IR 05000261/1986012

Insp Rept 50-261/86-12 on 860505-09.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters,Housekeeping,Inservice Insp & IE Bulletin & Inspector Followup Items

ML20210V334
Person / Time
Site:	Robinson
Issue date:	05/21/1986
From:	Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210V326	List: IR 05000261/1986012 ML20210V322
References
50-261-86-12, IEB-82-02, IEB-82-2, NUDOCS 8606100583
Download: ML20210V334 (9)

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$2 K8cg UNITED STATES

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'o NUCLEAR REGULATORY COMMisslON REGION 11

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'+9 . . . . . ,d Report No.: 50-261/86-12 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket No.: 50-261 License No.: DPR-23 Facility Name: H. B. Robinson InspectionConuped: ay 5-9, 1986 Inspect r:. ( _ 5 J/ [

W. P. Kleinsorge / Date' Signed Approved by: [, k. [A A 2/ hI J.o. Blake,"Section Chie '

Date Signed Engineering Branch /

Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection involved 38 inspector-hours on site in the areas of licensee action on previous enforcement matters (927018)

(92702B), housekeeping (548348), material identification and control (429028), ,

material control (429408), inservice inspection, inservice testing of pumps and

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valves (61700), IE Bulletin (IEB) and inspector followup item Results: No violations or deviations were identifie .

8606100583 860523 PDR ADOCK 05000261 G PDR

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s REPORT DETAILS Persons Contacted Licensee Employees

• D. R. Quick, Acting Plant Manager

• J. M. Curley, Director, Regulatory Compliance

• H. J. Young, Director, Quality Assurance / Quality Control (QA/QC) e

• E. M. Harris, Director, ONS

• Farmer, Senior Engineer - Performance Engineering

• J. C. Sturdavant, Regulatory Compliance

• G. Homa, Regulatory Compliance Other licensee employees contacted included engineers, technicians, and office personne NRC Resident Inspectors

• H. E. P. Krug, Senior Resident Inspector

• R. M. Latta, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on May 9, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the license (0 pen) Inspector Followup Item 50-261/86-12-01: "IST Procedure Revisions" -

paragraph The licensee did identify as proprietary some of the materials provided to or reviewed by the inspector during this inspection, however, those materials are not discussed in this repor . Licensee Action on Previous Enforcement Matters (Closed) Violation 50-261/84-09-02: " Failure to Establish Adequate Maintenance Procedures" CP&L's letter of response dated May 25, 1984, has been reviewed and determined to be acceptable by Region I The inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letter of respons The inspector concluded

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that CP&L had determined the full extent of the subject noncompliance, performed the necessary survey and follow-up actions to correct the present conditions and developed the necessary corrective actions to preclude recurrence of similar circumstances. The corrective actions identified in the letter of response have been implemente (Closed) Violation 50-261/84-13-01: " Hold Point Bypassed Without Documented Authorization" CP&L's letter of response dated June 8,1984, has been reviewed and determined to be acceptable by Region I The inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letter of respons The inspector concluded that CP&L had determined the full extent of the subject noncompliance, performed the necessary survey and follow-up actions to correct the present conditions and developed the necessary corrective actions to preclude recurrence of similar circumstances. The corrective actions identified in the letter of response have been implemente (Closed) Violation 50-261/85-22-01: " Failure to Perform IST in Accordance with ASME Section XI" CP&L's letters of response dated August 12 and 30,1985, have been reviewed and determined to be acceptable by Region II. The inspector held discussions with the cognizant engineer and examined the corrective actions as stated in the letters of response. The inspector concluded that CP&L had determined the full extent of the subject noncompliance, performed the necessary survey and follow-up actions to correct the present conditions and developed the necessary corrective actions to preclude recurrence of similar circumstance The corrective actions identified in the letters of response have been implemente . Unresolved Items Unresolved items were not identified during this inspectio . Independent Inspection Effort Housekeeping (548348), Material Identification and Control (429028) and Material Control (429408)

The inspector conducted a general inspection of the protected area to observe activities such as housekeeping, material identification and control; material control, and storag Within the areas examined, no violations or deviations were identifie . _ _ , - - . -- - _ _ - _ _ , _ _ _ - _ _ - _ _ _ _ _-

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3 Inservice Inspection (ISI)

The inspector examined documents, activities, and records as indicated below to determine whether ISI was being conducted in accordance with applicable procedures, regulatory requirements, and license commitment The applicable code for PSI /ISI is ASME B&PV Code Section XI,1977 Edition with Addenda through summer 1978. The ASME B&PV Code Section V, 1980 Edition was used by the inspector for review, Review of Procedures (730528)

The following procedures were reviewed in the areas of procedure approval and qualification of NDE personnel:

Procedure ID Title W-ISI-8, Rev. 8 " Visual Examination" W-ISI-11, Rev. 10 " Liquid Penetrant Examination" E-ISI-10,Re " Qualification of Ultrasonic Manual Equipment"

-W-ISI-47, Rev. 4 " Manual Ultrasonic Examination of Welds in Vessels"

-W-ISI-206, Rev. 1 " Manual Ultrasonic Examination of Welds" W-ISI-70, Rev. 2 " Magnetic Particle Examination" W-0PS-NSD-101

_ Liquid Penetrant The inspector reviewed Procedure W-ISI-11, Rev. 10 to ascertain whether

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it had been reviewed and approved in accordance with the licensee's established QA procedures. The above procedure was 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; dry surface prior to developing; type of developing; examination technique; and evaluation techniqu ' Magnetic Particle The inspector reviewed procedure No. W-ISI-70, Rev. 2 to ascertain whether it had been reviewed and approved in accordance with the licensee's established QA procedures. The above procedure was reviewed for technical adequacy and for conformance with ASME,Section V, Article 7, and other licensee commitments / requirements in the below listed areas: examination method, contrast of dry powder particle

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color with background and surface temperature; suspension medium and surface temperature for wet particles; viewing conditions; examination overlap and directions; pole or prod spacing; current or lifting power (yoke) and; acceptance criteria, Ultrasonic The inspector reviewed procedures W-ISI-47, Rev. 4, W-206, P.ev. 1, and W-ISI-10, Rev. 6 to ascertain whether they had been reviewed and approved in accordance with the licensee's established QA procedure The above procedures were reviewed for technical adequacy and conformance with ASME,Section V Article 5 and other license commit-ments/ requirements in the below listed areas: type of apparatus used; extent of coverage of weldment; calibration requirements; search units; bream angles; DAC curves; reference level for monitoring disconti-nuities; method of demonstration of penetration; limits for evaluating and recording indications; recording significant indications and; acceptance limit The procedures identified in 6.b., 6.c., and 6 d , above were reviewed for completion of required record Within the areas examined, no violations or deviatiors were identifie . Service Water Piping Degradation (927068) Background The degradation of the service water system is described in RII Report No. 261/84-45. Additional inspection in this area is reported in RII Report Nos. 261/84-48, 261/85-12, and 261/85-22. This inspection is a continuation of the inspection described in the above report The licensee committed in CP&L letter RESP /84-1267, dated January 4, 1985', to an inservice monitoring program to include 15 service water welds that would represent a variety of configurations, lengths of corrosion (microbiological attack) and sleeved as well as nonsleeved joints. These joints were to be radiographed (baseline) prior to start up and re-radiographed (inservice monitoring) in six weeks i one wee Should no further attack be identified the next radiographic examina-tion would be scheduled three months two weeks late The licensee radiographed 15 weld joints (baseline) on December 12, 1984, (except for weld 2S03-2 radiographed on November 19, 1984),

re-radiographed the same 15 weld joints on February 26, 1985, and re-radiographed the same 15 weld joints between May 31, 1985 and June 14, 1985. In addition, two more welds 3-S03-3 and 3-S03-5, were added to the sampl The same sample of 17 welds were re-radiographed during the period October 29 - November 4,1985 and the results reported to the NRC by CP&L letter RNPD/86-124 dated January 31, 198 .

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Inspection

The inspector reviewed a sample of six of the radiographs (inservice monitoring) made late in 1985 and compared them with baseline radio-

graphs made in late 1984. The inspector reviewed the radiographs to determine whether there had been any corrosion growth between the baseline radiographs of December 28, 1984, and the (inservice monitoring) radiographs of October 29 - November 4, 198 Results ,

The inspector could not identify any indications of corrosion that I clearly had increased in size from the baseline radiographs of December 28, 1984, to the inservice monitoring radiographs of October 29 - November 4, 1985. The inspector noted that the licensee's radiographic technique had changed since the last inservice monitoring radiographs of June 1985. This change caused distortion resulting from geometric unsharpness. The distortion made it extremely difficulty to l determine corrosion indication enlargemen In view of this, the inspector discussed the matter with the licensee and made the following recommendations:

- Prior to the next inservice monitoring radiographic inspection, develop an optimum technique for the three radiographic conditions encountered: 6" pipe waterfilled sleeved; 6" pipe waterfilled not sleeved; and 3" pipe waterfilled sleeve Increase the number of exposures per joint from two to three or mor Increase the number of station markers to one every inch approxi-mately.

4 - Establish a fixed starting point for station markers (flow arrow)

and permanently mark the same on each pipe join Mark each piece of radiographic film with joint number and

exposure dat Mark the baseline radiographs with the station numbers used in the next and all future inservice monitoring radiograph The CpAL letter of January 31, 1986, stated that "the next inspection is currently planned to occur af ter refueling Outage #10." The licensee informed this inspector that this inspection was tentatively planned for June 1, 1986.

I Within the areas examined, no violations were identified.

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8. Inservice Testing of Pumps and Valves (61700)

The inspector reviewed procedures and records as described below, to determine whether applicable code, procedure, and regulatory requirements were being met. The applicable code for Inservice Testing (IST) of pumps and valves is ASME Boiler and Pressure Vessel (B&PV) Code Section XI, 1977 Edition with Addenda through summer 197 Inservice Test Program Review CP&L submitted a revised IST program, for the second inspection interval (March 7, 1984 - March 7, 1991). The submittal by letter was dated January 13, 1984 and supplemented by letter dated April 13, 198 Subsequently it was superseded with letters dated March 10,1981 and December 9, 198 faR completed review of these submittals and documented the same in NRC letter dated Decer.aer 23, 198 The NRC December 23, 1985 letter identified possible deficiencies in the scope of the submitted program as discussed below:

- NRR identified 22 valves which appear to perform a containment isolation function, but are not tested in accordance with the requirements of 10 CFR 50, Appendix NRR stated that if any of these valves are determined by the licensee to be containment isolation valves requiring Appendix J testing, they must be categorized A or A/C as applicable in the IST program and tested accordingly. The licensee has determined that all but two valves (855 and 518) are not postulated leak paths as defined by the FSAR and Appendix J. Valve 855 has been categorized "A" and valve 518 has been categorized as "A/C". Both valves have been included in the IST progra NRR indicated 11 relief requests which had insufficient technical basis or information submitted, and were, therefore, not grante Nine relief requests have been resubmitted, with additional information, for reconsideratio The tests discussed in relief request Nos. 2.3.3 and 3.4.1.2 will be performed as specified in the December 23, 1985 letter. The above will require procedures OST-402, Rev. 3 " Diesel Fuel Oil System Flow Test Refueling" and OST-403, Rev. 4 " Diesel Fuel Oil Transfer Pumps Test (Monthly)",

to be modified to comply with the NRR position for Relief Request No. 2.3.3. To comply with the testing schedule, the procedures must be amended prior to testing. The testing must be complete 90 days following the resubmittal by CP&L to NRR (May 2,1982).

Pending review by NRC of amended versions of OST-402 and OST-403, this matter will be identified as inspector followup item 50-261/86-12-01: "IST Procedure Revisions".

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7 Auxiliary Feedwater System (AFWS) Check Valve Leakage Leaking AFW check valves in the AFWS branch lines can introduce hot water to the AFW pump casings. Hot water in the pump casings can lead to steam binding and a subsequent AFW pump trip. This scenario has occurred at H. B. Robinson Unit 2. In view of the leakage problem, Region II recommended that these check valves be included in the licensee's inservice testing progra The staff of the division of licensing has evaluated the value of requiring these valves to be leakrate tested in accordance with Section XI of the ASME Code (these valves are required to be in licensee IST programs, but are currently only required to be full-stroked to the open position). The staff indicated the leakrate testing would not adequately protect against the steam binding phenomena since Section XI only requires this type of testing at least each two year To investigate and resolve the concern of steam binding in AFW pumps, Generic Issue No. 93 has been initiated. The Division of Licensing indicated in their letter dated November 22, 1985, that in the interim (prior to the resolution of Generic Issue 93) that the staff feels that the plant should utilize a surveillance procedure by which test personnel measure the temperature of the AFW pumps casings or their discharge piping each shift (three times per day). Records of measured temperatures and related corrective actions should be maintained in order to establish trends. Actual measurement of temperature will be less qualitative than the procedures currently in use and should provide more assurance that the fluid inside the AFW pumps casings is maintained well below saturation condition To date, the licensee continues to use a surveillance procedure under which the AFW pump casings temperatures are checked each shift (two times a day - 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) and, if found to be hot to the touch of a person's hand, the aump casing is to be vented to prevent the possi-bility of vapor bindin The licensee stated that he has not received any direction from the NRC to amend his surveillance procedure for AFW pump casing . IE Bulletin (IEB)

(Closed) IEB No. 82-02: " Degradation of Threaded Fasteners in the Reactor Coolant pressure Boundary of PWR Plants"

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The inspector has reviewed CP&L's letters of July 30, 1982 and March 8, 1985, and determined that the requested actions of the bulletin have been acceptably addresse The inspector held discussions with responsible engineers, reviewed supporting documentation and observed representative samples of work to verify that the actions identified in the letters of response have been complete _

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10. Inspector Followup Items (0 pen) Item 261/84-45-01: " Service Water Degradation" This matter was further examined during this inspection and is discussed in paragraph 7 of this report. This item remains ope (Closed) Item 50-261/84-45-04: " Maximum Valve Stroke Time" This item concerned large discrepancies between actual as-measured stroke time and maximum stroke time permitted by CP&L procedure TMM-00 The licensee has revised his program such that maximum permitted stroke times are now consistent with the guidelines provided by staff of the Division of Licensing. The inspector has no further question (Closed) Item 50-261/84-48-04: " Sleeve Data Sheet Discrepancies" This item concerned discrepancies on service water sleeve fabrication /

installation data sheets. The licensee has corrected the discrep-ancies. The inspector has no further question I