IR 05000321/1993004

Insp Repts 50-321/93-04 & 50-366/93-04 on 930329-0402.No Violations or Deviations Noted.Major Areas Inspected:Isi Observation of Work Activities & Evaluation of Recorded Ultrasonic Data

ML20036A171
Person / Time
Site:	Hatch
Issue date:	04/21/1993
From:	Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20036A163	List: IR 05000321/1993004 ML20036A162
References
50-321-93-04, 50-366-93-04, NUDOCS 9305100138
Download: ML20036A171 (11)

Text

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REGION II

h 101 MARIETTA STRE ET, N.W.

! ATLANTA, GEORGI A 30323 , r Y'g...../ i Report Nos.: 50-321/93-04 and 50-366/93-04 Licensee: Georgia Power Company - P. O. Box 1295 Birningham, AL 35201 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5

Facility Name: Hatch I and 2 Inspection Conducted: March 29, - April 2, 1993 Inspector: \\M 1/ 070- 93 u J. % Coley Jf.

\\ Date Signed m [ i Approved by: , - >,Y Y 2/ 73 m . ){ Blake, Chief D' ate Signed Materials and Processes Section Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of inservice inspection (ISI) - observation of work activities and evaluation of recorded ultrasonic data, assessment of erosion / corrosion (E/C) for Units I and 2, and previously open inspection findings.

Results: In the areas inspected, violations or deviations were not identified, i In general, the ISI program was found to be functioning well. Although, vendor weaknesses were observed by the inspector during observation of in-process work activities (paragraph 2.a.(1)) and evaluation of recorded data (paragraph 2.b.). The findings were considered by the inspector to be of the type which should be identified by Southern Nuclear Operating Company (SNC) during their final review of documentation which had not been performed.

Effective corrective action was taken by SNC and General Electric (GE) on the inspector's findings.

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i ! i l The inspector's assessment of E/C activities revealed that Unit I has.not !

experience any significant E/C. Unit 2 however, has experienced E/C to a greater degree. This difference in the E/C rates between the two units is due - specifically to unit design differences. The inspector also concluded that the licensee's E/C inspection program has been effective in identifying system

degradation. The licensee is presently in the transitional period of updating

their present E/C program to the recommendations of the Electric Power

Research Institute's (EPRI) new draft report for " An Effective Flow-l accelerated Corrosion Program". The licensee also expects all E/C susceptible , I systems to be modeled and inspection priority determined in accordance with

j EPRI's CHECMATE computer program prior to the next outage for both units.

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> , j l ] REPORT DETAILS j l i 1.

Persons Contacted ,

• G. Brinson, QC Supervisor
• G. Goode, Manager Engineer Support
• R. King, Supervisor, Engineering Support l
• W. Kirkley, Manager, Health Physis and Chemistry
• P. Norris, Senior Engineer

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• D. Read, Assistant General Manager, Support

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• S. Tipps, Manager, Nuclear Safety and Compliance

! Other licensee employees contacted during this inspection included

engineers, technicians, and administrative personnel.

Other Organizations ! Southern Nuclear Operating Company (SNC) l

• W. Flowers, Engineer, Safety Assessment Engineering Review (SAER)
• 0. Fraser, Site Supervisor, SAER

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• R. Healey, Senior Nuclear Specialist l
• B. Syx, Senior Project Engineer
• T. Wells, Senior Engineer

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• A. Zabala, Senior Engineer

~ NRC Resident Inspectors ' I

• L. Wert, Senior Resident Inspector

! j E. Christnot, Resident Inspector ! B. Holbrook, Resident Inspector

• Attended exit interview

Acronyms and initialisms used throughout this report are listed in the l last paragraph.

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2.

Inservice Inspection (ISI) Unit 1 The inspector reviewed documents and records, evaluated recorded ultrasonic data, and observed in process examination activities as indicated below to determine whether ISI was being conducted in accordance with applicable procedures, regulatory requirements, and licensee commitments.

The applicable code for ISI is the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME B&PV) Code, Section XI,1980 Edition with Addenda through Winter 1981 except that the extent of examination for Code class 2 piping welds in the Residual Heat Removal (RHR) Emergency Core Cooling (ECC), and Containment Heat Removal (CHR) systems were determined by the requirements of the 1974 Edition with Addenda through the Summer 1975.

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< The 2nd 10-year interval began for both units 1 and 2 on January 1,

1986. By letters dated June 25, 1985, and February 7, 1986, Georgia

Power Company (GPC) submitted their 2nd 10-Year interval ISI program for j units 1 and 2.

The NRC approved the program by Safety Evaluation Report

dated September 29, 1986.

By letter dated September 11, 1987, GPC submitted a revision to the ISI program, which incorporated comments from the SER. On February 24, 1988, revision 2 was submitted ' incorporating the comments from a meeting with the NRC requesting

additional information on the revision 2 of the program. On September 8, ' 1988, GPC provided the additional information on revision 2 of the program. The SER was issued on June 22, 1989, covering review of , revision 2 of the program and revision 1 of the ISI plans for both

units. Twenty-five (25) relief requests were included and were granted,

granted with comment, withdrawn by the licensee, denied, or deemed not . l to need approval.

i The licensee is currently in the 3rd 40-Month period of the 2nd 10-Year interval. The current outage is the 1st outage of the period for Unit 1.

The licensee's Engineering Support organization is responsible for administering the ISI and plans. SNC, working through the site Engineering Support organization, implements the inspection program and

plans using SNC procedures and QA controls, and contractor inspection ' personnel. For the current outage, General Electric (GE) was the contractor.

Procedures are approved through the GPC Plant Review Committee (PRC).

a.

Observation of ISI Work and Work Activities (73753) (Unit 1) The inspector observed the work activities detailed below, as well as the applicable examination procedure, equipment calibration and/or certification records, and personnel qualification and certification records.

(1) Manual ultrasonic examinations (UT) of Reactor Water Clean-up Welds (RWCU) Calibrations and manual UT examinations were observed on the following 6 inch diameter Class 1 RWCU Welds, after mechanical stress improvement process (MSIP) had been performed.

Weld Identification Weld TYDe/ location IG31-IRWCUM-6-D-8 Circumferential 1G31-1RWCUM-6-D-10 Circumferential 1G31-1RWCUM-6-D-10-A Circumferential 1G31-1RWCUM-6-D-11 Circumferential 1G31-IRWCUM-6-D-8-LD Longitudinal /Down-Stream IG31-IRWCUM-6-D-10-LD Longitudinal /Down-Stream 1G31-lRWCUM-6-D-10-A-LU Longitudinal /Up-Stream . , _ ___ -_ _ _ . .- ..

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l Welds Examined Continued j IG31-lRWCUM-6-D-10-A-LD Longitudinal /Down-Stream l IG31-IRWCUM-6-D-Il-IR Longitudinal / Inner-Radius ' IG31-1RWCUM-6-D-11-OR Longitudinal / Outer-Radius During calibrations for the Reactor Water Cleanup Welds the l inspector noted that a GE examiner was calibrating a 60*

shear wave transducer for a one-sided examination on a stainless steel weld. Since a refracted longitudinal (RL)

wave transducer is needed to insure sound penetration

through stainless steel weld metal the inspector asked the , examiner why he was using a shear wave transducer. The i l examiner showed the inspector where paragraph 11.2.1 of the

' examination procedure (UT-H-400 Rev. 11) allowed him to use

either a shear or a RL wave transducer.

l i The inspector however, was aware that a review of this procedure in October 1992, (Inspection Report No.

50-321,366/92-25) had identified the lack of specific

procedural requirements defining when a RL transducer was

l expected to be utilized, and that SNC had agreed to revise ' - the procedure at that time. The inspector held discussions ' l with the SNC ISI supervisor and Level III examiner to ! determine why this vague requirement was still in the

' examination procedure. The inspector found that SNC had i corrected the paragraph 6.2.4, identified by the inspector l in the November,1992 report, however, SNC had failed to reviewed the procedure in its enttisiy to determine if this l was the only paragraph which had the vague requirement.

l SNC agreed to review the procedure and revise any paragraph which contained the vague requirement. SNC also assured the inspector that this problem would have been identified by the Level III during his final review of documentation since it was SNC's policy to use RL wave transducers as a conservative measure on all one-sided stainless steel weld examinations.

(2) UT of Feedwater Nozzle N4D using General Electric's Reactor Inspection System (GERIS 2000) In their letter to NRR dated October 19, 1992, GPC proposed to change the requirements for the liquid penetrant (PT) and UT contained in NUREG-0619. The PT examinations were . scheduled to be performed during the Spring 1993 refueling outage for Unit I and the Spring 1994 refueling outage for Unit 2.

The licensee has performed UT examinations every i second refueling outage as specified in NUREG-0619 on both units. No reportable indications have been detected.

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In a letter dated January 25, 1993, the NRC staff informed GPC that additional information was required to assess GPC's proposed alternative examination using the GERIS 2000 UT System in lieu of the manual UT and the in-vessel PT. GPC provided the response in a letter dated February 22, 1993, which stated that in consideration of the remaining time until the Unit 1 outage and the potentially generic application of the proposed plan, GPC requested that the review of the plan described in their October 19, 1992, letter be deferred.

Consequently, GPC requested schedular j relief for the PT examination requirement contained in NUREG-0619 for one cycle on both Units 1 and 2.

The NRC staff evaluated the licensee's request and concluded that a one cycle, schedular relief from the PT examination requirements was acceptable, for both units, provided that j the licensee implemented part of its plan from the October 19, 1992, letter as follows: (a) Perform an automated UT examination on Unit I with GERIS 2000 System. If a flaw indication is detected that is interpreted to be a crack, the corrective action PT described in NUREG-0619 must be implemented.

l (b) Provide the technical basis and sufficient information to address the Spring 1993 examination results before February 1, 1994.

(c) Perform an automated UT on Unit 2 with a similar inspection system and examination procedure.

(d) Provide the technical basis and sufficient information to address the Spring 1994 examination results before September 1, 1994.

The inspector reviewed the supplemental information provided by the licensee in their February 22, 1993, letter.

This information described the examination methodology used by GE in their mockup test of a reactor vessel feedwater nozzle.

In addition, the inspector observed GE perform the OD examinations of Zones 2B and 3 on Feedwater Nozzle N4D safe-end using GE's examination procedure No. GE-UT-402 Rev.0.

For the safe-end examination, the UT scanner was mounted on a channel track clamped around the nozzle safe-end.

The scanning mechanism was magnetically attached to the channel track.

GE uses a DSC type reference block to verify system linearity. The 6" thick block has a EDM notch.125" deep by .010" wide and I" long on the inner surface of the block and is also used to verify system detection / resolution

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capabilities. This block was used in the mockup qualification test performed by GE.

The entire examination is based on results of the qualification test performed by GE using a specific feedwater nozzle. During tnis qualification effort GE's scanning fixture alignment and beam angle computations worked well. This allowed GE to determined that the system could detect a.150" deep notch in any zone of the nozzle.

The inspector inquired as to whether GE had used as-build drawing dimensions for the Hatch Unit 1 examinations. This is essential since the angle beam examirdions utilize compound interface angles, based on the nozzle's outer and internal surface configurations, and proper alignment of the t i scanning fixture. The inspector was informed that all angle ccmputations were derived from the Hatch as-build drawing dimensions.

The GERIS examinations had just started when the inspector condu-ted his inspection of this system and no examination l dat:..as available for review and evaluation. However, ' equipment calibration / certification data and personnel qualification / certification were reviewed.

(3) Liquid Penetrant (PT) Examination Activities The inspector observed two GE examiners perform a PT examination on the D-4 Recirculation System Nozzle Safe-end weld (Weld No. IB31-1RC-12BR-D-4). The examiners shared the examination responsibilities for this weld in order to reduce radiation exposure for one individual. The inspector observed the examination to determine whether the examination v.as conducted in accordance with SNC's PI Examination Procedure No. PT-H-600, Rev.3. and to insure that the examiners inspection techniques did not allow recordable indications to go undetected, in addition to determining that the examination techniques and evaluation of the indications were satisfactory. The inspector reviewed the examination procedure, verified the certification of the examination materials, and reviewed the examiners qualification / certification records.

Within the areas examined, no violation or deviation was identifie _ _. .. ._ _ __ . s - !

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ISI Data Review and Evaluation (73755) ) The inspector reviewed UT records and automated UT data where applicable for the SMART 2000 System's examinations of the

following 28" diameter and 12" diameter recirculation system

] welds.

, Weld Identification No.

Pipe Confiauration l '

IB31-1RC-12AR-H-3 Elbow to Pipe Overlay

IB31-1RC-28-A-4 Elbow to Pipe Overlay IB31-1RC-28-B-7 Elbow to Pipe i 1B31-IRC-AR-J-3 Elbow to Pipe Overlay l

IB31-lRC-AR-K-3 Elbow to Pipe Overlay ! IB31-lRC-28-A-3 Pipe to Elbow , i

During the review of GE's indication resolution sheet for weld No.

l IB31-lRC-AR-J-3 the inspector noted that the GE Level II data !

analyst did not detect a lack of fusion indication in the weld i overlay repair that had been reported in the 1991 UT data which ! was taken with SNC's P-Scan automated system. The inspector and l GE's Level III Examiner reviewed the SMART UT data for this weld

I at the request of the inspector and discovered that the indication ! was readily discernible in both the A-Scan and C-Scan

presentations. GE then conducted a manual UT examination of the i weld and this examination also confirmed the indication to be lack ! of fusion between weld passes in the overlay weld repair. The ! Level II data analyst was unable to explain how his evaluation concluded that the indication was not discernible. He did however ' agree with the inspector and the Level III examiner that the > indication was lack of fusion. Subsequent discussions with the ' Level III revealed that the data analyst was on the 12 hour backshift which could have affected his evaluation.

Althogh, the above welds had not received a final evaluation by the SNC Level III examiner, the inspector held discussions with ' the SNC ISI Supervisor and Level III examiner and expressed i

concern for the integrity of the SMART 2000 UT data evaluations . when a known indication was apparently not discerned by the GE ! data analyst.

j SNC later informed the inspector that GE's ISI Project Manager was requiring that all SMART 2000 data analysis be evaluated by two I data analysts.

In addition, SNC and GE held a lessons learned i ~ meeting with all ISI examiners on April 1, 1993 to review the ' inspector's findings and to insure that all examiners realized their responsibility to be knowledgeable of the examination

methods, and procedural requirements. The inspector concluded l ' that the corrective actions taken on this finding were appropriate.

, t Within the areas examined, no violation or deviation was identified.

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. j 3.

Erosion / Corrosion E/C Assessment - Units I and 2. (49001) l

, As a result of the high percentage of E/C reported repairs, i replacements, or components requiring continued UT monitoring noted

during a recent review of the licensee's 90-Day ISI Report for the 1992, ! ' Unit 2 Refueling Outage, the inspector became concerned that system j degradation due to E/C may be exceeding the licensee's sample inspection

program efforts to control it.

In addition, the licensee's E/C program ! had been examined previously, and program weaknesses were identified in j NRC Inspection Report 50-321,366/92-25.

- The reported weaknessen dealt primarily with programmatic issues which

, the licensee intends to correct as part of upgrading their program to , ' the EPRI's new E/C guidance. The licensee also intends to model all the t " E/C susceptible systems to EPRI's CHECMATE computer program in order to determine component examination priority. However, this planned program " upgrade is not scheduled to be completed until next outage for both.

l units and if E/C has not been reasonably controlled in previous years even EPRI's CHECMATE computer program cannot be expected to identify all components subject to failure.

l The inspector therefore notified the licensee in advance that this inspection would address the effectiveness of the licensee's efforts to

.' control E/C. This notification was done in order that the cognizant ' personnel, drawings, liquid sealant repair logs, and applicable completed records would be available in a timely manner.

The inspector held discussions with the cognizant engineers, reviewed . E/C documents and completed records (dating back to 1982 when GPC's E/C - program started for Units I and 2), reviewed can sealant repair log records (to determine how often this type of repair has been required during operating cycles), and reviewed marked-up drawings of component replacements and repairs (to determine E/C patterns in susceptible i - systems).

t Based on the above discussions and reviews, the inspector's assessment revealed that Unit I has not experienced significant E/C. Unit 2 however, has experienced E/C to a greater degree. The difference in the ! , E/C rates between the two units is due specifically to unit design , differences. The assessment also concluded that the licensee's E/C inspection program to date, has been effective in identifying system ' degradation due to E/C.

In addition, the high repair and replacement rate noted by the inspector during the review of the Unit 2, 90-Day ISI Report was the result of conservative engineering. None of the i components replaced or repaired had reached their calculated service , life span.

Within the areas examined, no violation or deviation was identified.

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l 4.

Licensee Corrective Action on Previously Open Inspection Findings f (92701) Units I and 2 ! a.

(Closed) Unresolved Item No. 50-321,366/92-25-01,"Significant l Examination Differences" i The licensee's re-examination of Weld No. 2-E41-2HPCI-10-D-27 using the examination criteria delineated for the 1st Interval ISI ! examinations revealed that an examiner could have concluded that there was no recordable indications in this weld based on the.

l indications amplitude, and position. However, the SNC committed

to re-examine this weld during the 'next (Spring 1994) outage of Unit 2 to insure that the indications are not service induced.

? During the inspector's exit meeting this item was discussed with plant management. The inspector expressed the concern that field surveillance inspections of vendors should be performed by the , licensee to identify items such as identified by the inspector in ' this report. Management acknowledged the inspector's comment however, no commitment was made by the licensee at this time.

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(0 pen) Unresolved Item No. 50-321,366/92-25-02," Improper l Certification of Welding Materials" l The inspector was unable to close this item because the licensee j scheduled response to licensing is not due to be complete until

August 7, 1993. The un-timeliness of this reply was discussed l with senior management in the exit meeting.

j c.

(0 pen) Inspector Follow-up Item 50-321,366/92-29-02," Inspection of Shroud Pcess Hole Covers" ! This item was issued to track the licensee's commitment to re-examine the shroud manway covers during the present outage for ' Unit I and during the Spring 1994 outage for Unit 2.

The inspection however, will not be applicable for Unit I because the licensee intends to replace the manway covers on Unit I this outage with a non-welded design manway cover. Discussions with the licensee concerning the Unit 2 manway covers revealed that GE could not use the non-weld design manway covers on this unit because of difference in plant design. Therefore, this item will remain open until a replacement is found for the Unit 2 manway covers next outage or the installed manway plates are t re-examined.

I Within the areas examined, no violation or deviation was identified.

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Exit Interview The inspection scope and results were summarized on April 2, 1993, with those persons indicated in paragraph 1.

The inspector described the areas inspected and discussed in detail the inspection results listed below.

Proprietary information is not contained in this report.

Dissenting comments were not received from the licensee.

6.

Acronyms and Initialisms ASME - American Society For Mechanical Engineers B&PV - Boiler and Pressure Vessel Code CHR - Containment Heat Removal System ECC - Emergency Core Cooling System - E/C - Erosion / Corrosion EDM - Electrical Discharge Machining EPRI - Electric Power Research Institute GE - General Electric GERIS - General Electric Reactor Inspection System GPC - Georgia Power Company ISI - Inservice Inspection MSIP - Mechanical Stress Improvement Process No.

- Number NRC - Nuclear Regulatory Commission NRR Nuclear Reactor Regulation - PT - Penetrant Testing PRC - Plant Review Committee QC - Quality Control RHR - Residual Heat Removal System RL - Refracted Longitudinal RWCU - Reactor Water Cleanup System SAER - Safety Assessment Engineering Review SER - Safety Evaluation Report SNC - Southern Nuclear Operating Company UT - Ultrasonic Testing i }}