IR 05000344/1992033

Insp Rept 50-344/92-33 on 921207-11.No Violations or Deviations Noted.Major Areas Inspected:Licensee Erosion/ Corrosion Program Activities,Including Followup of Previously Identified Items

ML20127F585
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/29/1992
From:	Royack M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20127F567	List: IR 05000344/1992033 ML20127F563
References
50-344-92-33, NUDOCS 9301200296
Download: ML20127F585 (10)

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U.S. NUCLEAR REGULA10RY COMMISSION

REGION V

Renort No.: 50-344/92-33 Docket Np2: 50-344 License No : NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 facility Name: Trojan Nuclear Plant insAettion at: Rainier, Oregon ins.paction Conducted: December 7-11, 1992 Insoector: C. Clark, Reactor Inspector, Region V Angroved By: cs

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I2[d3h2, F. Royack,~ Acting Chief d Dat'e Sig'ned Engineering Section Inspection Summatv:

Jainttilgn_durina the period Decem j or 7-11. 1992 finigection Report N M-344/92-33)

Areas Inspected:

t l A routine inspection of the licensee's erosion / corrosion program activities L was conducted. The inspection included followup of previously identified ( items. NRC inspection proceduret, 49001, 92701 and 92702 were used as guidance

for this inspection.

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Safety Jigues Manaagment System (SIMS) Items:

l None Resulti:

Senerai Conclusions and Specific Findinas:

• The licensee had implemented an erosion / corrosion monitoring program consistent with their commitmer,ts to the recommendations of Generic Letter 89-08. The program appeared to be comprehensive and aggressiv ;

gDR ADOCK 05000344 PDR

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e The erosion / corrosion monitoring program appeared to have strong management suppor * Quality assurance involvement in the development and implementation of the erosion / corrosion monitoring program had been minimal until 199 Sionificant Safety Hattet:

None Summary of Violationi:

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None Op1D 112MI Summary:

There were no new open items identified. One open item (Section 3.1) was close _ _ - .__

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DETAILS, Persons Contacted 1.1 Eartland Generitt Electric

• D. A. Holly, Hechanical Engineer, Nuclear Plant Engineering

• J. Kent, Acting Manager, Surveillance and Test Engineering

• R. D. Machon, Plant General Manager F. J. Neimann, Nondestructive Testing-Level III, Surveillance and Test Engineering J. H. Pedro, Compliance Specialist, Nuclear Compliance

• S. H. Quennoz, Manager, Technical Services

• S. K. Sttdham, Erosion / Corrosion Outcge Coordinator, Surveillance 1 and Test Engineering

• T. D. Walt, General Manager, Technical Functions

• W. J. Williams, Manager, Nuclear Compliance D. H. Witt, Hechanical Engineer, Nuclear Plant Engineering 1.2 Oreaon Department of Enerov

• V. Sarte, Resident Inspector U.S. Nuclear Reaulatory Commission

• J. Helfi, Resident Inspector, Region V The inspector also held discussions with other licensee and contractor personnel during the course of the inspectio * Denotes those attending the Exit Meeting on December 11, 199 .0 insnection of ErosionlCorrosion o Monitorina Proarams (49001) Introdurtion The purpose of this inspection was to evaluate the licensee's long term erosion / corrosion (E/C) monitoring program to determine (1) if the program was being conducted in accordance with NRC guidelines established in Ger;eric Letter (GL) 89-08, " Erosion / Corrosion-Inducted Pipe Wall Thinning," (2) if the program was being conducted in accordance with licensee commitments and procedures, (3) if management control problems or generic weaknesses existed, and (4) if quality assurance (QA) or independent reviews of the program had been conducte Erosion / corrosion monitoring is generally conducted on non-safety related carbon steel piping. No unique regulatory requirements apply to the content of the licensee's progra .2 Program Description The inspector reviewed available documents and identified that in 1982 the licensee initiated a program for long term monitoring for pipe wall

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thinning due to E/C. The licensee developed the E/C program in response to a January,1982, Trojan extraction steam supply elbow failure. In 1985, the licensee incorporated the recommendations from the 1985 Electric Power Research Institute (EPRI) workshop on E/C. They also included information from their evaluation of a March 9,1983 rupture of a Trojan four inch diameter heater drain pump discharge pipe. In 1987, the licensee expanded the E/C program based on information contained in the Nuclear Power Operations (INPO) Significant Operating Event Report (SOER) 87-3, which provided detailed information on a Surry 1 pipe break event, and problems identified during the Trojan 1987 outag In 1987, the licensee contracted with Technicon Enterprises Incorporated to review the Trojan E/C program. Technicon completed the initial review and provided recommendations for program improvements in a report dated June 26, 1987. The licensee evaluated this Technicon information and included part of it in the Trojan E/C program. Later in 1987, Technicon completed E/C mlyses of selected Trojan systems using their own program. Trojan modified their program based on the Technicon analytical method prior to the 1988 outage. The licensee's current E/C monitoring program was described in Surveillance and Test Engineering Procedure (STEP) 30-40, Revision 1, " Erosion / Corrosion Monitoring Program," issued February 28, 1991. For single phase flow, STEP 30-40 used velocity, temperature, and geometry as tne primary factors to assess potential E/C problem areas. For two phase flow, STEP 30-40 used the product of the Keller's Equation wear rate and a component geometry factor to obtain a wear rate adjusted for geometry. This adjusted wear rate was then used in the same manner as with single phase flow to estimate wear period, project remaining service life, and determine examination priority and schedul As of December 11, 1992, the licensee had:

e Implemented their own program per STEP 30-40 for analysis of E/C in high energy piping systems and the service water system, o Performed E/C examinations of approximately 2434 components since ;

198 e Issue ( a contract to Altran Corporation for development and trial implementation of E/C CHECMATE analyses for the Trojan Pla These analyses were initially scheduled to be completed by February,199 e Prepared two new draft procedures, Revision 2 to STEP 30-40 and Revision 0 to Trojan Plant Procedure (TPP) 19-24, " Erosion / Corrosion Program," to reflect the nuclear plant engineering (NPE) involvement and responsibilities for controlling and implementing the E/C program. The corporate / site nuclear plant engineering department has responsibility for TPP 19-24 and the site surveillance and test engineering (STE) department hs responsibility for STEP 30-4 : -_

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Generic Letter 89-08 requested licensees to provide assurance that a _ "

program-had been implemented which consisted of systematic measures to-

. ensure that-erosion / corrosion did not' lead to degradation of single-phase-and two-phase-high-energy carbon steel systems. The licensee's_ July _21, 1989 response to GL 89-08 identified that an E/C program with systematic measurements equivalent-to the Nuclear Utility Management and Resources Council (NUMARC) Program described in NUREG-1344, " Erosion / Corrosion-

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Induced Pipe Wall- Thinning in U.S. Nuclear Power Plants," had been implemented. The inspector reviewed the licensee's program documents and -

implementing procedures and concluded that they conformed with thez licensee's commitments submitted in their July 21, 1989, response to GL 89-08, 2.3 Proaram Implementation ,

The inspector reviewed the methods which the licensee was using to determine E/C wear rates and which pipe and components.to be. ins)ecte The inspector also reviewed the documentation and calculations t1at supported the program, the inspection data feedback to the analysis group, and action taken for degraded condition Items noted by the inspector during this inspection are detailed below.--

2. Analysis Proaram In 1987 Technicon performed E/C analysis of the following systems:

Feedwater Auxiliary Feedwater Extraction Steam '

Main Steam Auxiliary Steam Process Steam Startup Boiler-

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Condensate Heater Drain Reheater Drain Miscellaneous Vent and Drains-Steam Generator Blowdown The-licensee evaluated the Technicon analyses and incorporated the applicable information into their E/C program.- The 1987 Technicon analyses' predicted higher E/C wear rates than the licensee's current program. Actual component' measured wear rates have been.close to:

-_ current program predictions -Since the licensee's current program

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and the measured wear rates appeared to. correlate closely, the-licensee has followed their current E/C' program _ guidance. The licensee noted that there isistill considerable uncertainty in the current state of-'the art for wear predictio The inspector determined that the licensee was currently actively involved-in the CHEC/CHECMATE Users Group (CHUG).- As a result of

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1 this CHUG involvement and as part of the CHUG on-site assistancc !

program, the licensee had received on-site reviews of their E/C !

program activities. The licensee had contracted with Altran Corporation for development and implementation of E/C CHECMATE Analyses by February,1993, to sup) ort the 1993 Trojan Refueling Outage Schedule. At the time of t11s inspection it appeared the NPE Department would have responsibility for controlling and updating the new Altran CHECMATE analyse These CHECMATE analyses will be j used as a second party check of the current licensee E/C program I based on review of the licensee's analyses ar.d inspection results, l The inspector concluded that the licensee program adequately ;

identified E/C wear rate areas and actions to preclude excessive i thinning of those areas. The inspector observed that the program j was established to define and expand inspection locations for future .

outages and schedule repairs or replacements, l 2.3.2 Selection Criteria The inspector reviewed the licensee's system selection criteria for determining which systems would be included in their E/C progra The %spector observed that the Technicon analyses had established a l line selection criteria which followed the guidelines contained in l NRC Bulletin 87-01, " Thinning of Pipe Walls in Nuclear Power i Plants," and GL 89-08. The inspector reviewed system parameters for four systems and concluded that the selection criteria had been properly applie .3.3 Data Inout The inspector reviewed the Technicon analyses for four subsystems to verify that the current data had been entered en the component data sheets. The inspector reviewed approximately 387 1991 outage ultrasonic thickness reports to verify data from a sample of these reports had been correctly entered in the Trojan plant data base titled "ECPLAN".

The inspector concluded that the licensee and Technicon had utilized appropriate sources of input data and had accurately entered the data for analysi . Inspections The E/C engineer had the responsibility to annually define the refueling outage E/C examination program based on previous examinations and current industry trends and standards. The inspector reviewed the E/C selection for the 1993 refueling outage contained in a scope memorandum (MHS-048-92) dated June 2, 199 This memorandum identified that the licensee had chosen approximately 355 high energy piping components for E/C inspection during the 1993 refueling outag An outage report documenting inspection activities, problems,

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concerns, manpower requirements, expenditures, etc., was required to be issued after each refueling outage. The inspector reviewed the outage reports for 1982, 1985, 1987, 1990, and 1991 and other documentation of past refueling outage examinations. The inspector concluded that the number of components examined since 1985 appeared to be above the number of components other facilities typically have examined in this time period. As of the completion of the 1991 outage, the licensee identified they had performed E/C examinations of approximately 2434 components since 1982. Several of these components have had several E/C examinations performed during an outage at various grid spacings from two inch down to 1/4 inch. The licensee program specified that when an E/C examination at the standard two inch grid spacing identified questionable wall thickness readings, additional E/C examinations may be requested at a smaller grid spacing. During the 1991 outage the licensee performed approximately 387 E/C examinations on approximately 253 component The licensee's current standard grid layout / marking for inservice inspection (ISI) E/C examinations of piping was to take readings in the direction of flow on the weld (centerline), at the toe of the weld, and at specified circumferential band locations spaced every two inches along the length of pipe. The standard inspection technique measured data at the grid intersection points only, and did not incorporate any scan of the area between points for localized minimum wall areas. The inspector reviewed photographs of inspection locations that were permanently marked with inspection grids, and had observed similar grid marked inspection locations during the Trojan 1991 refueling outage ISI review. However, the inspector was unable to visually inspect exact locations during this inspection due to installed piping insulatio The inspector concluded that the scope of the licensee's inspections was adequat . Examiner Certification The inspector reviewed licensee Quality Inspection Procedure (QIP)

17-9, Revision 0, " Ultrasonic Thickness Measurement," Nuclear Quality Assurance Procedure (NQAP) No.120, Revision No. 2,

" Qualification and Certification of VT-1 and Nondestructive Examination Personnel," and three NDE examiner certification records. The inspector observed that the licensee utilized Volt quality service group personnel to layout the grid patterns and to perform the ultrasonic (UT) examination during refueling outage The inspector reviewed Volt technical service Quality Ascurance Procedure (QAP) -3, Revision 3, " Qualification and Certification of Nondestructive Testing Personnel," which was issued April 13, 1992, to establish criteria for the qualification and certification of Volt technical services nondestructive examination personnel. The inspector noted that Volt procedure QAP-3 required four hours of training and four hours of experience for qualification and

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certification of Volt UT thickness measurement examiner Volt QAP-3 used the guidelines of the American Society of Nondestructive Testing (ASNT) Recommended Practice No SNT-TC-1A,

" Personnel Qualification and Certification in Nondestructive Testing " The inspector reviewed SNT-TC-1A and concluded that it allowed for certification of personnel specifically for UT thickness examination The inspector concluded that the examiner qualification and certification procedures and records reviewed were adequat . Measurement. Eouipment Calibration and Control -

The UT thickness equipment used during the E/C examinations was not under the control of the licensee's material and test equipment .

(Mile) program. The licensee stated that since the E/C program was 3 not required to be covered by a 10 CFR Part 50, Appendix B, quality assurance program, therefore the UT thickness equipment, calibration standards, etc., did not have to be in the licensee M&TE progra The inspector reviewed documentation on five calibration standards used for E/C thickness equipment calibration and found as built sketches which showed the thickness of each standard. The licensee checked the thickness of these standards using calibrated micrometer The calibration standards observed were uniquely identified for material identification and traceabilit Procedure QlP 17-9 required the UT thickness equipment linearity to be checked at the beginning of each day of testing and the UT equipment calibration to be checked at the end of each examination sequence, every hour during continuous use, and when ever thickness readings suggest

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invalid test result The inspector concluded that the measurement equipment calibration and control was adequat . Material Reoairs and Replacements The inspector reviewed several corrective actions initiated in 1990 and 1991 by the licensee as a result of identified E/C wea Components with identified E/C wear were evaluated and analyze Items found unacceptable either had the frequency of examinations increased or were replace The inspector observed several examples where UT examinations and/or direct measurement of the wall thickness of removed degraded components were performe The licensee stated that they routinely took measurements of removed E/C components. The examination of degraded components af ter removal, provides an additional opportunity to confirm the accuracy of the UT examination technique,

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as well as to validate the licensee's analytical predictions of E/C wear rate The inspector observed several examples where the licensee performed U1 examination and/or direct measurement of the wall thickness of new replacement components to baseline the component wall thickness for the E/C programs. The licensee stated that baseline data was being routinely take The inspector concluded that the licensee's program incorporated adequate corrective actions for components with identified E/C wall thinnin . Proaram Manaaement/0uality Assurance Overview

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The inspector reviewed the management of the licensee's program and had the following observation .3. Proaram Responsibility The licensee's E/C monitoring program was described by Revision 1 of STEP 30-4 Per discussions with the licensee, in the future nuclear plant engineering will assume responsibilities for the EPRI CHECMATE program, selection of components for examination, and other areas that surveillance and test engineering are now assigned responsibility for in STEP 30-40. The licensee was working on two new draft procedures, Revision 2 of STEP 30-40 and Revision 0 of TPP 19-24, to describe the program changes and responsibilities for controlling and implementing the licensee's future E/C progra The inspector reviewed Revision 1 of STEP 30-40 and concluded that the existing program responsibilities were adequately define .3. Quality Assurance The inspector reviewed licensee memorandum DLN-231-92 issued June 18, 1992. The subject of this document was " Nuclear Quality Assurance Audit of Surveillance and Test Engineering Activities, AP-680." Attached to the memorandum was a quality assurance (QA)

audit performed May 4-20, 1992. This audit appeared to be the first oae documented in the E/C program area. The audit recommended that the licensee consider coating surfaces subject to the E/C program UT thickness examinations with high temperature paint. This coating would provide a smooth examination surface and eliminate the need for extensive surface preparation. The licensee stated that they were considered this recommendation for future outage wor The inspector discussed the QA department involvement with the licensee. The licensee acknowledged that this involvement was required to assess the adequacy of the program and the quality of its implementation. The licensee was planning on expanding the scope of QA involvement in this are l

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The inspector concluded that while the QA oversight of the E/C program had been minimal, the plans for increasing QA involvement were considered reasonabl .3. Lona Term Strateay The inspector observed that the licensee's program did not currently include a documented long term strategy for reducing general E/C wear rates as recommended by the EPRI guidelines. The licensee program was designed for long term monitoring for E/C wear and component repair / replacement with higher wear resistant material as required. Per discussions with the licensee, the industry was researching various methods for reduction of E/C wear and the licensee was following this development wor The inspector concluded that the licensee was still developing their long term strategy for reducing E/C wea .4 Summary of E/C Proaram Strenaths and Weaknesses

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During discussions with the licensee and review of licensee documents the inspector identified specific strengths and weaknesses in the implementation of the licensee's E/C progra . Strenaths 2.4. Continuity and Enaineerina Involvement Some of the surveillance and test engineering personnel developing and supervising the program were involved in the program since its inception. The personnel had a good working knowledge of the program and its limitations. The personnel were sery knowledgeable about the cause and effects of E/ .4. Exoerience

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Actual plant problems and experience with E/C had been incorporated into the E/C program and were an important element in the licensee's progra .4. Manaaement Support Management attention and support of the E/C program and its development was evident by the ample funds provided for the examination of approximately 2434 components as of the date of this inspection. Per discussion with E/C personnel and review of the funds expended during the latest refueling outages for support of E/C program activities, it appeared the E/C program had strong management suppor .

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2. Weaknesses 2.4. Quslity Assurance involvement Quality assurance involvement in the development and implementation of the E/C program had been minimal until 199 .5 Conclusion The inspector concluded that the licensee was developing a comprehensive and aggressive program for long term monitoring of E/C in accordance with their commitments to GL 89-08. The program applied generally to non-safety related carbon steel piping. The inspector also concluded that the licensee was aware of the limitations in the accuracy of the predictive state of the art for wear rate No violations or deviations from NRC regulatory requirements were identifie .0 Followuo on Corrective Actions for Violations and Dev ations (92702)

i (Closed) Violation No. 50-344/91-14-01: Check Valve CC2044 Found to be Unacceptable and a Corrective Action Requgst was not Issued This violation identified that an inspection of Component Cooling Water makeup valve discharge check valve CC2044 identified that all the stellite had been removed from the valve body seat areas. The valve was reassembled, and the maintenance request (MR) to perform the work was closed out. However, no corrective action request (CAR) was issued to obtain an engineering evaluation of the as found nonconforming conditio The failure to issue a CAR immediately after identification of a nonconforming condition was a repeat violatio The inspector had questioned if this condition could have rendered the valve unable to perform its safety function, A previous inspector review of pertinent licensee documents and corrective actions identified the following:

• An August 7, 1991, response letter to the NRC identified personnel error and failure to follow procedure as the reason for this violation. This letter also identified that the licensee issued MR 91-3778 to replace valve CC2044 and CAR C91-0408 to evaluate and correct license weaknesses identified in the review of this violation. The licensee also provided counseling to applicable personnel on the need to follow procedural instruction e The licensee's initial engineering evaluation identified that the valve was acceptable for continued use. The licensee evaluation identified that the stellite coating function was to protect applicable valve internals from the long-term effects of corrosion,

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and the lack of stellite did not impact the capability of the valve to seat properly, e The licensee identified additional corrective actions to be accomplished. These were:

Trojan Plant Procedures (TTP) 14-03 " Work Control," and other administrative procedure would be revised so that the work and the craft supervisor reviewing the MR would be directed to review the " work complete" section for deficiencies that need further evaluatio Planning guidelines would be revised to instruct planners to verify any HR containing Periodic Engineering Test (PET) 9-11

" Check Valve Monitoring Program," the plant engineering test procedure for check valves, contains initial and final inspection completion sign-off's for the surveillance test engineer or designe During this inspection the inspector reviewed Section 4.ll.la 1) of Revision 2 to TPP 14-3 and Section 4.8.6 of Temporary Change Notice N to Revision 20 of AP 3-1 and verified the licensee's initial identified additional corrective actions had been performed. Revision 5 of TTP 14-3 contained the latest licensee instructions for post-work review Based on the inspector's review of the above identified documents, the inspector concluded that the licensee actions on this item were adequate to resolve this item. This item is close .0 Exit Meetino The inspector met with the individuals denoted in Section 1, on December 11, 1992. The scope of the inspection and the findings up to the time of the meeting were discussed. The inspector identified that additional information had been requested, and this information would be reviewed in the NRC Regional Office in order to complete the inspection. Review of the additional information was completed and the results are included in this report.

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