ML20134M441

Insp Repts 50-348/85-33 & 50-364/85-33 on 850729-0802. Violations Noted:Failure to Perform Independent in-process Insps of Class 1 & 2 Pipe Welds & to Follow Procedures for Verification of Spring Support Settings

ML20134M441
Person / Time
Site:	Farley
Issue date:	08/21/1985
From:	Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134M427	List: IR 05000348/1985033 ML20134M425 ML20134M433
References
50-348-85-33, 50-364-85-33, NUDOCS 8509040124
Download: ML20134M441 (11)

See also: IR 05000729/2008002

Text

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UNITED STATES

NUCLEAR REGULATORY COMMisslON

REGION 11

3 j 101 MARIETTA STREET, N.W.

• 2 ATLANTA. GEORGI A 30323

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Report Nos.: 50-348/85-33 and 50-364/85-33

Licensee: Alabama Power Coinpany

600 North 18th Street

Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley

Inspection c t uly 29 - August 2, 1985

Inspec or:

B.

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Date Signed

. 0W

Appro ed b / 9[ts [

/ Blake, Section Chief Date Signed

ineering Branch

0 ision of Reactor Safety

< SUMMARY

Scope: This routine, unannounced inspection entailed 39 inspector-hours on site

in the areas of inservice inspection (ISI) (Units 1 and 2), maintenance welding

and nondestructive examination (NDE) (Units 1 and 2), and licensee action on

previous enforcement matters (Unit 1).

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Results: Two violations were identified - failure to perfonn independent

in-process inspections for class 1 and 2 pipe welds - paragraph 5.a.(5)(a) and

failure to follow procedures for verification of spring support settings -

paragraph 7.c.

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! REPORT DETAILS

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1. Persons Contacted

i Licensee Employees

• J. D. Woodard, Plant Manager

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• D. N. Morey, Assistant Plant Manager - Operations

• L. Ward, Maintenance Superintendent

, *R. M. Coleman, Systems Performance Supervisor

• W. G. Ware, SAER Supervisor

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• L. M. Stinson, Plant Modifications Supervisor

H. R. Garland, Maintenance Supervisor

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D. B. Hartline, Generat'1g Plant Engineer - Supervising

i G. S. Waymire, Generating Plant Engineer  ;

j S. T. Burns, Jr., Project Engineer - NETS

j Other Organizations

W. H. Coggins, Supervisor of Field Design Section, DAVCON

R. Davis, NDE Level III, Southern Company Services

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NRC Resident Inspectors

• W. H. Bradford, Senior Resident Inspector

j *B. R. Bonser, Resident Inspector

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• Attended exit interview

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2.- Exit Interview

i The inspection scope and findings were summarized on August 2,1985, with

, those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail .the inspection findings listed

below. No dissenting comments were received from the licensee.

(0 pen) Inspector Followup Item 348, 364/85-33-01, Review of Special

! Processes Manual, paragraph 5.a.(1)

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(0 pen) Unresolved Item 348,. 364/85-33-02, Welder Qualification Status  !

Records,' paragraph 5.a.(4) '

! (0 pen) Inspector Followup Item 348, 364/85-33-03, Qualification of.

Inspectors for Maintenance Activities, paragraph 5.a.(5)(b)

. (0 pen) Violation 348/85-33-04, Failure. to Perform Independent In-Process

Inspections for Class 1 and 2 Pipe Welds, paragraph 5.a.(5)(a)

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(0 pen) Violation 348/85-33-05, Failure to Follow Procedures for Verification

of Spring Support Settings, paragraph 7.c.

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

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 348/85-22-01, Failure to Follow ISI Plan. Alabama Power

Company's letter of response dated June 5,1985, has been reviewed and

determined to be acceptable by RII. Based on examination of corrective

actions as stated in the letter of response and discussions with responsible

licensee personnel, the inspector concluded that Alabama Power Company had

determined the full extent of the subject violation, performed the necessary

survey and followup actions to correct the present conditions, and developed

the necessary actions to preclude recurrence of similar circumstances. The

inspector reviewed the following to verify implementation of corrective

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actions:

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Corrective Action Report (CAR) No. 997

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FNP-1-STP-157.0, Revision 2, Inservice Inspection of Class 1 and 2

Systems and Components

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FNP-2-STP-157.0, Revision 2, Inservice Inspection of Class 1 and 2

Systems and Components

4. Unresolved Items (92701)

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. One new unresolved item identified during this inspection is

discussed in paragraph 5.a.(4).

5. Maintenance Welding and Nondestructive Examination (NDE) (Units 1 and 2)

The inspector examined the welding and NDE activities described below to

determine whether applicable regulatory and code requirements were being

met. In general, the governing code is ASME Section XI,1974 Edition, S75

Addenda. For maintenance welding and NDE of ASME Code Classes 1, 2, and 3

piping and components, the codes listed below apply as implemented by

Alabama Power Company (APCO) Nuclear Generation Welding Manual (FNP-0-M-023)

and NDE Program Manual (FNP-0-M-024). These manuals are evoked by site

procedure FNP-0-AP-12, Revision 4.

Welding - ASME Section III,1974 Edition, S75 Addenda

- ASME section IX, Latest Edition and Addenda

NDE - ASME Section V, 1980 Edition, W80 Addenda

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a. Nuclear Welding (55050)

The inspector examined the following activities relative to the welding

maintenance program:

(1) Welding Program - General

The inspector reviewed the welding program in general as defined

by the following:

- FNP-0-AP-12, Revision 4, " Control of Special Processes During

Operations"

- FNP-0-M-23, Nuclear Generation Welding Program Manual

During this review, the inspector noted several areas of weak-

ness, i.e., areas where the program did not contain sufficient

i detail. Examples were:

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Lack of guidance relative to in-process inspections - fitup,

welding procedure requirements, final weld size, etc.

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Insufficient details on material storage and issue

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Lack of requirements for detailed weld joint record

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Insufficient details on maintaining status of welder qualification

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The licensee pointed out that a new Special Processes Manual, in

preparation and scheduled for issuance in September 1985, would

provide much more detail and would strengthen weak areas in the

welding program. The inspector briefly reviewed a draft of the

new manual, and it appears that the manual will greatly improve

the welding program. Pending review of the new manual after final

issuance, Inspector Followup Item 348, 364/85-33-01, Review of

Special Processes Manual, is opened.

(2) Welding Material Control

The applicable procedures for welding material control are:

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FNP-0-AP-12

- FNP-0-AP-9, Revision 10 " Procurement and Procurenent

Document Control

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FNP-0-M-23, WP-011, Revision 1, " Welding Procedure for ASME

Section III"

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Relative to welding material control, the inspector verified that

- the licensee had established procedures for purchasing,

receiving, storing, disbursing and handling of welding

materials

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welding material storage procedures contained requirements

for environmental (moisture) control

- procedures contain effective measures for limiting moisture

pickup and maintaining identification after issue to the

welder

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welding material control system meets requirements for the

most restrictive application

(3) Welding procedures

The inspector verified that the licensee had established

procedures for preparation, qualification, approval, certification

and issue of welding procedure specifications. The applicable

1 procedures are:

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FNP-0-M-23 including WP-011

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FNP-0-AP-1, Revision 16 " Development, Review and Approval of

1 Plant Procedures"

(4) Welder Performance Qualification

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The inspector _ verified that the licensee had established

procedures for qualification of welders. The applicable

procedures are:

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FNP-0-M-23, WP-011

- FNP-0-M-23, WP-030, Revision 1, " Welder Qualification

Procedure"

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FNP-0-AP-12

The inspector reviewed original qualification records and

qualifiction status records for welders F-5, F-9, F-10, and F-12

who performed welding on the welds listed in paragraph (5) below.

The inspector noted that the method being used to track welder

qualification status, the " Performance Qualification Renewal"

form, precludes verification that welders maintain their qualifi-

cation by welding with each, process every three months as required

by ASME Section IX. Actual welding dates are not being entered on

the fom; the fonn indicates that the welder welded some time

within a calendar quarter, e.g., 07/01/85 - 09/30/85. In

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discussion of this problem with the licensee, it was also

detennined that the form is being filled out prior to start of the '

quarter based on the welder having welded the previous quarter.

Using this system, it is impossible to determine if the welder

used each process every three months. In addition, the makeup of

I the form indicates that the Maintenance Supervisor, who signs as

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the " Responsible Supervisor", witnesses the welding. Discussions

revealed that he does not actually witness the welding. It was  ;

also noted that the Maintenance Supervisors' signature was not

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. dated. Due to the questions relative to maintenance of welder

qualification status, the licensee agreed to review past mainte-

nance welding records and determine if welders have welded

. production welds with expired qualifications. Pending evaluation

I of the licensee's review, this matter is considered unresolved and.

! is identified as Unresolved Item 348, 364/85-33-02, Welder

l Qualification Status Records.

(5) Production Welding

. In lieu of observation of welding, the inspector reviewed weld

records consisting of " Weld Process Control Sheets" for the

following Unit 1 Welds:

Work Request No. Weld No. Weld Size Weld Class

! 94322 & 88067 S-1 2" 2

! 94322 & 88067 S-2- 2" 2

i 94322 & 88067 S-3 2" 2

I 94322 & 88067 S-4 2" 2

! 94322 & 88067 S-5 2" 2

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94322 & 88067 F-1 2" 2

94322 & 88067 F-2 2" 2

j 94322 & 88067 S-1A- 2" 2 >

! 84604 1. 2" 1

l 84604 2 2" 1

! 84604 3 2" 1

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84604 4 2" 1

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! During review of the records, the inspector noted the following

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problems:

! (a) The Process Control Sheets did not indicate any in-process

i quality inspections such as.fitup, compliance with procedure

l requirements, final weld size, etc. The only inspection was

a final NDE inspection for each weld. The licensee indicated

l that in accordance with their program, as defined in plant

procedure FNP-0-AP-31 Revision 7, -" Quality Control

Measures", the welders and welding foremen are responsible

for the quality of the weld -and are qualified as level II

inspectors to ANSI Standard N45.2.6. Unless independent L

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inspections are specified on the Process Sheet, no

inspections other than the welder's and foreman's is

required. If an independent inspection is specified on the l

Process Sheet, the responsible group supervisor for the work  ;

activity being inspected shall assign a qualified inspector  ;

to perform the required inspection. The independent

inspector may be another maintenance journeyman or foreman

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who is qualified to procedure FNP-0-AP-31 and is independent

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of the work actually being inspected. However, as noted no

independent in-process inspections were specified or

performed for the above welds.

Paragraph NA-4133.10 of ASME Section III, the applicable code

for the above welding, requires that in-process inspections

> to assure conformance with instructions and procedures be

performed and that the inspections be performed by persons

other than those who performed the activity being examined.

In addition, such persons are not to report directly to the '

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imediate supervisors who are responsible for the work being

4 inspected.

! 10 CFR 50, Appendix B, Criteria X, requires that a program

for inspection of activities affecting quality be established

and that such inspections be perfonned by individuals other

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than those who performed the activity being inspected.

Paragraph 17.2.10 of the Farley FSAR, which implements

l. Appendix B, Criterion X, states that maintenance activity

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inspections will include the original inspection requirements

to the extent the original requirements can be determined

from available documents. The welds in question originally

received in-process inspections such as fitup, final visual,

4 procedure compliance, etc.

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This failure to perform in-process inspections by independent

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inspection personnel for the above listed welds is in -

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violation of 10 CFR 50, Appendix B, Criterion X, and ASME -

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Section III and is identified as Violation 348/85-33-04,

Failure to Perform Independent In-process Inspections for

Class 1 and 2 Pipe Welds.

(b) As noted above, procedure FNP-0-AP-31, which implements ANSI

Standard N45.2.6 and Regulatory Guide (RG) 1.58, . allows

welders and foremen to be qualified as Level II inspectors

and perform welding inspections. Position 3 of RG 1.58

j requires that specific technical abilities of the person

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being certified should be related to the specific assigned

task.

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Inspector certification records for one foreman and one

welder were reviewed and the following areas that appear to

violate RG 1.58 and ANSI Standard N45.2.6 were identified:

• ' - The " Basis for. Certification" by the Farley program is l

education and experience. - For the records reviewed, it

is impossible to determine if the documented experience

is related to the specific assigned task (welding,

i electrical,etc.)

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4 - Maintenance journeymen and' f oremen are certified as

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level II inspectors in the general area of " Maintenance ,

' Activities" regardless of the maintenance area to be

inspected. This general activity classification is-too '

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broad to assure that inspectors are qualified as related

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'to specific assigned task (welding, electrical, etc.). ,

i During discussion of this matter with site QA personnel, the

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inspector found that the licensee had an open QA audit

finding (see . QA Audit Finding FNP-NC-43-85-8(17)) almost

identical' to that identified above. At the time of the

l current inspection, the audit' finding was still being

evaluated.

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l Pending review of the licensee's corrective

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action to the QA audit, this matter is identified as

! Inspector Followp Item 348, 364/85-33-03, Qualification of

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Inspectors for Maintenance Activities. '

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b. Nondestructive Examination (57060 and 57070)

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(1) Liquid Penetrant (PT) Examination ,

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. The inspector examined the PT activities described below relative

to maintenance activities.

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(a) Procedures NDE-PT-001, Revision 1 " Liquid. Penetrant

Examination (Color Contrast and Fluorescent)", was reviewed

to determine whether the procedure had been approved and

issued in accordance with the QA program. In addition, the

procedure was reviewed to determine whether the following

I' parameters were specified and controlled in accordance with

l applicable requirements:

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Method consistent with applicable codes

Specification of brand names and types of penetrant

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s materials

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Specifications of limits of sulfur and total halogens

for materials

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Pre-examination surface preparation and cleaning

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Minimum drying time following surface cleaning

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Penetrant application and penetration time

- Temperature requirements

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Solvent removal

- Method and time of surface drying prior to developing

- Type of developer and method of application

- Examination technique

- Time interval for interpretation

- Required lighting

- Technique for evaluation

- Acceptance standards

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Reporting requirements

- Requalification Requirements

- (b) Personnel qualification / certification records for NDE

personnel who performed PT inspection of the welds listed in

paragraph 5.a.(5) above were reviewed.

s (c) The inspector reviewed PT inspection records for the welds

listed in paragraph 5.a.(5) above.

(2) Magnetic Particle (MT) Examination

The inspector examined the MT activities described below relative

to maintenance activities.

(a) Procedure NDE-MT-001, Revision 2, " Magnetic Particle

Examination Procedure", was reviewed to determine whether the

procedure had been approved and issued in accordance with the

QA program. In addition, the procedure was reviewed to

determine whether the following parameters were specified and

controlled in accordance with applicable requirements:

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Method - Continuous

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Surface Preparation

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Particle Contrast

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Surface Temperature

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Light Intensity

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Coverage

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Prod Spacing

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Magnetizing Current

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Yoke Pole Spacing

- Acceptance criteria are specified consistent with the

applicable Code and specific contract requirements.

(b) Personnel qualification / certification records for 2 Level II

MT examiners associated with maintenance activities were

reviewed.

Within the areas inspected, one violation was identified. No deviations

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were identified.

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6. Inservice Inspection - Review of Procedures (73052) (Unit 1) )

ISI procedures were reviewed as indicated below to determine whether the

procedures were consistent with regulatory requirements and licensee

conmitments. In accordance with the " Ten Year Inspection Plan of the

J. M. Farley Plant - Unit 1" and the " Ten Year Inspection Plan of the

J. M. Farley Nuclear Generating Plant - Unit 2", the applicable code is the

ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition with Addenda

through S75.

NDE procedures for the areas of examination listed below for outage 1 of

period 3 were examined to deterriine whether the. procedures were consistent

with licensee Technical Specification commitments and specified the

examination category, method of examination, and extent of examination.

- Reactor Vessel (RV) Closure Head Welds 1, 2, 3, 4 and 5

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Pressurizer Shell Welds

- Steam Generator Primary Head Welds

- Reactor Coolant Pipe Welds _ _ _ ~

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

7. Inservice Inspection - Data Review and Evaluation (737558) (Units 1 and 2)

The inspector reviewed the ISI NDE records described below to determine

whether the records were consistent with regulatory and code requirements.

See paragraph 6 above for the applicable code.

a. NDE records for the following reactor vessel welds were reviewed:

Unit ' Outage Weld 150

1 Period 3, Outage 1 5 (Head to Fla'nge) ALA-102

2 Period 2, Outage 1 1 (Flange to Shell) APR-1-1100

The records were reviewed in the areas of:-

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Methods, extent, and technique comply with~ISI program

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Examination data meets applicable acceptance criteria

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Recording, evaluation, and disposition of findings are in

accordance with applicable procedures

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Examination results compared with recorded results of previous

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examinations

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Methods used sufficient to determine the full extent of

indications

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b. NDE Records for the.following pipe welds were reviewed:

Unit Outage Weld ISO

1 Period 3, Outage 1 2 and 5 ALA-134

1 Period 3, Outage 1 2 and 3 ALA-145

1 Period 3, Outage 1 141 and 143 ALA-223

2 Period 2, Outage 1 1DM APR-1-4300

2 Period 2, Outage 1 4-6 and 4-17 APR-2-2110

2 Period 2, Outage 1 4 and 52 APR-2-2314

The records were reviewed in the areas of:

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Calibration data sheets

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Proper recording of recordable indications

- Evaluation of examination data by Level II or Level III examiner

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Evaluation of data complies with applicable procedures

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Evaluation of indications complies with applicable procedures

c. During review of the above records, the inspector reviewed the

licensce's program for inspection of pipe supports required to be

inspected by ASME Section XI. Inspection data for Unit I spring type

hangers, inspected during the last outage (period 3, Outage 1), were

reviewed.

The inspector found that for Unit I spring hangers "A" on 150 ALA-221

and "F" on ISO ALA-218, the support settings were not verified as

required by ASME Section XI, Table IWC-2520. Paragraph 3.6.1 of

Procedure ISI 8, revision 07, Am. 01, " Visual Examination Procedure",

requires that hangers having calibrated load indicators have the scale

reading recorded. Paragraph 4.10 of FNP-1-STP-157.0, Revision 1,

" Inservice Inspection of Class 1 and 2 Systems and Components",

requires that support settings of constant and variable spring type

hangers be verified. This failure to verify support setting is in

violation of 10 CFR 50, Appendix B, Criterion V, and is identified as

Violation 348/85-33-05, Failure to' Follow Procedures for Verification

of Spring Support Settings. ,The inspector noted that although the

licensee's procedures and QA program had been violated, the ASME Code

had not been violated at the-time the violation was found. ASME

Section XI requires that the supports in question be inspected during

the third 40 month period. Since or.ly th'e 1st outage of the period has

passed, the settings can be verified during a future outage prior to

expiration of the period. However, it is not certain that the licensee

would have caught the omission had the inspector not reviewed the

records.

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Within the areas inspected, one violation was identified. No deviations were

identified.

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