ML20205R087
| ML20205R087 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 11/04/1988 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| P-88396, NUDOCS 8811090440 | |
| Download: ML20205R087 (16) | |
Text
- - - - - - - -
.j O Public Service'
- % h P.o. Box M0 Denver, CO 10201 0840 16805 WCR 191/2, Platteville, Colorado 80651 November 4, 1988 Fort St. Vrain Unit No. 1 P-88396 U. S. Nuclear Regulatory Commission ATTN
- Document Control Desk Washington, D.C.
20555 Docket No. 50-267
SUBJECT:
NRC Inspection Reports 88-15 and 88-23
REFERENCE:
(1) NRC Letter, Callan to Williams, dated September 13,1988(G-88367)
(2)
NRCLetter,CallantoWilliams}
dated October 5, 1988 (G-88401 Gentlemen:
This letter is in response to the Notices of Violation and Notice of Deviation (Reference 1) received as a result of a special inspection conducted by Region IV personnel during the period July 11 through August 5, 1988 This letter also responds to the Notice of Violation and Notice of Deviation (Reference 2) received as a result of a special inspection conducted by Mr.
L.
E.
E11ershaw at General Atomics International Services Corporation during the period September 12-16, 1988.
Since b0th these inspections are closely related, PSC requested an extension to the response to Inspection 88-15 (Reference 1). On October 11, 1988, Mr. Robert Farrell, of the NRC, granted, by phone, this delay until November 4, 1988 and requested that PSC respond to both inspections in a single letter.
The following response to the items contained in the Notice of Violation (Inspection 88-15) is hereby submitted:
A.
Failure to Follow Procedures for Control of Records Criterion XVII of Appendix B to 10 CFR Part 50 requires each licensee to establish requirements concerning record retention, such as duration, locatior., and assigned responsibility.
Administrative Procedures Manual (APM) Procedure Q-17. Issue 11, dated March 26, 1987, states in paragraph 4.5, Records Storage, "Records are stored in the Record Center building (see Attachment Q-170) which meets the requirements of a records facility as describet; by ANSI N45.2.9."
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GG11090440 801104 ADOCK0500g7 DP l
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e P-88396 Page 2 November 4,1988 l
Contrary to the above, it was determined that charts generated by control room recorders are not stored in the facility described in the above referenced procedure.
Based on an interview with the supervisor of the Records Center, and confirmed by reference i
to the ifcensee's Record Retention Schedule, these particular lifetime records are retained on site for 1 to 2 years only.
After that time, the records are sent to the Rocky Mountain Records Storage Center, a comercial facility, located in Denver, Colorado.
This is a Severity Level V violation.
(Supplement I) (267/8815-01)
(1) The Reason for the Violation if Admitted:
The violation is admitted. PSC's procedure Q-17, Quality Records, does make provisions for storing quality records offsite, but this provision applies only to those records that are microfilmed.
For those records in question (recorder charts), microfilming was not feasible.
The volume of the records, however, was significant and as a j
result of space limitations in the Records Center, the records were sent to an offsite storage facility with the 4
intent that the offsite facility provided adequate records I
protection. Although not intentional, this transfer of records represents a violation of Q-17 requirements.
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(2) The Corrective Steps Which Have Been Taken and the Results Achieved:
Recognizing that the existing Records Center cannot accommodate the volume of records in question, and that i
J modification activities of the Records Center could not be j
made until mid 1989, PSC began an imediate search of the local area for an alternate facility that would provide ANSI l
N45.2.9 type storage on an interim basis.
l l
PSC is currently comitted to the storage of Quality Records i
in a facility that meets the requirements of ANSI N45.2.9-1974, with the approved exception that we have a 3-hour fire rated facility.
PSC has not been able to find a comercial facility that would fulfill all of the requirements of ANSI l
N45.2.9-1974, however PSC has located a comercial facility that meets the equivalent requirements of ANSI N45.2.9-1979, l
PSC is finalizing a technical evaluation of this facility l
with the intent of relocating the records in question on an intorim basis to this facility as soon as possible.
i 1
- e.
P-88396 Page 3 November 4, 1988' A PDR to Q-17 will be issued to accommodate provisions for.
this conrnercial offsite. facility.
It is anticipated that the PDR and the transfer of records will be accomplished by November 30, 1988.
(3) The Correc tive Steps Which Will Be Taken to Avoid Further Violations:
PSC has initiated design modifications for the Records Center to enlarge the qualified storage area.
These modifications are currently scheduled for completion in mid 1989.
It is felt, however, that there will still be a need for an overflow facility.
In this respect, PSC will continue the evaluation of alternate facilities and will submit necessary changes to the UFSAR for the July 1989 update.
(4) The Date when Full Compliance Will Be Achieved:
Full compliance will be achieved with completion of the modifications to the Records Center and in conjunction with l
the UFSAR update.
8.
Helium Circulator Installation Without Appropriate Authorization Criterion VIII of Appendix 8 to 10 CFR Part 50 states, in part.
"Measures shall be established for the identification and control of materials,
- parts, and components, including partially fabricated assemblies..
These identification and control l
measures shall be designed to prevent the use of incorrect or i
defective material, parts, and components."
I i
Paragraph 4.8 of APM Procedure Q-8, Issue 7, dated September 30, 1986, permits conditional release of items which have not been accepted by Quality Assurance / Quality Control (QA)/(QC), provided that a conditional release request has been approved by the l
Nuclear Engineering Division (NED)
Site Engineering l
Manager /Designeo and the QA Services Manager / Designee in l
accordance with Attachments Q-8A and Q-88 of the procedure, l
Contrary to the above, S/N 0-2101 helium circulator was installed (with an attached hold tag signifying QA/QC had not performed receipt inspection) without submitting a conditional release request for the approval of the NED Site Engineering Manager and the QA Services Manager.
This is a Severity Level IV violation.
(SupplementI)(267/8815-03) i
p P-88396 Page 4 November 4, 1988 (1) The Reason for the Violation if Admitted:
The violation is admitted.
The procurement system for FSV is established and supported by procedures that utilize the concept of a receiving warehouse, which. is physically outside the plant protected' area, to process incoming material.
The receiving warehouse not only provides a physical barrier in the control of material released for use, but it also facilitates receiving inspection and provides for a material hold aree prior to material release.
The receiving warehouse, however, is relatively small in size, and whfie the vast majority of material procured for FSV can be processed in the receiving warehouse, unusually large items must be transferred to. alternate inspection locations to accommodate adequate storage while the receiving inspection process is completed.
This relocation process is utilized infrequently; therefore, methods for handling these types of materials are not specffically described by the procedural system and are handled on a case by case basis.
Given these circumstances, when circulator C-2101 arrived at FSV, a decision was made to provide for an alternate receiving / storage location within the plant (namely, the turbine deck). With full knowledge that PSC was extending the boundaries of the receiving warehouse, a QC "Hold Tag" that was intended as a receiving hold tag was placed on the circulator and it was transferred to the turbine deck for storage pending completion of receipt inspection activities.
This activity set the stage for the sequence of events that followed.
After the circulator was transferred to the turbine deck, the "Hold Tag" which was placed for receiving inspection control under the provision of Procedure Q-8, was interpreted by plant personnel as & Non Conformance Report (NCR) Hold Tag under the provision of Procedure Q-15.
Procedure Q-15 states in part
. Work shall not be allowed to begin or continue on the nonconforming part of an item until the NCR has been dispositioned and approved".
The receiving inspection activities were not signed off because an NCR had been generated as a part of the receiving inspection activities involving some material certification issues for some of the bolting material. This NCR had been dispositioned and was in the final approval cycle when the decision was made to install the circulator.
The decision to install, however, was made under the provision of Procedure 0-15 in that no work was being performed on the nonconforming part of the circulator, since the bolts in question, as identified by the NCR,were still accessible, and the NCR was in the approval cycle. The circulator was in the installation process when it was identified that the receiving inspection had not been signed off and the "Hold Tag" was a receiving issue as well as ao NCR issue,
j P-88396 Page 5 November 4, 1988 (2) The Corrective Steps'Which Have Been Taken and the Results Achieved Upon notification that the he11um circulator was being installed prior to completion of the receiving inspection process, stop work was implemented.
The NCR resulting from the incomplete inspection was completed and transmitted to the Receiving Inspector.
The i
Receiving Inspector completed the Receiving Inspection i
Report (RIR) and removed the hold from the Receiving Inspection Tag.
(3) The Corrective Steps Which Will be Taken to Avoid Further i
Violation There are few cases where material is too large and /or.
I inappropriate to inspect at' the receiving warehouse f
facil i ty.
PSC considers the lack of adequate material control and the installation of circulator C-2101 without a i
full. receipt inspection to be an isolated case.
Procedures e.xist for receipt inspections, but these procedures can be clarified to address these types of unusual circumstances, j
Procedure Q-7 will be revised to address how PSC can store large items at a segregated, alternate location for receiving inspection.
This clarification will ensure that the circumstances are documented and that a receiving i
inspection "Hold" is on the material.
Additionally, Procedure P-5 will also be revised to address the identification, authorization and controls needed to establish alternate receipt inspection areas as well as the controls for releasing material from the area.
(4) The Date When Full Compliance Will be Reached Procedures Q-7 and P-5 will be revised by January 15, 1989, i
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P-88396 Page 6 November 4, 1988 C.
Failure to Control Special Processes Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "Measures shall be established to assure that special processes, including welding, nondestructive testing,... are controlled and accomplished... using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Contrary to the above:
)
l 1.
Steam inlet piping stud threads (Part No. FP-91-M-19-4-42) were fluorescent magnetic particle examined in one direction only, and not in the directions required by paragraph 4.2.7 of Procedure QCIM-24, Issue 4, effective cate September 22, 1987.
l 2.
Repair welding of upper strut to scroll plate welds in the "B" Helium Circulator, S/N C-2105, was performed prior to quaf f fication of the welding procedure specification.
This is a Severity Level IV violation (Supplement I) (267/8815-06) l l
(1) The Reason for the Violation if Admitted: (Part 1) l The violation is admitted.
PSC agrees that the fluorescent l
magnetic particle examination of the steam inlet piping stud thresds (Part No.
FP-91-M-19-4-42) was not performed in strict accordance with Procedure QCIM-24, Issue 4
"Fluorescent Magnetic Particle Inspection." The procedure required two directions of examination, with the Ifnes of magnetic flux for the second examination being perpendicular to the flux direction in the first examination.
- However, the fluorescent magnetic particle examination was conducted on the steam inlet piping stud threads with lines of magnetic flux "approximately" in two directions using a three turn coil as allowed by ASME Code Section V.
(2) The Corrective Steps Which Have Been Taken and the Results Achieved:
(Part 1)
As an additicel confirmatory non-destructive evaluation, the steam inlet piping stud threads wre flucrescent dye penetrant examined on August 9,
1988.
This was in corrpliance with requirements contained in Attachment 1 of PSC letter P-88019.
P-88396 Page 7 November 4, 1988 In add tion, a
"Nondestructive Examination Technique Validation" was conducted to verify that the technique utilized during the original examination of the steam inlet piping stud threads was viable.
The results of the validation concluded that the three turn coil technique produces valid test results and provides 100% coverage of test pieces.
(3) Corrective Steps Which Will be Ta ken to Avoid Further i
Violations (Part 1):
Magnetic Particle Inspection Procedure QCIM-24 is being revised for clarification to require that at least two examina*'ons shall be performed on each area.
The second examina s 'on shall be with lines of magnetic flux approximately perpendicular to the flux direction in the first examination.
i (4) Date When Compliance Will be Achieved (Part 1):
Full compliance was achieved October 28, 1988 with the issuance of the revised Procedore QCIM-24.
C.
Failure to Control Special Processes (continued)
(1) The Reason for the Violation if Admitted (Part 2):
The violation as presented is not accepted for the following reasons. A welding procedure for the strut repair of C-2105 was qualified in accordance with ASME Code Section IX, and PSC Procedure Q-9, utilizing a P-5 base material.
It was detemined prior to start of the repair that the baso material of the struts and scroll plate was actually a P-4 base material. At this point in time, a technical review of the procedure for P-5 base material detemined tha t this procedure would be applicable for welding a P-4 base material for the following reasons:
1.
All essential variables for tha P-5 procedure were the same for the P-4 procedure as de fined by ASNE Code Section IX.
2.
Section IX does allow welding P-5 to P-4 base metals with a P-5 base metal qualification.
Since the essential variables of the two procedures were the same, it was interpreted that a P-5 qualification would be applicable for a P-4 base material.
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P-88396 Page 8 November 4, 1988 3.
Due to the higher alloy content of the P-5 base metal as compared to the P-4 base metal, the P-5 base metal is considered to be a more difficult material to weld.
Therefore, qualification of a P-5 base metal procedure would indicate that a P-4 base metal coupon would pass qualification tests utilizing the same essential variables.
4.
A P-4 base metal procedure qualification test in accordance with ASME Code Section IX was to be completed in parallel with the strut rept.ir.
5.
An additional consideration involved the fact that the weld repair involved non-pressure retaining parts that are not ASME Code components.
In order-to control and assure that a procedure qualification test was completed, a Nonconformance Report (NCR No.88-195) and hold tag were issued to document the technical position taken with regard to the weld procedure.
To disposition these documents, a qualification test was required prior to operation of C-2105.
It is PSC's position that the technical evaluations l
performed and the documented control provisions required prior to returning the circulator to service represent adequate control of the welding repair in question.
Based on the PSC/NRC management conference of October 3, 1988 PSC is cognizant of NRC's concern of using the NCR process to enter into a predetermined non conforming condition.
In retrospect, PSC recognizes tha t it was inappropriate to utilize the NCR process as the vehicle for documenting the weld procedure deviation. As a result, a management Task Team was appointed to evaluate the NCR process.
1 (2) The Corrective Steps Which Have Been Taken and the Results f
Achieved (Part 2):
A procedure qualification test utilizing P-4 base metal in accordance with ASME Code Section IX was completed prior to l
reassembly of C-2105.
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P-88396 Page 9 November 4, 1988 The management Task Team evaluated the NCR process with the results that the existing procedures, when properly implemented, meet the requirements of 10 CFR 50, Appendix B, Criterion 15.
The Task Team also concluded that in this
- case, the NCR process, while providing the necessary elements of control, had been inappropriately applied.
(3) The Corrective Steps Which Will be Taken to Avoid Further Violations (Part 2):
PSC will develop an alternate process to evaluate and document predetermined deviations from technical requirements.
(4) The Date When Full Compliance Will be Achieved (Part 2):
The new p*ocess for evaluating and documenting predetermined technical deviations or potential non-conformances will be finalized and implemented by March, 1989.
The following response to the item contained in the Notice of 04,sation (Ins,.oction 88-15) is hereby submitted:
Based on the results of an NRC inspection conducted on July 11 through August 5,
1988, a dev htion from your conmitments was identified.
The deviation consisted of failure to comply with commitments made to the NRC relative to procurement of hel wm circulator fasteners.
In accordance with the "General Statement 9f Policy and Procedure for NRC Enforcement Actions,"
Appendix C (1988), the deviation is listed below:
Paragraph 6.0 of Attachment I to Public Service Company of Colorado (PSC) Letter P-88019 to the NRC connits, in part, with respect to current helium circulator fastener procurements to require:
(1) chemical and mechanical certified mill tc:t reports; (2) furnace charts for all heat treating;and(3) fluorescent penetrant inspection of all completed fasteners per ASME Code Section V.
Article 6, with no lirear indications in Shanks or threads pemitted.
In deviation from the above:
1.
PSC did not obtain chemical and mechanical certified mill test reports and heat treat furnace charts for Helium Circulator Part No.
C2101-300-95 (original Pare No.
C2101-300-53) spring plungers; and 2.
PSC perfomed a fluoreJcent magnetic particle inspection of only the threads of Helium Circulator Part No.
FP-91-M-19-4-42 steam inlet piping studs.
(267/8815-04).
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m m
P-88396 Page 10 November 4, 1988 (1) The Reason for the Deviation if Admitted:
The Deviation is.1dmitted with the following mitigating circumstances:
It was concluded ard reported in P-88019 that the damage to t
C-2101 resulted from caustic-induced stress corrosion cracking of certain fasteners in the circulator that had been exposed to turbine-drive steam with significant levels of sodium.
Letter P-88019 was submitted as a result of problems idantified with certain fasteners in the steam-end only of the helium circulator and those corrective actions requl red to prevent recurrence.
Scction 6.0. of letter P-88019 (entitled "Quality Assurance Reouirements for Helium Circulator Fastener Procurement)
was added in direct response to questions raised by the NRC in letter G-07434, dated December 8, 1987.
The questions in this 1rtter were related specifically to the use of A-286 and Incoral X-750 fastener materials in the repair of Helium Circulator C-2101.
However, in Section 6.0 of P-88019, it was not made clear that the QA requirements listed were intended to apply only to the new A-286 and Inconel X-750 fasteners procured for use in the steam-end of the helium circulators.
The spring plunger does not function as a conventional fastener and the preload and service-related stresses on it r
are negligible.
For these reasons, the spring plunger was not considered as a "fastener *' requiring the full complement i
of QA requirements intended for and applied to all of the t
other A-286 and Inconel X-750 true fasteners.
I GA certifications, supported by Certified Hill Test Reports and a chemical analysis overcheck, were considered l
1 i
sa tisfactory to establish the quality of the spring i
plungers.
Letter P-88019 implied that the Inconel X-750 material to be used for the spring plunger would be procured in the same heat treated condition as the rest of the Inconel X-750 threaded fasteners. At the time of the submittal of P-t
- AFM9, this indeed was PSC's and GA's intent.
However, the i
spring plunger supplier later infonned GA that they could
[
not supply the caterial in the special heat treat condition.
but rather, it could be supplied in accordance with Material Specification AMS-5667.
Lipon PSC review, it was concluded that while the Inconel X-750 supplied with a conventional
[
heat treatment per AMS-5667 may not provide the greatest resistance to stress corrosion cracking, it would be a significant improvement over the original spring ple1ger j
i
F P-88396 Page 11 November 4, 1988 material (carbon steel).
1his reasoning was the basis of justification for authorizing the use of the available, conventionally heat treated Inconel X-750. As further precaution again;t spring plunger failure, PSC plans to replace the spring plunger, along with certain steam-end fasteners, at intervals of nc greater than 40,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of strculator operation, as indicated in P-88019.
Since Section 6.0 of P-88019 did not make clear that the QA requirements listed were intended to apply only to the new A-286 and Inconel X-750 fasteners, the implication was that these requirements would also apply to the steam inlet piping studs (FP-91-M-19-4-42).
PSC considers it technically acceptable to perfom a fluorescent magnetic particle inspection in lieu of a fluorescent penetrant inspection.
PSC also considered it technically unnecessary to perfom similar examination on the shanks of the studs since the shanks are not service-loaded.
This was an apparent deviation from the implied commitment identified in letter P-88019.
As indicated at the PSC/NRC management cor,ference on October 3,1988, the root cause of the deviations stems from tm primary areas.
- First, the report provided two general pieces of information in Table 3 wherein overall material changes were identified and secondly in Section 6 wherein quality requirements for new fasteners were identified.
These two general pieces of infomation were not specifically tied together which led to interpretation problems.
The second issue resulted from PSC personnel treating the circulator report and the specific technical requirements as a "perfomance based program" wherein acceptable technical substitutions could be made within the constraints of our QA program controls without the necessity of specific NRC notification.
Imediate Corrective Action Taken l
A memorandum dated August 8,
1988 was issued by the Manager l
Nuclear Engineering to all engineering personnel advising them of potential technical deviations and PSC's policy for compliance with NRC connitments.
I All steam inlet piping studs were given a fluorescent penetrant inspection in addition to the magnetic particle inspection.
Actions Taken to Prevent Further 9ecurrence At PSC's Senior Planning Team meeting on October 4, 1988 the elements of these technical deviations, as well as all other I
matters discussed at the October 3,
1988 PSC/NRC management conference, were discussed in detail with senior management.
f i
P-88396 Page 12 November 4, 1988 The following. response to the item contained in the Notice of Violation (Inspection 88-23) is hereby submitted:
~
Failure to Control Special Processes Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "Measures shall be established to assure that special processes, including welding, nondestructive testing,... are controlled and accomplished... using qualified proceduros in accordance with applicable codes, standards, specifications,
- criteria, and other special requirements."
Paragraph 2.2 of Quality Procedure No 9 in General Atomics Quality l
Assurance Manual, Revision A,
effective date Februa ry 16,
- 1986, l
- states, in part, "Special processes shall be performed... in accordance with qualified written procedures, specified in the Traveler or other work instructions."
Contrary to the above, repair welding was perfonned on Helium Circulator S/N C-2101, in which the following conditions were identified:
i 1.
The repairs of crccked strut welds were performed using an improperly qualified welding procedure specification (WPS),
2.
The repair of a crack in the scroll was performed using a WPS which did not address all the required essential and nonessential variables.
This is a Severity Level IV violation.
(Supplement I) (267/8823-01)
(1) The Reason for the Violation if Admitted (Part 1):
A violation for failure to docement the technical justification for deviating from drawings and procedures is admitted.
PSC personnel were sent to General Atomics (GA)
)
facilities on October 10, 1988, to perform a special audit concerning the welding repairs to circulator C-2101.
GA repaired the cracked scroll (Inconel 718) and cr Mked strut I
welds (1-1/4% Cr, 1/2% Mo), as described and cespositioned 1
in GA Nonconformance Report 11857.
These two weld repairs 1
required different weld procedures.
The cracks in the strut welds and scroll were ground out and liquid penetrant examined to assure the removal of the cracks in accordance with GT. Traveler PC 40973.
The scroll was weld repaired and liquid penetrant examined in accordance with GA Traveler PC 41064 The strut welds were weld repaired and liquid penetrant examined in accordance with GA Traveler PC 41029.
A General Atomics QA inspector monitored preheat temperatures, interpass temperatures and electrical characteristics during the actual weld repairs of 'the cracks in the strut welds and scroll.
Circulator steam ducting assembly drawing 90-C2101-431 (Note
- 10) requires that the welding procedure and welders be qualified to the requirements of ASME Code Section IX.
However, for the specific welo repairs, GA took the position
y P-88396 Page 13 November 4, 1988 tha t since the scroll and the struts are not part of the primary or secondary closures and thus are not ASME Code components, the welding procedures for the circulator repair need not be qualified in accordance with ASME Code Section IX.
However, GA did not document and justify in writing this deviation from the drawing requirements.
The actual weld repairs were conducted during the time period of January 14 to February 8,
1988, utilizing only.
PQR's and shop travelers.
7The rQR for the strutt was revised numerous times during
+4 after completion of welding.
These changes resultt! in confusion as to what actual variables were utilized Juring the strut welding repairs and welding of the tes" coupons.
The testing performed on the strut coupon consisted of radiographic examination, micro and macro examination, and microhardness testing.
No tensile or bend testing, as required by ASME Code Sectian IX, was performed.
t PSC determined the PQR for the scroll weld was not supported by bend tests as required by ASME Code Section IX which was a deviation from drawing requirements.
GA did not document and justify this deviation from the drawing requirements.
However, mechanical testing of the scroll weld coupon to determine tensile strength, yield strength and elongation had been performed at roon temperature and at 450 degrees F.
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GA also performed a technical evaluation of the weld repair area and determined
'he mechanical properties of the weld repair to be acceptable.
t (2) The Corrective Steps Which Have Been Taken and the Results Achieved In letter P-88387, dated October 26, 1988 PSC describes in some detail, the results of a special audit conducted by PSC of GA activities related to this issue.
s GA generated WPS's for the strut and scroll weld repairs.
In nrder to verify what welding variables were utilized for the strut and scroll weld repairs PSC requested that GA l
revise the WPS's to reflect the actual essential and nonessential variables utilized for the weld repairs.
GA i
was able to revise the WPS's from the PQR's, shop travelers and data obtained from monitoring of preheat temperature, interpass temperature and electrical characteristics during the weld repairs.
The revised WPS's were reviewed by PSC and found to be in compliance with ASME Code Section IX requirements.
PQR's were also revised to reflect actual essential and j
nonessential variables utilized in welding the test coupons.
7 The revised PQR's were reviewed by PSC and found to be in i
compliance with ASME Code Section IX.
I P-88396 Page 14 November 4, 1988 i
GA completed and tested a second coupon for the strut WPS in accordance with ASME Code Section IX requirements.
/SC reviewed the results in accordann with ASME Code Section IX requirements and found the result., to be acceptable.
A nonconformance report for the drawing deviation of the scroll weld repair was issued by GA and accepted by PSC.
PSC completed rn overall review of the immediate corrective dCtions and revised documentation.
Based on this review, PSC has accepted both the scroll and strut weld repairs for circulator C-2101 as documented in PSC letter P-88387.
(3) The Corrective Steps Which Will be Taken to Avoid Further Deviations PSC reviewed the welding program
- o determine if these mistakes were programmatic or an iso'ated incident.
PSC reviewed Traveler 91-M-19-0001-2, Holium Circulater Steam Inlet
- Water Piping Disassembly, PC a1436.
From review of this.raveler and previous review of cravelers duri.19 audits conducted January 1986, and 1988, it appears that this situation was an isolated incident.
The auditors reviewed the following welding procedures which are used for circulator repair:
Manual Shielded Metal Arc Welding of Carbon Steel (P1),
WS-206, 2,Jue E, dated 4/1/80; GTAW of Carbon Steel (PI),
WS-1, Issue E, dated 2/5/86; Manual GTAW P1 to P8, WS-li2, Issue D, dated 3/21/80; Manual Gas Tungsten Arr. Welding of Stainless Steel (P8) Pipe and Tube; WS-131, dated 2/12/86, Issue L; and Manual Gas Tungsten Arc Helding of Stainless Pipe and Tube (P8) WS-130, deted 8/31/81, Issue M.
The auditors also reviewed the General Atomics "Welder Qualification Status Report.
ASME Code Certified", dated September 13, 1988.
Based on this review, PSC reached the c.' clusion that GA has adequate controls for their weldirg program.
As further action, however, to prevent recurrence:
1.
GA personnel involved with the violation have been re-instructed as to the need to develop qualified weld procedures for specialty repair welds, 2.
A restrictioa will be added to the PSC Approved Vendor List (AVL) to require GA to have PSC review and approve all welding procedures before GA performs repair welding. This AVL revision will be completed November 14, 1988.
M.
P-88396 Page 15 November 4, 1988 (4) The Date When Full Compliance Will be A:hieved Full compliance will be achieves with issuance of the AVL.
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The following response to the item contained in the Notice of Deviation (Inspection 88-23) is hereby submisted:
Based on the results of an NRC inspection conducted on September 12-16, 1988, a deviation from your commitments was identified.
The deviat!on consisted of failure to comply with comitments made to the NRC relative to procurement of helium circulator fasteners.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1988),
the
[
deviation is listed below, t
Paragraph 6.0 of Attachment I to Public Service Company of i
Colorado (PSC) Letter P-88019 to the NRC commits, in part, with respect to current helium circulator fastener procurements to require fluorescent penetrant inspection of all completed fasteners per ASME Code Section V, Article 6, with no linear indications in shanks or threads pennitted.
In deviation from the above, there was no documented evidence to show that fluorescent penetrant inspection had oeen performed on 1
Helium circulator Part No. C2101-300-95 (original Part No. C2101-300-53) spring plungers.
(267/8823-02)
As discussed in the response to Deviation 8815-04 above, PSC did not h
and does not consider the spring plungers to be fasteners.
As also discussed above, the requirements imposed upon fasteners in letter P-88019 did not explicitly exempt the spring plungers.
In letter P-88366, dated October 21, 1988, PSC comitted to provide the NRC better definition and clarification of quality assurance requirements i
relative to the procurement of circulator related fasteners.
This l
1etter, to be sent in January,1989, should resolve this issue to the j
NRC's satisfat'. ton, j
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P-88396 4
-16 November 4, 1988 Should you have any further questions, please contact Mr. M. H.
Holmes at (303) 480-6960.
Sincerely, R. O. William ls,jfLf g ) 0- MI/w-Jr. Senior Vice president, // Nuclear Operations R0W:DCG/enn Attachment cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westerman, Chief Projects Section 8 Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain I l l 1}}