IR 05000324/1989043
| ML20005E482 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/14/1989 |
| From: | Blake J, Robert Carrion, Economos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20005E481 | List: |
| References | |
| 50-324-89-43, 50-325-89-43, NUDOCS 9001050314 | |
| Download: ML20005E482 (14) | |
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Sa nae UNITE] STATES -
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o NUCLEAR REGULATORY COMMIS$10N l-p
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REGION 11 i-g j
101 MA RIETT A $T R E ET. N.W.
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ATLANT A. GEORGI A 30323
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I Report Nos.: 50-325/89-43 and'50-324/89-43 Licensee:
Carolina Power and Light Company l
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P. O. Box 1551
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Raleigh, NC 27602'
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Docket Nos.:- 50-325 and 50-324 License Nos.:,DPR-71 and DPR-62 i
b Facility Name:
Brunswick 1 and 2
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Inspection te :
e ber 13-27 and 27-30 and December 1, 1989 i
Inspecto s.
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Approv d by-4 /
M J. J Make, Section Chief Date Signed t ials and Processes Section n ineering Branch Division of Reactor Safety i
SUMMARY Scope:
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.This routine, unannounced inspection was performed as a followup effort to
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l-those documented in Reports 89-33 and 89-35 in order to observe recirculation pipe replacement activities including welding, nondestructive testing, and
' review of licensee action (s) on previously identified inspector findings.
l Results:
l During the first week of this inspection, the inspectors observed that welding and QC personnel employed by GE. were not observing certain specification /
procedural requirements associated with machining and welding on nozzles. This l
was evidenced by (1) a failure to maintain up-to-date complete and accurate
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production welding records, (2) a failure to weld in accordance with code and applicable procedure requirements, and (3) a failure to follow postweld heat treating procedure requirements.
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This performance resulted in three non-cited violations (NCVs), 324/89-43-01, L-02, and -03 paragraphs 2.a and 2.b.
These violations meet NRC Enforcement Policy for not issuing a Notice of Violation and are not cited.
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9001050314 891221 DR ADOCK 050
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' On. the: second and final-week of this inspection,. the lead inspector observed
'l that significant changes had taken place which were culminated by GE's
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- self-imposed work-stoppage resulting' in increased online QC personnel,. field i
supervision, engineering surveillance and training.
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REPORT DETAILS 1.-
Persons Contacted.
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Licensee Employees
- C, F. Blackmon, Operations Manager E. Betz, Level III Examiner, Corporate
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T. W. Gillman, Mechanical Engineer, NED c
R. Hanford, Manager, Material Engineering, NED P
- J. L. Harness, General-Manager, BNP
- R.- E. Helme, Manager, Technical Support
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- J. R. Holder, Manager, Outages and Modifications
- L. E. Jones, QA/QC Manager
- R. Jordan, Project Manager, Recirculation Pipe J. A. McKee, Manager, Quality Control T. Pitchford, Lead Engineer, Recirculation Projects
- R. M. Poulk, Supervisor, Regulatory Programs
- R. L. Warden, Manager, Maintenance General Electric, Nuclear Plant Services P. Briggs, Regional Manager, QA
- G. W. Rowe, Principal Engineer C. Vanderpass, Welding Specialist Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personnel.
NRC Resident Inspectors
- W. Levis, Resident Inspector
- D. Nelson, Resident Inspector
- W. Ruland, Senior Resident Inspector
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2.
Replacement of BWR Recirculation Piping - Unit 2 (2513/12)
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a.
Nuclear Welding (55050)
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Inspection Report 89-35 discussed the welding program associated with
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this pipe replacement.
Items discussed included qualification of l
welding procedures and welders, control procedures, and travelers
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and subtier documents used to record hold points, milestones, etc.
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Applicable codes and standards for pipe installation, fabrication and testing were discussed in detail in the aforementioned report.
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the work effort which will be documented by the present report the
applicable code is ASME B&PV Code,- Section III,1986 Edition with
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1988 addenda.
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At the start of this inspection on November 13, 1989, the status of work was that all the risers had been cut and removed from the
drywell; cladding was being removed from the inlet nozzles; the sweepolets were being machined and weld prepped; riser extension pieces were being cut to size and weld prepped for welding to the new
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risers; and the new safe ends had been receipt inspected by the-licensee and turned over to GE for further processing / machining. At this time, the inspectors conducted a walkdown of the work. areas inside the drywell to observe the activity on the nozzles and
corresponding sweepolets on the ringheaders. Activities in progress at this time included machining, preheating' of nozzles prior to weld-butter application, and, visual and liquid penetrant examina-tions.
Through discussions and record review, the inspectors noted that rejectable linear indications had been observed in the clad in the bore of nozzle N2A adjacent to the machined surface. Nonconformance
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report (NCR) #5-4040-010 was generated by GE and work instructions with appropriate limits and QC hold points were issued to' remove and correct the problems.
Similarly, crack type indications, characterized as intergranular stress corrosion cracking were identified in the counterbore area of "J" sweepolet. NCR #5-4040-014
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was generated with appropriate work instructions to remove the indications, retest the area, and machine the required weld prep.
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Between November 14-16, 1989, the inspectors observed preheat and welding activities on inlet nozzles A, B, and C to verify that: work was conducted in accordance with weld travelers, and/or joie process control sheets (JPCS's), which were available at the work station; welding procedures and weld data sheets were at the work station; welding technique, sequence and heat-input, wire feed, travel speed and electrical characteristics were as specified; shielding gas flow, and composition was as specified; that welding equipment including power cables and gas liners were in good condition; and that preheat and interpass temperatures were being controlled to specification requirements.
Within these areas, the inspector noted the following:
Nozzle N2A:
Filler metal was issued to welding operator P-7982, but the materials did not appear on the weld log used to document welding sequence, filler materials used, and welding operator at the work station. Also, a change of wire spool / filler metal made prior to the start of the second weld layer had not been recorded.
(This omission was initially denied by the welding foreman who subsequently reversed his position after the inspector demonstrated by cotaparison with the
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i amount of material used on other nozzles, that a spool
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change had to have taken place).
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The inspector discussed these findings in detail-with p
site management and stated that a violation of failure f
to follow procedure (s) would be identified (NCV i.
324/89-43-01); however, because al'1 discrepancies
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described above were of minor safety significance and were corrected or corrective action was initiated
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prior to the close of this inspection, this NRC identified violation is not being cited because the criteria specified in Section V.A of the NRC Enforcement Policy was satisfied.
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Nozzle N2B:
The weld traveller showed filler metal issued to welding operators H-3613 and G-1776.
However, these welders did not appear on the weld log at the work station and, therefore, it could not be shown whether they had or had not welded on the subject nozzle.
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Also, the welding operator (s)
responsible for depositing passes 6 and 9 of the third 16yer did not appear on th.c welding log located at the work station.
This inspector finding is another example of NCV 324/89-43-01, discussed above.
During the nozzle bore cladding - operation and the deposition of the third layer on the subject nozzle, a
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weld head approximately 8" long, was made without the
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addition of filler metal.
On November 16, 1989, GE issued NCR #5-4040-013 to identify the problem as it had occurred and was discovered by the GE QC inspector.
In an effort to determine the root cause of the problem, GE interviewed the welding operators and welding foreman who had been at the work station during the time period of the problem. The GE report stated that the individuals involved admitted to experiencing equipment problems
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but denied performing any operation in violation of approved procedures. This incident and welding equip-ment problems experienced around the time that this l
bead was being deposited were not documented on the weld log at the work station.
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Because this onsite GE investigation failed to resolve the status of the field weld in question, GE communi-l.
Material Technology Center in San Jose, California and cated the problem to cognizant personnel at the
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implemented corrective measures to prevent the recurrence of similar problems.
These measures i
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included (1) inersase of foreman coverage to allow for
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three welding foremen, (2) provide an additional L
welding supervisor on site at all times, and g
(3) provided an additional welding engineer to help
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perform surveillance of the welding program, i
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By memorandum dated November 20, 1989, from G. M. Gordon to G. Rowe, GE accepted the proposition
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that a portion of the weld bead was remelted without the normal feeding of filler metal and acknowledged the possibility of a slight variation in the dendritic u
structure and the ferrite content, due to differences in the cooling rate between the two conditions.
Further, the' letter stated that there was no
' technical reason to expect that the remelted weld metal would be structurally different from the original deposition.
In conclusion, GE's position was that the area of the weld, that was rewelded without the addition of filler metal, was metallurgically and structurally sound, and therefore, suitable for the intended function.
The inspector discussed this issue in detail with site management emphasizing that although this problem was the. result of improperly operating welding equipment, the real responsibility rests with GE's site management for. f ailure to provide the necessary supervision, instruction and controls to prevent such problems. The inspector informed the licensee that welding without filler metal was a violation of ASME Code Section IX QW-404.14 and the applicable weld procedure specification (WPS) 8.3.11W Rev. 3.
This was identified to the licenses as NCV 324/89-43-02 because:
it had been identified by the contractor /
licensee; a metallurgical investigation showed that the condition would not compromise the structural integrity of the subject nozzle; and corrective actions were implemented to help prevent the recurrence of such problems prior to the close of this-
inspection; thus satisfying the criteria specified in Section V. A of NRC's Enforcement hiicy.
Nozzle N2C:
Improper alignment of machining equipment caused uneven material removal from the face of the subject nozzle between the 8-12 o' clock positions.
In this quadrant, the cladding was machined down to bright e
metal while the weld deposit on the remaining section of the nozzle had been untouched. Work had stopped when the inspector observed the conditions described.
Concerns over the failure to properly center the
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were expressed to licensee management.
Following an i
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investigation, it was learned that the root cause of
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the problem rested with inadequate adjustment features,
on the machine in use.
The inspector questioned how c
this performance could be acceptable to the licensee and asked if the machine in question would be modified E
or replaced. The licensee indicated that the latter would be done.
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In addition to the above, the inspectors reviewed information type radiographs taken of nozzles A, B, and C base metal, between _ the counterbore and the weld prep, following removal of cladding from the ID. The radiographs were free of code rejectable indications.
On' November 27, 1989, the lead inspector returned to the site to
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continue to monitor production welding activities and nondestructive testing results. Upon arrival, the licensee provided the following work progress status:
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'A' Nozzle -
Completed final weld prep and RT'O.
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'B' Nozzle -
Continued pWHT, following breakdown of heating Coil.
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'C' Nozzle -
On Hold because of RT identified, rejectable indications in weld-butter.
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(4)
'O' Nozzle -
PWHT in progress.
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'E' Nozzle -
Fitting-up of sacrificial ring.
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'F' Nozzle -
RT of naked nozzle found acceptable.
Attached Thermo couples for preheat.
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'G' Nozzle -
Completed hot notch and face back machining
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operations, (8)
'H' Nozzle -
Continued corrosion resistant ' clad (CRC) weld, s
welding 5th layer.
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'J' Nozzle -
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'K' Nozzle -
RT of naked nozzle found acceptable. Waiting on available cooperheat coils to commence preheat.
Also at this time, the licensee stated that during the weekend of November 18, 1989, GE stopped production welding, and restructured the working hours to two, 10-hour shifts. The craft were divided in two crews of five welders each per shift and assigned one supervisor per crew.
Welding in process observed and/or monitored by the inspector was as follows:
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Riser to Extension / Prep Welds
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"A" Riser, FW-802 Observed Fitup, root pass, i.e.,
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consumption of insert, hot pass and weld-out of remaining joint.
Root pass radiographed
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Completed weld,
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radiographed and accepted. Commence grinding for ISI examination.
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"C" Riser, FW-805 Observed - Fitup, root pass and hot pass and monitored the completion of the remaining joint.
Root pass radiographs were satisfactory.
"E" Riser, FW-808 Observed - Root and hot pass deposition along with portions of two additional passes.
This weld was completed and was being radiographed for code acceptance at the close of this inspection on December 1, 1989.
For these welds the inspector reviewed field weld travelers and verified weldirg parameters such as described earlier in,this report.
Welding and Thermal Treatment of Nozzles
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"H" Nozzle Observed welding of corrosion resistant clad (CRC) and weld buttering.
"G" Nozzle Observed welding of weld buttering, welding of sacrificial ring.
"N" Nozzle Observed welding of CRC welding.
As discussed earlier, the inspector reviewed field weld travelers, JPCS's and other subtier records to verify that welding parameters such as described earlier in this report were consistent with procedural and code requirements as applicable.
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Postweld Heat Treatment Particular attention was paid to postweld heat treating (PWHT)
requirements.
This interest was attributed to the tight thermal tolerances and requirements established to control heat-up/ ramp-up rates and the soak temperature ranges.
According to heat treat procedure, CPL-15 Rev. 1, the ramp-up rate was not to exceed 200 F/hr and 140'F, in any 10-minute interval during the heating and cooling above 800 F.
The soak temperature was set at 1050'F i 50'F with the proviso that every effort be made to maintain the temperature to the high side of the 1050*F to 1100 F range during the soak period.
Nozzle geometry, coupled with the use of an EPRI recommended technique for PWHT these nozzles, caused some difficulty with temperature control.
The technique used, called for indirectly heating the nozzle by driving heat through the sacrificial ring / prep
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P which was welded to the nozzle.
The proximity of the clad to the
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thick section of the nozzle, meant that both the thin and a thick portion of the nozzle section had to be brought up to the soak range
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without violating heat-up rates and that the temperature be
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maintained at the soak range by regulating heat input to bring the heavy nozzle section into the soak range without overheating the thin
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section of the nozzle near the weld.
Tha inspector followed closely the - preheat, prep,,interpass and postweld heat treatment of the subject nozzles, reviewed strip charts,. equipment calibration, quality records and personnel qualifications.
Within these areas, the inspector noted that in order to alleviate the described problem, GE recommended and the
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licensee approved, raising the lower end of the soak temperature range to 1050'F and the tolerance from 150'F to 100 F.
This was to be implemented through a Field Revision Request to the heat treating procedure CPL-15. Also, the inspector noted that three of
the ten nozzles, A, B, and C had been successfully PWHT, although some minimum temperature range problems were experienced with Nozzle B.
Other nozzles where problems were encountered included D, F, and G.
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"D"'s PWHT was aborted because of heating element (s)
breakdown. Nozzle "F" did not make it because of failure to maintain the minimum temperature requirements. On December 1,1989, prior to starting the heating-up for PWHT of nozzle N2G, the contractor, Cooperheat, Inc., load tested the PWHT equipment with the - heating
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l elements on the subject nozzle. While this test was in progress, the operator left the equipment unattended to respond to a heating i
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element failure on N20 nozzle. During his absence, a period of about
30 minutes, the temperature of the N2G nozzle rose from about 120'F
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to 640'F. Because this heatup rate violated that specified in CPL-15 (200 F/br), the licensee issued NCR number 5-4040-033, Rev. O, dated December 1, 1989. For leaving the equipment unattended, the licensee dismissed the two individuals responsible for the violation and took immediate preventative / corrective actions.
These included the stationing of a QC inspector on a continuous basis at the Cooperheat power supply and control panels to monitor all thermal treating activities and, requested that Cooperheat supply additional supervision to cover these activities. The inspector discussed this matter in detail with site management and stated that a violation for failure to follow procedure would be identified (NCV 324/89-43-03);
however, because all discrepancies described above were of minor safety significance and were corrected or corrective action was initiated prior to the close of this inspection, this licensee identified violation was not being cited because the criteria specified in Section V.A of the NRC Enforcement Policy was satisfie [*
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Review of In-Process Radiographs
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In an effort to assure weld quality and minimize repairs following
weld completion, the licensee has established certain in process hold points where welds are radiographed for information purposes.
One'of the hold points requiring radiography precedes PWHT, following weld-buttering.
The inspector reviewed radiographs taken at this point for nozzles N2A, N28, N20, and N20.
Another hold point
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requiring radiography, for similar purposes, follows weld prep
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machining af ter PWHT. Radiographs which had been shot at this point included nozzles N2A, N20,_ and N2F.
Of these three welds, radiographs of N2C nozzle depicted three very small but rejectable
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linear type indications which were believed to be lack of fusion located between adjacent weld beads.
The weld was nonconformed and preparations were made to remove the indications and repair the weld.
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Following completion of this inspection, the licensee telephoned to
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inform the inspector that a similar condition was identified in
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nozzles N2B and N20.
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Except for the three NCVs discussed above, no other violations or deviations were identified.
3.
Licensee Action on Previously Opened Items (92701)
(Closed) Unresolved Item 87-18-02,
" Approval of Overlap Modeling Technique" l
This item deals with an analysis technique utilized to reduce a model which is too large for a given computer into partial models by including a common, or ' " overlapped", section within the associated partial models.
Industry practice over the past twenty years has varied significantly and a uniform method of analyzing overlapping analytical models was not a
developed.
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The NRC concern was that UE&C Procedure DEDP-2607 used for computerized piping analysis in the Brunswick Stress Analysis Problems did not meet the modeling criteria established in NUREG/CR-1980, BNL-NUREG-51357.
Per NRC i
Inspection Report 87-18, dated July 21, 1987, the licensee was requested l
to resolve the issue by taking one of the following actions:
l (1) Submit a complete report, including theory, development, process, two complete examples for comparison with NUREG/CR-1980 r
BNL-NUREG-51357 output, and explanation of results, to NRR for approval.
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(2) Recalculate the stress analysis based on the NUREG for all lines where the UE&C Overlap Modeling Technique was used.
I (3) Show that the UE&C Overlap Modeling Technique was approved by NRR for another licensee and provide the reference.
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The licensee commissioned UE&C to do Study Report No. 7992.001-5-M-037 to
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identify / review the previous stress analyses which utilized overlap analysis models and determine the adequacy of the supports located within the overlap zones. The report identified a total of 18 overlap models,
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categorized as 16 Main Run Overlaps and 2 Branch.Run Overlaps. Two of the models are for the RHR-Systems, while the other sixteen are for the i
Instrument Air System.
The report explains the methodology adopted, presents four. examples using the technique, and summarizes the results.
However, the licensee later decided to analyze the identified lines without using overlaps, i.e., as large continuous systems, in the case of
the RHR System.
For the Instrument Air System, the licensee has implemented Plant Modifications87-169 and 87-170, for Units 1 and' 2,
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l respectively, to install a pneumatic nitrogen system to act as a backup.
With the addition of the pneumatic nitrogen system, the Instrument Air System has been downgraded to a Non-Q, Non-Seismic system, although a i
seismic analysis was done for several isos to protect the containment
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boundary. A final analysis for the majority of the identified isos has
been completed without using the overlap technique and the remainder, except for one case, will be completed as part of the licensee's Piping
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Design Turnover Program (DTOP), expected to be finished in 1991.
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noted exception is the case where the Unit 1 isometric sheets 682 and 733 have been split into two independent systems upon the implementation of
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Plant Modification 84-195, the installation of the backup pneumatic nitrogen system.
l Therefore, the actions taken by the licensee in reanalyzing the identified lines without using the overlapping technique render this Unresolved Item f
moot and.it is considered to be closed.
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(Closed) Unresolved Item 88-36-04, " Accuracy of As-Built Phase II Piping System Walkdown Verification"
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The inspectors discussed the status of the Walkdown Verification Program with the Quality Control Supervisor. The program is on schedule. All
Unit 2 walldowns are now complete. Minimal effort has been expended on
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Unit I to date but will begin in earnest in Spring 1990 with the Unit 1 refueling outage.
To assure program continuity as well as to reduce l
required personnel training, the same crews who did the Unit 2 walkdowns
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will do the Unit I walkdowns.
Therefore, because the licensee has an ongoing program concerning this issue, this item is closed.
(0 pen) Inspector Followup Item 88-36-02, " Final Safety Summary Report for IEB 79-02" (0 pen) Inspector Followup Item 88-36-03, "Hilti Anchor Bolt Allowable l
Review and Justification per IEB 79-02, NRC Information Notice Nos. 86-94 and 88-25" These two IFIs will be addressed simultaneously in the same report because they are so closely related. Originally expected to be completed by this
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fall, the priorities were adjusted so that those associated with the
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IO Unit 2 : outage became more important.
Licensee commitments were made to resolve these issues by April 30, 1990.
Therefore, pending licensee issuance and NRC acceptance of the report,'these items remain open.
(Closed) Inspector Followup Item 88-36 05, "QA Auditing of the Supports in As-Built Phase II Piping System Walkdown Verification Program and the Modified Systems with QC Inspections"
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The inspectors held discussions with the Manager of QA Engineering to L
determine program status and - activities.
The program is currently somewhat more comprehensive than originally envisioned and will be a
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p valuable tool for Engineering and Management for future support installation / inspection.. Its focus is the engineering / technical basis for the final design packages, including drawing review.to ensure that L
critical attributes (such as welds, dimensions, notes, etc.) were considered; calculation. review. to ensure that appropriate design
methodology (such as design basis, allowable stresses, engineering i
,iudgement, etc.) was used; and review of other relevant information, as provided.
It is noted that this review will not constitute a c
re-inspection of the support. However, field observation of the support will probably be part of the drawing review.
The size of the sample of final design packages to be reviewed has been statistically determined to bel 24 and the specific packages were randomly selected. Currently, of the design packages selected, only five supports are in progress.
While several small discrepancies have been noted,- no major discrepancies were found. - The next design packages will be reviewed upon the completion of the Unit 2 refueling outage, The licensee QA program appears to be well designed and is being implemented.
In that continued review of. these efforts are part of the routine inspections of this area the item will be closed.
4.
Independent Inspection Effort a.
The inspectors reviewed licensee efforts in the areas of HPCI valve alignment modification and Service Water valve modification as follows:
I HPCI Valve Alignment Modification
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The inspectors learned that the Unit 2 HPCI System was being j
modified during this outage such that the E41-F006 valve is
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being relocated outside the MSIV pit and a new 14" ASME l
Section III Class I check valve (E41-V159) is being installed where the F006 valve had been.
In addition the F006 valve is being replaced by a new double disc gate valve. Completion of these activities will result in the following:
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For the E41-F006 valve:
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j Improved reliability because it will be located in a less
harsh environment and would allow for increased access to,
the valve for manual operation, if necessary.
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i Correct the thermal binding potential and reduce the
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required torque for the valve motor operator, thereby i.
reducing the required DC motor size and corresponding DC l.
loads on the battery following a LOCA or loss of Off-Site l
Power.
I For the E41-V159 check valve:
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Removal of a potential source for violating the environ-
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mental qualification of safety-related equipment located inside the Reactor Building by preventing the backflow of hot feedwater, which could cause thermal transients on the HPCI valves and piping.
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Isolation protection of the Reactor Building environment from a potential High Energy Line Break (HELB) regardless of the position of Valve E41-F006.
The inspectors reviewed Plant Modification 87-260 for the Safety
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Analysis and Safety Evaluation as well as the associated Stress Package, which included Calculation No. 87-260-01 and Isometric Drawing F-02846, Sheet 17, Revision P0, dated August 1,1989.
All documentation appeared to be adequate for the work being done. Plant Modification 87-259 has been prepared for Unit 1 and will be implemented during the next Unit I refueling outage, b.
Service Water Valve Modification The inspectors learned of a modification to the Unit 2 Reactor Building Closed Cooling Water (RBCCW) Heat Exchanger Supply valve, SW-103, in that a motor operator was being added to the valve which had previously been manually operated.
Upon reviewing Plant Modification 89-049, it was noted that this action is one of several e
being undertaken to upgrade and ensure that the Service Water System performance meets the parameters established for the design basis accident.
Licensee evaluations of the system determined that the single-failure criteria analysis for safety systems was not adequately met and that the Service Water Pump performance characteristics could not ensure reliable pump performance during a
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worst case scenario of the design basis accident.
The addition of the motor operator to the SW-103 valve will give it the ability to stop valve closure at a throttling setpoint position. In combination with the SW-106 valve, which is immediately downstream of SW-103, an adequate flow path to prevent overload of the pump motor thrust
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bearing is ensured when two pumps are in operation as well as ensuring adequate restriction to prevent operation of the pump in a
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-run-out condition by reducing supply to the RBCCW heat.exchangers
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'when' only a single pump is running. _ Also, because the addition-of t
'
[-
.the motor operator to Valve SW-V103 utilizes the same logic as Valve
!
SW-V106 but is powered from the other,(Division II) E buses, reduced
'!
service water supply to the _ RBCCW heat exchangers during a LOCA-is
,
F ensured, thereby satisfying single-failure criteria analysis i
. requirements. -The inspectors also reviewed the associated stress
!
,
,
calculations, No. 89-049-02, Revision P0, dated May 26, 1989.
They
'
e appeared to be acceptable.
Plant Modification 89-048 has been
,
completed for Unit I and will be implemented during the upcoming
.
L refueling outage.
l
,
f 5.
Exit Interview The inspection scope and results ' were ' summarized on November 17 and r
December 1, 1989, with those persons indicated in paragraph 1. - The
inspectors described.the areas inspected and discussed in detail Lthe
'
inspection results listed below. Proprietary information is not contained
r in this report. Three NCVs, 324/89-43-01,--02, and -03 were_ identified
(paragraphs 2.a and 2.b) for:
(1) failure to maintain _up-to-date, e
e l-complete and accurate production welding records; (2) failure to weld in
~
accordance with code and applicable welding procedure requirements; and
(3) failure to follow postweld heat-treating procedure requirements, i
!
However, these violations meet NRC Enforcement Policy for not issuing a
!
f Notice of-Violation,- and therefore, are not cited. Dissenting comments
!
'
were not received from the licensee, i
t-
.;
I)
-
!
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=
,
-
u
,
_
.