ML19325D091

Responds to Violations Noted in Insp Repts 50-498/89-36 & 50-499/89-36.Corrective Actions:Heat Input Parameters for Welding Performed by Const & Maint Depts to Be Monitored on Surveillance Basis & Electrodes Removed from Incorrect Oven

ML19325D091
Person / Time
Site:	South Texas
Issue date:	10/12/1989
From:	Rosen S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ST-HL-AE-3254, NUDOCS 8910180354
Download: ML19325D091 (8)

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PO Box 1700 11ouston. Texas 77001 (713) 228 9211 Hausson Lighting Ae Power- , . - . - , .

October 12, 1989 ST-HL AE 3254 File No.: 002.04 10CFR2.201 r-U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station L- Units 1 and 2 Docket Nos. STN 50 498 STN 50 499

b. Resoonse to Notices of Violation (498/8936 01. 02: 499/8936-01. 02)

Houston Lighting & Power Company (H14P) haa reviewed Notices of f Violation (498/8936 01, 02; 499/8936 01. 02) dated September 12, 1989, and. t submits the attached response pursuant to 10CFR2.201. Included is a response addressing actions to be taken to resolve the discrepancy noted between the text of the South Texas Project Electric Cenorating Station Final Safety Analysis Report and actual welding proceddre qualification practices.

If you should have any questions on this matter, please contact Mr. M. A. McButwett at (512) 972 8530.

b 0NM S. L. Rosen 4 Vice Prcsident Nuclear Engineering and Construction SLR/PLW/nl Attachments: Response to Notice of Violation (498/8936-01; 499/8936 01) 1:

Response to Notice of Violation (498/8936 02; 499/8936-02) l Resolution of Procedure Qualification Discrepancy 3

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s910180304(,h98 DR ADOCK FDC Of ,

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i A1/046.NL8 A Subsidiary of Ilouston Industries Incorporated l:

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llouston lj hting g k Power Chimpany ST HL AE-3254 File No. 002 Page 2  ;

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Regional Administrator, Region IV Rufus S. Scott  ;

Nuclear Regulatory Commission Associate General Counsel  ;

611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company l Arlington, TX 76011 P. O. Box 1700 ,

Houston, TX 77001 George Dick, Project Manager I U. S. Nuclear Regulatory Commission INPO '

Washington, DC 20555 ' Records Center 1100 circle 75 Parkway Jack E. Bess Atlanta, CA 30339 3064 1 Senior Resident Inspector Unit 1 c/o U. S. Nuclear Regulatory Commission Dr. Joseph M. llendrie P. O. Box 910 50 Be11 port Lane Bay City, IX 77414 Be11 port, NY 11713 -

J. I. Tapia D. K. Lacker ,

Senior Resident inspector - Unit 2 Bureau of Radiation Control i c/o U. S. Nuclear Regulatory Commissien Texas Department of Health I P. O. Box 910 1100 West 49th Street '

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Bay City, TX 77414 Austin, TX. 78756 3189 J. R. Newman, Esquire Newman & lloltzinger, P. C.  ;

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1615 L Street, N. W.

Washington, DC 20036 R. L. Range /R. P. Verret Cer. tral Power & Light Company .

P. O. Box 2121 Corpus Christi, TX 78403 R. John Miner (2 Copies)

Chief Operating Officer .

City of Austin Electric Utility 721 Barton Springs Road Austin, TX 78704 R. J. Costello/M. T. Hardt City Public Service Board P. O. Box 1771 San Antonio, TX 78296 A1/046.NL8

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Attachment 1  :

R ST.HL AE 3254 Page 1 of 2 i

I South Texas Pro,tect Electric Cenerating Station Units 1 and 2 l Docket Nos. STN 50 498 STN 50 499 i

Resoonse to Notices of Viointion (498/8936 01. 490/8936 01) i I. Statement of Violation Criterion X of Appendix B to 30 CFR Part 50 states, in.part, "A program for inspection of activities affecting quality shall be established and executed by or for the nrganization performing the activity to verify conformance with documented instructions, procedures, and drawings for accomplishing the activity. Such inspection shall be performed by individuals other than those who performed the activity being inspected

. .. Both inspection and process roonitoring shall be provided when control is inadequate without both . ...

Contrary to the above, the inspectors determined through interviews with personnel from the departments of Nuclear Assurance, Quality Control, and Support Construction, that in-process monitoring of welding parameters, such as, amperage, voltage, and travel speed, was not being conducted for the welding performed during the outage.

II. Houston Lichtine & Power Position HL&P concurs that the cited violation occurred. However, note that the actual. issue is lin,1ted to amperage, voltage, and travel speed (which are enamonly referred to as heat input parameters). Other variables have been routinely monitored / inspected by both Support. Construction and Quality Control, including cleanliness, joint preparation, fit up, preheat, proper gas shielding /purgi.ng, interpass temperature, and welder qualification.

III, Reason for Violation The root cause of this violation is inadequate procedural implementation i i of the welding program. This program was intended to require random '

L monitoring of parameters, including various heat input parameters.

l Failure to implement this requirement has been attributed to lack of detail in specifying the types of parameters to be monitored.

Heat input variables are not essential variables except for i impact tested applications. No such welds have been conducted under the HIAP program since commercial operation except for a manway repair (which was subjected to heat input monitoring). While heat input control is considered to be good practice in stainless steel welding, heat input control is not critical in PWR's. Therefore, lack of monitoring of heat input variables does not lead to technical concerns with tho welding performed. Furthermore, no adverse condition has been identified with any field welds due to lack of heat input parameter monitoring.

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g o Attachment 1 i L ST.HL.AE.3254 Page 2 of 2

- IV. Corrective Action Taken and Resglis Achieved Directions have been given that heat input parameters for welding performed by the construction and maintenance departments be monitored .

on at least a surveillance basis.

In addition, Quality Control inspection personnel were directed to monitor these additional heat input welding parameters on a surveillance basis.

V. Actions Taken to Prevent Recurrence e

Procedure OPMP02.ZW.0001, " General Welding", and/or welding forms will

• be revised to identify the specific types of parameters and attribales to be monitored during in process surveillance of welding activities, r This is expected to be completed by October 31, 1989.

I Procedure NDEP 3.0, " Visual Examination of Welds", will be revised to clearly define QC's role relative to surveillance of welding parameters.

This proced' ire will provide QC monitoring of heat input welding parameters. This is expected to be completed by October 31, 1989.

VI. Date of Full Comoliance Surveillance of weld parameters has been implemented by internal memorandum as described under Section IV. Requirements will be formally .

implemented by procedure revision by October 31, 1989, t

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Attachment 2 ST HL AE 3254 Page 1 of 3 o

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Units 1 and 2 Docket Nos. STN 50-498, STN 50 499 Resoonse to Notice of Violation (498/8936-02: 499/8936-02)

I. Statement of Violation Criterion V of Appendix B to 10 CPR Part 50 requires activities affecting quality to be prescribed by documented procedures and accomplished in accordance with these procedures.

Paragraph 6.2 in Revision 4 to Procedure OPMP02.ZW 0004, " Control of Filler Meterials," states in part, "After opening hermetically sealed containers and color coding, all low hydrogen and stainless steel electrodes which are not immediately issued for production use shall be stored in holding ovens . . . . Each holding oven shall be clearly marked to indicate its contents and shall contain no more than one classification of covered electrodes or more than one heat code of the same size."

Contrary to the above, three of seven holding ovens being used in the Unit 1 Filler Material issue Area contained either more than one classification of covered electrodes or more than one heat code of the same size, none of which were identified as being contained within the ovens.

1. Oven OSC 101, which was identified as containing 3/32 and 1/8 inch E9018-B3 electrodes, also contained 1/8 inch E9018 electrodes mixed in with the 1/8 inch E9018 B3 electrodes.

2. Oven OSC 102, which was identified as containing 3/32 and 1/8 inch E308L 16 electrodes, Lot Nos~. 2849816 and 2449256, respectively, also contained 3/32 inch E308L 16 electrodes, Lot No. 2549410, mixed in with the identified 3/32 inch E308L 16 electrodes.

3. Oven OSC 108, which was identified as containing 3/32 and 1/8 inch E7018 electrodes, also contained 3/32 inch E309 16 electrodes mixed in with the 3/32-inch E7018 electrodes, and one 1/8 inch E8018 B2 electrode mixed in with the 1/8 inch E7018 electrodes.

II. Houston Lichtine & Power Position HL&P concurs that the cited violation occurred.

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I Attachment 2 ST HL AE 3254 Page 2 of 3 III. Reason for Violation The root cause leading to commingling of covered electrodes at the Building 26 Weld Filler Material Issue area was insufficient training of Support Construction Department rod room attendants. These rod room attendants did not understand the procedural requirements for issuing color coded rods for contractors and maintaining separation of material by type. In addition, a substitute rod room attendant recently assigned to that position had only a minimal amount of experience and had not been familiarized with that rod room prior to his assignment.

Nuclear Plant Operations Department rod room attendants were not affected by these concerns.

IV. Corrective Action Taken and Results Achieved The corrective actions taken were as follows:

1) Electrodes found to be in the incorrect oven in Building 26 were removed.

2) A self imposed stop work order was issued to stop issuance of weld filler material from Building 26. This was to be in effect until corrective actions and actions to prevent recurrence had been taken.

3) Nuclear Assurance performed a verification of the satisfactory compliance of weld filler caterial issue areas with procedural requirements.

4) An investigation was initiated to determine the potential impact on plant systems ar.d equipment should weld. filler material have been incorrectly issued and used in permanent plant installation.

The self-imposed stop work order was released following verification of the training of Support Construction Department rod room attendants and verification by Nuclear Assurance of satisfactory compliance with requirements in weld filler material issue areas. The investigation determined that incorrect filler material may have been issued; however, this possibility is limited to nonsafety-related applications.

Filler material of two different heats might have been used in safety-related applications, but there is no adverse impact since both heats are equally acceptable.

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ST HL AE 3254

- Page 3 of 3 V. Actions Taken to Prevent Recurrence  !

i Rod room attendants have been trained in the requirements for issuing

color-coded rods for contractors and for maintaining separation of material by type.

VI. Date of Pull Comn11ance [

All corrective actions have been completed. The stop work order was '

lifted after verification of the training of Support Construction ,

Department rod room attendants and satisfactory completion of a review of weld filler material issue areas by Nuclear Assurance, r

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i. ST.HL AE-3254 Page 1 of 1 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Units 1 and 2 Docket Nos. STN 50 498. STN 50 499 Discrenancy Between the FSAR and WPS Oualifications Concerning Heat Incut Controls During the inspection conducted during the period August 21-25, 1989, a discrepancy concerning heat input used during welding procedure qualification for welding austenitic stainless steels was noted between the text of the South Texas Project Electric Generating Station (STPEGS) Final Safoty Analysis

Report (FSAR) and actual welding procedure qualification records. The inspectors noted that the FSAR addresses requirements for establishing heat.

i input during welding procedure qualification, but that the procedure qualification records did not record heat input parameters. The inspectors noted that the heat input controls specified in the FSAR are considered good welding practice and not regulatory requirements. However, HL&P was requested to resolve the discrepancy between the FSAR and the welding procedure qualifications.

Appropriate sections of the FSAR will be revised to clarify the intent, i.e., that heat input limits are specified in the welding procedure specification, but are.not required to be recorded in the procedure qualification records. This revision to the FSAR is expected to be issued by the end of 1990.

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