IR 05000261/1987016
| ML14191A822 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/05/1987 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191A821 | List: |
| References | |
| 50-261-87-16, NUDOCS 8706250191 | |
| Download: ML14191A822 (13) | |
Text
REc UNITED STATES o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report No.:
50-261/87-16 Licensee:
Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility Name: H. B. Robinson Inspection e :/My 18-21, 1987 Inspecto :
'& 7 0Date ied Approv b
___ e, Section Chief ate igne E gi ering Branch ivsion of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of housekeeping (54834B), material identification and control (4290218), material control (429408),
service water piping degradation (92706B), repair of leaking lower control rod drive mechanism (CRDM) Canopy seal weld, inservice inspection (ISI) - review of procedures (73052) and inspector follow item Results:
No violations or deviations were identifie PDR ADOCK 05000261 Q
REPORT DETAILS 1. Persons Contacted Licensee Employees
- J. M. Curley, Acting General Manager
- H. G. Young, Director Quality Assurance/Quality Control
- Sayer, Acting Director of Regulatory Compliance
- S. W. Farmer, Performance Engineer Other licensee employees contacted included engineers, technicians, and office personne NRC Resident Inspectors H. E. P. Krug, Senior Resident Inspector R. M. Lata, Resident Inspector
- Attended exit interview Exit Interview The inspection scope and findings were summarized on May 21, 1987, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the license (Open)
Inspector Followup Item (IFI)
50-261/87-16-01:
"MT Procedure Discrepancies" - paragraph 8c(2)(c)
(Open) IFI 50-261/87-16-02: "ISI Replacement Verification of Acceptability" - paragraph 8d The licensee did identify as proprietary some of the materials provided to or reviewed by the inspector during this inspection, however, that material is not discussed in this repor. Licensee Action on Previous Enforcement Matters (92701B) (92702B)
This subject was not addressed in the inspectio. Unresolved Items Unresolved items were not identified during this inspectio. Independent Inspection Effort Housekeeping (54834B),
Material Identification and Control (42902B)
and Material Control (42940B)
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. Service Water Piping Degradation (92706B)
a. Background The degradation of the service water system is described in RH Report No. 261/84-45. Additional inspection in this area is reported in RII Report Nos. 261/84-48, 261/85-12, 261/85-22, 261/86-12, and 261/87-0 This inspection is a continuation of the inspection described in the above report In CP&L letter RESP/84-1267, dated January 4, 1985, the licensee committed 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 non-sleeved joint These joints were to radiographed (baseline)
prior to start up and re-radiographed (inservice monitoring) in six weeks +/- one week. Should no further attack be identified, the next radiographic examination 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 sample. 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 The inspector reviewed a sample of six of the radiographs (inservice monitoring) made late in 1985 and compared them with baseline radiographs made in late 198 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 The inspector noted that the licensee's radiographic technique had changed since the last inservice monitoring radiographs of June 198 This change caused distortion resulting from geometric unsharpnes This distortion made it extremely difficult to determine corrosion indication enlargement. In view of this, the inspector discussed the matter with the licensee and made the same recommendations for improvement. The licensee implemented the inspectors recommendations in their December 8-12, 1986, radiographic examination of the service water system sample. This examination detected new indications and apparent further growth of the microorganism induced corrosion (MIC).
This radiographic examination indicated that six of the 15 sleeved welds sampled in containment and in the auxiliary building exhibit apparent new growth in the sleeve-to-pipe fillet weld heat affected zone. The results of the December examination were reported to NRC Region II by CP&L letter, dated January 16, 198 All the six-inch welds in the containment have been sleeve The licensee has determined that the growth rate of the indications is conservatively approximately 5/8-inch circumferentiall The licensee has reviewed all past radiographs for the non sleeved welds in the auxiliary buildin They have identified 17 welds which, given the 5/8-inch circumferential growth rate, would exceed the five inch structural limit by the 1988 refueling outag Those 17 welds have been sleeve During the 1987 outage, the licensee has completed a chemical treatment intended to remove the biological based fouling from the service water syste This treatment consisted of a temporary recirculation/flushing loop established with each individual cooler unit and its pipin A combination of a biodispersent and a biocide was recirculated in the loop to clean the system's interior wall areas followed by a flushing with service water. After completion of treatment with biodispersent/biocide, the system was cleaned with a hydrogen peroxide solution (< 3%),
to further break up interior fouling and kill microorganisms, and flushe When treatment was complete, each cooler unit piping was restored, tested, and returned to servic Complete cleaning of the piping interior was not accomplished, however, it was significantly reduce Samples were taken, by the supplier of the chemicals, for chemical and bacteriological evaluation of the system before and afte The licensee has not received the results as of this writin Radiography of the sample welds is scheduled for the week of May 2 The. inspector discussed the above with the licensee and reviewed the Cleaning Procedure SP-766, "Service Water System Chemical Cleaning Procedure for HVH-1, 2, 3, and 4", and reviewed associated record Within the areas examined, no violation or deviations were identifie.
Repair of Leaking Lower Control Rod Drive Mechanism (CRDM) Canopy Seal Weld The repair of the control rod drive mechanism (CRDM) housing atop the reactor vessel head was necessary to preclude further reactor coolant leakage. This leakage was through the canopy weld which joins the bottom of the mechanism housing with the top of the head adapter, a flared pipe which penetrates the head. At the K-6 core location, repeated attempts at weld repair on this canopy have faile Further repair would have questionable results and require high amounts of radiation exposure due to the inaccessibility of this mechanis In light of the fact that no operating mechanism is integrated with the K-6 core location, the cutting and removal of the mechanism and installation of a welded cap on the head adapter was considered the most practical solution to the leakage proble A Westinghouse (W) generic analysis justified operation of a reload cycle core without part length rod Based on this report and Technical Specification Change No. 38, HBR 2 has operated since the Fall of 1975 without part length rods being inserted in the core. In the Fall of 1979, the part length rods were removed and thimble plug assemblies were installed in their place to maintain the thermal and hydraulic
- characteristics of the eight affected elements. The part length rods were stored in the spent fuel poo The CRDM for the part length rods were locked out and are not maintained as operational; however, with the exception of those at the K-6 core location, components remain in place to keep the weights at the same. At the K-6 location, the mechanism and part length rod was removed and a cap is welded to the head adapte The part length CRDS is described in the original FSAR, Section 3.2.3,.the removal of the mechanism and installation of the cap were accomplished by W under the umbrella of the W Quality Assurance Program to the requirements of ASME Boiler and Pre sure Vessel Code Section III 77S78, with Contract Quality Control examiners provided under a labor contract from National Inspection and Consultants, Inc. (NIC).
The Cap was installed with a consumable insert tungsten inert gas butt weld, which was subsequently, visually, liquid penetrant and radiographically examined. The radiography was performed by the licensee The weld will be pressure tested during the startup reactor coolant system pressure tes The inspector conducted interviews with cognizant licensee personnel, and examined the documents listed below to ascertain whether the repair had been accomplished consistent with applicable procedural and regulatory requirement Documents Examined Modification Package No. 81 W Stress Analysis Package S.0.Q129 W Visual Inspection Procedure NDE-110 W Liquid Penetrant Inspection Procedure NDE-210 W Welding Procedu e Qualification Records V Qiality Releases Certified Material Reports W Cdrtificate of Compliance W Calibration of Reports W Weldi Qualification Test Records Certification of Inspection and Testing Personnel Within the areas examined, no violations or deviations were identifie. Inservice Inspection (ISI) - Review of Procedures (73052)
The inspector reviewed procedures, interviewed licensee/contractor personnel and reviewed records to determine whether the licensee's program pertaining to ISI is complete and in conformance with regulatory requirements and the; licensee's commitments, as indicated belo Unit 2 which commenced commercial operation on March 4, 1971, is in the second 40 month period of the Isecond ten year ISI interval March 7, 1981, to February 19, 1992, al permitted by ASME Section XI Subsection IWA-2400(c)
due to the 349 day duration of the steam generator replacement outag ISI inspection activities have been or are being performed by contractors under the umbrella of the Contractors Quality Assurance (QA)
programs, as indicated below:
Westinghouse (W)
-
Weld inspection implemented by 10 year contract Combustion Engineering (CE)
-
Reactor vessel inspections, and steam generator tubes, second period Babcock and Wilcox (B&W)
-
Steam generator tubes baseline (after steam generator replacement) for first period a. Program Requirements The inspector reviewed the licensee's commitments in the SAR, Technical Specification (TS),
and approved ISI program to ascertain whether ISI procedures adequately cover all areas specificed in the licensee's commitments for ISI and PSI requirement.6 Procedure Approval The inspector reviewed the below listed procedures to determine whether the ISI procedures have been approved by authorized licensee personnel and by the Authorized Nuclear Inservice Inspector (ANII)
where applicabl Procedures Reviewed CP&L-PLP-025, Rev. 0
"Inservice Inspection Program" W-ISI-8, Rev. 9/
"Visual Examination" P&L-SP-729 Rev. 0 W-ISI-11, Rev. 10/
"Liquid Penetrant Examination" UP&L-SP-731, Rev. 0 W-ISI-70, Rev. 2/
"Magnetic Particle Examinations" TP&L-SP-736, Rev. 0 W-ISI-47, Rev. 4/
"Manual Ultrasonic Examination of Welds in UP&L-SP-735, Rev. 0 Vessels" W-ISI-206, Rev. 1/
"Manual Ultrasonic Examination of Welds" TP&L-SP-738, Rev. 0 W-ISI-48, Rev. N/A
"Manual Ultrasonic Examination of Reactor UP&L-SP-733, Rev. 0 Vessel Weld and Stud Hole Ligaments Reactor Vessel Flange" W-OSP-NSD-101, Rev. 5/
"Preservice and Inservice Inspection CP&L-SP-737, Rev. 0 Documentation" CE-ROB-410-004, Rev. 0
"Procedure For Multi-Frequency Eddy Current Examination of Nonferromagnetic Steam Generator Tubing Using MIZ-18 Equipment" CE-ROB-410-005, Rev. 0
"Eddy Cu 'rrent Data Analysis Procedure Evaluation of Westinghouse Steam Generator Tubi ng" C. Non-destructive Examination (NDE)
(1) Procedure Review The inspector reviewed the procedures indicated in paragraph (b)
below to determine whether requirements are specified and agree with licensee's commitments including specified or referenced acceptance levels; qualifications of NDE personnel are specified in accordance with the licensee's approved ISI program; methods
of recording, evaluating and dispositioning findings are established and reporting requirements are in compliance with applicable Code requirements; and procedures delineate the scope of work and division of responsibilities between the licensee and the contracto (2) Technical Content (a) Visual Examination The inspector reviewed the below listed visual examination procedure to determi7ne whether it contain information or reference to a g4neral inspection procedure or supplementary instructions sufficjint to assure that all parameters are specified and controlled within the limits permitted by the applicable Code and other additional specification require ments; each essential examination variables are defined and whether these variables are controlled within the limits specified by the applicable Code and other specification/
contract requirement Specific areas examined were:
method; application; how visual examination is to be performed; type of surface condition; method or tool for surface preparation; direct or remote viewing; special illumination, instruments, or equipment; sequence of performing examination; data to be tabulated; acceptance criteria are specified consistent with the applicable Code and report form or general statement to be complete Procedure Examined ISI-8 (b) Liquid Penetrant Examination The inspector reviewed the below listed liquid penetrant examination procedures to determine whether they contain information or reference to a general inspection procedure or supplementary instructions sufficient to assure that all parameters are specified and controlled within the limits permitted by the applicable Code and other additional specification requirements; each essential examination variables are defined and whether these variable are controlled within the limits specified by the applicable Code and other specification/contract requirement Specific areas examined were:
specified test method is consistent with applicable Code requirements; brand names and specific types (number or letter designation if available of penetrant, penetrant remover, emulsifier and developer are specified; penetrant materials used for nickel base alloys are required by procedure to be analyzed
for sulfur using the method prescribed by the applicable Code; penetrant materials used for the examination of austenitic stainless steel are required by procedure to be analyzed for total halogens using the method prescribed in the applicable Code; method for acceptable pre-examination of surface preparation are specified and consistent with the applicable requirements, cleanliness acceptance requirements are consistent with applicable Code requirements, surface area to be examined is consisted with applicable Code requirement; procedure established a minimum drying time following surface cleaning; method of penetrant application and penetration (dwell)
time are specified and that the penetration time is consistent with the penetrant manufacturer's recommendation; examination surface is specified and is consistent with the applicable Code; procedures (when applicable) specify acceptable methods for removing water-washable penetrant consistent with the applicable Code; method of applying emulsifier (when applicable) and the maximum emulsification time is specified and consistent with the applicable Code; method for removal of solvent removable penetrant when applicable)
are specified; method and time of surface drying prior to developing is specified; type of developer to be used, method of developer application and the time interval between penetrant removal *and developed application specified; examination technique is specified and the permitted time interval during which the "final interpretation" is performed within the range of 7-30 minutes after developer application; minimum light intensity at the inspection site is prescribed; technique for evaluation of indications is specified, acceptance standards are included and these are consistent with applicable Code and specific contract requirement; reporting requirements are specified; and procedure requires requalification when changes are encountere Procedure Examined ISI-11 (c) Magnetic Particle Examination The inspector reviewed the below listed magnetic particle examination procedure to determine whether it contain information or references to a general inspection procedure or supplementary instructions sufficient to assure that all parameters are specified and controlled within the limits permitted by the applicable Code and other additional specification requirements; each essential examination variable is defined and whether these variables are
controlled within the limits specified by the applicable Code and other specification/contract requirement Specific areas examined were:
method - continuous; surface preparation; particle contrast; surface temperature; light intensity; coverage; prod spacing; magnetizing current and yoke pole spacing; and acceptance criteria are specified consistent with the applicable ASME Code Section and specific contract requirement Procedure Examined ISI-70 With regard to the examination above, the' inspector noted the following discrepancies in Procedure I$-70, Rev. 2:
-
Procedure does not specify fluorescent examination will be performed in a darkened area contrary to ASME B&PV,Section V, Paragraph T-725.3,
"Fluorescent Particles."
-
Procedure does not require fluorescent examiners to be in darkened area for at least five minutes prior to performing the examination to enable his eyes to adjust to dark viewing and if examiner wears glasses:
or lenses, they shall not be photo sensitive. This is contrary to good industry practic The ASME has added this as a requirement to the 1983 Editilon of Code?Section V, paragraphs T-726;(c)(2)and (1).
The procedure does not address the calibration or accuracy verification of the light meter used to verify the intensity of the ultraviolet ligh The Licensee indicated that they would make appropriate changes. Pending NRC review of the amended procedure this matter will be identified as Inspector Followup Item 50-261/87-16-01: "MT Procedure Discrepancies."
(d) Ultrasonic Examination The inspector reviewed the below listed ultrasonic examination procedures to determine whether they contain information or references, a general inspection procedure or supplementary instructions sufficient to assure that all parameters are specified and controlled with the limits permitted by the applicable Code and other additional specification requirements; essential examination variables are defined and whether these variables are controlled
within the limits specified by the applicable Code and other specification/contract requirement Specific areas examined were:
type or apparatus to be used including frequency range as well as linearity and signal attenuation accuracy requirements, is specified, extent of coverage (beam angles, scanning surface, scanning rate and directions) as well as the scanning technique are specified and are consistent with the applicable ASME Code and contract requirements; calibration requirements, methods, and frequency including the type, size, geometry, and material of calibration reflectors within the block are clearly specified and consistent with.the applicable ASME Code and contract requirements; sizes and frequencies of search units are specified and are consistent with applicable ASME Code and contract requirements; beam angles are specified and are consistent with the applicable ASME Code and contract requirements; methods of compensation for the distance traversed by the ultrasonic beam as it passes through the material including distance - amplitude correction curves, electronic distance -
amplitude correction and transfer mechanisms, if used, are specified and consistent with the applicable ASME Code and contract requirements; reference reflectors for accomplishing transfer and the frequency of use of transfer mechanism if applicable, are specified and in accordance with the reference level for monitoring discontinuities is defined and the scanning gain setting specified and that these values are in accordance with the applicable ASME Code and contract requirements; methods of demonstrating penetration and coverage are established; levels or limits for evaluation and recording of indications are specified are in accordance with applicable ASME Code and contract requirements; method of recording significant indications is established and that the reporting requirements are in accordance with applicable ASME Code and contract provisions; and acceptance limits are specified or referenced and are in accordance with the applicable ASME Code and specific contract requirement Procedures Examined ISI-47 ISI-206 ISI-48 (e) Eddy Current Examination The inspector reviewed the below listed eddy current examination procedures to ensure that the:
multi-channel examination unit is specified; method of examination is
described; method of calibration and sequence of calibration is described; requirements of TS or ASME Code Section XI (whichever.is applicable) have been addressed; procedures meet the requirements and intent of RG 1.83; licensee has written approval for use of Code cases such as "N-401".
Procedure Examined ROB-410-004 ROB-410-005 Code Repair and Replacement Procedure Review The inspector reviewed repair and replacement procedures indicated below to ensure that the elements of the procedures are consistent with the applicable areas of the ASME Code and the approved ISI program. The specific elements examined were:
Repair:
identification of the NDE method that revealed the flaw and the description of the flaw; description of the flaw removal method; procedure for weld and postweld heat treatment, if applicable, including review of procedures for welding prior to authorization of the repair and review of qualifications of welders performing the repair; provisions for using the services of an Authorized Inspection Agency when making a weld repair, as well as for having the ANI review and approve the repair procedure before its performance; description of the NDE program to be used after the repair is completed; and delineation of the scope of work and division of responsibilities between the licensee and contractor, if a contractor is use Replacement:
provisions to verify that the replacements met the requirement of the edition of the Construction Code to which the original component/part was constructed, the provisions of later editions of that same Code, or Section III of the ASME Code; provisions to ensure that the replacements ordered as spares met the requirements of the appropriate Construction Code used for part/component it was intended to replace, the provisions of later editions of that Code, or Section III of the ASME Code; justification, consistent with NRC guidelines, for not requiring a Code Stamp; evaluation of the suitability of the replacement prior to authorizing its installation; retention of reports and records as required by the Construction Code and ASME Code Section XI; and performance of a PSI prior to the return to service of the replacement component or part in. accordance with the applicable Cod II
Procedures Reviewed CP&L-TMM-015, Rev. 4
"Inservice Inspection Repair and Replacement Program" CP&L-TMM-016, Rev. 3
"Inservice Inspection Repair and Replacement Program Hydrostatic and Pneumatic Testing Requirements for Class 1, 2, and 3 Systems and Components" With regard to the examination, the inspector noted that the licensee's replacement program does not'specifically address the requirements of ASME B&PV Code,Section XI, paragraph IWA 7220,
"Verification of Acceptability."
The licensee indicated that all the elements of IWA-7220 are addressed in the various separate procedures and program They also indicated that they would clearify TMM-15 as necessary to clearly address the IWA-7220 requirements. Pending the NRC review of the revision to TMM-15, this matter will be identified as Inspector Followup Item 50-261/87-16-02:
"ISI Replacement Certification of Acceptability."
Within the area examined, no violations or deviations were identifie. Inspector Followup Items (Open) Item 261/84-45-01:
"Service Water Degradation" This matter was further examined during this inspection and is discussed in paragraph 6 of this report. This item remains open.