IR 05000245/1989007

Insp Repts 50-245/89-07,50-336/89-06 & 50-423/89-07 on 890221-0303.No Violations or Deviations Noted.Major Areas Inspected:Site Observations & in-ofc Review of Data in Areas of Inservice Insp & Secondary Water Chemistry

ML20248J163
Person / Time
Site:	Millstone
Issue date:	03/23/1989
From:	Carrasco J, Mcbrearty R, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20248J161	List: IR 05000245/1989007 ML20248J159
References
50-245-89-07, 50-245-89-7, 50-336-89-06, 50-336-89-6, 50-423-89-07, 50-423-89-7, IEB-88-011, IEB-88-11, NUDOCS 8904140338
Download: ML20248J163 (11)

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U.S. NUCLEAR REGULATORY COMMISSION-

. REGION I-Report No /89-07-50-336/89-06= >

50-423/89-07

" Docket'No '50-245 50-336-50-423 License N '0PR-21 DPR-65~

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NPF-49 Licensee: .-Northeast Nuclear Energy Company-P.O. Box 270 Hartford, Connecticut 06141 Facility Name: Millstone Units 1, 2, and 3 l

" Inspection At:; 'Waterford, Connecticut

. Inspection Dates: febyuar h March 3, 1989 Inspectors: 4 77 J. 'a r/r co, Reactor Engineer, MPS, EB, 3!l#h

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DRS, egion I 1 70 !

R. McBrearty, Reactgr Engineer, MPS, EB, date D , Region I

! 79 R. W. Winters, Reactor Engineer, MPS, EB, date DRS Regt n epproved by: f .

p J/$J//f J Strosnidef,. Chief, Materials & Processes date ection, Engir.ccring Branch, DRS, RI Inspection Summary:- Routine unannounced inspection on February 21 - March 3, 1989 (Report Nos. 50-245/89-07, 50 336/89-06, and 50-423/89-07)

Areas Inspected: The' inspection consisted of site observations and in office

. review of data in the areas of inservice inspection, secondary water chemistry, eddy current examination of stea,, generator tubes and follow-up of previous NRC item 'Results: No violations or deviations were identified. One unresolved item regarding personnel certification testing was identifie T8904140338 890404

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i DETAILS 1.0 : Persons Contacted

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. Northeast' Nuclear Energy' Compan (1) L. Baird, NUSCO Inservice Inspection Coordinator-J. Benson, Corporate Engineering, Level III, ECT J. Bergin, Civil / Structural Engineering (1) T. Blanchard, Jr. , Inservice Inspection Coordinator W- Briggs, NUSCO, Civil Structures

. i K. Burton, Assistant Superintendent, linit 3 (2) C. Clement, Superintendent, Unit 3 ,

R. Fuller, NUSCO, NDE Level.III, Reliability Engineer R. Griswold, Supervisor, Stores (2) J. Harris, Engineering Supervisor, Unit 3

. V._ Jones, Corporate Engineering, Chemistry

.(1)(2) 'J. Keenan,-Superintendent, Unit 2'

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C. Libby, Quality Assurance Supervisor S. Ragland, Plant Chemis+, Unit 2 (1)(2) J. Resetar, Unit 2, Engineering-W. Richter, Engineering Supervisor, Unit 3 -

J.1 Waters, Supervisor, Chemistry l Combustion Engineering D. Lynch, Supervisor Eddy Current Testing R. Maurer, Supervisor, Eddy Current Data Analysis EBASCO R. Zieber, Site Supervisor United States Nuclear Regulatory Commission (2) S. Barber, Resident Inspector, Unit 3 (2) P. Habighorst,-Resident Inspector, Uni (1) L. Kolonauski, Resident Inspector, Unit 1 (1) W. Raymond, Senior Resident Inspector (1) Attended exit meeting February 24, 1989 (2) Attended exit meeting March 3, 1989 l

The inspector also contacted other administrative cnd technical personnel during the inspectio ____ _ _ _ _ _ a__.m_-.-u_-._ _ _ _ _ _ _ _ _ .

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2.0 Scope of the Inspection-(Millstone Unit No. 2)

Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the ASME Boiler and Pressure Vessel Code provides rules for the examination, testing and inspection of components and systems in a nuclear: power plant.Section XI mandates that the plant owner develop a program which will demonstrate conformance to Code requirements, and that the licensee perform inservice inspections (ISI) to comply with those requirements and progra Examination of the steam generators is a special case of ISI and-is governed by the Technical Specification The following areas were selected for inspection:

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Implementing nondestructive i smination (NDE) procedures

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Observations of work in progress

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Personnel qualification / certification records  !

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Steam generator eddy current inspection

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Review of secondary water chemistry operating results

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Licensee's' response to NRC concerns  !

3.C Review of NDE Implementing Procedures (73052) (Millstone Unit No. 2)

Inservice inspection at Millstone Unit 2 is performed in accordance with the licensee's procedures. Vendor NDE technicians are provided training on each procedure which they will be required to implement and, in addition, each individual is required to pass a practical examination' administered by the licensee prior to performing actual examination I The inspector reviewed selected procedures to ascertain compliance with ASME Code and regulatory requirements and for technical adequacy. The following procedures were selected for inspection: l

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NU-LP-1, Revision 8, Procedure for Liquid Pere uant Examination {

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NU-MP-1, Revision 7, Procedure for Magnetic Porticle Examination

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NU-VT-1, Revision 8, Procedure for Inservice Visual Inspection

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NU-UT-2, Revision 6, Ultrasonic Examination Procedure for Austenitic and Dissimilar Metal Piping Welds

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NU-UT-7, Revision 3, Ultrasonic Examination Procedure for Vessel Welds

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MU-UT-28, Revision 0, Ultrasonic Examination Procedure for l Regenerative Heat Exchanger Welds

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The inspector determined that the aforementioned procedures complied with applicable Code and regulatory requirements, and further, that the procedures were technically adequate for their inter.ded us .0 Observations of Work in Progress (73753) (Millstone Unit No. 2)

The' visual examinations (VT-3) of reactor pressure vessel components and welds were performed by EBASCO technicians using remote, underwater video camera The results of the inspections were recorded on video tape to l permit' review and evaluation by the licensee Level I ]

The inspector observed video tapes of the-visual examination . ohe reactor pressure vessel bottom head and the flow baffle skir The l observations were made to ascertain compliance with Code and regulatory j requirements and that tape quality and clarity was adequ:te for performing a meaningful evaluation of the result 'The inspector found that the quality of the video tapes was excellent and provided the means for an intelligible evaluation and disposition of

. examination results. The inspector further determined compliance with-applicable Code and regulatory requirement .0 Steam Generator Inspection-(73753) (Millstone Unit No. 2)

The' inspector discussed the ongoing' eddy current inspection of the steam generators with licensee personnel and with the eddy current testing contractor,' Combustion Engineering. From these discussions the inspector

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determined that the licensee had inspected approximately 2880 tubes full length (tube end to tube end) in each of the two steam generators. In addition, all tubes not plugged or sleeved were inspected from the top of the tubesheet to an elevation of 20 inches (below the 1st support plate).

These inspections were performed using a standard bobbin coil. The  ;

inspections from the tube sheet to the 20 inch elevation were designed to look for pitting in the sludge pile region. Approximately 40 tubes in each steam generator were found with rejectable pits in the sludge pile region. As a result of these inspections several anomalous indications were identified and the licensee switched to a motorized rotating pancake coil (RPC) to better characterize the anomalie The inspector observed eddy current testing of the steam generators being performed by Combustion Engineering. The testing in progress was by RPC of the tube area two inches above and below the top of the tube shee This testing identified circumferential cracks on the secondary sid All cracks identified were within 1/4 of an inch above the top of the top of the tube sheet. Approximately 230 and 40 cracked tubes had been identified in steam generators 1 and 2, respectively. The licensee planned to stabilize and plug these tubes. RCP inspections were still in progress at the end of the NRC inspection. The pattern of the testing was 100% of the tubes in a series of roughly concentric rings starting from

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the center of the steam generato The licensee planned to continue testing in this pattern for'five rows of tubes beyond the last identified crack to assure that all cracks had been foun . Evaluation of Eddy Current Data Working >with a vendor of eddy current inspection services, the licensee

' has developed a technique for the analysis of eddy current data using a computer to identify defects. The system works by having the computer-identify predetermined anomalies. .The operator then analyses the computer identified anomaly and establishes the required defect identification. . In qualifying this system the licensee administered the same test given to the. primary analysts and found the computer / level II analyst combination scored higher'than the average individual analyst. As a result the

. computer was used as the secondary analysis of the eddy current dat Primary analysis was performed by qualified / certified Level II analyst Advantages of-the. computer analysis system include speed since the computer is about four tir.es faster than individuals, lack of fatigue, and output since the computer does not require breaks. One significant disadvantage is that_ the computer will identify only defects that have been programmed and will miss new or unusual defects, another disadvantage is that the programming had progressed to bobbin coil testing onl The RPC data analysis was being performed by a primary and secondary analys In addition to the Combustion Engineering analysts, the licensee had assigned two engineers, certified as Level III in eddy current testing, to the site to monitor the steam generator testing and act as arbitrators for differences that could exist between analysts. These Level III

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l engineers were not directly associated with the testing but rather were in a position to keep their perspective on the testing and watch for emerging patterns and to plan appropriate action Based on the above, the inspector concluded that the licensee has developed a significantly improved method.of data analysis using the computer rather than individuals. In addition by having Certified Level III individuals available. questions regarding the data could be quickly resolve .0 NDE Personnel Qualification and Certification Records (73753) (Millstone Unit No. 2)

Qualification and certification records of EBASCO personnel, the licensee's ISI vendor, were selected for inspection to ascertain that the j technicians were certifie1 in accordance with SNT-TC-1A, the governing document. Records of licensee personnel who performed the visual inspections of the pressurizer sorge line in accordance with IE Bulletin ;

88-11 were inspected to ascertain that the certifications complied with I the licensee's progra l l

An additional inspection area included the type and administration of the specific examination required by SNT-TC-1A for the certification of NDE 3

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. personnel to Level'II in the ultrasonic, magnetic particle and liquid ;

penetrant methods. The American Society for Nondestructive Testing j (ASNT) document SNT-TC-1A requires that a specific examination be administered to each candidate for certification to a NDE method, and provides guidance regarding the content of the examination. Paragraph 8.3 of the 1980 Edition of SNT-TC-1A states that, "the written examination should be administered without access to reference material (closed book)

except that necessary data, such as graphs, tables, specifications, procedures, and codes may be provided." Also, SNT-TC-1A Interpretation Panel response to inquiry 77-5 states: "It is intended that codes, specifications, ind/or procedures are 'necessary data' under paragraph 8.5 of the 1975 edition of SNT-TC-1A, provided that examination questions are asked that require reference to such data and that such data cannot be used to answer questions related to other closed book portions of the examination."

The inspector determined that the licensee's program requires that vendor ,

ultrasonic examination personnel must pass the licensee's ultrasonic l practical examination and receive training on the use of procedures which they will be responsible for implementing. How ver, the inspector's review of the licensee's and the vendor's specific examinations and the accompanying reference material which was und for the certification of NDE examiners showed that the examinations were administered as "open book" tests in that reference material was provided for each question in each of the tests and, in most cases, the reference ciaterial was identified for each questio The licensee's representatives stated, as !

did the EBASCO Site Supervisor, that he interpreted SNT-TC-1A to allow l the use of reference material and that he was unaware of interpretation j 77-5 requiring closed book examinations. Based on inspections at other facilities, the NRC has determined that uncertainties exist within the industry regarding the requirement for closed book examinations. In this l regard, NRC is aware that another utility has requested further 1 interpretation from the ASNT Interpretation Panel and the licensee was advised to contact the Panel to verify the intent of SNT-TC-1A regarding !

the use of reference material and " closed book" tests. This issue is considered unresolved pending licensee action and subsequent NRC review (50-336/89-06-01).

Notwithstanding the issue of closed book specific examinations, the personnel who performed ISI at the site were experienced technicians who had performed examinations during previous outages at the sit Additionally, all ultrasonic examination technicians were required to successfully pass the licensee's practical examination before performing examinations at the site. The licensee visual examination personnel certification program and written examinations are of the closed book typ Further, at least one of the contractor examiners is listed on the latest EPRI registry of personnel qualified for the detection of intergranular stress corrosion cracking although there is no requirement for that kind of qualification to perform examinations at a PWR fac.ilit .

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. Tracking of ISI Findings (Millstone Unit No. 2)

ISILfin'ings which require licensee evaluation and-disposition are documented

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n d L' on an Unresolved Indication Report (UIR) and when the disposition requires defect removal 'a nonconformance_ report (NCR) is issued in addition to the UIR. The.following VIRs were selected for review:

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,-- 89-001, Visual Inspection of Spring Hanger PSLH-5

-- '89-002, Visual Inspection of Spring Hanger PSLH-8

-- 89-003,. Visual Inspection of Spring Hanger PSLH-9

-- 89-004, Visual Inspection of Spring Hanger PSLH-4

-- 89-005, Visual Inspection of Spring Pedestal Support PSLH-2

-- 89-017, Ultrasonic Examination of Pressurizer Skirt

-- 89-030,' Magnetic Particle Examination of RPV Stud Number S-33 UIR 89-001 through 89-005~ inclusive were issued to document findings resulting from NRC Bulletin 89-11, Visual Inspection of the Pressurizer Surge Lin These findings are discussed in Section 9.0 of this repor VIR 89-017 was evaluated to be a geometr.ic reflector which was detected over.the entire circumference of the component. Plots of the reflector-location and sketches of the component confirmed the evaluation. UIR-89-030 documented linear magnetic particle indications 'n o the RPV stud -

and awaited disposition by the NUSCO Level III and the responsible  !

Engineer. These two VIRs were open as of February 23, 198 ,

Unresolved Indication Reports are evaluated and dispositioned by the I Responsible Engineer. The licensee's tracking system assures that closecut I is accomplished prior to plant start up from the refueling outag : 8.0 Secondary Water Chemistry (Millstone Unit No. 2)  !

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' Water chemistry data were reviewed as part of this steam generator inspection and maintenance inspection. The methods of collecting and verifying the accuracy of these data were not included in the scope of this inspectio The inspector discussed the secondary water chemistry control program with the Unit 2 chemist, the operator of the full flow condensate polishers, and'the corporate chemistry engineer. The inspector determined the results of the water chemistry control program were due to a team approach with each of these individuals and their groups

, contributing to the programs success. Table 1 shows typical values for the control of the secondary water during the last fuel cycl .

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TYPICAL' SECONDARY WATER CHEMISTRY RESULTS g

Parameter Blowdown Feedwater Condensate' EPRI Guidelines Pump Discharge Blowdown Sodium (ppb) 0.60 0.11 (1) 0.10- '20 ma l Chloride.(ppb). 2.60 0.025 0.02 20 ma Sulfate (ppb) 0.70 ----- -----

20 ma Cat Cond (umho/cm ) 0.27- 0.10 0.08 0.8 ma Oxygen (ppb) 0.11 0.53 5 max. (2)

Hydrazine (ppb) 4 min- 20 min. (2)

Boron'(ppm)(3) 6.25 0.78 0.26 ----

(1) Most values from in line monitors were below minimum detectable level (2) Feedwater sample-(3) Boron added as counter measure to stress' corrosion cracking of tubes From the TABLE 1 the water chemistry maintained by the licensee during

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the past cycle is significantly better than that recommended by the EPRI guideline .0 Licensee's Actions on Previous NRC Concerns Bulletin 88-11, " Pressurizer Surge Line Thermal Stratification," requests that_ licensees of operating PWRs conduct a visual inspection (ASME,Section XI, VT-3) of the pressurizer surge line at the first cold shut

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down exceeding seven days after receipt of the Bulletin. The inspection is' intended to identify any gross discernible distress or structural damage in the entire pressurizer surge line, including piping, pipe supports, pipe whip _ restraints, and anchor bolt _

The licensee performed the requested visual inspection at Millstone Unit No. 2 which was observed by the resident inspector on February 8, 198 ,

The inspector reviewed the visual examination data including five VIRs and the qualification and certification records of the licensee personnel i who performed the visual inspection of the surge line. The review was l performed to ascertain that the inspection results were properly documented and that the examiners were certified in accordance with the i licensee's progra !

Four of the five UIRs were dispositioned as acceptable and the fifth was dispositioned as rejectable due to a loose bol The inspector discussed the four acceptable dispositions with the Responsible Engineer and agreed that the dispositions were proper. The rejectable condition was corrected by retorqueing the nuts, but the UIR remained open pending completion of the review process. The four

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i remaining VIRS were properly closed out. Additionally, the visual inspectors were found to be certified in accordance with the licensee's program which follows the EPRI recommendations for qualifying and certifying visual inspection personne Licensee actions 1.b,1.c and 1.d are required by the Bulletin to be ;

responded to within four (4) months of receipt of the Bulletin which is l dated December 20, 1988. At the time of this inspection, the licensee I had not completed the required actions including consideration of thermal stratification and the suggested analysi (Closed) Unresolved Items (50-245/85-01-01 and 50-336/85-02-01):

Qualification of Lead Auditor ,

The inspector reviewed the licensee's auditor training program and determined that the licensee has committed to qualify Lead Auditors in accordance with ANSI N45.2.23. In addition to these requirements, auditors are required to attend a one week Quality Assurance indoctrination training school and pass a written examination. Other training is provided based on the position analysis performed by the Quality Assurance Supervisor. Three of the twelve courses in this additional training include ASME Codes (32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />), Millstone Unit 3 systems (60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />), and Millstone Units 1 and 2 Components (16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />).

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(Closed) Unresolved Items (50-245/86-16-03 and 50-336/86-17-J2):

Evaluate Project Material On Hol The inspector observed that material left from projects and returned to '

the storeroom is stored in bins clearly identified as a QA Hold Area. The j licensee has established a program to evaluate this left over material and either assign a control number to each item and place it in stores or to dispose of it. The program is designed to prevent inadvertent use of unidentified material and items in safety related application These items are close '

(Closed) Unresolved Item (50-336/86-27-01): Formalize Block Wall Surveillance Procedure The inspector reviewed procedure EN-21201, Revision 0, Inspection of i Safety Related Masonry Walls to determine if the procedure included an appropriate frequency of inspections and contained adequate acceptance j standards for safety related block walls. Based on this review, the inspector determined that the procedure is adequat This item is close _ _ _ _ _ _ - _ _ _ - - - _ .

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(Closed) Unresolved Item (50-336/86-27-02): Procedure for Repair of-Mortar Joint !

The.-inspector reviewed SP-CE-302, Revision 0, Specification'for 1-Inspection, Evaluation and Repair of Cracks in Safety Related Concrete l Masonry Wall Section 4.4 of this specification clearly establishes '

generic guidelines for.the repair of cracks in masonry walls. Specific

• repair procedures based on these. guidelines are_ developed on a case by case basis as required. The inspector determined that this specification i provides proper repair steps in accordance with.widely used industrial ;

practices for the repair of cracks in masonry walls lu This item is close (Closed) Unresolved Item (50-423/86-25-01): Seismic Modification Required to the 301A-2 125 Volt Battery Charger. (Reference'LER 86-36.) !

Ouring inspection 86-25 the seismic modification for 125 volt battery charger 301A-2'was only of temporary nature meaning that battery charger 301A-2, static invertor 3VBA*INV-3 and adjacent cabinet 3 BYS*CHRG-3

.were strapped together with three separate is x 20 GA. banding straps with shims placed between the top and the bottom of the cabinets. This in effect prevents the cabinets from hitting each other during a seismic event. However, the permanent solution of reinstalling these three components with a gap of 1" from' each other in accordance to SWEC E&DCR L No.~ T-J-07629 was not implemented during inspection 86-2 The inspector observed that the permanent seismic modification for the-125 volt battery charger 301A-2 was properly implemented in accordance with the approved E&DCR No. T-J-0762 This item is close (Closed) Deviation (50-423/87-15-01):_, Qualification of Masonry Walls from

._the Requirements of Appendix A of the Standard Review Plan (SRP), Section 3. The original masonry wall calculations for the battery room exceeded ACI 531-79 and the Standard Review Plan stress loads committed to in the FSA The inspector reviewed Attachment 3 to the licensee's September 17, 1987 letter (calculation No. 51-524990-244-CC(3), Rev. 0). The reanalysis of the masonry walls in this calculation demonstrated that the masonry walls meet the intent of the Standard Review Plan (SRP).

This deviation is close i

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i-(Closed) Violation (50-423/87-15-02): Failure of Design Control Measures to Verify the Adequacy of Battery Room Wall Desig The battery room wall calculations were signed as complete when, in fact,

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deficiencies existed that should have been nuted during the independent review proces ,

The licensee stated that any future modifications or evaluations of masonry walls will be governed by procedures NE&O 5.05, Design Input and Design Verification, Rev. 1 and NE&O 5.06, Preparation, Review and Approval of Design . Analysis and Calculations, Re/.1, to precluda any erroneous interpretations'of the Standard Review Plan (SRP).

Based on his review, the inspector determined that the licensee has taken the proper corrective and preventive measures to reassess the masonry wall program in order to assure appropriate design control of future masonry ;

wall design activitie This violation is close .0 Unresolved Items '

Unresolved items are matters about which more information is required in order to ascertain whe'aer they are acceptable ite:ns or violation Unresolved items are discussed in paragraph .0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance interviews on February 21 and 27, 1989. The findings of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the February 24 and March 3,1989 exit interviews (see paragraph forattendees).

At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involved within the scope of this inspectio _ _ _ _ _ _ _ - __