ML20206D389

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Insp Repts 50-259/87-11,50-260/87-11 & 50-296/87-11 on 870224-27.Violations Noted:Combination Weld Procedure Qualification Record Lacking Weld Deposit Thickness Range Info & Failure to Provide Adequate Measures
ML20206D389
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 03/13/1987
From: Blake J, Economos N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206D324 List:
References
50-259-87-11, 50-260-87-11, 50-296-87-11, NUDOCS 8704130319
Download: ML20206D389 (8)


See also: IR 05000259/1987011

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UNITED STATES

[ pef! 'o NUCLEAR REGULATORY COMMISSION

y' , REGION 11

g j 101 MARIETTA ST REET, N.W.

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r ATL ANTA, GEORGI A 30323 i

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Report Nos.: 50-259/87-11, 50-260/87-11, and 50-296/87-11

Licensee: Tennessee Valley Authority

6N 38A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Docket Nos.: 50-259, 50-260 and 50-296 License Nos.: DPR-33, DPR-52,

and DPR-68

Facility Name: Browns Ferry 1, 2, and 3

Inspection Conducted: February 24- ( 1987

Inspector:

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N. E no N

fate)1gned

Approved by: - 3 9/3 7

J. J B14ke~ Chief Da'te Signed

Mat ri,Is an,d Processes Section

D1 ision of Reactor Safety

SUMMARY

Scope: This special unannounced inspection was conducted in the area of

recirculation nozzle safe-end welding and previously identified enforcement

matters.

Results: Two violations were identified - Combination Weld Procedure Qualifi-

cation Record Lacking Weld Deposit Thickness Range Information, paragraph 5; g

and Failure to Provide Adequate Measures for the Control and Identification of

Welding Consumables, paragraph 3.a.

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0704130339

DR 07033o

g ADOCK 05000259

PUR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

  • R. L. Lewis, Plant Manager
  • J. A. Savage, Compliance Engineer
  • C. McFall, Compliance Engineer

S. P. Stagnolia, Section Manager, Nozzle Replacement Group

W. R. Bentley, NDE Level III Examiner

R. Latimer, Supervisor, Inservice Inspection

H. S. Dean, QA Evaluator, Quality Surveillance

J. C. Pettitt, Section Supervisor, Nozzle Replacement Group

T. Everitt, Welding Engineer, Nozzle Replacement Group

D. Odom Welding QC Coordinator

Other licensee employees contacted included construction craf tsmen, i

engineers, technicians, office personnel.

NRC Resident Inspectors

  • G. L Paulk, Senior Resident Inspector
  • C, A. Patterson, Resident Inspector
  • Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on February 27, 1987,

with those persons indicated in paragraph I above. The inspector

described the areas inspected and discussed in detail the inspection

findings. No dissenting comments were received from the licensee.

Violation 259, 260, 296/87-11-01, Combination Weld Procedure Qualifica-

tion Record (PQR) Lacking Weld Deposit Material Thickness Measurement,

paragraph 5.

Violation 259, 260, 296/87-11-02, Failure to Provide Adequate Measures

for the Control and Identification of Welding Consumables, paragraph 3.

Inspector Followup Item 260/87-11-03, PQRs Used to Qualify Welding

Procedure Lack Adequate Referencing System, paragraph 5 .

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

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3. Licensee Action on Previous Enforcement Matters

a. (Closed) Unresolved Item (50-260/86-34-02): Documentation and

Traceability of Filler Metal Quality Records

This item was opened because certain weld material quality records

were not available for review at the time of the NRC inspection

between October 6-10, 1986. At the time, the licensee offered to

retrieve the requested information and forward it to Region II for i

the review. On or about October 14, 1986 the licensee representative

contacted this inspector and stated that certain discrepancies had

been identified in the documents used for issuance, control and

traceability purposes. Because these discrepancies were considered

significant and involved violations of site implementing documents,

the licensee issued a corrective action report (CAR), No. CAR-86-0201

dated October 14, 1986. The weld materials for which quality records

were requested and discrepancies identified were as follows:

575 Control Number Type Size

7386-00585 E7018 1/8" diam.

5685-06945 E7018 3/32" diam.

5686-1190 E7018 3/32" diam.

Specifically the discrepancies noted on the aforementioned CAR were

as follows:

(1) Form 575 No. 5686-11900 contained no heat number.

(2) Form 575 number 5686-011473 was first issued as 575 control

number 7386-00585. When the warehouse changed the 575 control

number on its copy, it did not send copies of the 575 form with

the change control number to the tool rooms. Therefore, the

voided 575 control number was referenced in work plans (WPs) and

modification requests (MRs) instead of the new number. Control l

575 number 5685-06945 specifies that 921210 is the heat number I

for E7018, 3/32 diameter welding electrodes, 921210 is the lot l

number and not the heat number.

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Discussions with licensee representatives disclosed the above

discrepancies reflected violations of site implementing procedures

BF6.2 and BF16.4 which require that, the correct heat number be

recorded on the TVA 575 Form and that welding material in tool room ,

be identified by the correct 575 control number including heat l

number. Further discussions with cognizant licensee personnel '

disclosed that upon further investigation other discrepancies of a

similar nature were found. Also, it was disclosed that until recently

each site organization, i.e. plant maintenance and modifications

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etc., maintained and distributed weld materials from their own

separate inventories. In other words, the same material was being

issued by several site organizations conceivably under different

575 control numbers. Apparently this system has the potential for

creating documentation and material control problems as evidenced

by the aforementioned CAR. This situation was corroborated by the

licensee's root cause analysis statement on the subject CAR. It

stated that, identical welding materials are presently maintained in j

maintenance, modification and direct charge status at BFN. This '

o creates the potential for (material) issuing errors and therefore

subsequent changes to 575 control number. The licensee's stated

actions to prevent recurrence of this problem were as follows:

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In the future, all weld electrodes will be placed in modifica-

tions inventory. This will resolve the inadvertent issue of

like uaterials from the incorrect inventory and therefore

eliminate the need to change 575 control numbers.

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Power Stores issuing personnel have been retrained in the

importance of proper weld rod issues.

Because the licensee eventually retrieved the information requested,

the inspector closed the subject unresolved item. However, the

inspector stated that because the documentation discrepancies in the

issuance and control of weld material had gone undetected and therefore

uncorrected prior to the request for information on October 10, 1986,

a violation was being issued to underscore the fact that the weld

material control program at this site was inadequate. This failure

to provide adequate measures for the control and identification

of materials (welding consumables) was a violation of 10 CFR 50,

Appendix B, Criterion VIII and was identified as violation 259, 260,

296/87-11-02, Failure to Provide Adequate Measures for the Control and

Identification of Welding Consumables.

b. (Closed) Violation 259, 260, 296/86-34-01, Welder Performance

Qualification Records Lacking Thickness Range Information.

The licensee's letter of response dated December 30, 1986, has been

reviewed and determined acceptable by Region II. The inspector

held discussions with the cognizant licensee personnel and examined

the corrective actions as stated in the letter of response. The

inspector concluded that the licensee had determined the full extent

of the subject noncompliance, performed the necessary followup

actions to correct the present conditions, and developed the

necessary corrective conditions. The corrective actions identified

in the letter of response have been implemented.

4. Unresolved Items

Unresolved Items were not identified during this inspection.

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5. Inspection of Replacement of Recirculation Piping (Unit 2) (TI2512/13)

The inspection effort in this area was a followup to previous inspections

conducted by Region II staff and subsequently documented in inspection

reports 50-260/87-01 and 50-260/87-04. Selected aspects of ,the licensee'.s-

l welding activities and related QA/QC records were reviewed to ascertain

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whether they were consistent with applicable code and regulatory require-

ments. The recirculation nozzle safe-ends and associated piping are being

l installed in accordance with ASME, Code Section(s) XI/III (80W81); fabri-

cation and nondestructive examination are performed to the requirement of

ASME Section III, (S83) addenda. The original code of record for this

system was USAS B31.1 Power Piping Code 1967 Edition. The inspector

observed safe-end to nozzle welds both those that had been welded out and

others in process. Weld fabrication was being performed with a consumable

insert welding procedure GTA-88-C-5 Revision 3, using the automatic gas

tungsten arc (TIG) process. Automatic TIG welding machines were used to

control welding parameters and fabricate the weldment. Qualified welding

operators using remote control devices assisted by TV monitors maintained l

control of the fabrication. At the time of this inspection, the safe-end

to nozzle welds on nozzles B, D, F and G had been completed. Consumption,

of.the insert and deposition of the hot passes was in progress on nozzles l

C & J. Areas of interest included weld bead appearance, configuration, '

fusion and width, arc behavior, weld pool turbulences or lack thereof,

wire feed, travel, and oscillation. These conditions / parameters were

observed to ascertain compliance with the aforementioned welding procedure

and code requirements.

Fabrication history and QA/QC inspections performed on each nozzle is

maintained through the use of a workplan and inspection record (WP&IR),

document which appears as attachment 2 to BF-SDSP-8.4 Rev.1. The

inspector reviewed WP&IR No. 2174-86, Nozzle C and No. 2177-86,_ Nozzle F

for completeness and accuracy; hold points designated by the authorized

nuclear inspector were identified as line items in the plar,s. In addi-

tion, the inspector reviewed the following documents: -

1.M.1.2 Rev. 4 TVA General Welding Procedures Specification

BF6.2-05 Quality Control of Welding Activities

BF16.4 Rev. 4 Material, Components and Spare Parts Receipts,

Handling, Storage Issuing, Return to Storeroom

and transfer

BF-SDSP-13.2 Rev. 1 Welding and Brazing Filler Material

Control. . .

MAI-49 Rev. 3 N2 Nozzle Safe-End and Riser Elbow Assembly

Replacement.

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Weld Procedures and Associated P M

PQR Thickness

Weld Procedures PQR Date. Range

GT-88-0-1A Rev. 1, 11-6-78 GT-88-0-1 03-06-78 3/16" - 1.00"

GT-88-0-6 Rev. O, 11-6-86 GT-88-0-1 05-28-74 1/16" - 11/16"

GT-88-0-1 05-14-70 1/16" - 1/2"  ;

GTA-88-C-5 Rev. 3, 1/21/87 GTA-88-C-1 09-26-72 3/16" - 1.436"

GT-SM88-0-1B Rev. 2, 4/4/85 GT-SM88-01 09/18/70 3/16" - 1 7/16"

GT-SM88-0-2 06/24/74 3/16" - 4 1/2"

Performance Qualification Test

Thickness

Test No. Weld Procedure Range

GTA-7-C-3-H(a)Rev.O,11-5-86 GTA-88-C-5 3/16" - 1.436

Within these areas the inspector noted the following:

Weld procedure GT-SM88-0-1B above was qualified as a combination procedure

using both the gas tungsten arc process and the shielded metal arc process

as permitted by the code. To do this, the licensee used PQRs, GT-SM-0-1

and GT-SM-0-2 which were qualified using the gas tungsten arc process

(GTA) for the root portion of the weldment and the shielded metal arc

process (SMAW) to weld out the remainder of the weld joint. The aforemen-

tioned weld procedure references General Welding Procedure Specification

1.M.1.2 (R4) which in turn reference ASME Code Section IX as the governing

code for welding procedure qualifications. The weld procedure and associ-

ated PQRs are contained in TVA's specification G-29M, DPM.N73.M.2. In

reference to the use of combination welding procedures on production

welds paragraph QW-200.4 of ASME Section IX, requires that these proce-

dures be qualified for the deposited weld metal thickness range for each

of the processes to be used in the production joint. Also, the code

states that-the qualified thickness of each process shall not be additive

l in determining the maximum thickness of the production joint welded.

Contrary to this requirement the inspector noted that neither of these

. two PQRs provided the thickness of the metal deposited by each process

[ as required by the aforementioned code. This failure to comply with

applicable ASME Section IX requirements is in violation of paragraph

(a)(1) of the 10 CFR 50.55a and is identified as violation 50-259, -260,

-296/87-11-01, Combination Weld Procedure Qualification Record Lacking

Weld Deposit Material Thickness Measurements.

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Also, during this review the inspector noted that, weld procedure

GT88-0-1A Rev. 1, 11/6/78 referenced PQR GT88-0-1 as that used to qualify

the procedure. However, the inspector noted that there were three PQRs

having. number GT88-0-1, see above, each qualified on a different date, a

different pipe diameter and thickness range, Also, the one qualified on

3/6/78 showed the weld joint configuration sketch with a backing strip

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instead of the open butt as indicated by the procedure and PQR number

designation. The inspector discussed this discrepancy with cognizant

licensee personnel who agreed that the PQRs should be numbered in a manner

that would show that all three were interrelated with the applicable weld ~

procedure and therefore help minimize the existing confusion factor. I

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Also, the inspector suggested that the joint configuration sketch be

revised to be consistent with the designated PQR number. This matter was

identified as an inspector followup item until the appropriate corrective

action has been taken by the licensee. IFI 259, 260, 296/87-11-03, PQRs,

used to Qualify Weld Procedure Lack Adequately Referencing Information.

a. Review of Material Quality Records

The inspector reviewed quality records for equipment, replacement I

materials and welding consumables listed below.

Welding Machine -

Machine S/N, 1231, 1239, 1544, 1196

Calibration

Records

Safe Ends - Grade SA-182, F316NG, 12" diameter heat

I Replacements No. 131BN

RT Plugs -

Grade SA-182 F316NG Threaded

Replacement Pipe,

12" diameter -

Grade SA403, WP316NG, Ht #D440904, D442604,

D45A704, D442004, D451004, D441104

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Weld Consumables -

Insert - 1/8"x5/32" IN308L Ht #5493T308L

Wire - 0.045" 9 ER308L Ht #SE0591

These records were retrievable complete and accurate. Within the

areas inspected no violations or deviation were identified.

b. Radiography (57090)

As part of the current inspection effort, the inspector reviewed

radiographs of two completed safe-end and nozzle welds identified as

"B" and "G". TVA Radiographic Procedure N-RT-1, Revision 5, written

to comply with ASME Section III, Edition (80W81), was used to produce

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the radiographs. Radiographic film associated with subject welds was

reviewed to ascertain whether radiographic quality was in accordance

with the above code and procedural requirements in the following

areas:

(1) Penetrameter type, size, placement

(2) Penetrameter sensitivity

(3) Film density, density variation

(4) Film identification

(5) Film quality

(6) Weld coverage (overlap)

Within these areas the inspector noted that the linear indication at

the root of the nozzle "G" weld safe-end, discussed earlier in

Reports 50-260/87-01 and -04, had been interpreted by TVA's Level III

NDE examiner as a root condition associated with weld joint geometry,

12 chamfer, and the shape of the consumed insert. To support this

position, the licensee presented a sequence of radiographs from

mock-up weld specimen "T", and nozzle "G" taken with different

techniques including parallax. The inspector agreed with the

licensee's interpretation but stated that because this matter was a

part of a broader concern which was documented in Report., 50-260/

87-01 and 50-260/87-04 it was preferable to let the matter be

resolved by those individuals more familiar with the concern. In

response to the inspector's request, the licensee provided duplicate

radiographs from the mock-up welds and the "G" nozzle. The radio-

graphs, along with a 31 inch long sample segment of weld removed from

mock-up weldment "T" were brought to the Region for further review

and evaluation by the staff.

Within the areas inspected, no violations or deviations were identified.

6. (Closed) Inspector Followup Item 86-34-03, Weld Gap in Gusset Plate

Weldment.

This item was identified when the inspector noted that a plate in ring-

girder #2, on the side of Bay-2 exhibited a gap about 3/16 inches wide in

the fillet weld area. The associated work plan was WP2067-86 and

applicable drawing was 48W1218-7R10. The inspectors requested that the

weldment in question be reinspected, evaluated by design engineering and

the results presented to the inspectors for review on a future inspection.

During the current inspection the inspector reviewed the licensee's j

corrective actions which were documented under action item no. SLT-86- 1

1086-002 generated by Design Engineering. Other documents reviewed

included:

a. Calculation - BFEC10367, sheet 40.10A and .10B

b. Design Drawing - 48W128-7, Rev. 13 I

c. Work Plan - WP 2067-86 )

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Corrective action on the subject weld has been completed and the work plan

is in the final closecut cycle. Therefore, this item is considered

closed.

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