IR 05000324/1993013
| ML20035D366 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/24/1993 |
| From: | Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035D359 | List: |
| References | |
| 50-324-93-13, 50-325-93-13, NUDOCS 9304130129 | |
| Download: ML20035D366 (10) | |
Text
{{#Wiki_filter:J ' [p # 4(4[of t UNITED STATES NUCLEAR REGULATORY COMMISSION & 9-o REGION 18 $ M, ,$ 101 MARIETTA STREET, N.W.
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{{ 1" ATLANTA, GEORGI A 30323 ! ,
%.".#...# APR S 1993 Report Nos.: 50-325/93-13 and 50-324/93-13 , i Licensee: Carolina Power and Light Company
P. O. Box 1551 Raleigh, NC 27602 Dockets Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: March 8-12, 1993 S..M.
%J.L.Coley b. _ J-a3-73 \\
Inspector: - Date Signed Approved By: J /J. Blake, Chief Da'te Signed ((aterials and Processes Section Engineering 3 ranch Division of Reactor Safety SUMMARY Scope: - This routine, announced inspection was conducted in the areas of welding, < erosion / corrosion, and previously identified inspection findings.
! Results: i Although, all corrective actions on programmatic welding discrepancies
identified by the licensee have not completed, significant improvements were i noted in the area of welding.
l A review of the licensee's erosion / corrosion (E/C) activities for Units 1 and ' 2 revealed that the licensee's program has been effective in controlling the effects of E/C for the both Units and that this issue should not be a factor for Unit 2 startup.
Corrective actions taken by the licensee on previously identified inspector findings were also found to be satisfactory.
In the areas examined, no violations or deviations were identified.
9304130129 930405 PDR ADOCK 05000324 G PDR .- - -. _ - - - - -- -
. _ _ _ i i ! i REPORT DETAILS l ti 1.
Persons' Contacted ! Licensee Employees } !
- J. Crider, Manager, Inservice Inspection (ISI)
- T. Eason, Supervisor, Quality Control-
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- R. Godley, Manager, NRC Compliance
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- P. Godsey, Senior Specialist, ISI
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- M. Kirkland, System Engineer
- J. Langdon, Supervisor, Nondestructive Examination (NDE)
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- J. McGowan, Specialist, Regulatory Compliance
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- D. Meleg, Corporate NDE i
- R. Morgan, Plant Manager, Unit 1 i
- J. Parks, Manager, Projects l
- G. Spry, Project Welding Engineer
- E. Willett, Manager, Outage Management and Modifications i
i NRC Resident Inspectors ! !
- R. Prevatte, Senior Resident Inspector j
D. Nelson, Resident Inspector .i
- Attended exit interview i
Acronyms and initialisms used throughout this report are listed in the ! last paragraph.
, 2.
Review of Welding Activities Units 1 and 2 (55050) This audit of welding activities was conducted as a followup inspection ] to the December 28-31, 1992, reactive inspection reported in NRC , Inspection Report No. 50-325, 324/92-47. The objective of this j , inspection was to review corrective actions taken by the licensee and to ' determine by direct observation whether these corrective actions had i been fully implemented.
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Background
During the second quarter of 1992, surveillances performed by CP&L's Quality Control organization identified significant discrepancies in the welding program at the Brunswick facility.
- i ' The discrepancies included welders working to verbal instructions, ' ! ' inadequate welding controls, improper welding techniques being used, and inadequate control of welding filler materials.
Later, on August 17, 1992, welding program deficiencies affected in-process work activities when a welder improperly used stainless steel filler material on the copper-nickel 2B Residual Heat
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I . Removal Service Water Pump Discharge and immediately observed the weld crack.
The licensee subsequently obtained the services of an outside consultant to independently assess Brunswick's welding program.
The assessment identified weaknesses in the areas of welder ' training on procedural requirements; improper brazing procedure qualification; weaknesses in material control procedures;
inadequate control of welding materials; weld requisition reports ! improperly filled out; and welders not qualified for the process i or welding procedure specification which they were assigned.
On December 15, 1992, a Brunswick welder used a carbon steel weld rod to weld a stainless steel clip to a carbon steel support tube.
] This was done in the welding shop. The error was caught by the welder when he noted a " golden tint" to the base metal. The
welder's foreman also recalled that two such clips had been
installed in the Unit 1 drywell.
These clips had been inspected and accepted by quality control.
The error was discovered to be . that engineering had incorrectly called for the use of the t'rbon steel rod.
! On December 17, 1992, the licensee issued a "Stop Work Order" on
all welding activities until in-process work packages could be reviewed to ensure that the packages contained the correct
instructions, correct materials were being assigned to be used, and that the welders were qualified for the welding procedure , specification assigned. The "Stop Work Order" was lifted by ! ' management on December 18, 1992.
On December 28, 1992, the inspector arrived at the Brunswick site to evaluate the licensee's corrective measures taken in response to the identified welding discrepancies. The inspector's review of welding activities and the licensee's audit findings revealed that programmatic weaknesses in welding were due to inadequate _ supervision of the welding processes, lack of formal training on , procedural requirements for welders and supervisors, and ineffective filler material controls.
, The inspector was satisfied that immediate corrective actions , taken by the licensee, and close management over-sight, could adequately control materials and welding processes until all audit activities conducted by the licensee were complete and long-term permanent corrective actions could be initiated.
In addition CP&L's Nuclear Assessment Department (NAD) was scheduled to conduct a seven man two week audit of welding , starting January 4th thru January 15th,1993, and the results of I this audit was anticipated to further identify programmatic ! problems in welding which the licensee would need to address in their permanent corrective action.
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Review of Audit Findings, Corrective Actions Taken, and Revisions j to Welding Procedures.
The inspector's review started by examining the'NAD audit performed at the Brunswick Nuclear Plant (BNP) during January 1993. This assessment of plant activities was to determine the following: i
The adequacy and effectiveness of BNP in implementing the
Corporate Welding Manual.
The effectiveness of the Corporate Welding Manual.
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The organization in place to control and monitor
activities conducted under the corporate welding program.
The depth and nature of the problems in the welding area.
- The match between problems identified and the resultant i
corrective actions implemented and planned, The result of the team's assessment was that BNP was considered effective in controlling special processes.
However, the i following five issues and one weakness were identified for
improvement.
It should be noted that issues identified for ' improvement were based on best practice rather than minimum l acceptance standards implemented by requirements. Therefore, l identification of an issue for improvement did not necessarily l indicate unsatisfactory performance; i Documentation needed to identify base materials necessary ! '
for planning a welding activity is not always available l l (particularly applicable to plant maintenance).
Management has not been effective in monitoring for, l
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identifying, and responding to problems in the conduct of , welding and special process activities.
The September 1991, assessment of the Technical Services
, l Department activities (Report No. 0130-91-01) did not l address long-standing weld material control problems at BNP.
This was the last formal assessment of special process I activities at BNP by NAD.
Initial and continuing training on Corporate Welding Manual .
and. site procedures which govern special processes is not l adequate.
Work packages are not comprehensive, complete or user i
friendly.
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. Weaknesses; Observation of the filler metal storage area at-
the main tool room revealed poor organization of the storage bins.
The inspector's evaluation of the licensee's assessment was that i it did not contain any new information.
Each of the above issues i had been identified by the licensee previously in 1992, and therefore, was expected to be corrected as part of the licensee's j ongoing permanent corrective actions.
! The inspector also reviewed the following documents: QC Assessments for 1993, (Corrective actions completed and those
still in-progress;) Corporate Welding Manual procedure revisions; and BNP's new welder / supervisor / weld station attendant general welding training work package.
This review also included a review of training rosters to ensure that all welders / supervisors and weld station attendants listed as qualified had received this j needed training.
l Document ID Document Reviewed ' B93-002QC Assessment of Plant Activities l (Audit of Filler Mat'l Storage, welding - equipment operation, and inprocess welding) ! B93-004 QC Assessment of Plant Activities (Audit of Control of Covered Electrodes) B93-007 QC Assessment of Plant Activities (Assessment of welder training) NW-03 Rev. 3 CP&L's Corporate Welding Manual . Procedure for Welding Material Control l NW-02 Rev. 3 CP&L's Corporate Welding Manual Procedure for Qualification of Wclders and Welding Operators Draft Reply BNP Proposed Corrective Actions to the NAD's l
Audit No. B-SPP-93-01
' ACR-B-92-826 Short Term Corrective Actions to Adverse c Condition Report (Fact No 92B826B) ACR-B-92-826 Corrective Actions to Adverse Condition Report
~(Facts No. 93B9006) j i ' ACR-93-035 Adverse Condition Report on failure of Welding Instructions to Include Fit-Up QC Hold Points as Required By BSEP SPEC. 048-10 ACR-93-069 Adverse Condition Report on NAD Issue , .. . . -. - - -. \\
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. The inspector's evaluation of the corrective actions identified in f the.above documents, and the impact of their implementation, as l reported in paragraph 2.b below, indicate that the BNP welding i program has been significantly. enhanced. However, continued l effective training, objective QC surveillances, and aggressive
management will also be needed to ensure its long term success.
! , b.
Observation of In-process Welding Activities - ! The inspector examined the folbwing areas and activities to i determine, by direct observation, whether welding activities are
performed in accordance with Section IX of the ASME Code. Areas examined included BNP's welding school, the central tool room rod issue station, the clean maintenance shop, and the Unit 1 Reactor ! Building.
l The inspector was impressed by the licensee's enhancement of the l welding school. The entire welding school had been remodeled and organized for efficiency. The weld issue station in the welding school was excellent, with all welding materials and tools - properly identified and segregated.
, The rod issue station which had been located in the central tool ! room had been moved to a separate room within this building. The j inspector's examination found that rod issue and materials
controls for this station was also very good. The rod issue ! attendant was-interviewed at length concerning his , , responsibilities for ensuring proper material controls. This
interview revealed that recent training conducted at BNP for .I welders, rod issue attendants and supervisor appeared to have been , well understood by the attendant.
The inspector also reviewed 6 weld material requisitions to l determine if the proper information had been filled in the ' appropiate blanks and if signatures on the form were those of
individuals certified to sign.
The inspector observed the following in-process welding to
determine whether these activities were in accordance with the r licensee approved procedures; Component No.
Modification No.
Descriotion 1-M21-P005 92-070 Rack 1-H21-P005 ! Conduit Support i PS-8080 91-041 Containment Atmosphere ' Control Support . CS-9104-C-1519 91-041 Conduit Support Control Building
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, ' i As a result of the above observation of welding activities, and material controls in affect during the observations, the inspector concluded that welding activities at BNP are presently being
conducted in an effective-manner. Continued progress by the licensee in this area will be reviewed during a subsequent i inspection.
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Within the areas examined, no violations or deviations were identified.
3.
Evaluation of Erosion / Corrosion Activities for BNP-Units 1 & 2 (49001) [ The E/C program for two-phase piping at BNP started with the 1985 examinations of fifty-four sites on twenty-seven lines on Unit 1.
, Forty-five sites on twenty-six lines were subsequently examined on Unit ' 2 in 1986.
Both inspections were successful in detecting E/C in the piping.
In 1987, single phase piping was added to the E/C inspection programs.
In order to determine the effectiveness of the licensee's E/C programs, the inspector held discussions with the E/C engineer and i reviewed the following documents: j f Documer,ts Reviewed r Carolina Power and Light, BSEP Erosion / Corrosion Inspection {
Program: Engineering Procedure ENP-51, Rev.2 Carolina Power and Light Letter of Response to NRC Bulletin'87-01,
Serial No. NLS-87-181, Dated September 10, 1987
Carolina Power and Light Letter of Response to NRC Generic Letter l
89-08, Serial No. NLS-89-206, Dated July 10, 1989
. Erosion / Corrosion Inspection Results for 1991, Unit-2 Refueling l
Outage #9 l - s Erosion / Corrosion Inspection Results for 1990/1991, Unit 1 !
Refueling Outage #7
Erosion / Corrosion Inspection Results for 1989, Unit 2 Refueling , Outage #8 i . ' Erosion / Corrosion Inspection Results for 1988, Unit 2 Refueling
Outage #7 ,
Erosion / Corrosion Inspection Results for 1988/1989, Unit 1 j
Refueling Outage #6 ! i Erosion / Corrosion Inspection Results for 1987, Unit 1 Refueling !
. Outage #5 !
! The inspector's review of the licensee's E/C activities revealed that l . selection of components for inspection was based entirely on service
l conditions and industry experience.
Procedures implementing the program ! ! ! ! ! ! _ - - >
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were also minimal guidelines.
However, the licensee appeared to be taking the conservative approach of replacing piping with improved E/C
resistant materials on multiple trains and both units when erosion was , first detected.
This process of component replacement also allowed the sample size to remain small and still be functional. The sample of inspection sites selected each outage revealed a population-to-defect detection rate of approximately 10 percent. Repairs made during plant , ' operations using liquid sealant were also minimal.
Carolina Power and Light (CP&L) is presently in the process of upgrading l their E/C program.
In addition to drafting new programmatic procedures, ! all susceptible systems with piping above 21/2 inches have been modeled l , ' into the Electric Power Research Institute's (EPRI) CHECMATE computer i program. The recent modeling of systems revealed that each site
previously selected by CP&L for E/C examination was determined to be a ' minus T-Crit component by CHECMATE. This confirms that proper
components were previously selected for E/C examination and that concerns about E/C should not be a issue that would affect Unit 2 startup.
Within the areas examined, no violations or deviations were identified.
4.
Licensees Action on Previously Identified Inspection Findings - Units 1 & 2 (92700 & 92701) i ! ' (Closed) Violation 50-325,324/92-15-06, " Failure to Include Safety I Related Supports in ISI Program" !
! CP&L's Letter of Response Dated August 3, 1992, and Supplemental Letter of Response Dated March 2, 1993, were reviewed by the inspector.
The Inspector also reviewed the data previously omitted from the ISI
structural programs by the licensee, and their vendors.
Initiatives
' ' addressed in the Brunswick three year plan to insure that adequate audits of programs inputs are performed to prevent the recurrence of j this type of discrepancy were also reviewed. As a result of these reviews the inspector concluded that the licensee's corrective actions
are satisfactory.
Note: This item was a Unit 2 restart item.
, , i (Closed) Unresolved Item 50-325,324/92-47-01, " Material Control ' Weaknesses In Welding Test Shop" As described in paragraph 2.b of this report material control problems i , l have been satisfactorily addressed by the licensee for the weld issue i i stations in the weld test shop, the fabrication shop, and the central l tool room.
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{ (Closed) Unresolved Item 50-325,324/92-27-01, " Inservice Inspection ! j Program System Boundaries" I t The licensee's audit findings of the ISI programs system boundaries as ! l delineated in the licensee's response to ACR 92-696 revealed that only j one system, the penetration cooling system components upstream of valve j
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RCC-V186 should have been classified as ASME Class 2 in lieu of non-code.
Hydrostatic test requirements for the penetration cooling system were missed during the first 10-year interval because of the improper i boundary break.
It was the licensee's position, however, that the
, integrity of the penetration cooling system had been verified by the l ' completion of local leak rate testing (LLRT) which is performed ' simultaneously with the reactor building closed cooling water (RBCCW) system. The last Unit 1 LLRT was performed 11/13/92; while Unit 2 test > was performed 12/12/93. A visual leakage inspection walkdown was also l performed on the entire penetration cooling system as one of the initial conditions of the integrated leak rate test.
These tests indicated that ' the penetration cooling /RBCCW systems were essentially leak tight.
However, during the first 10-year interval a leakage test would not have { been an allowable substitute for the hydrostatic strength test.
j In 1991, the ASME Code issued Code Case N-498 which deleted the requirements for hydrostatic testing of ASME Class 1 and 2 systems.
CP&L has informed the NRC of its intent to use Code Case N-498 in letter l No. NLS-92-300, dated December 22, 1992.
The inspector was also shown a , draft letter to NRR which will report the 1st interval missed i hydrostatic tests and give details supporting CP&L's position that having missed the test did not compromised the integrity of the system
for interval 1.
' Based on the ASME Code's recent relaxed position on hydrostatic testing, and CP&L's in-process correspondence this item is considered closed.
' Within the areas examined, no violations or deviations were identified.
5.
Exit Interview l . The inspection scope and results were summarized on March 12, 1993, with
- l those persons indicated in paragraph 1.
The inspector described the ! areas inspected and discussed in detail the inspection results.
j j~ comments were not received from the licensee.
Proprietary information is not contained in this report.
Dissenting ! j ! ! l . ., ! -
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Acronyms and Initialisms i ACR - Adverse Condition. Report i ASME - American Society of. Mechanical Engineers . BNP - Brunswick Nuclear Plant-BSEP - Brunswick Steam Electric Plant
CP&L - Carolina Power and Light { E/R - Erosion / Corrosion ! ILRT - Integrated Leak Rate Test j ISI Inservice Inspection - . LLRT - Local Leak Rate Test l NAD - Nuclear Assessment Department i NDE - Nondestructive Examination l No.
- Number l Nos.
- Numbers i NRC - Nuclear Regulatory Commission l NRR - Nuclear Reactor Regulations QC - Quality Control
RBCCW - Reactor Building Closed Cooling Water system l i .
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