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*~U.S. NUCLEAR REGULATORY COMMISSION

[W 0FFICE.OF INSPECTION AND ENFORCEMENT

REGION III

Reports No. 50-329/80-27; 50-330/80-28

Docket Nos. 50-329; 50-330 Licenses No. CPPR-61; CPPR-82

Licensee: Consumers Power Company1945 W. Parnall RoadJackson, MI 49201

Facility Name: Midland Plant, Units 1 and 2

Inspection At: Midland Site, Midland, MI

Inspection Conducted: September 23-24, November 3-4, 12-13, 19, 1980

%.J.?%L- / , /4, /CInspector: K. D. Ward

M ->ab h / /Approved By: D. H. Danielson, Chief /A//4'/[6

' 'Engineering Support Section 2

Inspection Summary

Inspection on September 23-24, November 3-4, 12-13, 19, 1980 (ReportNo. 50-329/80-27; 50-330/80-28).Areas Inspected: Review of preservice inspection (PSI) procedures, workactivities, nondestructive examination (NDE) personnel certifications anddata; IE Bulletin 80-08 activities. The inspection involved a total of 39inspector hours onsite by one NRC inspector.Results: No items of noncompliance or deviations were identified.

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DETAILS

Persons Contacted

Consumers Power Company (CPCo)

*D. Turnbull, Sr. Superintendent Engr.*D. Keating, Section Head, Inspection, Examination, and Test

Verification, (IE & TV)*F. Pimental, Supervisor, Welding and NDE*D. Karjala, Senior EngineerH. Leonard, Section Head QAEK. Rafferty, QAE (IE & TV)J. Zimmerman, QAE (IE & TV)

Babcock and Wilson Construction Companyr

*G. Navratil, Group Leader

Southwest Research Institute (SWRI)

F. Leonard, Inspector Engr.R. Niemeyer, Team Supervisor

Hartford Steam Boiler Inspection and Insurance Company (HSB)

-P.-Fisher, Authorized Nuclear Inservice Inspector (ANII)

The inspector also contacted and interviewed other licensee and contractori employees.

* Denotes those attending the final exit interview November 19, 1980.,

Licensee Action on Previous Inspection Findings

(0 pen) Unresolved Items (329/80-17-02) and (330/80-19-02): Radiographiclinear indications of welds in two borated water storage tanks. Graverand Bechtel are discussing the acceptance criteria of the radiographiclinear indications of welds in the two borated water storage tanks. TSisis to be resolved in the near future.

(Closed) Unresolved Items (329/80-17-03) and (330/80-19-03): Stainlesssteel pipe with inside linear indications. The inspector reviewed the" Failure Analysis Report" and actions taken of the investigation. Theinvestigation determined that the indications were manufacturing imperfections

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of a type which is normal for Type 316 austenitic stainless steel seamlesspipe and of a depth which is within acceptance limits for both ASME III,.

Class 2 piping systems and the design wall thickness requirements.

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*- Licensee Action on IE Bulletin 80-08

References:

a. NRC memorandum dated April 9,1980, to CPCo (IE Eulletin 80-08titled " Examination of Containment Liner Penetration Welds").

b, CPCo letter dated July 11, 1980, to Region III (Response to IEBulletin 80-08).

c. CPCo letter dated August 14, 1980, to Region III (Final response toIE Bulletin 80-08, Units 1 and 2).

(Closed) Unresolved Item (329/80-17-01): Final response to IE Bulletin 80-08,Unit 1. The inspector reviewed the final response and actions taken forIE Bulletin 80-08 and has no questions at this time.

(Closed) Unresolved Item (330/80-18-01): Final response to IE Bulletin 00-08,Unit 2. The inspector reviewed the final response and actions taken forIE Bulletin 80-08 and has no questions at this time.

Functional or Program Areas Inspected

1. General-

References:

a. NRC Reports No. 50-329/79-20; 50-330/79-21 (PSI)b. NRC Reports No. 50-329/80-03; 50-330/80-03 (PSI)c. NRC Reports No. 50-329/80-07; 50-330/80-07 (Investigation

into allegations)d. NRC Reports No. 50-329/80-17; 50-330/80-18 (PSI)

2. Procedure and Manual Review

The inspector reviewed the following procedures:

a. New Procedures

(1) B&W, Supplier Quality Evaluation, 9A-156, Revision 2,June 2, 1980

(2) B&W, Nonconformance Reporting, 51.-157, Revision 0, April 28,1980

(3) B&W, Technical Procedure Describing the Use of the EddyCurrent Data and Calibration Sheets, ISI-53, Revision 0,October 9, 1980

(4) B&W, Administrative Procedure for Access Control, ISI-58,-Revision 0, October 15, 1980

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* (5) B&W, Administrative Procedure for Control of Manualsand Reports, ISI-71, Revision 5, October 7, 1980

(6) B&W,' Administrative Procedure for Handling NondestructiveExamination Data for Preoperational or Inservi. -Examinations, ISI-74, Revision 2, September 23, 1980

(7) B&W, Administrative Procedure for the Design, Fabrication,and Certification of Calibration Standards, ISI-76,Revision 8, October 7, 1980

(8) B&W, Administrative Procedure for Tagging and Correctionon Nonconforming Items, ISI-78, Revision 5, October 8,1980 <

(9) B&W, Administrative Procedure for Preventive Maintenanceof Nondestructive Examination Equipment, ISI-81, Revision 4,September 13, 1980

(10) B&W, Eddy Current Examination of OTSG Tubing in 177 SteamGenerators, ISI-401, Revision 12, September 12, 1980

(11) B&W, Technical Procedure for the Evaluation of Eddy CurrentData of Nuclear Grade Steam Generator Tubing, ISI-460,Revision 0, October 31, 1980

b. Revised Procedures

(1) B&W, Quality Assurance Records, 9-QA-214, Revision 4,June 2, 1980

(2) B&W, Audits, 9-QA-215, Revision 4, June 2, 1980

(3) B&W, Quality Assurance Audits, 9A-153, Revision 5,June 2, 1980,

(4) B&W, Qualification of Audit Personnel, SA-154, Revision 4,June 2, 1980

(5) B&W, Personnel-Qualification - Liquid PenetrantExamination, 9A-167, Revision 12, June 4, 1980

(6) B&W, Personnel Qualification - Magnetic ParticleExamination, 9A-168, Revision 10, June 17, 1971

(7) B&W, Personnel Qualification - Ultrasonic Examination,9A-169, Revision 11, May 4, 1980

(8) B&W, Personnel Qualification - Radiograph Examination,9A-170, Revision 11, June 4, 1980

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(9) B&W, Personnel Qualification and Certification, VisualExamination, 9A-172, Revision 6, Jun.2 14, 1976

(10) B&W, Control of Special Processes, 9-QA-208, Revision 5,June 2, 1980

(11) B&W, Inspection, 9-QA-209, Revision 6, April 23, 1980

(12) B&W, Control of Measuring and Test Equipment, 9-QA-210,Revision 4, November 1, 1979

(13) B&W, Inspection, Test, and Operating Status, 9-QA-211,Revision 4, June 2, 1980

(14) B&W, Nonconforming Items, 9-QA-212, Revision 5,April 28, 1980

(15) B&W, Corrective Action, 9-QA-213, Revision 5, April 28,1980

c. Field Changes in Procedures

(1) B&W, Wet and Dry Method of Magnetic Particle ExaminationUsing the Electromagnetic Yoke, ISI-271, Revision 1,September 9, 1979

; (2) B&W, Identification and Layout of Welds and SysteaComponents, ISI-362, Revision 7, June 7, 1979

(3) B&W, Ultrasonic Examination of Vessel Welds and NozzleInside Radius Sections, ISI-133, Revision 0, July 9, 1980

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(4) B&W, Administrative Procedure for Use of the Data BaseSystem, ISI-75, Revision 1, May 7, 1979

d. Preservice Inspection Manual for Units 1 and 2

(1) B&W, Eddy Current Examination of Steam GeneratorTurbing, Manual Number #6, Revision 0, October, 1980

e. SWRI Procedures

(1) SWRI, Mechanized Ultrasonic Examination of VesselComponents and Vessel Welds, NDT-700-5, Revision 4,September, 1980

(2) SWRI, Mechanized Ultrasonic 'Jamination of FerriticVessels Greater Than 2 Inches in Thickness, NDT-700-6,Revision 5, September, 1980

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. (3) SWRI, Mechanized Ultrasonic Examination of PipingWelds, NDT-700-6, Revision 10, September 1980

(4) SWRI, Manual Ultrasonic Examination of Nuclear ReactorPressure Vessel Flange Ligaments, 600-5, Revision 30,September 1980

(5) SWRI, Special Process Control No. NQAP 11-1, Revision 1,,

February 11, 1977 (Qualification and Certification of

NDE Personnel)

(6) SWRI, Deviations to Nuclear Field Services SectionOperating Procedures, 1X-FE-101-1, September 1976

(7) SWRI, Procedure for Preparing Preoperational ExaminationFinal Reports, Inservice Examination Final Reports, andTopical Reports, IX-FE-102-0, April 1976

i (8) SWRI, Onsite Ultrasonic Examination Records Control,X-FE-105-0, October 1980

(9) -SWRI, Control of Nuclear Inspection Equipment andMaterials, XIII-AG-101-1, April 1980

(10) SWRI, Data Storage and Retrieval, XVII-AG-101-01,March 1976

(11) SWRI, Manual Ultrasonic Examination of Pressure VesselWelds, NDT-600-15, Revision 45, September 1980

, (12) SWRI, Mechanized Ultrasonic Examination of VesselComponents and Vessel Welds, NDT-700-5, Revision 4,

i September 1980

(13) SWRI, Mechanized Ultrasonic Examination of FerriticVessels Greater Than 2 Inches in Thickness, NDT-700-6,Revision 5, September 1980

(14) SWRI, Mechanized Ultrasonic Examination of Piping Welds,NDT-700-7, Revision 0, September 1980

No items of noncompliance or deviations were identified.

3. Material and Equipment Certification

The inspector examined and verified the adequacy of the calibrationstandards, preparation of weldments and certification documentsrelative to the following items:

a. Ultrasonic instruments, calibration blocks, and transducersand couplant 4

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b. ' Liquid penetrant, Magnaflux materials, penetrant, cleaner anddeveloper

c. Magnetic particle, Magnaflux materials and equipment

d. Eddy current, equipment, main frame, digital multi-meter,function generator, universal counter and dual power supply

No items of noncompliance or deviations were identified.

4. NDE Personnel Certifications

The inspector reviewed the following NDE personnel certifications' la accordance with SNT-TC-1A, 1975 Edition:

B&W

Name UT PT ET MT

Z. Dargarty II II IIT. Altizer II I IIG. Baker I I II

N. Cage II II II

J. Evans II II II

j D. Gaskill II II II

SWRI

Name E; M. Ehnstrom II

G. Ergish I| P. Gaines II'

D. Kling II

| F. Leonard II

K. Krzywosz III

No items of noncompliance or deviations were identified.

5. Observation of Work and Work Activities

The inspector observed the following work and had discussions with.,

personnel during review of the PSI activities. These observations'

included calibrations, preparation of welds, performance of theexaminations and the documentation.

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a. Ultrasonic examination of pipe to valve weld #2-EBC-4-10 onthe main feedwater system, Unit #2.

b. Ultrasonic examination of circle seam weld #1-T-52-17 on the.

pressurizer, Unit #1.

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* c. Magnetic particle examination of weld #1-ELB-11-34 on themain steam generator, Unit #1.

d. Eddy current examination of steam generator tubes, Unit #2b.

Ultrasonic examination of inlet nozzle weld #2-CCA-8-8, N-Il 30 ,e.Unit #2.

. No items of noncompliance or deviations were identified.

6. Review of Data Reports and Audits

The inspector. examined and determined that the data reportsdemonstrated that the QA/QC requirements were met. The requiredinformation was available for the PSI.

The following documents were also reviewed:

a. CPCo audits of B&W PSI #M-01-26-0, #M-01-29-0-01, #M-03-56-01,and #01-ETC.

b. CPCo " Inspection /0verinspection Record", reports of B&W UTsteam generator A nozzle to head welds and circle seam welds;also SWRI UT of reactor vessel.

No items of noncompliance or deviations were identified.

7. Independent Inspection

CPCo received four allegations concerning B&W NDE work from anindividual previously employed at the Midland Site (File 16.0,Serial 98FQA80, dated April 11, 1980). The following is a listing ofthe allegations, including the actions taken by and conclusions of thelicensee.

Allegation 1

A number of radiographic location markers, in part or entirely,were removed from piping systems during grinding for inserviceinspection and were not replaced accurately. It is noted that theindividual making the allegation had performed some of the work.

Action Taken

Made overlays of the file radiographs of weld number ICCA21-2 at.dcompared the overlays to the actual weld. Significant differenceswere noted in that the location markers were on the opposite side

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-of the weld from that indicated on the overlay.;

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Conclusion*

This allegation was substantiated as location markers were replacedinaccurately. B&W CC has issued a nonconformance report in thismatter. B&W committed, in the NCR among other items, to check all

' welds prepared for ISI after final radiography. The check wouldinvolve making an overlay, checking the stamping, and correctingwhere necessary. CPCo was able to correctly locate the markerson the joints and radiography was not required. (This item isclosed).

Allegation 2

One view of one of the " cold leg" steam generator outlet veld jointsin Unit #1 was radiographed using an fridium source rather than theprocedurally required cobalt source. It is noted that the individualmaking the allegation had performed the work.

Action Taken

Reviewed the final radiographs and the radiographers; records for thequestioned weld joints in both Units 1 and 2. The records state thatall eight joints were radiographed using a cobalt source. A reviewof all of the radiographs reveals no indication that a cobalt source wasnot used. A second separate review of the steam generator outlet weldjoints for Unit I was conducted by a NDE Level III. qualified CPCo reviewerwith the same results. Since iridium was frequently used for informationshots, the individual making the allegations may not have known what shotwas to be presented as the final radiograph.

Conclusion

This allegation could not be substantiated. The source used for finalradiography of the questioned joints was cobalt. (This item is closed).

Allegation 3

Field radiographs of the feedwater nozzles do not meet the requiredgeometric unsharpness (Ug) due to inadequate film to object contact.

Action Taken

Randomly selected 12 completed feedwater nozzle welds for review ofthe records and radiographs. Because the allegation was not completelyclear as to the system in question, all four auxiliary feedwater nozzles(two in each unit) were reviewed as well. Those radiographs includedwork done by the individual making the allegation. The radiographers'records indicate that the required geometric unsharpness requirementswere met for both systems as calculated from the information suppliedby the radiographer. An examination of the physical configuration ofthe welds in the systems eliminated the auxiliary feedwater system from

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'*consideration and indicated that the feedwater nozzles, due to a uniquephysical geometry, could very well present problems achieving proper filmto object contact. A " test shot" of a feedwater nozzle was taken, with aNDE Level III qualified CPCo observer in attendance, to determine if properfilm to object contact was obtained under field conditions. The " test shot"shows that proper film to object contact would not be obtained under allconditions thus bringing Ug requirements beyond procedurally allowablerequirements.

Conclusion

This allegation was substantiated as geometric unsharpness requirementsfor the feedwater nozzles were not met. B&W CC has issued a noncon-formance report in this matter. Reference B&W CC NCR 1725 for completedetails. This is an open item. Resolution is pending completion ofreview and analysis of radiographic data of pipe welds presently beingconducted by B&W Engineering.

Allegation 4

Field radiographs of the feedwater nozzles welds show a " bad" adjacentshop weld and that when informed of the " bad" weld, B&W CC managementinstructed the radiographer to trim the film to eliminate the " bad" shopweld.

('_ tion Taken

Reviewed feedwater nozzle weld radiographs until a shop weld with anASME Section III rejectable indication (lack of penetration) was located(Weld No. 2E51B 6U). Radiographs of approximately twenty of one hundredtwenty-eight upper welds were reviewed before the condition was identified(there are four radiographs per weld). The drawing showing the shop weldwas then reviewed to ascertain the required nondestructive examinationf~r that shop weld. Drawing No. 143023E Revision 12 (Bechtel No. 7220M 1.6-32-3) requires the weld to be magnetic particle examined only on theexterior surface. The weld was made to ANSI B31.1.

Conclusion

This allegation was not substantiated as the weld meets the requiredacceptance criteria. The individual concurred that the weld identifiedby CPCo QA is the one he was concerned with. CPCo QA is further reviewingthe situation in house as to whether the defect would affect the intendeduse of the item. It is noted that the film had not been trimmed. This isan open item. Resolution is pending completion of review and analysis ofradiographic data of pipe welds presently being conducted by B&W Engineer-ing.

The inspector reviewed the licensee's documentation of their investiga-tion. No items of noncompliance or deviations were identified.

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Exit Interview

The inspector met wit!, site representatives (denoted in Persons Contactedparagraph) at the conclusion of the inspection. The inspector summarizedthe scope and findings of the inspection noted in this report.

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