ML20207J189

Insp Repts 50-335/86-25 & 50-389/86-24 on 861117-21.No Violations or Deviations Noted.Major Areas Inspected:Maint & Mod Welding,Inservice Testing Program for ASME Class 1,2 & 3 Pumps & Valves & Inspector Followup Items

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: ML20207J136 ML20207J189
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

/jeEtzgDo NUCLEAR REGULATORY COMMISSION

y" g REGloN 11

g j 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.: DPR-67 and NPF-16

Facility Name: St. Lucie 1 and 2

Inspection Condu d: November 17-21, 1986

Inspect r: . @ :7 m -m /d-// 7/#6

B. R. //

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r Date Signed

Approved by: // . /f

, /fsc.'ti on

Mef /2 /7 /2

'Jf67 D6te Signed

ginee g Branch

Division of React ety

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

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being tested in accordance with code requirements. Procedure QI 11-PR/

PSL-7, Revision 1 covers testing of relief valves.

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4. Unresolved Items

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

Maintenance -

General Maintenance (GM) Procedure M-0400,

Revision 8, Welding Manual

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Parts of the Welding Control Manual

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

l 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:

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That the licensee had established procedures for purchasing

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

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That receiving _ operations were conducted in accordance with

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

! inspected and weld material control observed during observation of

welding (see paragraph 5.d below).

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That there were effective procedures for maintaining identifica-

l 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

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

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" E70S-2 065472 90865-65398

1/8" E70S-2 065415 90865-77385W

3/32" E70S-2 065433 90865-79937

1/8" ER316 L1861 43921-56890

1/8" ER308 98520 SL74-294

3/32" ER308 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:

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WTS 6, Revision 2, Weld Procedure Qualification Requirements

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WTS 1, Revision 0, Processing Change Requests To the Welding

Control Manual

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ASP-6, Revision 5, Welding Control

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.

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(4) Completed and accepted radiography (RT) film for the following '

welder qualifications were reviewed:

Welder WPS

. LMAD WPS 89

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:

Weld 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

• Category 8 welds were observed since no higher class welds were

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:

Weld 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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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

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Procedures, drawings, and other instructions were at the work

station and readily available

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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

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Preheat and interpass temperatures were in accordance with

procedures

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Electrodes were used to positions and with electrical

characteristics specified

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Shielding gas was in accordance with the welding procedure

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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

procedures

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Gas purging, if specified, was used in accordance with applicable

procedures

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Process control system had provisions for repairs

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Welders were qualified

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No peening performed on root and surface layers

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Weld inspection personnel were qualified

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.

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Welding Procedures - Welding Procedure qualification is covered by

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 4

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

f Calibrations"~

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2-0010125, Revision 18, " Schedule of Periodic Tests, Checks and '

! Calibrations"

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QI 11-PR/PSL-7, Revision 1, " Control of Code Safety and Relief Valves"

a. The above pro 9 rams and administrative procedures and the below listed

l Quality Instructions (QIs) were reviewed for general content and to the

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extent necessary to verify that the licensee had assigned responsi-

bilities for: preparation, review and approval of IST procedures;

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scheduling of IST; performance of test functions; performance of

l. maintenance; and performance of calibrations.

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QI 6-PR/PLS-1, Revision 11, " Document Control"

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QI 5-PR/PSL-1, Revision 29, " Preparation, Revision, Review,

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.

Unit 1 -

Data Sheet 8 - 1986

Data Sheet 9 - 1986

Data Sheet 10 - 1986

Data Sheet 11 - 1986

Routine Pump Test Summary - 1986

Unit 2 -

Data Sheet 8 - 2nd, 3rd, 4th Qtrs., 1986

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.

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The . discharges to the Safety Injection -(SI) Tanks have two

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:

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There is an alarmed pressure monitor between the two

check valves

There is an alarmed level monitor in the tank

The valves are leak checked per Technical Specification

requirements.

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HPSI and LPSI' system pumps in parallel trains take suction

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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