IR 05000255/1989026
| ML20005H253 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/08/1989 |
| From: | Danielson D, Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054B390 | List: |
| References | |
| 50-255-89-26, NUDOCS 9001240338 | |
| Preceding documents: |
|
| Download: ML20005H253 (11) | |
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Ah U. S. NUCLEAR REGULATORY-COMMISSION ' A , ', '
REGION III
' ., " < . . LReport No.: 50-255/89026(DRS) b
- Docket No.':~,50-255 License No.:
DPR-20 , , . K Licensee: Consumers Power Company ?gg 1945 West Parnall Road Jackson,'MI--49201 ,. , Facility Name:. Palisades Site l
Inspection At:- Covert,: Michigan 49043 and - ' ". HAFAl International, Riviera' Beach, FL 33419 . ' Inspection Conductep August 21 through' October 23, 1989 ,T Inspecto d d (MM /d-f7 J W son (Team Leader) Date , ' G.' Johnson, NRR " R.~A. Hermann, NRR . , - D. W olly,Sout st Research Institute) Approved By: D. M. Da son, Chie /.2[8/# c Materials and Processes Section Dat'e / M - , !-
- Inspection Summary
. . . 23, 1989 (Report No. 50-255/89026(DRS)) . 1 Inspection on August 21 through October . L
- Areas Inspected: Announced special team. inspection of alternate test methods-L
' performed in. lieu of!ASME Section XI required hydrostatic testing (73053,- , -73755). This insaection was initiated in response to allegations concerning - ' , .-the validity of t1e alternate testing (99014).
l Results:- One violation with multiple examples was identified: failure to R adequately: control the' pressure testing of plant systems (Paragraphs 2.b and l ,2.c).
L Based on the results of the inspection, the following weaknesses were noted: Though Quality Assurance involvement was evident, technical reviews of the , implementing test procedures were inadequate.
L u-Documentation reviews of the completed tests appeared to be nonexistent.
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W, h" DETAILS p , '1..' Persons Cont' acted ~ D , b Consumers Power Company (CPC) ' p Mi ' J. Slade, Plant Manager- + ' +K. Toner, Project Superintendent
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- +R. VanWagner, ISI Supervisor
". '*+D, Malone, Licensing Engineer ,
- +T. Fauty, ISI' Coordinator
'U.S. Nuclear Regulatory Commission (U.S. NRC) +D. H. Danielson,-Chief, Materials and Processes Section
- +J. M. Jacobson, Metallurgist
' Southwest Research Institute (SWRI)
- D. W. Jolly;. Institute Scientist
. Denotes those attending the interim exit meeting on August 22, 1989.
' + Denotes those participating in the final exit meeting'via telephone on ,0ctober 23, 1989.
2.
Allegation Followup (RIII-89-A-0036) , The concerns addressed in this_ inspection report were extracted from , ' ' correspondence with, and interviews of, two former employees of HAFA International Inc. The concerns relate-to the testing performed on p(lant' systems by HAFA, utilizing the " Instrumented Inspection Technique" IIT)'as an-alternative to the ASME Code required hydrostatic test.
This inspection was conducted as a joint _ effort by both Region III and i NRR staff. A consultant from SWRI was utilized to. aid in the technical - evaluation of the_ acoustic leak sensing testing associated with the IIT.
In addition to the review of test related documentation performed at the plant, an inspection at the HAFA facility was also conducted, a.
Background Topical Report HAFA 135(P) was submitted for NRC review by letter dated April 2, 1985. The staff reviewed the subject document based on the NRC policy and guidance provided in NUREG-0390, Vol. 7, No. 2, " Topical Report Review Status," dated October 15, 1984. This ' topical report was approved by the staff in a letter dated November 7, , 1985, which then permitted its use by reference in licensee applications to the extent specified and under the limitations delineated in the topical report and the associated NRC proprietary and nonproprietary safety evaluations.
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- .The-staff's original review of the topical. report considered the ASME.SectioniXI requirements for pressure tests from the 1980 Edition
<- > through Winter'1981 Addenda; These requirements were cited for- , explanatory purposes only and were not intended to limit the ? ~ alternative testing method to the requirements in this edition'and addenda.- I The Code requires that pressure-retaining components within each system boundary be subjected to. system pressure tests; in these pressure tests, visual examination (VT-2).is performed to locate - evidence of: leakage. Pressure and temperature requirements are t . defined for:the type of test being performed and the system er-component Code Class.
System boundaries are located'at the _ intersection of Code Class changes._ The pressure test hold time is- . . recuired to be a minimum of 10 minutes for uninsulated components anc four hours for insulated components.- ' - For Class'1 systems and components, the hydrostatic test is required to be. performed at not less_than 1.10 times the nominal operating g pressure at 100*F or less.
However, the pressure can be lowered incrementally with increasing temperature to 1.02 times the operating pressure at a temperature of 500*F provided limiting i conditions specified in the Technical Specifications are not.
violated.
- For-Class-2 systems and components, the hydrostatic test pressure is required to be at least 1.10 times the lowest pressure setting of safety or relief valves'provided_for overpressure protection for systems with a design temperature of.200 F-(93 C) or less and 1.25 ' times this. pressure for systems designed for over 200'F. These requirements also apply to Class 3 components.
.The infouation and -test data contained in topical report . . FAFA 135(P) were presented to demonstrate that the IIT is capable of ' detecting and locating external' system leakage, intersystem valve leakage, reducing personnel exposure to radiation, detecting small leaks, eliminating the potential for overpressurization of lower pressure rated piping and components, and is therefore a suitable ' alternative to Section XI requirements for hydrostatic tests. The staff regarded.the attributes described above as the IIT concept that would be implemented by reference in license applications pursuant to e its' letter dated November 7, 1985.
g The staff determined that sufficient information was presented in topical report HAFA 135 (P) to support the conclusion that the IIT is a suitable alternative for the pressure test requirements of ASME Section XI. The staff found that the Code requirements, where practical to meet, will be complied with and in situations where the requirements are impractical, the regulations will be followed prior to implementation of the alternative testing method.
However, the Code requirement for the 4-hour hold time prior to visual examination of insulated systems and components may be reduced to 2 hours if the
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i ' alternative method'is utilized.- The staff regards the conditions
' wt ' described above as limitations associated with the acceptance of
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- topical report HAFAL135(P) as defined in;its letter dated
' November 7,. 1985.
[ HAFA personnel conducted two types of pressure tests under the y umbrella of "IIT."
The first type of test was used to detect ' pressure boundary and intersystem leakage utilizing leak measuring ' '; devices (LMD's). The'_ purpose of the LMD's (flow meters) was to - ' - measure the replacement volume of flow necessary to maintain the test pressure._: Exit flow through potentially leaking boundary valves was r-also to be measured. Any difference between make-up flow and the-- measured exit flows was, ostensibly, system external leakage. This , Jinstrumentation was to be supplemented by acoustic. leak sensing ,-equipment-(ALSE) to aid in identifying leak locations. A supporting ASME VT-2 type examination-could be performed in conjunction with , , ' ' 'the IIT.
The second type of, test-utilized acoustics without flow measurement'- i for the detection of_ leakage. This type of testing was performed - on both water filled and steam systems. The NRC staff did not ' ' approve this methodology in its November 1985 letter. This type of examination'is'briefly mentioned in the topical report, however, supporting test information demonstrated inconclusive results, , b.- Concerns (1) Allegation-The treasurer of HAFA also performed the function of QA manager. This would appear to conflict with the requirements of 10 CFR 50, Appendix B, Article 1.
NRC-Review Due to the death of the individual hired by HAFA as QA Manager, the treasurer took over the position for a period of time.
Conclusion This' allegation was substantiated in that the treasurer of HAFA .. did temporarily perform the function of QA manager. Though it " is understood that HAFA is a small company, it is considered inappropriate for this individual to perform the QA function as sufficient independence from cost and schedule was not demonstrated.
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A - (2)4' Allegation Test engineers submitted written exams prepared by themselves as ev.idence of qualification for acoustic testing. This practice violates the intent of-the ASNT SNT-TC-1A " Recommended
- Practice"..
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- -The qualification records of several individuals were reviewed-and interviews were conducted to determine their validity..
Records, in' general, were found to be in a state.of disarray, _ fincomplete, and in.one instance a resume was found to ' ' misrepresent the-individual's academic credentials. The results of this' review.are forwarded via distribution of this inspection.
, report to the-NRC's Vendor Branch for information.
. i Conclusion ' ' Interviews with the.HAFA staff indicated that.the subject + individuals had not submitted completed exams, developed by-themselves, as evidence.of' proficiency. This allegation could ^a' 'not be substantiated in that no documented evidence.of the - alleged practice was noted, ' , f (3) Allegation , Each sensor / channel was not individually evaluated for reliability ' before, during,'and after testing.
NRC Review-
- A' review of test logs, procedures, and interviews with test personnel indicated that a pencil-lead break functional check was performed prior to testing.
Interim or post-test functional
checks were not performed :and attenuation measurements were not obtained to determine the adequacy'of sensor spacing.
Conclusion , This allegation'was substantiated:in that interim and post checks on sensor channels were not performed. The pencil-lead a break check performed prior to testing is not considered an acceptable method of sensor calibration due to the fast-rise / decay transient as opposed to the continuous signal produced by a leak.
Interim and post verification of channel , , sensitivity is considered essential in the evaluation of test data.
i 10 CFR 50, Appendix B, Criterion XI requires that test procedures include provisions for assuring that all prerequisites for a given test have been met. The procedural deficiency in the area of sensor calibration is an example of a violation of this criterion (255/89026-01A).
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< "' (4): Allegation ,A band' pass filter of-. 100-300 KHz was used when experience shows leaks to most' likely be below.100 KHz.
< -NRC Review , ~ 'A review'of test logs, procedures, and interviews with test , g personnel indicated that indeed, a 100-300 KHz band pass filter was'used during the testing.- r
Conclusion . - > 'This allegation was substantiated in that a.100-300 KHz band pass filter was; utilized; however, the technical significance .is minimal.
. Water leaks produce a relatively wide spectrum of acoustic.
frequencies. -Water leaks usually. induce frequencies greater
than.100 KHz in the piping.
. (5)_-Allegation.
' . Claims of real time RMS data gathering were made.when the ' electronics and software were not' equipped'to do this; also ,. voltmeters were used.for this purpose without technical justification.
- ,- i NRC Review' J A review of. test logs, procedures, equipment characteristics,. and personnel interviews was performed. Electronic circuits, Lsuch as those employed by the HAFA equi > ment, produce an analog ' ' DC voltage response representative of. tie true RMS voltage.
' Since lea _k detection depends on a change in signal with respect to'a change in pressure and not an absolute value,- a voltmeter, though'not-ideal, may be used.
Conclusion This allegation was substantiated in that the true RMS voltages .~ were not being-recorded. The overall technical significance of
,,.: . this practice is minimal. The question of whether the HAFA w data gathering practice can be considered "real time" or not, is arguable, and not considered significant.
' (6) Allegation Temporary secretaries were used to take real time data when the test leader was not at the test locations.
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NRC Review: , This allegation implies that untrained, unsupervised personnel i W were utilized as data takers. -Interviews with both plant and
'HAFA-personnel indicated-that data takers were adequately ~ ' trained for their function and worked in conjunction with more-i experienced test personnel.-
, Conclusion
, !This: allegation could not_be substantiated and furthermore, the reading of a digital ceter at prescribed intervals is not , < considered-to be.a function requiring extensive training.
No evidence of unqualifiedLtest personnel being utilized to . evaluate data was noted, y (7)' Allegation - Background measurement practices were inadequate.
, ' T ,NRC Review .A review of test logs, procedures, and personnel indicated that background measurements were appropriate. A review of the data l evaluation criteria indicates that the sensitivity of the leak . -detection process'is inversely _ proportional to background noise i ' amplitude.
, -. Conclusion . 't This allegation could not be substantiated in that background-noise measurements appeared to be' appropriate. However, qualification testing to define the relationship between background noise level and leak detection sensitivity was not performed.
It is critical that-the sensitivity of the leak ~ detection system not change during the course of the test.
10.CFR 50, Appendix B, Criterion XI requires, in part, that procedures include provisions for assuring that the test is performed under_ suitable environmental conditions.
The lack of ! l-a qualified,l defined relationship between backgrotnd noise level and leak detection sensitivity is another example of a violation of this criterion (255/89026-01B).
(8) Allegation Why weren't readings taken over the entire pressure ramp? NRC Review Interviews with personnel indicated that a power failure occurred in the containment during the pressure ramp. This power failure caused some loss of data.
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This allegation was substantiated in that acoustic readings f
- were not available for a considerable portion of the pressure S
ramp.
Since.the detection of. leakage depends on the change in W acoustic' signal with respect to a change in pressure, the lack - '
of portions of data erodes the validity of this. test.
! ' .(9) Allegation ' The testLleader hand marked a blank computer generated graph to - indicate pressures when the instrumentation. software was not ' ccapeble of this.
. p . ' . I ' NRC-Review: , -A review'of the test documentation revealed that some graphic ' - representations of. test data had been developed.
It was s apparent that points on the computer generated graph format had e ' been hand marked. These graphic representations were reviewed against tabulated data and verified to be accurate.
p ', Conclusion- '
s The implicatio'n of the allegation is that deception was- <
- intended. The data points were verified to be accurate and the use ofta. computer generated format-is not considered unusual.
The graphical representation cf data, whether; computer or hand plotted,iis a commonly used aid for evaluating that data. This allegation _could not be substantiated in that deception is not.
i . suspected.
~ L(10) Allegation The alleger stated that he observed cross talk between ' instrument channels when servicing the equipment, but this . problem was not reported.. .i * .NRC-Review A review of test documentation did not disclose indications of equipment. problems due to cross-talk between channels.
Interviews with test personnel indicated that occasionally the . LED indicator for-some channels would be constantly on. This
condition indicates that the signal level was constantly above the preset threshold level but, does not affect the RMS measurement.
L Conclusion This allegation could not be substantiated in that no indications of cross talk between instrument channels were noted upon review of the test data.
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(11) Allegation - Malfunctioning channels, deb'onded sensors, and failed coaxial-cables were not reported.. > NRC Review , Ai review of test data did not disclose indications of failed equipment.
Interviews with. test personnel indicated that- ' p equipment problems were corrected before the start of the 1 test.
-Conclusion During the. installation of electronic test equipment in the plant,-it is not considered unusual to experience the problems-
- noted by the alleger. Records of test data and interviews-with- ' test personnel indicated that-equipment problems were corrected before:the actual test.
This allegation could not be substantiated.
' -(12) Allegation An evaluation of HAFA's acoustic' leak detection method, authored by Dr. M. Hamstad of the University of Denver, was challenged by the' alleger.
. NRC Review This report was reviewed for information only.. The report in P question was not submitted to the NRC for formal review or use in supporting HAFA's claims.
+, Conclusion
E A' technical-review of the subject report is not within the scope of this inspection.
"c.- Additional Inspection of,the IIT Process ' Though the alleger's concerns were directed primarily at the acoustic ' -leak testing of the steam and feedwater systems, the NRC inspection team also reviewed the IIT testing of water filled systems. As previously stated, this methodology utilized LMD instrumentation supplemented by acoustics to ostensibly detect and locate test boundary leakage.
The testing concept which was approved by the NRC staff included LMD instrumentation at all boundary valves. Accurate measurement of the replacement volume, necessary to maintain test pressure and leakage volumes through all test boundary valves was required.
Theoretically, if no external leakage is present, the algebraic sum of the inlet
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' flow and all outlet flows will be zero. Additionally, it was the stafffs understanding.ttet the entire test boundary would be instrumented with acoustic sensors.
> W i f A sample review of.the test data indicates that the implementation , r deviated from the' approved concept. This' review disclosed that some.
- test boundary valves were not instrumented at all, while others were instrumented with acoustic sensors.only.
In either case,'an > accurate measurement of boundary valve. leakage could not be quantified. - Additionally, the ability 'of the acoustic sensor. to - detect small intersystem valve leakage has not been demonstrated.
Furthermore, acoustic sensors were not placed along the test
boundary.at prescribed intervals.
! ' ~The basis of relief from Code required hydrostatic test 3ressures-and hold times when' utilizing the IIT process, was the a>ility of the methodology to quickly detect ~and locate small leaks in the test boundary. 'The. deviations in the implementation described above
eroded the basis for the reduced test pressures and hold times.- Additionally, a demonstration of the.IIT process performed at the 'HAFA facility showed that the leak detection sensitivity was- ~ insufficient.- Small pinholes'due to erosion / corrosion or tight cracks - ' in the; piping would not be. detected. Based on a review of-the test
. . procedures utilized for conducting the tests, it was determined that inadequate detail contributed to the deviations described above.
' , , Procedures reviewed include: ' Palisades Procedures > J IIT of Main Steam Line R0-108
, , TIT of Critical Service Water Header B R0-107
IIT of. Aux Feedwater Pump Suction Piping R0-109
, IIT of Aux Feedwater Pump P8A/P8B Discharge R0-110
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4, IIT of Aux Feedwater System P8C Discharge R0-111 ' HAFA Procedures ' Application of Acoustic Emission Meters for Leak Sensing 12.14 Application of IIT Acoustic Testing During IIT Leak Testing MP-3-01 IIT Acoustic Leak Testing of Pressure Retaining Components OP-13.02 The following are examples of procedural deficiencies noted: Acoustic sensor placement is not consistent with that
experimentally qualified (approximately 20 feet maximum spacing).
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Excessive discretion regarding LMD' placement was left to the > test : leader.
.. ' Guidance for~the evaluation of the IIT data was not provided.
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- 10 CFR 50, Appendix B, Criterion XI requires, in part, that test l
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- procedures incorporate acceptance limits and that adequate test-instrumentation is available and used.
The. procedural deficiencies noted above are additional examples of a violation of this criterion (255/89026-01C).
. The acoustic testing performed on the steam and feedwater systems, as'previously stated, is beyond the scope of that approved by the NRC j . . staff. Additional problems associated with the acoustic leak- -l
'g~ testing are detailed in Enclosure 3.
! 'd.
, Conclusions Based;on the information described above and inspections at other.
facilities, the staff has reassessed its conclusions regarding-the-
IIT - The staff has determined that the IIT methodology as implemented
-is1 ineffective, problems exist _with the qualification of examination ! -. personnel, licensees failed to assure the technical adequacy of the i examination procedures in terms of the control of test equipment and j ' acceptance criteria, and licensees failed to exercise adequate control
.of contractor personnel.
i + - . , The> inspection team has concluded that the IIT performed on the
plant _ systems is invalid., The VT-2 visual examinations were
Jerformed at operating pressures and for the most part at reduced .1old times which is not consistent with.ASME Code requirements.
Per ,HRC letter to CPC dated November 2, 1989, operability determinations ' on affected systems should be made and a plan for_ corrective actions l established.
. ith regard to the concerns brought to the NRC's attention, this W , allegation is considered closed.
3.
Exit' Interview-The Region III inspector met with the licensee representatives (denoted
in.Paragrapn 1) on August 21, 1989, and at the conclusion of the inspection on October 23, 1989, via telephone. The inspector summarized the purpose and findings of the inspection. The licensee representatives acknowledged this information. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection. The licensee representatives did not identify any such documents / processes as proprietary.
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