ML20207J189
| ML20207J189 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/17/1986 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207J138 | List: |
| References | |
| 50-335-86-25, 50-389-86-24, NUDOCS 8701080332 | |
| Download: ML20207J189 (13) | |
See also: IR 05000335/1986025
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UNITE 3 STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN 11
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101 MARIETTA STREET.N.W.
2
ATLANTA, GEORGI A 30323
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Report Nos.:
50-335/86-25 and 50-389/86-24
Licensee:
Florida Power and Light Company
9250 West Flagler Street
Miami, FL 33102
Docket Nos.:
50-335 and 50-389
License Nos.:
Facility Name:
St. Lucie 1 and 2
Inspection Condu
d: November 17-21, 1986
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Inspect r: .
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Date Signed
Approved by: //
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Division of React
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SUMMARY
Scope:
This routine, unannounced inspection was in the areas of maintenance /
modification welding (Units 1 and 2), Inservice Testing (IST) Program for ASME
Classes 1, 2 and 3 pumps and valves (Units 1 and 2), and inspector followup items
(Units 1 and 2).
Results:
No violations or deviations were identified.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
D. A. Sager, Plant Manager
- L. W. Pearce, Operations Supervisor
- N. G. Roos, Quality control (QC) Supervisor
- S. C. Sanders, FP&L Welding Supervisor-Plant
- P. D. Waldrop, FP&L Welding Supervisor-Construction
- D. M. Stewart, Lead Test and Performance Engineer
- E.' B. Carlile, Project Field Engineering Representative
- P. W. Heycock, ISI Coordinator
A. B. Johnson, Assistant Plant Engineer
J. Eyer, QC Engineer
R. t Miller, Quality Control
Other licensee employees contacted included construction craftsmen,
engineers, technicians, security force members, and office personnel.
NRC Resident Inspector
- R. V. Crlenjak, Senior Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on November 21, 1986, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
The following new
items were identified during this inspection.
(0 pen) Inspector Followup Item 335/86-25-01, 389/86-24-01, Review of Revised
Welding Program
paragraph 5.
(Open) Inspector Followup Item 389/86-24-02, Revision to Valve Stroke
Testing Frequency Requirements
paragraph 6.b.
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
(Closed) Unresolved Item 335/85-04-03, Testing of Category
"C" Relief
Valves. This item raised a question relative to the fact that originally,
relief valves in systems other than the pressurizer and main steam systems
were not in the licensee's IST program.
Based on differing opinions and
interpretations, it is not clear when the valves should have been added to
the IST program. The valves have now been included in the program and are
being tested in accordance with code requirements.
Procedure QI 11-PR/
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PSL-7, Revision 1 covers testing of relief valves.
4.
Unresolved Items
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Unresolved items were not identified during the inspection.
5.
Maintenance / Modification Welding (55050 and 55100) (Units 1 and 2)
The inspector examined the welding activities described below relative to
maintenance / modification to determine whether applicable code and regulatory
requirements were being met. In general, the licensee controlling documents
are:
Modification (Backfit)
FP&L Welding Control Manual, Revision 21
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Maintenance
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General Maintenance (GM) Procedure M-0400,
Revision 8, Welding Manual
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Parts
of
the
Welding
Control
Manual
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Implemented by GM Procedure M-0400
In accordance with these licensee documents, the following codes apply:
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ASME Boiler and Pressure Vessel (B&PV) Code,Section XI, 1980 Edition,
W81 Addenda
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ASME B&PV Code,Section III, 1980 Edition, W80 Addenda
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AWS Structural Welding Code D1.1, 1983 Edition
a.
Welding Material Control
The inspector verified that the filler materials used for the welds
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observed (see paragraph 5.d.) were the correct materials specified by
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the Welding Procedure Specification (WPS) and that in general, filler
materials specified on WPS were compatible with specified base
materials.
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The inspector performed the following verifications related to control
and handling of welding material:
That the licensee had established procedures for purchasing
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receiving, storing, disbursing, and handling of welding materials.
The applicable procedures are:
WTS-3, Revision 3, Weld Material Control
GM Procedure M-0028, Revision 2, Welding Electrode and Filler
Metal Control
QP-4.1, Revision 18, Control of Procurement Originated by
Operating Plant Personnel
QP-4.4, Revision 18, Review of Procurement Documents for
Items and Services Other Than Spare Parts
QP-7.1, Revision 8, Receipt Inspection of Materials, Parts,
and Components at the Plant Site
QI-4.1, Revision 8, Procurement Document Control
Construction Administrative Procedure ASP-6, Revision 5,
Welding Control
Engineering Department Specifications - MN Series
That receiving _ operations were conducted in accordance with
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applicable procedures.
Purchasing and receiving records for the
welding materials listed below were reviewed.
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That welding material storage and handling procedures contained
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requirements for environmental control and that actual practice
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followed. these requirements.
The backfit rod issue station was
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inspected and weld material control observed during observation of
welding (see paragraph 5.d below).
That there were effective procedures for maintaining identifica-
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tion of welding materials and that procedures are aaforced.
Identification control was inspected during observatio: of welding
(see paragraph 5.d below).
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That the welding material control system met the requirements for
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the most restrictive application and personnel involved were
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knowledgeable of the system.
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That the method of disbursement of welding materials was effective
and controlled in accordance with approved procedures.
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That required ASME Code tests were performed on each lot of
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welding material.
The purchasing, receiving inspection and
material certification documentation were reviewed for the
following welding materials used for the welds listed is paragraph
5.d below.
Size
Iype
Ht. No.
P.O. No.
3/32"
E7018
77871
90865-3884
3/32"
E7018
33043
90865-79478B
1/8"
065472
90865-65398
1/8"
065415
90865-77385W
3/32"
065433
90865-79937
1/8"
L1861
43921-56890
1/8"
98520
SL74-294
3/32"
09735
SL75700
3/32"-
ER4043
3809
22279-23010
3/32"-
RCuAL
G-7139
02471-79697A
b.
' Welding Procedures
The inspector determined if procedures had been established for
preparation, qualification, approval / certification and revision of
WPSs.
The applicable procedures are:
WTS 6, Revision 2, Weld Procedure Qualification Requirements
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WTS 1,
Revision
0,
Processing Change Requests To the Welding
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Control Manual
ASP-6, Revision 5, Welding Control
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c.
Welder Performance Qualification
(1) The inspector verified that procedures had been established for
qualification and maintaining qualification status of welders and
welding operators in accordance with ASME Code requirements. The
applicable procedures are:
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WTS
5,
Revision 1,
Welding
Performance Qualification
Requirements
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ASP-6, Revision 5, Welding Control
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(2) The inspector reviewed a sample of the qualification and
qualification status records for the below listed welders relative
to the welds listed in paragraph 5.d below.
Welder
LMAH
LMAF
LMAE
LMAJ
LFHQ
LFOS
LFMV
(3) Welder LMAD was observed in the process of welding a test assembly
to qualify for WPS 36.
(4) Completed and accepted radiography (RT) film for the following
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welder qualifications were reviewed:
Welder
WPS
LMAD
WPS 89
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LMAD
WPS 9
LMAD
WPS 5
LMAD
WPS 43
d.
Production Welding
The inspector observed in process welding and reviewed in process
records for the following welds:
Size
Category
2F-9-FP-0155-005-A
6" x .280"
8Y*
2F-9-FP-0155-008
6" x .280"
8Y*
Traveler 86-859
2" sch. 40
8*
2"-FP-62
available for observation and all categories are welded to the
same requirements.
Since no other welds were available for observation, the inspector
reviewed completed records for the following welds:
Size
Category
2F-2-SI-0652-001
3" x .216"
3A
2F-2-SI-0652-002
3" x .316
3A
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Traveler 86-779
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Traveler 86-778
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Traveler 86-777
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Traveler 86-695
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Traveler 86-696
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FW-1, 2, 3, 4, 5 and 6
Traveler 86-780
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3
Traveler 86-782
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Traveler 86-645
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The welding was observed and the records reviewed to determine whether:
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Work was conducted in accordance with a document which coordinates
and sequences operations, references procedures, establishes hold
points, and provides for production and inspection approval
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Weld identification and location were as specified
Procedures, drawings, and other instructions were at the work
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station and readily available
WPS assignment was in acccrdance with applicable code requirements
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Welding technique and sequence were specified and adhered to
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Welding filler materials were the specified type and traceable to
certifications
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Weld joint geometry was in accordance with applicable procedure
and was inspected
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Alignment of parts was as specified
Preheat and interpass temperatures were in accordance with
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procedures
Electrodes
were
used
to
positions
and with
electrical
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characteristics specified
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Shielding gas was in accordance with the welding procedure
Welding equipment was in good condition
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'Interpass cleaning was in accordance with applicable procedures
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Temporary attachments were removed in accordance with applicable
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procedures
Gas purging, if specified, was used in accordance with applicable
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procedures
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Process control system had provisions for repairs
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Welders were qualified
No peening performed on root and surface layers
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Weld inspection personnel were qualified
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Examination of the welding program, as detailed in the above para-
graphs, revealed the following weaknesses in the program:
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Welding Material Control - Backfit was working to procedure WTS 3
of the Welding Control Manual. Maintenance was working to General
Maintenance Procedure M-0028.
The following problems were
identified with procedure M-0028:
Paragraph 9.2.3 addresses exposure times for types E-7016,
7018, 8016, 8018, 9016 and 9018 electrodes.
Exposure times
for other coated electrodes are not addressed.
Paragraph 9.2.4 is not clear.
It appears that part of the
paragraph has been left out.
Paragraph 9.2.7 does not specify any controls for portable
rod ovens.
Paragraph 9.2.6 does not provide definitive instructions for
use of the " Welding Rod Control Log."
Based on discussion with the Welding Supervisor, return of
unused welding material is not allowed.
The procedure
indicates that unused material is to be returned.
Material traceability - Procedure is not clear about how
material identification is maintained and transferred to the
traveler.
Procedure has few definitive requirements.
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Welder Qualification - Both backfit and maintenance are working to
procedure WTS 5 of the Welding Control Manual.
The following
problems were identified with procedure WTS 5:
The procedure refers to WTSs 9.2, 9.3 and 9.6.
It appears
these documents were never issued.
Paragraph 6.0 details a computerized system for maintaining
welder qualifications current.
Backfit is using the system.
However, maintenance is using an informal manual log. The
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log has inconsistencies since it is informal. Without tne
use of the informal log, it is not possible to verify for
certain that a welder has maintained his qualification.
In paragraphs 6.6 through 6.9, the terms " Weld Currency
Report" and " Welders Performance Qualification Report" are
not clear. The frequency for issue of these two reports is
not spacified. Maintenance is not using these two reports.
There is very little detail on the qualification process.
ASME Section IX is referenced for details of testing, i.e.
test assembly details, required NDE or mechanical testing,
etc. Based on discussions with welding supervision, it is up
to the welding supervisor to specify the details of testing.
The inspector pointed out that this method of operation leads
to inconsistencies and errors. Some welding supervisors that
are more experienced will be able to interpret code require-
ments for testing, while less experienced welding supervisors
might not.
The procedure does not contain requirements for positive
identification of welders.
Details for qualification renewal when a welder.does not weld
in the required three or six months (when welding with
another process) are not clear. Requirements, including test
assembly to be welded and how it is to be tested, need to be
clarified.
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Weld Traveler - For Maintenance, process control is covered by
Maintenance Procedure M-0400.
Instructions
for processing
Traveler need to be added to procedure.
Welding Procedures - Welding Procedure qualification is covered by
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procedure WTS 6 of the Welding Control Manual. Processing of WPS
is not clearly covered by Procedure WTS 6.
Although a significant number of weaknesses were identified in the
welding program, the inspector did not identify any code or procedure
violation in observation of welding or review of completed records.
In
addition, discussions with welding supervisor revealed that the
licensee had identified weaknesses (many similar to those identified by
the inspector) in the welding program and had initiated steps to
correct the weaknesses prior to the current inspection.
A Quality
Improvement Team (QIP), for improvement of procedures and a Welding
Improvement Team, for improvement of the welding program, had been
formed.
The purpose of the Welding Improvement Team was to correct
known weaknesses in the welding program and to formulate a welding
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program suitable for all FP&L entities,
i.e.,
St. Lucie Maintenance,
St. Lucie Backfit, Turkey Point, etc. The inspector reviewed internal
licensee correspondence documenting formation of the Welding Improve-
ment Team, the agenda for the team, and some identified welding program
problems to be resolved by the teams.
Inspector Followup Item
335/86-25-01, 389/86-24-01, Review of Revised Welding Program, is-
opened pending review of the revised program to verify correction of
known weaknesses.
Within
the
areas
inspected,
no violations or deviations were
identified.
6.
Inservice Testing (IST) Program For ASME Classes 1, 2, And 3 Pumps And
Valves (Units 1 And 2)
The inspector examined the IST activities described below to determine
whether regulatory and code requirements were being met. In accordance with
the pump and valve program (submitted by FP&L letter L-80-136, dated May 1,
1980) and the Safety Evaluation Report (SER), dated April 2, 1985, the
applicable code for Unit 1 is the ASME B&PV Code,Section XI,1974 Edition
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S75 Addenda.
In accordance with the pump and valve program (submitted by
FP&L letter L-83-644, dated October 6,1983) and the SER dated January 13,
1986, the applicable code for Unit 2 is the ASME B&PV Code,Section XI, 1980
Edition, W80 Addenda.
See RII . Reports 50-335/85-04, 50-389/85-04, 50-335/85-14 and 50-389/85-14
for documentation of previous inspections in this area.
For the current
inspection, only changes to documents since the last inspection were
reviewed.
The IST Programs are implemented by the following St. Lucie Administrative
Procedures:
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0010132, Revision 7, "ASME Code Testing of Pumps and Valves"
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1-0010125, Revision 67, " Schedule of Periodic Tests, Checks and
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Calibrations"~
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2-0010125, Revision 18, " Schedule of Periodic Tests, Checks and
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Calibrations"
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QI 11-PR/PSL-7, Revision 1, " Control of Code Safety and Relief Valves"
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a.
The above pro 9 rams and administrative procedures and the below listed
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Quality Instructions (QIs) were reviewed for general content and to the
extent necessary to verify that the licensee had assigned responsi-
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bilities for:
preparation, review and approval of IST procedures;
scheduling of IST; performance of test functions; performance of
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maintenance; and performance of calibrations.
QI 6-PR/PLS-1, Revision 11, " Document Control"
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QI 5-PR/PSL-1, Revision 29,
" Preparation,
Revision, Review,
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Approval of Procedures"
b.
The inspector reviewed procedures 1-0010125 and 2-0010125 and discussed
scheduling with responsible personnel to verify that tests are
scheduled at reauired frequencies.
The inspector found that Data
Sheet 8 of procedure 0010125, used to schedule testing of valves to be
stroke tested quarterly, has a " built-in" possibility of allowing the
surveillance interval for an individual valve to exceed the Technical
Specification requirements.
The Unit 2 Technical
Specifications
defines the ASME Section XI three month test frequency as 92 days and
allows a 25 percent extension on the interval. In accordance with Data
Sheet 8, valves are tested during the months of February, May, August,
and November. The date an individual valve is tested is not recorded -
only the completion date of Data Sheet 8.
Therefore, if a particular
valve is tested at the beginning of the month for one quarter and at
the end of the month the next quarter, the 92 day plus 25% surveillance
interval will be exceeded by approximately one week.
However, based
on informal logs kept by QC and discussions with QC relative to the
tight controls QC maintains over insuring that required schedules are
maintained, it is unlikely that surveillance intervals have been
violated. The licensee agreed that the procedures need to be revised
to insure procedurally that surveillance intervals are not exceeded.
Pending review of revised procedures, Inspector Followup Item 389/86-24-02,
Revision to Valve Stroke Testing Frequency Requirements, is opened.
This problem is unique to Unit 2 in that the Unit 1 Technical Specifi-
cations do not define surveillance intervals specified by ASME Section XI.
c.
The inspector reviewed the control room " Pump and Valve Summary" as
listed below to verify that status lists were maintained and reflected
properly scheduled tests.
Data Sheet 8 - 1986
Unit 1
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Data Sheet 9 - 1986
Data Sheet 10 - 1986
Data Sheet 11 - 1986
Routine Pump Test Summary - 1986
Data Sheet 8 - 2nd, 3rd, 4th Qtrs., 1986
Unit 2
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Data Sheet 9 - 2nd, 3rd, 4th Qtrs., 1986
Data Sheet 10 - 1986
Routine Pump Test Summary - 2nd, 3rd, 4th Qtrs. ,1986
d.
Based on a number of problems in the industry with check valves, a
question has been raised relative to the need for testing check valves
in both directions.
St. Lucie Unit 1 pump and valve' program SER states
that when a check valve has two functions important to safety - to open
under certain conditions and close under others, the exercising test
must verify movement to the positions necessary to satisfy both of
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these functions. ASME Section XI requires exercising to the position
required to fulfill the valve function. During the current inspection,
the question was discussed with licensee's engineering personnel. The
following summarizes the discussion:
(1) FP&L was not aware of any check valves that require exercising in
both directions to fulfill their safety function.
(2) FP&L considers that the function of each valve should be reviewed
and, -in addition to performing the required code tests, attempts
should be made to perform any other testing / monitoring considered
warranted from a safety / reliability standpoint.
(3) The inspector questioned the licensee relative to the following
instances where the need to test check valves in both directions
has been questioned.
The questions and the licensee's responses
are included.
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The Auxiliary Feedwater Pump (AFW) have check valves that are
tested to open to fulfill their function. The valves need to
close to prevent hot water / steam from over heating the AFW
pumps under certain conditions.
The licensee pointed out
that temperature of piping upstream of the check valves is
monitored on a periodic basis to detect a heatup problem.
The . discharges to the Safety Injection -(SI) Tanks have two
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valves in series whose safety function i s to open.
The
valves are closed and isolate the lo,/er pressure SI tanks
from the higher pressure reactor coolant during normal
operations.
Therefore, performance of the valves in the
closed direction is important to prevent over pressurization
of the SI tanks. The licensee pointed out that to protect
from overpressurization:
<
There is an alarmed pressure monitor between the two
There is an alarmed level monitor in the tank
The valves are leak checked per Technical Specification
requirements.
HPSI and LPSI' system pumps in parallel trains take suction
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from a common line and discharge into a common line. The
pump discharge lines have check valves that open to fulfill
their safety function.
If the pump in only one train is
operating and the check valve in the parallel non-operating
line is not closed or has excessive leakage, the recircula-
tion back through the non-operating check valve might cause
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insufficient flow for the system to fulfill its function.
The licensee pointed out that in addition to check valves,
each discharge line has an isolation valve. Also, since the
flow rate in each train is tested separately, in effect check
valves are being checked for excessive backflow in that if
the backflow through the non-operating train is excessive,
the flowrate in the system will not be acceptable and the
test will fail.
. 7.
Inspector Followup Items (IFIs) (Units 1 and 2)(92701)
a.
(Closed) Inspector Followup Item 335, 389/85-14-01, Valve Stroke Times.
This item pertained to the fact that valve stroke times related more to
system performance requirements rather than to
veri fying
the
operational readiness of the valves.
The licensee has re-examined
valve stroke times and revised the program to specify more realistic
valve stroke time,
b.
(Closed) Inspector Followup Item 389/83-26-03, Augmented ISI of RCP to
Pump Welds.
This item pertained to reference in the SSER of the
possibility of augmented ISI being evoked during initial review of the
ISI program for reactor coolant loop to pump welds that could not be
inspected 100% to ASME Section XI during Preservice Inspection. Relief
Request No. 5 to the initial ISI program requested relief from code
requirement for these welds.
The SER dated October 10, 1986 approved
the relief, request without augmented inspection.
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