IR 05000361/1993039
| ML20059K405 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/10/1994 |
| From: | Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20059K397 | List: |
| References | |
| 50-361-93-39, 50-362-93-39, NUDOCS 9402020079 | |
| Download: ML20059K405 (13) | |
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NUCLEAR REGULATORY COMMISSION
REGION V
I Report Nos.:
50-361/93-39 and 50-362/93-39 Docket Nos.:
50-?61 and 50-362 License Nos.:
Southern California Edison Company.
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Irvine Operations Center 23 Parker Street Irvine, California 92738 Facility Name:
San Onofre Units 2 and 3 Inspection at:
San Onofre Site, San Clemente, California
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Inspection date: December 6 through December 10, 1993 Inspector:
C. A. Clark, Reactor Inspector Accompanying Personnel: M. C. Modes, Chief, Materials Section / Engineering Branch / Region 1 CT S l-1o-94 Approved by:
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W. P. Ang, Chief, Date Signed
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Engineering Section
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Inspection Summary:
Insoection durina the period December 6 throuah December 10. 1993 (Recort Ros. 50-361/93-39 and 50-362/93-39)
Areas inspected:
This routine announced inspection reviewed Inservice Inspection (ISI)
activities conducted during the current Unit 3 cycle seven (U3C7) refueling outage and the licensee's actions for open items identified in NRC inspection
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reports.
Inspection procedures 73051, 73753, 92701, and 92702 were used as-i guidance for this inspection.
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Safety Issues Manaaement System (SIMS) Items:
None.
9402020079 940110 -
PDR ADOCK 05000361-
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Results:
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General Conclusions And Specific Findinas:
ISI work activities were documented in accordance with the
licensee approved program and procedures.
However, the-inspector noted that initial UT examinations were normally. performed with UT equipment that had been calibrated using a one and one-half Vee (V) beam path. The licensee had not determined whether the-
interference criteria had been met, for each weld examined, prior to performing the one and one-half V calibration. This was of concern because examination performed with a one and one-half V
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beam path calibration is potentially not as sensitive as one performed with a one-half V beam path calibration. However, the licensee's UT-examinations appeared to meet the minimum applicable requirements of the ASME code.
Personnel involved in ISI examination activities for the U3C7
refueling outage were knowledgeable and qualified in their activities.
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Review of the ISI program status revealed a strong, comprehensive
system for control, review, and correction of ISI programmatic elements. The personnel managing the ISI program were t
knowledgeable of ASME requirements and-the program complied with
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the ASME code requirements.
I Sianificant Safety Matters:
None.
Summary Of Violation Or Deviations:
i None Open Items Summarv:
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The inspector left two follow-up items open.
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. DETAILS
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1.
Persons Contacted Southern California Edison Company
- D. Alexander, Engineer, Quality Assurance IQA)
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- M. Anderson, Supervisor, Nuclear Engineering Design Organization
- D. Axline, Engineer, 'Onsite Nuclear Licensing (ONL)
- C. Brandt, Senior Engineer, QA
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- D. Breig, Manager, Station Technical (ST)
- L. Cash, Manager,-Maintenance Organization
- W. Clay, Engineer, ONL
- J. Curran, Project Manager,-Design Basis Documents-
- E. David, lead Engineer, Nuclear Engineering Design Organization
- R. Douglas, Engineer, ONL
- G. Gibson, Supervisor, ONL
- R. Giroux, Engineer, ONL
- M. Herschthal, Manager, Nuclear Engineering Systems
- D. Irvine, Supervisor, ST
- B. Joyce, Manager, Units 2 and 3 Maintenance
- R. Krieger, Vice President, Nuclear Generation
- W. Marsh, Manager, Nuclear Regulatory Affairs
- D. Niebruegee, Senior Engineer, ST
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- S. Shaw, Supervising, Nuclear Services
- M. Short, Manager, Site Technical Services Others
- T. Boyers, Supervisor, ABB Amdata
- R. Erickson, Site Representative, San Diego Gas & Electric
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- C. Harris, Site Representative, Riverside C. Thompson, Factory Mutual, Lead Authorized Nuclear Inservice Inspector (ANII)
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- M. Wade, Resident Site Manager, ABB Amdata q
U. S. Nucleat.Reculatory Commission
- J. Russell, Resident Inspector
- D. Solorio, Resident Inspector The inspectors also held discussions with other licensee an'd contractor personnel during the inspection.
- Denotes those attending the exit meeting on December 10, 1993.
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- 2.
Inservice Inspection - Review of Proaram (73051)
a.
Purpose The purpose of this inspection was to ascertain whether the licensee's First Ten Year Interval of the Inservice Inspection (ISI) Program for San Onofre Nuclear Generation Station (SONGS),
Units 2 and 3, was complete and in conformance with regulatory requirements and the licensee's commitments, b.
Backaround A licensee August 6, 1993, letter submitted a revision to the SONGS Units 2 and 3 Inservice Inspection Program for the number of welds to be inspected during the first ten year interval. The information provided in this ISI program revision was reviewed.
c.
Review of ISI Proaram The NRC review of the SONGS Units.2 and 3 ISI Program was completed by Mr. M. Modes of NRC Region I and the results of the review are included as Attachment 1 to this report.
No violations or deviations of NRC requirements were identified.
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3.
Inservice Inspection - Observation Of Work And Work Activities (73753)
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Purpose
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The purpose of this inspection was to review a sample of completed Unit 3 Inservice Inspection (ISI) work and to observe available work activities in progress to determine if the inspection, repair, and replacement of Class 1, 2 and 3 pressure retaining components were being performed in accordance with applicable requirements, b.
Backaround During this inspection the licensee was conducting the Unit 3 cycle seven (U3C7) refueling outage, which was the third and final period of the first ten year ISI interval. Unit 3 started commercial operation en April 1, 1984. On October 25, 1985, the licensee connitted to using August 18, 1983, the Unit 2 ISI interval start date, as the ten year ISI interval start date for both Units 2 and
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The first ISI interval ended on August 18, 1993.
The licensee had extended the current inspection interval until March 31, 1994. The extension was needed in order to complete nondestructive examinations outside the containment building. The extension was allowed by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code)Section XI,
" Rules for Inservice Inspection of Nuclear Power Plant Components,"
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- Subarticle IWA-2400, " Inspection Intervals." The licensee notified the NRC of this extension when they submitted their ISI plan for the second ten year inspection interval on August 16, 1993.
Section 4.0.5 of the San Onofre Nuclear Generating Station (SONGS)
Unit 3 Technical Specifications (TS) required that ISI be performed in accordance with Section XI of the ASME Code and applicable
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Addenda. The Code inspection requirements are the basis for inservice examinations and tests conducted during the initial 120-months of commercial operation inspection interval, which began on April 1, 1984. The licensee's ISI program was based on the 1977-Edition of the ASME Code,Section XI, with Addenda through Summer 1979 (77S79), for Class I components and the 1974 Edition with.
Addenda though Summer 1975 (74S75), for Class 2 and 3 components.
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To meet the requirements of the ASME Code for ISI and other
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surveillances the licensee issued Site Technical Services Order
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S0123-IN-1, Rev. 3, " Inservice Inspection Program," to define policy, licensing commitment requirements, and designate mtnagement responsibilities..To implement the ISI Program requirements
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r identified in Order S0123-IN-1 the licensee issued procedure 50123-XVII-1, Temporary Change Notice (TCN) No. 6-3, " Inservice Inspection Program Implementation."
The services of an Authorized Nuclear Inservice Inspector (ANII)
had been procured and the ISI plan had been reviewed by the ANII in accordance with Article IWA-2120 of the ASME Code. ABB Amdata, a division of ABB Combustion Engineering Nuclear Power, was the contractor performing ISI activities during this outage. ABB
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Amdata was determined by the licensee to be an acceptable licensee contractor based on a Nuclear Procurement Issues Committee (NUPIC)
Joint Utility Audit, which included a licensee auditor. The Nuclear Oversight Division evaluated the NUPIC audit report for
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compliance with their Quality Assurance Program requirements and j
approved ABB Amdata services on March 23, 1992.
c.
Schedulino Of Work The inspector reviewed licensee ISI plans and schedules for the current ISI interval to determine if changes to the inspection plan had been properly documented and approved.
The inspector found that all changes to the ISI plan had been properly documented and approved.
d.
Review Of Personnel Oualifications And Certifications
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The inspector reviewed the qualifications and certifications of the ABB Amdata personnel who were conducting ISI examinations during the U3C7 refueling outage.
These personnel were certified for Level I and II examination activities under American Society for Nondestructive Testing Standard SNT-TC-1A. The inspector also
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I reviewed a sample of the qualifications and certifications of licensee and contractor Level III examiners. The inspector verified that the records contained the required information, such as: employer's name, person certified and the activity that they were qualified to perform.
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Observation Of Work tere were no ISI work activities in progress for the inspector to
,erve during this inspection.
In June and July of 1993, the NRC rformed observations of ISI work activities performed by.the same rISI contractcr, ABB Amdata, during the Unit 2 Cycle Seven (U2C7)
refueling outage. Except. for the use of one and one-half V l
calibrations for all observed UT examinations, as noted in open item 50-361/93-16-01 (see Section 3.a. below), there were no
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concerns
^+ified for the Unit 2 ISI work activities observed by
the NRC this year. The NRC findings for the Unit 2
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observatu.. a ISI work activities were documented in NRC Inspection Report Nos. 50-361/93-16 and 50-362/93-16.
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At the time of the inspection, no ASME Code repair activities were
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in progress. However, during the inspection, the inspector discussed Code repair activities with the ANII. The inspector concluded that the ANII was aware of Code repair and replacement activities being performed during the outage, and was also familiar with tt
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Review of ISI Data The inspector reviewed U3C7 ISI data packages for ISI Zones 3, 5,
6, 7, 8, 9, 10, 24, 25, 28, 42,'45, 48,.52, 53, 59, and 80. The required documentation was complete.
Examination results, i
evaluations, and any corrective actions, repairs or replacements l'
were recorded as specified in the ISI program and procedures.
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Sensitivity Of Ultrasonic Examinations-The UT examination records reviewed by the. inspector indicated that-
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initial UT examinations were performed in accordance with procedure S023-XXVII-4.0.19 utilizing equipment calibrated using a one and one-half V beam path. The licensee stated that the contractor-I examination personnel had been trained to evaluate each weld.
examination area in accordance with the criteria in Subarticle III-3230 of Section XI of the applicable ASME Code, and that each weld examination had been performed in accordance with'the requirements of the ASME Code. The licensee also stated that if a questionable UT indication was identified during the performance of ISI, every attempt was made to perform the examinations with the most-sensitivity as possible during evaluation of the indication, i
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Conclusions The inspector concluded that, except for open item 50-361/93-16-01, j
concerning initial UT calibration, the licensee was adequately implementing their ISI work activities in accordance with
regulatory requirements.
No violations or deviations of NRC requirements were identified.
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4.
Followup Of Previously Identified Items (92701)
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(0 pen) Followuo Item 50-361/93-016-01: ISI/UT - One-Half Vee Dimension A Calculations Oriainal NRC ODen Item NRC inspectors previously identified the following concerns with UT examinations performed by the licensee:
Section 8.3 of licensee procedure S023-XXVII-4.0.19, Rev.0,
" Ultrasonic Examination Procedure Class 1 and Class 2 Piping and CEDM Upper Pressure Housing Welds" stated that, "One and one-half V techniques shall be the preferred method of _
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calibration for the examinations described in this procedure."
The UT examinations observed by the NRC inspectors and
discussions with the licensee, identified that UT examinations performed per procedure S023-XXVII-4.0.19, were normally initially performed with equipment calibrated using a one and
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one-half V beam path.
Procedure S023-XXVII-4.0.19 was initially issued by Combustion Engineering, Inc. as procedure 9976-ISI-019.
Procedure 9976-ISI-
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019 was accepted by the licensee for performance of UT examinations at SONGS and assigned a licensee procedure number S023-XXVII-4.0.19 on approximately March 22, 1986.
Ultrasonic shear waves travel through material from the outer
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surface to the inner surface where the wave is reflected back,
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along a different path, to the outer surface. -The path this wave travels is shaped like a V and is commonly described as a V-path.
Ultrasonic examinations are most sensitive for detecting cracks when the angle beam travels a one-half V path.
Subarticle III-3230 (a) of the Code requires that angle beam paths required by Subarticle III-4420 and III-4430 be obtained on the sweep display during calibration.
Subarticle 111-4420 and 111-4430 require one-half or one V path, as applicable, for examinations of weld seams.
Subarticle 111-3230 (a) of the Code recognizes that variables, such as weld preparation, weld crown width, or physical interference may preclude half-V examination of the weld root as shown in figure (Fig.) 111-3230-1 of this subarticle.
Subarticle 111-3230 provides
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criteria for these variables which requires that the beam path be increased at least one-half V if the interference criteria is met.
If the subarticle interference criteria is met, the angle beam path can be increased to one and one-half (1-1/2) V to provide full t
coverage of the weld area.
During a July 29, 1993, telephone call between'the licensee and the Region V inspectors the licensee could not confirm whether the
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Subarticle III-3230 interference criteria had been met prior to performing only one and one-half V calibrations and associated examinations. The licensee stated they would review their records
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and calculations used in developing procedure S023-XXVII-4.0.19,
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and notify the inspectors if evaluations for the interference criteria had been performed.
Licensee's Actions In Response To The Ooen Item The licensee informed the inspector that they had taken the following actions:
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Reviewed their records and calculations for information used
during the acceptance of Combustion Engineering procedure 9976-ISI-019 (S023-XXVII-4.0.19).
As part of their normal review activities for improving the
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ISI program, they had implemented a review of procedure S023-XXVII-4.0.19 and were evaluating if the procedure could be i
improved by:
(1) Deleting the words in Section 8.3 of procedure S023-
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XXVII-4.0.19, that identified that the one and one-half V l
technique was the preferred method of calibration for UT
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examinations.
(2) Adding a table with a calculated acceptance criteria for
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the dimension A on Figure 11I-3230-1 of Subarticle III-
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3230, per specified calibration. block, material
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thickness, and initial examination beam angle. This table would provide the information required for i
evaluations of Subarticle 1I1-3230 interference criteria.
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(3) Recording an actual measurement of the Figure 111-3230-1-dimension A for each weld, examined, on the examination data sheet, along with the actual beam angle and length of the examination V path.
Inspector's Action Durina The Present Inspection The inspector noted that the licensee had not formally documented
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their actions taken on this item, so the' inspector held discussions with the licensee and ABB Amdata personnel to determi' e the results n
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of their efforts.
In these discussions the licensee stated the following Their review had not located any calculations developed for i
evaluations of the interference criteria of Subarticle III-3230, for each weld in their ISI program. Nor did their ISI program require documentation of such _ calculations.
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The ABB Amdata examination personnel'were trained 'to evaluate
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each weld per the interference criteria of Subarticle III-3230, and had applied this training as required during ISI-
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examinations at SONGS.
When questionable UT indications were identified during the u
performance of ISI, in accordance with Article 111-3000, the most sensitive examination possible was performed during the follow-up evaluation of the indications.
Proposed changes to procedure S023-XXVII-4.0.19 (noted above)
were being considered to ensure documentation of the acceptability of the sensitivity of the ASME Code required UT equipment calibration performed for each of the ISI weld examinations.
Discussion And Conclusion The licensee had no readily available _ record of interference evaluations for their performance of one and one-half V UT calibrations / evaluations versus one-half V.
However, the licensee appeared to have met the minimum applicable ASME requirements.
In addition, the licensee was evaluating improvements to its procedural requirements for interference evaluations for performance of UT. This item will remain open pending inspector review of further licensee evaluations of licensee procedures for the second ten-year inspection interval, b.
(0 pen) Unresolved item 50-361/93-016-03: Cold Pullina of Pipina to Alian Mismatched Pioina without Enaineerina Instructions Oriainal NRC Open Item NRC inspectors previously identified that safety related piping may have had loads / stresses applied that exceeded their design analysis
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during cold pulling operations, to align mismatched piping, and performed without engineering instructions, procedures or specific training.
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Licensee's Actions In Response To The Ooen Item The licensee initiated reviews of previous outage work, revision of applicable procedures, and training as noted below:
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July 22, 1993, issued TCN 4-11 to procedure 50123-I-1.7,
" Maintenance Order Preparation, Use and Scheduling," which added instructions to implement interim measures to address cold pull issues until a procedure for cold pulling of piping was implemented.
July 28, 1993, issued Required Reading Assignment No. 518 to
familiarize all maintenance personnel with the details of TCN 4-11 to procedure S0123-I-1.7.
July 30, 1993, documented (E-Mail) review of ASME Code piping.
- work performed by Nuclear Construction during the U2C7 refueling outage to identify any piping mismatches that may
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have required cold pulling of piping. No example of cold pulling of ASME piping was identified.
August 3,1993, documented (E-Mail) closure of licensee
Regulatory Commitment Tracking System _(RCTS) item 93070030.
This item identified that the licensee had reviewed maintenance work orders (MW0s) issued 'for the Unit 2 Cycle
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seven (U2C7) refueling outage to identify any piping
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mismatches that may have required cold pulling of piping.
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example of cold pulling of piping was identified.
August 30, 1993, documented (" Memo to File") a licensee review
of maintenance work orders (MW0s) issued for the Unit 2 Cycle six (U2C6) and the Unit 3 Cycle six (U3C6) refueling outages, to identify any piping mismatches that may have required cold pulling of piping. No new examples of cold pulling of piping
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were identified.
September 13, 1993, documented (E-Mail) a summary of the
training provided in five classes to a total of sixty six licensee personnel, on the subject of cold pulling piping.
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September 17, 1993, issued Design Change Notice (DCN) No. 1 to
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i document No. CS-P204, Rev.19, " Fabrication and Installation of ASME Section I, III & XI Piping," to revise procedures for
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handling pipe ends closure mismatches during construction l
work.
Inspector's Action Durina The Present Inspection The inspector reviewed the licensee actions taken on this item,
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along with the applicable documentation identified above.
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Discussion And Conclusion f
The inspector determined that the licensee had implemented actions to address this concern.
In the area of nuclear construction work,
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document CS-P204 had been revised to reference licensee Calculation No. M-DSC-270, Rev. O, " Handling of Pipe Ends Closure Mismatches,"
to include engineering instructions on cold pulling of' ASME Code piping to correct identified piping mismatches.
In the area of maintenance work, the licensee had provided training on how to handle cold pulling of piping, but it did not appear that the existing maintenance documents had been revised to ensure the engineering instructions of Calculation No. M-DSC-270 were
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implemented for maintenance work. This item will remain open pending clarification that maintenance work procedures provide engineering instructions for any required cold pulling of ASME Code
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piping.
No violations or deviations of NRC requirements were identified.
5.
Exit Meetina The inspector conducted an exit meeting on December 10, 1993, with members of the licensee staff as indicated in Section 1 of this report.
During this meeting, the inspector summarized the scope of the inspection activities and reviewed the inspection findings as described in this report. The inspector identified that he had requested some additional information that would be reviewed in the region. This additional information was reviewed by the inspector and included in Section 4 of this report. The licensee acknowledged the inspection findings as identified in this report.
The licensee did not identify as proprietary any of the information provided to, or reviewed by, the inspector during this inspection.
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Attachment 1 Introduction Southern California Edison, San Onofre Nuclear Generating Station (SONGS),
submitted a request for relief from the requirements of the American Society for Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI,
" Inservice Inspection Reauirements," 1977 Edition with addenda up to summer of 1979 (ASME Section XI, 77S79), that welds chosen for examination in
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categories BJ and CF be volumetric examined for a zone of interrogation consisting of 1/3 of the lower portion of weld thickness, heat-affected-zone (HAZ) and base material, as well as a surface examination by either liquid penetrant or magnetic particle testing. SONGS proposed a volumetric examination of 100% of the weld thickness in lieu of any surface examination.
This relief request, identified by SONGS as B-7, was denied by the NRC in
" Safety Evaluation Report of the First Ten-Year Interval Inspection Program (TAC 54148 and 54149)," by letter of transmittal from L. E. Kokajko to
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H. B. Ray, dated 10/12/90. The NRC, in its statement of denial, entertained reconsideration of the request if SONGS could demonstrate that the proposed substitute would detect the types of surface connected flaws that liquid penetrant or magnetic particle would detect.
SONGS attempted to perform a demonstration of the proposed method using a pipe into which eight (8) surface flaws had been introduced.
It should be noted that ASME Code Case N-409-2, " Procedure and Personnel Qualification-Requirements for Ultrasonic Detection and Sizing of Flaws in Pipes," dated May 13, 1991, and acceptable to NRC staff (with prior notification) in Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability ASME Section XI Division 1," Revision 10, dated July 1993, requires a minimum of eight (8) flawed grading units and sixteen (16) unflawed grading units for detection qualification. Of these units, seven (7) must be detected and a maximum of two (2) false calls are allowed.
SONGS used seven (7) flawed grading units and only two (2) unflawed grading units.
The demonstration resulted in the detection of only two (2) graded units; both were linear flaws located in the toe of the weld. The remaining five (5) grading units, consisting of six (6) flaws in the weld surface, were undetected. SONGS was unable, under these conditions, to demonstrate the acceptability of the proposed alternate examination.
Unfortunately, SONGS had undertaken a large number of examinations, during the period between the submittal of the relief request and the failure to demonstrate its acceptability, utilizing only the proposed method.
SONGS was required, by the ASME code plan, to have completed fifty. percent (50%) of the required examinations, both surface and volumetric of the 1/3 zone, by the end of the second inspection period in the first. inspection interval. The SONGS interval was synchronized for both units at August 18, 1993, as allowed in the original SER of October 12, 1990, and will end, under 10 CFR 50.55(a)
provisions, no later than August 18, 1994. The original B-7 relief request was revised by the SONGS submittal of March 20, 1992.
Thus,'a_ period of eight years and seven months had elapsed without surface examinations at SONGS.
SONGS could not meet the schedular requirements of ASME because the milestones had already been passed. SONGS found themselves, according to their ISI plan, having to perform one thousand two hundred thirty one (1,231)
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surface examinations on a very short' schedule.
They only had until the end
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of the first ten year interval to complete all the examinations.
SONGS undertook a review of their program and discovered that they could not be completely certain what the true population of welds at Unit 2 and Unit 3
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were.
In addition, they discovered that the original program included welds that only required an. augmented examination by the Updated Final Safety Analysis Report (Section 6.6.10) and would, therefore, not require a surface examination.
Review Because of these uncertainties, SONGS found-it necessary to essentially rebuild their ISI program. This effort included going back to all the original piping drawings and determining that design changes and modifications had been included. The Southern California Edison Nuclear Engineering Design Organization recertified the drawings and produced a set of piping isometrics from.which the total weld population could be derived with greater certainty. This effort was initiated by SONGS Corrective Action Report (CAR) P-1390, Revision 0, " Failure to Implement the Inservice Inspection Program." CAR P-1390, Revision 0, included provisions for quality assurance involvement in verifying the corrective actions. QA inspectors verified that the nondestructive evaluation vendor was qualified, that the authorized nuclear inspector was informed, that the ASME required NIS-1 report was submitted in a timely fashion, and that the ISI program was effective (consistent documentation, record retention, schedular commitments, etc.).
In addition, QA inspectors walked down the drawings, now being used by ISI, for zones 15, 18, 57, 59, 62, 66, 74 and 75.
It was noted in QA Surveillance Report 50S-141-93, dated August 13, 1993, that the piping was insulated and only supports, and valves were verified. The QA manager int m : awed the QA auditor and indicated that the piping in Unit 3, Zone 15 wc2 not insulated and the auditor verified the weld locations.
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Conclusion This review of the SONGS program status reveals a strong, comprehensive system for control, review, and correction of ISI programmatic elements. The personnel managing the program were knowledgeable on ASME requirements and were able to answer the most detailed questions of the inspector.
The SONGS
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ISI program complies with the ASME requirements.
In addition the removal, from the original ISI program, of the Augmented Inspection required-inspections, justifiably reduced the number of-required surface inspection
population. The examinations undertaken to date have been by surface and volumetric methods in conformance with the ASME requirements.. The ISI
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program and NDE examinations at SONGS are currently in compliance with the requirements pre:,cribed for it.
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