ML17341A859

Responds to NRC 811202 Ltr Re Violations Noted in IE Insp Repts 50-250/81-26 & 50-251/81-26.Corrective Actions: Superintendent & Welders Reminded to Plug Warmers in

ML17341A859
Person / Time
Site:	Turkey Point
Issue date:	01/11/1982
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17341A858	List: ML17341A857 ML17341A859 ML17341A860 ML17341A861 ML17341A862
References
L-82-10, NUDOCS 8202050358
Download: ML17341A859 (18)

See also: IR 05000250/1981026

Text

P.O.BOX 529IOO MIAMI, FL 33152 USNRG.P.,E,GION:~

ATLANTA, GEQRIgtA IIp JIINlo P l:-5~iri,A~FLORIDA POWER&LIGHT COMPANY January 11, 1982 L-82-10 Mr.James P.O'Reilly Regional Administrator, Region I I U.S.Nuclear Regulatory

Commission

101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Dear Mr.O'Reilly: Re: Turkey Point Units 3 8I 4 Docket Nos.50-250, 50-251~IE Inn ection Report 81-26 Florida Power 8I Light Company has reviewed the subject inspection

report and a response is attached.There is no proprietary

information

in the report.Very truly yours, Robert E.Uhrig Vice President Advanced Systems 8 Technology

REU/PLP/ras

cc: Harold F.Reis, Esqui re..-;82020S0358

820i27..."'PDR ADQCK 05000250:iII 6"-':.'.PDR." PEOPLE SERVING PEOPLE

r/

RE: TURKEY POINT UNITS 3 5 4 DOCKET NO.50-250, 50-251 IE INSPECTION

REPORT 81-26 ATTACHMENT

FINDING N: '1 10 CFR 50, Appendix B, Criterion IX, as implemented

by paragraph 9.1 of the accepted guality Assurance Program, requires measures be established

to assure that special processes including welding are controlled'nd

accomplished

in accordance

with procedures.

CBSI procedure RTl, revision 4,"Radiographic

Examination

Procedure", paragraph 5.5.1, requires the lead letter"B" to be placed on the back of the film holders during radiography.

CB8I Nuclear guality Manual for ASME Section III Products, Revision 4, Construction, Section 8 Welding, paragraph 8.2.2.1, requires all welding materials to be stored in locked storage areas or locked electrode ovens.BPC Welding Standard WFMC-l, dated April 15, 1981, paragraph 4.5.6, requires portable rod warmers to be continuously

heated or energized during use except duri ng transit time..BPC Welding Standard WFMC-l, paragraph 4.5.6, further requires low hydrogen'ow

alloy electrodes

to be used di rectl'y from portable rod-warmer s.Contrary to the above, on November 4-5, 1981, adequate measures had not been established

to assure that special processes were controlled

in that: 1.The Lead Letter"B" was not attached to the backr of the film holders during radiography

of welder qualification

test assemblies.

2.Type E8018 wel-ding el ectrodes were stored in an unguarded un I ocked el ectrode oven.3.Cold flux covered welding electrodes

were left for approximately

eight hours in an unenergized

portable rod warmer.j 4.Type E7018 low hydrogen, low alloy electrodes

were used from an open bucket adjacent to an energized rod warmer.RESPONSE: Item l.1.FPL concurs with the finding.2.The lead lined box was being used for x-ray shots of welder qualification

sampl es and i t had been proven to be ef f i ci ent in el iminati ng backscatter.

The box is completely

lead lined especially

for this use.

II t

3.No corrective

action was taken.Several test"shots" were performed for review by the NRC representative, which had been loaded with lead letter"B".No backscatter

was detected.4.Al 1 code x-rays of wel ded seams and wel der qual i fi cati on x-rays, are"shot" with the lead letter"B" attached to the backside of the cassette.FPSL g.A.has witnessed several of these shots to verify this.5.The program was in full compliance

on 12/4/81.Item 2 1.FPL concurs with the finding.2.Personnel had removed the lock on the storage oven in order to put it on a storage oven in the contai nment building.The attendant was in the process of obtaining a replacement

lock from the gA office when the'bservation

was made.3.Personnel were informed to pay more attention to lost locks.No further i nstances of such lack of control have occurred.4.Additional

locks were purchased and stored inside the containment

for use if a lock gets misplaced or damaged.5.The program was in complete compliance

by the afternoon of ll/5/81.Item 3 1.FPL concurs with the finding.2.The reason for the violation is that when the welder arrived at his work station, he neglected to plug his rod warmer in.He was called out of the containment

to do other work and did not return, leaving the rod can unplugged the entire shift.3.The responsible

superintendent

and welder were reinstructed

on weld rod control requirements.

4.All welders are reminded to plug their warmers in.When the situation warrants further action, the welder's qualification

will be rescinded and he will be terminated

from the job.5.We consider that the program is in full compliance, and that this was an isolated incident.

I I

Item 4 1.We agree that Type E-7018 electrodes

were found as described, however, we do not agree that it is a violation.

The electrode under consideration

is Type E-7018.This electrode is a low hydrogen rod, but it is not a low alloy rod;therefore, this requirement

does not app'ly because low~yrogen rods are not required to be issued in a rod warmer, as are low hydrogen, low alloy rods.Secondly, Bechtel Specification

WFNC-l, Rev.0, Table 1, required'low hydrogen Type E-7018 electrodes

to be issued in a container in accordance

with Note 1 of Table 1.The maximum time out of the holding oven is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.We issue all covered rods in a portable rod warmer even though this is not a specification

requirement.

It is an acceptable

practice for a welder to transfer a portion of his rod to a container, other than a rod warmer, and use the rod from that container during welding.Since our working shifts are less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each and the welder returns his rod and rod can at the end of his shift, it is not likely that the rod would be out of an oven for greater than the specification

limit of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.2.Response is not required since we do not agree that Part 1 of the finding~~i s a vi ol ati on.3.No action is considered

necessary for correction.

4.No corrective

action is considered

necessary to prevent recurrence.

5.The program is considered

to be in full compliance.

li E"l'

FINDING B 10 CFR 50, Appendix B, Criterion XIII, as implemented

by paragraph 13.1 of the accepted guality-Assurance Program, requires measures be established

to control the handling, storage and preservation

of materials and equipment in accordance

with work and inspection

procedures

to prevent damage or deterioration.

Contrary to the above, on November 3-6, 1981, measures were not established

to control the storage and preservation

of materials and equipment in that the following were noted: 1.Approximately

five examples of riggi ng fr om or scaffolding

supported by installed safety related cable trays or piping.2.The licensee has no documented

procedures

to control rigging from or scaffolding

on safety related materials or equipment.

3.Numerous examples of extraneous

markings and various types of tape applied to the surfaces of safety related components, tanks and piping.4.The licensee has no documented.procedure

to control surface applied substances

for safety related stainless steel applications

to prevent deterioration.

Items 1 and 2 1.FPL concurs with the finding.2.At the time of the NRC visit, scaffolding

was being installed without contacti ng the contractors

Field Engineering

group.There was no set policy or procedure for review of exi sti ng systems used to rig from or scaffold off of installed components

to insure they were adequate to support the additional

load.3.A wal kdown of scaf folding and rigging was performed by the Field Engineering

group to insure equipment, piping and cable trays were not overloaded.

Field Engineering

has judged that no equi pment, piping or cable trays were over loaded.4~5.Supervision

was instructed

to review any scaffolding

attachments

to existi ng equipment, piping and cable trays with Field Engineering

prior to rigging and scaffolding.

Periodic walkdowns will be done by Field Engineering

to insure that any scaffolding

attachments

to existing equipment, piping and cable trays does not overload the equipment, piping and cable tray With the implementation

of Item 4 above, the program is now in full compliance.

t l k.

Items 3 and 4 1.FPL concurs with the finding 2.Uncontrolled

tape and marking pen ink used during construction/maintenance

were not properly removed after use.3.Construction

supervi sion will be instructed

at the end of each outage to remove all such tape/marking

pen ink from stainless steel surfaces as per Engineering

direction.

4.A site procedure ASP-15,"Control of Expendable

Products", was in the review stage during the NRC visit.As of the date of this letter, it is in the final signature cycle.5.The program will be in full compliance

as of February 12, 1982.Existing tape/ink will be removed as per Engineering

di rection before the start up of Unit 3.

4'

Par agraph (a)(1)of 10 CFR 50.55a requi res structures

and components

be fabricated

and inspected to quality standards commensurate

with the importance

of the safety function.ASME B and PV Code Section IX has been identified

as the applicable

code for welding procedure specifications.

Paragraph gW.201.1 of ASME Section IX requires that welding procedure specifications

list specific facts involved in qualifying

a procedure specification.

Contrary to the above, on November 4, 1981, structures

and components

were not fabricated

to quality standards commensurate

with the importance

of the safety functions in that the code required specific facts (non-essential

variables), gW-410.5 method of initial interpass cleaning;gW-410.10 single electrode or mul ti pl e el ect rode;gW-410.15 el ect rode spaci ng;gW-410.25 manual, semi-automatic or machine-atomatic

wel ding;and gW-410.26 peening;were not addressed in welding procedure specifications.

RESPONSE 1.FPL does not agree with the finding: the non-essential

variables delinated in the finding are either incorporated

by refer ence in the procedures

reviewed by NRC or not applicable

as explained below.1.ASME Section IX, paragraph gW-410.5-a

change in the method of initial and interpass cleaning (brushing, grindi ng, etc.)affected Welding Procedure Specifications

-Pl-AT-Lh(CVN), P3(G3)Pl-AT-Lh(CVN)

and P 1-A-LH.Response The welding procedure specifications

contain the statement,"This welding procedure specification

must be used in conjunction

with the General Welding Standard GWS-FM".By means of this statement, the referenced

general welding standard becomes a part of the welding procedure specification.

This results in many non-essential

variables being found in the general welding standards.

GWS-FM, Revision 4, paragraph 4.1.3 requires that fili ng, brushing or grinding be performed prior to fit-up (initial cleaning)and welding (in-process

cleaning);

additionally

this paragraph is supplemented

by paragraph 4.4.8 of GllS-FM, which states,"Each completed weld head shall be cleaned essentailly

free of slag, heavy oxide, glassy silicate deposits, or other foreign material before depositi ng successive

beads.Conclusion

The non-essential

variable listed in ASME Section IX, paragraph~~gW-410.5 is addressed in General Welding Standard GWS-FM.2.ASME Section IX, paragraph gW-410.10-A change from single electrode to multiple electrode, or vice versa, for machine or automatic welding only.

4

ASME Section IX, paragraph gW-410e15-A change in the electrode spacing for machine or automati c wel di ng only.Affected Wel ding Procedures

Specifications

-Pl-AT-Lh(CVN)

and P3(G3)Pl-AT-Lh(CVN).

~Res onse The inspection

report quotes the paragraph from ASME Section IX out of content.Paragraphs

gW-410e10 and gW-410e15 do not apply to the manual wel ding process, only to machine or automati c wel ding;therefore, the variables are not applicable

to these welding procedures.

3.ASME Section IX, paragraph gW-410.25-A change from manual to semi-automatic to machine automatic welding and vice versa.Affected Welding Procedure Specifications

-Pl-AT-Lh(CVN), P3 (G3)Pl-AT-Lh(CVN)P43A and Pl-A-Lh.~Res onse The four referenced

welding procedure specifications

concern the use of the manual shielded metal arc process and the manual gas tungsten arc process.This is evident from the date on the WPS's.The inspection

report therefore, quoted the referenced

paragraph from ASME Section IX out of context, since semi-automatic

or machine automatic welding are not applicable.

4.ASME Section IX, paragraph gW-410.25 addition or deletion of peening.Affected Welding Procedures

Specifications-Pl-AT-Lh(CVN), P3 (G3)Pl-AT-Lh(CVN), P-43A and Pl-A-Lh.~Res onse The use of peening i s not used on Bechtal pr ojects.In the event that peeni ng was needed, then the applicable

wel di ng procedure specification

or general welding standard would be revised to permit peening.If peening had been used to qualify the welding procedures, it would have been included in the procedure qualification

records and the welding procedure specification.

Based on the above, we consider that there are no deficiencies

in the referenced

welding procedure specifications

with respect to inclusion of non-essential variables.

These welding procedure speci fications in combination

with the applicable

general welding standards are in full compliance

with ASME Section IX requi rements.

~'~

COUNTY OF DADE STATE OF FLORIDA)))st Robert E.Uhri, being first.duly sworn, deposes and says: That.he is Vice President Light.Company, the herein;~of Florida Power 6 That he has executed the foregoing document;that the state-ments made in this said document are true and correct, to the best of his knowledge, information, and belief, and that he is authorized

to execute the document on behalf of said Robert E.Uhrig Subscribed

and sworn to before me this I/day of 19~/,,NOTARY.PUBLIC, in nd for the County of Dade, State of Florida Notary Public, State of Porida ct Large~~'y CommL+alon

Expiroa October 30, 1SS3 My COmmiSSiOn

eXpireS: Goiidad tbru Mayiiard aoiiding Agency

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