to be included in the sample shall be chosen by a second random selection process.
NOTE:
In general, a weld connection is defined as the total number of welds joining two members of an item or assembly together.
In certain cases, variations from this definition may occur because of the configuration of the item containing the connection.
In these cases, the connections shall be reviewed and defined by the Review Team Welding Engineer and the applicable ISAP VII.c. Population Engineer.
The following steps shall be conducted during the i
second random selection of the weld connection for the i
items containing more than one weld correction:
{
a.
The veld connections of the item shall be consecutively numbered 1 through n.
For example, if the item has 10 welded connections, they shall be consecutively numbered I through 10.
b.
Using random number tables provided by the i
CPRT statistics consultant, an additional random number from 1 through n shall be selected to identify the weld connection to be included in the sample of 60.
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CPP-022 Revision: 0 5.0 PROCEDURE (Cont'd) i 5.2 Phase 1 - Reinspection (Cont'd) 5.2.7 Welded connections coated with paint which have been-selected in accordance with Paragraphs 5.2.3 through 5.2.6 shall be visually inspected (through paint) by_
the QA/QC Review Team Inspection Group using ASME or VWAC acceptance criteria as appropriate in accordance with Reference 3.5.
5.2.8 Paint shall be removed from the weld connections which have been inspected through paint in accordance with Paragraph 5.2.7.
i 5.2.9 All uncoated weld connections of the sample of 60 selected in accordance with Paragraphs 5.2.3 through 5.2.6 shall then be reinspected by the Inspection Group in accordance with Reference 3.5.
4 5.2.10 Results of these visual inspections shall be documented l
and include, as a minimum, criteria utilized, weld a
connection identification, number of welds, identification of welder (s) and date of qualification, identification of weld procedure and date of qualification, attributes inspected, any discrepancies including the location, description, and other information deemed appropriate for subsequent evaluation.
Specific guidance is contained in i
Reference 3.5.
5.3 Phase II - Evaluation 5.3.1 Results of weld inspections shall be reviewed, evaluated, and analyzed during the Phase II evaluation process.
5.3.2 The selection of a sample size of 60 is intended to i
provide high (95%) confidence that a satisfactory l
evaluation of the welding process may be made utilizing data previously accumulated by the ISAP VII.c reinspections. This sample is confirmatory in nature and is not intended to serve as the basis for an accept / reject decision.
l 5.3.3 If discrepancies from applicable weld acceptance criteria are identified, they shall be evaluated by the SSEG in terms of design margin requirements and safety significance.
5.3.4 The results obtained from this sample shall be compared with previous data from Reference 3.4 to determine if any statistically significant differences exist.
If differences exist, further evaluation may be required.
This further evaluation may include only those areas of concern identified in the sample.
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CPP-022 Revision: 0 o
5.0 PROCEDURE (Cont'd) 5.3 Phase II - Evaluation (Cont'd) 5.3.5 The above results, as appropriate, along with any further evaluations and conclusions, shall be included in a final report to the Review Team Leader in accordance with Para. 4.3.2b.
The Review Team Leader, based upon this report, will decide how to proceed with veld reinspections of the applicable ISAP VII.c populations and the related ISAP VII.b.3 and VII.b.5 items.
6.0 ATTACHMENTS None e
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