ML20128K297

Insp Rept 50-302/85-23 on 850513-17.No Violation Noted: Failure to Follow Welding Procedure Spec Requirements for Torch Shielding Gas Flow

ML20128K297
Person / Time
Site:	Crystal River
Issue date:	05/30/1985
From:	Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128K270	List: ML20128K267 ML20128K280 ML20128K297
References
50-302-85-23, NUDOCS 8507100538
Download: ML20128K297 (12)

See also: IR 05000302/1985023

Text

"

s

'

. UNITED STATES

C Erg #

.

o,, NUCLEAR REGULATORY COMMISSION

.? o REGION 11

'

'

5 t 101 MARIETTA STREET,N.W.

1. ATLANTA, GEORGIA 3030:1

%,...../

1

Report No.: 50-302/85-23'

' Licen'see: Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733

Docket'No.: 50-302 License No.: DPR-72

Facility Name: Crystal River

Inspection Co d Sd:- 3 - 17

Inspector: Y- ' //* - 41M/M6

D3te 5igned

~

K.' P P sor

Approved by p/Bf

J. . lake, Sec'; ion Chief D' ate Signed

Eg eering Division

iv sion of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 37 inspector-hours on site

- in the areas of licensee action on previous enforcement matters, modification

progress, welding (55050), and nondestructive examination.

' Results: One violation was identified " Failure to Follow WPS Requirements" -

paragraph 6e.

.

8507100538 850606 2

DR ADOCK 050

(

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

-

.

. .,. h

e

si

REPORT DETAILS

I

h,s 1. Persons Contacted

> , y _

'

Licensee Employees

-;,,

,.

e

? *P. F. McKee, Plant Manager, Florida Power Corporation (FPC)

?, *K. F. Lancaster, Manager, Site Quality Assurance (QA)

. *J. G. Bradley, Manager, Site Quality Control (QC)

• W. L. Rossfield, Manager, Site Nuclear Compliance

/ *J. May, Welding Engineer

Other licensee employees contacted included construction craftsmen,

engineers, technicians, and office personnel.

OtherOrganizatio$

Fluor

• J. Warren, Project Engineer

• B. E. Drake, Engineer

NRC Resident Inspectors

y

-

• T. Stetka, Senior Resident Inspector

'

, *J. E. Tedrow, Resident Inspector

• Attended exit interview

2. Exit Interview

'

The inspection scope and findings were summarized on May 17,1985, with

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

are'as ' inspected and discussed in detail the inspection findings listed

below'; No dissenting comments were received from the licensee.

F

• , (0 pen) Inspector Followup Item 50-302/85-23-01: " Weld Undercut Acceptance

,,. Criteria" - paragraph 6a

'(Open) Unresolved Item 50-302/85-23-02: "WPS Validity" - paragraph 6c(1)

+

A-

'

(0 pen) Inspector Followup Item 50-302/85-23-03: "WPS Thickness Range" -

paragraph 6c(2).

,. e (0 pen) Violation 50-302/85-23-04: " Failure to Follow WPS Requirements" -

paragraph 6e

(0 pen) Inspector Followup Item 50-302/85-23-05: " Post Weld Heat Treatment

, Program Inconsistencies" - paragraph 6f

.

_ - . _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _

.-

.

.

2

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

(0 pen)UnresolvedItem 302/85-17-02: " Control of Filler Material".

This item involves the staff's concern over the adequacy of the licensee's

welding filler material control program. The welding filler material is

controlled by two procedures, M0P-412, " Control of Welding Consumables", I

Rev. O, dated March 27,1985, and MP524, " Control and Issue of Welding l

. Materials". MPS24 controls welding materials to the point of issue from the '

welding material issue station; M0P-412 controls welding materials in the

field from the point of issue from the welding material issue station to

deposition or. return to the welding material issue station where MP-524

takes over control. The inspector reviewed both procedures, inspected the

welding material issue station, and observed field welding for compliance

with both procedures in the applicable areas. The inspector found the

following areas of weakness in addition to these identified in IE Report

302/85-17:

The licensee has no documented program to control welding filler

'

a.

material stubs.

< b. There is no statement defining what the authorizing signature on the

welding material withdrawal order (WEW0) signifies.

c. The procedures permit welding filler material issued to one welder to

be used by other welders not listed on the WEW0. This is an open

invitation for the loss of control of materials.

,

d. The procedures permit the WEW0s to be kept with the document packages

j and not with the material thus providing an additional area of possible

'

loss of control and identification of the material.

The licensee agreed to address these issues in their review of both

procedures. This matter remains open.

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or devia-

tions. New unresolved items identified during this inspection are discussed

in paragraph 6c(1).

..

..

I.

D

-

..

3

5.. Independent Inspection Effort

Modification Progress

The inspector ~ conducted a general inspection of protected area, auxiliary

-building turbine building and the containment to observe modification

progress and activities such as welding, material handling and control,

housekeeping and storage.

Within the areas examined no violations.or deviations were identified.

6. Welding (55050)

'

' The - inspector observed welding work activities as described below, to

determine whether applicable code and procedure requirements were being met.

The applicable codes standards and specifications are listed below:

The Final Safety Analysis Report (FSAR) indicates the -following codes as

applicable:

Reactor Coolant Pressure Boundary (RCPB? Piping United States of

America Standard (USAS) B31.7 February :.968 Draft

Power Pi)ing USAS B31.1.0 - 1967 (But Fabricated, tested and inspected

to USAS 331.7 - February 1968)

Structures American Institute for Steel Construction (AISC) 1963,

" Specification for Design, Fabrication, and Erection of Structural

-Steel for Buildings"

" Requirement Outline for Fabrication of. Steel Structures" R.0. - 2968 of

March 9, 1970, specifies that welding shall be performed in accordance with

American Welding Society (AWS) D1.1-69. R0-2968 is the FPC document.that

provides requirements for fabrication of structures during construction at

the Crystal River Unit 3 site. The licensee indicated that the latest

edition of AISC code was used to write R0-2968, that revision of the AISC

code referenced AWS D1.1-69.

The licensee indicated the below listed codes are applicable for the present

outage:

RCPB Piping - USAS B31.7 - 69

P_ower Piping'- USAS B31.1.0-67

Structures - AWS D1.1-1980

Welder / Procedure Qualification - American Society of Mechanical

Engineers Boiler and Pressure Vessel

(ASME B&PV) Code Section IX -- The

latest at the time of qualification

Repair - ASME B&PV Code

Section XI - 1980 Edition

-

.

4

a. Review of Quality Program

The inspector reviewed the below listed documents to ascertain whether

these documents had been approved by the licensee and whether adequate

plans and procedures had been established to assure that the specified

activities would be controlled and accomplished consistent with

commitments and regulatory requirements.

No. Title

-

" Nuclear Quality Assurance Plan"

-

" Crystal River Unit 3 Final Safety Analysis

Report"

FPC-M0P-411, Rev. 1 " Control of Welding"

FPC-M0P-412, Rev. 0 " Control of Welding Consumables"

FPC-MP-525, Rev. 0 " Control of Welding"

FPC-MP-524, Rev. 0 " Control of Issue of Welding Material"

FPC-MTAP-W-010, Rev. 2 " Welding Procedure Specification Supplement"

FPC-MTAP-W-020, Rev. 2 " Qualification of Welding Procedures"

FPC-MTAP-W-030, Rev. 3 " Qualification of Welders"

FPC-MTAP-W-040, Rev. 2 " Storage Handling and Control of Welding

Consumables"

FPC-MTAP-W~041, Rev. 2 " Purchase of Welding Consumables"

FPC-MTAP-W-050, Rev. 2 " Control of Preheat, Interpass and Post Weld

Heat Treatment"

With regard to the inspection above, the inspector noted that M0P-411,

Section III, D60, and Section III, Table 1, require the user of the

procedure to know the direction of " primary tensile stress, shear,

compression" strettes to evaluate undercut. The inspector discussed

this matter with the licensee and indicated that this type of

determination is beyond the abilities of the expected users of the

procedure. The licensee indicated they will reevaluate this matter and

provide undercut acceptance criteria definitive and determinable at the

user level. This matter will be identified as inspector followup item

302/85-23-01: " Weld Undercut Acceptance Criteria."

. --_ __

-

,

5

b. Base Material and Filler Material Compatibility for Welding

(1) The inspector reviewed the base and filler material combinations

employed to evaluate the suitability of application.

(2) The inspector reviewed the licensee's program for control of

welding materials to determine whether materials are being

purchased, accepted, stored, and handled in accordance with QA

procedures and applicable code requirements. The following

specific areas were examined:

-

Purchasing, receiving, storing, distributing and handling

procedures, material identification, and inspection of

welding material issuing stations

.

i

-

Welding material purchasing and receiving records for the

following materials were reviewed for conformance with

applicable procedures and code requirements.

Type Size Heat / Batch No.

E-316 Insert 14548

ER-316 3/22" 40560

ER-316 1/8 51156

ER-308 1/8 98520

E-7052 Insert 421N3602

ER-70S2 3/32 065433

E-7018 3/32 33043

c. Welding Procedure Specification

The following Welding Procedure Specifications (WPS) were selected for

review and comparison with the ASME Code:

WPS PROCESS * PQR

8/8-TT-022 GTAW 76-003

8/8-TT-019 GTAW 76-002

1/1-TS-Q GTAW/SMAW 71-001, 71-002,71-003, 76-005

1/1-SS-022 SMAW 76-008, 76-006

• GTAW-Gas Tungsten Arc Welding

SMAW-Shielded Metal Arc Welding

The above WPSs and their supporting Procedure Qualification Records

(PQRs) were reviewed to ascertain whether essential supplementary

and/or nonessential variables including thermal treatment were

consistent with code requirements; whether the WPSs were properly

qualified and their supporting PQRs were accurate and retrievable;

.

m-

- .

6

whether all required mechanical tests had been performed and the

results met the minimum requirements; whether the PQRs had been

reviewed and certified by appropriate personnel and; whether any

revisions and/or changes to nonessential variables were noted. WPSs

are qualified in accordance with ASME Section IX, the latest edition

and addenda at the time of qualification.

(1) With regard to the examination above, a representative of the

licensee informed the inspector that some WPSs (specific WPS Nos.

not specified) were qualified by Catalytic, Inc. (CI) while they

had the contract for welding work at the Crystal River site.

Those procedures were not qualified by FPC. ASME B&PV Code,

Section XI, paragraph IWA-4500, requires that all welding be

performed in accordance witn WPS, which have been qualified by the

owner (FPC) or the repair organization. It has not been

determined whether FPC or CI was the repair organization as

defined in IWA-4300(c)(1)-(3). As FPC is the repair organization

for the currect outage, it remains undetermined whether those

unidentified WPSs are consistent with IWA-4300 and therefore valid

for this outage. If FPC is determined to be the repair organi-

zation during the contract period with CI, then the procedures

were qualified consistent with IWA-4300 and are valid for this

outage. Conversely, if CI is determined to be the repair

organization then the procedures would not have been qualified by

the owner (FPC) or the current repair organization (FPC) and

therefore not valid for this outage. Once the issue of repair

organization during the CI contract period is resolved, the

validity of the CI qualified WPSs will be determined by the NRC

staff. This matter will be identified as unresolved item 302/85-

23-02: "WPS Validity"_.

(2) With regard to the examination above, the inspector noted that the

supporting PQRs listed on the below listed WPSs do not support the

full thickness range listed on these WPSs.

ASME

WPS Section IX

Qualified

WPS Thickness PQR PQR Maximum

No. Range No. Thickness Thickness

1/1-SS-022 0.062"-1.500"76-008 & 0.562" 1.124"76-006 0.280" 0.560"

8/8-TT-022 1/16"-0.562"76-003 0.280" 0.560"

8/8-TT-019 0,062-0.562"76-002 0.280" 0.560"

The licensee indicated that they had other PQRs to support

1/1-SS-022, and they would amend all three WPSs to reflect

thickness ranges consistent with ASME B&PV Code Section III. This

matter will be identified as inspector followup item 302/85-23-03:

"WPS Thickness Range."

r-

.

.

7

d. Welder Performance Qualification

(1) The inspector reviewed the licensee's program for qualification of

welders and welding operators for compliance with QA procedures

and applicable code requirements.

(2) The following welder qualification status records and " Records of

Performance Qualification Test" were reviewed:

Welder Symbol

PF-4

PF-13

PF-46

PF-362

e. Production Welding

The inspector surveyed ongoing welding activities and selected typical

in-process operations representing different welding processes,

procedures and joint configurations for detailed review. The weld

joints selected are listed below. The review was conducted to

determine the following: work conducted in accordance with a

" traveler"; welding procedures and drawings available; WPS assigned in

accordance with applicable code; technique and sequence are specified;

materials as specified; geometry as specified; fitup and alignment as

specified; temporary attachments consistent with applicable code; gas

shielding and purging as specified; preheat is as specified; technique

is as specified; welding electrodes are as specified and consistent

with the code; gas flow is controlled as specified; welding equipment

is as specified; interpass temperature is controlled and consistent

with the applicable codes; interpass cleaning and backgouging are

performed as specified; process control system has provision for

repairs consistent with applicable codes; weld re9 airs are conducted in

accordance with specified procedures; base metal repairs are properly

,

documented; welder identification; peening not done on root or final

l weld surface layer; and contractor / licensee has periodic welding

l equipment preventative maintenance program.

l Welds Examined

Wold Numbers System

MU-85-128 Makeup

MU-85-129 Makeup

MU-85-42 Makeup

EF-85-110 Emergency Feedwater

With regard to the inspection above, the inspector noted the follcwing

on May 15, 1985, while observing inprocess welding on Field Weld

No. MU-85-128 being welded with WPS 8/8-TT-022.

. . .

_ _ . .

. .

8

.

-

The torch. shielding gas was 12 cfh and the maximum bead width was

7/16-inch; this is contrary to WPS 8/8-TT-022 which requires torch

shielding gas flow of 15 to 25 CFH and bead width for the filler

material size used of 3/8-inch maximum.

The inspector- discussed- the above with the welder concerned and his

supervisor. This discussion. concerned the importance of verbatim

compliance to procedures controlling activities affecting quality. On

May 16, 1985, the inspector observed the same welder, welding field

weld MU-85-129 welding with WPS 8/8-TT-022. The inspector made the

following observations:

- The bead width was consistent with the procedure requirements;

i however, torch shielding gas flow was now less than ten CFH.

The above are clear examples of failure to follow procedure for

activities affecting quality, which is in direct violation of Title 10

-Code of Federal Regulations, Appendix B, Criterion V. This violation

will be identified as 302/85-23-04: " Failure to Follow WPS Require-

> ments."

,

f. Preheat and Post Weld Heat Treatment-

'

-(1) Preheat

'

(a) The inspector reviewed the licensee's programs for weld

preheating to determine whether procedures were available

! when specified; procedures specify acceptable methods and

'

provide requirements for ~ monitoring and recording preheat

before, during, and if specified after welding, until post

-weld stress relief.

(b) The inspector observed preheat controls in process to .

~ determine whether procedures were being followed, and

'

temperatures were within specified limits. The welds listed

in paragraph 6e were examined.

(2) Post Weld Heat Treatment (PWHT)

(a) The inspector reviewed the licensee's program for PWHT to

1- determine whether procedures were available; had a system

capable of meeting of the heating and cooling rates, metal

temperature, temperature uniformity and control limits were

specified and consistent with the applicable codes; procedure

covered both local and furnace heating if used; and furnace

atmosphere controlled if used.

.

With regard to the examination above, the inspector noted the following

. inconsistencies:

+

t

i

-~ . _ . _ . _ . . __. ._. , _ _ _ _ _ . - - _ _ . -

- _ . _ _ _ . . _ _ _ , _ , . _ , _ . _ . _ . , _ _ . . _ , . _ _

,

l

.. .

9

- W-050 specifies heating and cooling rate maximums for temperatures

above 800 F; AWS D1.1 specifies maximum heating and cooling rates

for temperatures over 600'F.

- The preheat temperatures listed in W-050 are not consistent with

the preheat temperatures listed in USAS B31.1.0.

- The post weld treatment temperature ranges specified in W-050 are

not consistent with the preheat temperatures listed in USAS

B31.1.0.

The inspector discussed the above with the licensee, who indicated that

they would reevaluate W-050 and provide engineering justification for

all deviations from committed code requirements or ammend W-050 to

comply with the committed codes. This matter will be identified as

inspector followup item 302/85-23-05: " Post Weld Heat Treatment

Program Inconsistencies."

g. Examination of Welds

The inspector visually examined completed and accepted welds as

described below to determine whether applicable code and procedure

requirements were being met.

(1) The below listed welds were examined relative to the following:

location, length, size and shape; weld surface finish and

appearance (including inside diameter of pipe welds when

accessible); transitions between different wall thickness; weld

reinforcement -- height and appearance; joint configuration of

permanent attachments and structural supports; removal of

temporary attachments; arc strikes and weld spatter; finish-

grindioq or machining of weld surface -- surface finish and

absence of wall thinning; surface defects -- cracks, laps, and

lack of penetration, lack of fusion, porosity, slag, oxide film

and undercut exceeding prescribed limits.

Weld No. System

MU-85-115 Makeup

MU-85-116 Makeup

MU-85-30 Makeup

MU-85-37 Makeup

MU-85-38 Makeup

MU-85-49 Makeup

MU-85-56 Makeup

MU-85-57 Makeup

MU-85-58 Makeup

Within the areas examined no deviations or violations were

identified except as noted in paragraph 6e.

.

r-

a

. .

10

.

7. Nondestructive Examinations

The inspector reviewed procedures, observed in-process examinations and

reviewed' quality records as described below to determine whether applicable

code, procedure and regulatory requirements were being met. The applicable

code for nondestructive examination (NDE) is ASME B&PV Code, Section V,1974

Edition with Addenda through Summer 1975.

a. Review of Quality Program

The inspector reviewed the below listed documents to ascertain whether

the NDE program has been approved by the licensee and whether

adequate plans and procedures had been established to assure that the

modification project would be controlled and accomplished consistent

with commitments and regulatory requirements.

Procedure No. Title

FPC-SPS-PT-002, R4 " Visible Dye Liquid Penetrant

Examination Specification

FPC-SPS-PA-002, R1 " Liquid Penetrant Acceptance

Standard (AWS)"

FPC-SPS-PA-001, R4 " Liquid Penetrant Acceptance

Standard (ASME & ANSI)

b. Liquid Penetrant (570608)

(1) Procedure Review

The inspector reviewed Procedure Nos. FPC-SPS-PT-002, FPC-SPS-

PA-001 and FPC-SPS-PA-002 to ascertain whether it has been

reviewed and approved in accordance with the licensee's

established QA procedures. The above procedures were reviewed for

technical adequacy and conformance with ASME, Section V, Article 6,

and other licensee commitments / requirements in the below listed

areas: specified method; penetrant materials identified;

penetrant materials analyzed for sulfur; penetrant materials

analyzed for total halogens; acceptable pre-examination surface;

drying time; method of penetrant application; surface temperature;

solvent removal / water washable; dry surface prior to developing;

type of developing; examination technique; and eva'Jation

technique.

(2) Work Observation

The inspector observed the liquid penetrant examination of weld

joints indicated below: to determine whether procedure clearly

specified the applicable test; procedure was available; sequencing

and timing of examination in accordance with applicable code /and

'

F .

~ -

11

,

contract; materials available and properly identified; examiner

identification; location and extent of examination clearly

defined; and procedure compliance in the following areas; surface

preparation; penetrant type; application method; penetration time;

surface temperature; penetrant removal; drying; developed type and

application; developing time; evaluation in accordance with

procedure and with correct acceptance criteria; and surfaces

cleaned at conclusion of examination.

Weld No.

MU-85-115

MU-85-116

(3) Records Review

(a) The inspector reviewed the qualification documentation for

the below listed examiners in the following areas:

employer's name; person certified; activity qualified to

perform; effective period of certification; signature of

employer's designated representative; basis used for

certification; annual visual acuity; and color vision

examination.

RUV PT-LII

AJU PT-LII

JA PT-LII

,

(b) 'The inspector reviewed the below listed liquid penetrant

examination reports for compliance with procedure record

requirements.

Weld No.

60-85-38

MU-85-49

MU-85-56

MU-85-57

MU-85-58

(c) The inspector reviewed the " certification of contaminent

content" for the below listed liquid penetrant materials to

determine whether the analysis for halogen and sulfur is

consistent with applicable requirements.

.

M Batch No.

Penetrant 85C025

Cleaner 84K065

Developer 84M040

Within the areas examined no violations or deviations were identified.