IR 05000261/1981035

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IE Insp Rept 50-261/81-35 on 811215-18.Noncompliance Noted: Class 2 Piping Class Boundary Not Established in Accordance W/Reg Guide 1.26 for Weld Inservice Insp Program (Paragraph 6)
ML14176A731
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 12/30/1981
From: Blake J, Herdt A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14176A727 List:
References
50-261-81-35, NUDOCS 8203080494
Download: ML14176A731 (5)


Text

pjREOU UNITED STATES NUCLEAR REGULATORY COMMISSIO REGION II 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report No. 50-261/81-35 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:

H. B. Robinson Docket No. 50-261 License No. DPR-23 Inspection at binson site near Hartsville, South Carolina Inspector:

J. a'

Date Signed Approve by:

.

A. R. er f, Section Chief at Signed Engineering Inspection Branch Engineering and Technical Inspection Division SUMMARY Inspection on December 15-18, 1981 Areas Inspected This routine, unannounced inspection involved 28 inspector-hours on site in the areas of Inservice Inspection - Plans for completion of first ten year inspection interval; ISI -

Program development for second ten year interval; Implementation of ASME Section XI program requirement Results Of the three areas inspected, no violations or deviations were identified in two areas; one item of noncompliance was found in one area (Violation -

Class 2 piping class boundary not established in accordance with Regulatory. Guide 1.26 for weld ISI program (paragraph 6)).

8203080494 820302 PDR ADOCK 05000261 G

PDR

REPORT DETAILS 1. Persons Contacted Licensee Employees R. B. Starkey, Jr., Site Manager

  • J. M. Curley, Engineering Supervisor
  • G. Chappel, Engineering Supervisor
  • M. Page, Engineering Supervisor W. Farmer, ISI Engineer D. Bauer, QA Specialist Other licensee employees contacted included security force members, and office personne NRC Resident Inspector
  • S. Weise, RI
  • Attended exit interview 2. Exit Interview The inspection scope and findings were summarized on December 18, 1981, with those persons indicated in paragraph 1 above. The new violation and unre solved items were discussed in detai These items are as follows: /81-35-01 -

Violation -

Class 2 Piping -

Class boundary not established in accordance with Reg. Guide 1.26 for weld ISI progra /81-35-02 -

Unresolved Item - ISI program for second ten year inspection interval is 'not complet /81-35-03 -

Unresolved Item -

Personnel performing operational tests on pumps and valves do not appear to be certified as VT-4 visual inspectors per ASME Section XI requirement /81-35-04 -

Unresolved Item -

Administrative engineering and maintenance procedures do not appear to refer to repair and replacement rules of ASME B&PV Code Section X e..50-261/81-35-05

-

Inspector Followup Item -

Licensee response to generic letter 81-14 for Aux Feedwater System seismic qualificatio.

Licensee Action on Previous Inspection Findings Not inspecte. 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 paragraphs 7 and.

Independent Inspection During discussions with the licensee's engineering personnel the inspector was suprised to learn that they were still preparing the 120 day response: to NRC Generic Letter No. 81-14, Seismic Qualification of Auxiliary Feedwater Systems, dated February 10, 198 The licensee explained that, for reasons unknown, CP&L did not receive the generic letter when it was originally issued. They finally received the letter in late August and are therefore just reaching the 120 day response due dat The inspector requested that Region II be placed on distribution for the response for inclusion in inspection plans for the next refueling outag This was identified as Inspection Followup Item N /81-35-05

"Licensee Response to Generic Letter 81-14 for Aux Feedwater System Seismic Qualification."

6. Inservice Inspection -

Review of Plans for Completion of First Ten Year Inspection Interval H. B. Robinson went into commercial operation on March 7, 1971. During the first eighty months of commercial operation the unit was committed to the 1970 edition of ASME Section XI by the Plant Technical Specifications. The licensee conducted all inspections in accordance with the requirements of the 1971)edition with summer 1971 addenda of ASME Section XI in addition to the Tech Spec requirement As required by 10 CFR 50.55a(g) CP&L upgraded the ISI program to the requirements of the 1974 Edition, with Summer 1975 addenda, of ASME Section XI for the operating period from November 7, 1977 to the end of the first 120 month inspection interva ASME Section XI references Regulatory Guide 1.26 "Quality Group Classification and Stand ards" as the guidance for establishing the boundaries of the Class 2 and 3 systems for inservice inspectio The inspector met with the licensee's inservice inspection engineering personnel to review the plans and schedules for the completion of the first interval inspections. This review also included results of past inspections to determine what inspections are required during the final inspection outage for this interva During the review of piping isometric drawings the inspector noted that isometrics for the feedwater piping ISO's N CPL-215, CPL-216, and CPL-217, stopped at the first valve upstream of the steam generator. A review of plant Q-list drawings showed that the proper class boundary for the feedwater piping should have been a motor

)

operated isolation valve upstream of the feedwater control valv The inspector informed the licensee that the omission of the section of feedwater piping betwen the downstream side of the feedwater check valve and the isolation valve was a violation of ASME Section XI Rules for Classifica tion of Piping Systems, which is required by 10 CFR 50.55a, Codes and Standard This was identified as Violation N /81-35-0 The licensee stated that the ISI contractor would be contacted to determine what the impact of adding three or four additional valves and associated piping, in each feedwater line, would have on the class two inspection progra There were no other problems identified in this area of the inspectio. Inservice Inspection - Program Development for Second Ten Year Interval On March 10, 1981 CP&L submitted a letter, Serial No. NO-81-444, which included a schedule for updating the ISI program requirements to the ASME Section XI, 1977 edition with Summer 1978 Addend The letter included the proposed pump and valve test program for the new inspection interval but did not contain the component and weld inspection pla The letter stated that this portion of the ISI program would be developed and submitted prior to January 1, 198 During this inspection the inspector inquired as to the status of the promised submittal. The inspector was informed that the program was still under development and that a letter was being prepared to revise the sub mittal date to March, 198 The reasons for the requested extension was purported to be a lack of engineering personnel to work on the program since the engineering staff at the plant was required to provide support for five outages since the submittal of the March 10, 1981 lette The inspector informed the licensee that this would be carried as an Unre solved Item No. 50-261/81-35-02, "ISI Program for Second Ten Year Inspection Interval is Not Complete".

There were no violations or deviations noted during this part of the inspec tio. Implementation of ASME Section XI Program Requirements The inspector reviewed the licensee's administrative, engineering and maintenance procedures to determine if the requirements of ASME Section XI 77 and 78 Edition regarding personnel qualifications and rules for repair and replacement of components had been include After discussion with the licensee's engineering and QA personnel concerning these requirements, the inspector informed the licensee that the following two unresolved items would be included in this repor /81-35-03, Personnel Performing Operational Tests on Pumps and Valves do not appear to be certified VT-4 Visual inspectors per ASME Section XI requirement /81-35-04 Administrative Engineering and Maintenance Procedures do not appear *to refer to repair and replacement rules of ASME B&PV Code Section X These unresolved items were included to highlight the fact that the rules of ASME Section XI impact more than the inspection activitie The licensee's management should be aware that since March 7, 1981 the code of record for all activities associated with inspection (Except for the remaining inspections from the first ten year interval) and maintenance of H. B. Robinson has been ASME Section XI 1977 Edition with Summer 1978 addend There were no violations or deviations in this.area of the inspection.