IR 05000348/1985033

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)

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n UNITED STATES NUCLEAR REGULATORY COMMisslON REGION 11 3 j 101 MARIETTA STREET, * 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: ! 6!N (

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

! 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 i

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

• H. Bradford, Senior Resident Inspector j *B. R. Bonser, Resident Inspector

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• Attended exit interview i

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 o 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 The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . 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 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). 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 Addend 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 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, et 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

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 progra 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 opene (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" i

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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

The inspector _ verified that the licensee had established procedures for qualification of welder 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) belo 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 - 09/30/8 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 quarte 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 Record (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 N Weld N 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

94322 & 88067 F-1 2" 2

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

! 84604 " 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 t

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. Unless independent L

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4 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 inspectio 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 weld 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 examine 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

than those who performed the activity being inspecte Paragraph 17.2.10 of the Farley FSAR, which implements 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 i'

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 Weld (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

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

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

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 evaluate '

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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 Activitie '

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, 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 reviewe s (c) The inspector reviewed PT inspection records for the welds listed in paragraph 5.a.(5) abov (2) Magnetic Particle (MT) Examination The inspector examined the MT activities described below relative to maintenance activitie (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 progra 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 requirement (b) Personnel qualification / certification records for 2 Level II MT examiners associated with maintenance activities were reviewe Within the areas inspected, one violation was identifie 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 conmitment 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 S7 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 examinatio 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 identifie . 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 requirement See paragraph 6 above for the applicable cod 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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10 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 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 X Inspection data for Unit I spring type hangers, inspected during the last outage (period 3, Outage 1), were reviewe 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 recorde 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 identifie I; i

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