IR 05000395/1988022
| ML20205Q754 | |
| Person / Time | |
|---|---|
| Site: | Summer |
| Issue date: | 10/25/1988 |
| From: | Blake J, Coley J, Glasman M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205Q751 | List: |
| References | |
| 50-395-88-22, IEB-87-001, IEB-87-1, NUDOCS 8811090341 | |
| Download: ML20205Q754 (12) | |
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'*4 UNITED STATES
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NUCLEAR REGULATORY COMMISSION
~t REGION 11 o
f 101 MARIETTA ST., N.W.
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ATLANTA. GEORGIA 30323 Report No.:
50-395/88-22
Licensee:
South Carolina Electric aid Gas Company Columbia, SC 29218 p-Docket No.:
50-395 License No.:
NPF-12 Facility Name:
Summer Inspection Co
September 26-30, 1988
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Inspector :
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A le Date 51gned
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/Oftf LM Grasman Date Signed __
Approve b:
/o/I/2
. Blake, Chiet Date Signed
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erials and Processes Section ngineering Branch Division of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of Inservice Inspection - review of program review of procedure and observatica of work and work activities an,d NRC Bulletin 87-01.
%sults:
In the areas inspected, violations or deviations were not identified.
South Carolina Electric and Gas (SCE&G)nagement was actively involved in quality activities.- Inspecto-concerns, addressed in this report were aggressively, pursued by cognizant division managers.which dealt with pr
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personnel were well qualified, knowledgeable of requirements,ies.
and l confident in their programs to effectively control work activit
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, t 8811090341 esto29
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gDR ADOCK 05000395 PDC
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REPORT DETAILS
1. Persons Contacted
Licensee Employees j
"M. Browne, General Manager, Station' Support-
"J. Bryers, Engineer Regulatory Compliance
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"R. Clary, Manager, 6esign Engineering
- L. Collier, Welding Supervisor Su)ervisor, Mechanical / Chemical Plant Support "R.
Cox,ing'1am$ ssociate Manager, Design Basis Enginee
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"S.
Cunn A
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"H. Donne?ly, eriler Engineer Regulatory Interface
- W. Higgins, Supervisor ReulatoryCompliance "S. Hunt, Manager, Quality ystems.
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- A. Koon Manager, Nuclear icensing "T. McAllster, Supervisor, Quality Assurance
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- D. Moore, General Manager, Engineering Services
- K. Nettles General Manager Nuclear Safety
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"A. Paglia,, Senior Engineer,, Systems and Performance
- J. Skolds,. General Manager Nuclear Plant Operations
"G. Taylor, Manager,Operatlons
- M. Quinton Manager, Systems and Performance Engineering
- M. Williams,, Manager, Nuclear Licensing Other licensee employees contacted during thisengineers, technicians, and ins
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NRC Resident Inspectors l
- R. Prevatte, Resident InspectorSenior Resident Inspector P. Hopkins,
"Attended exit interview
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2. InserviceInspection(ISI)ReviewofProgram(73051)
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The inspectors reviewed proceduresrecords to determine whether the licensee' view!
inter s ISI program is complete and
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inconformance with regulatory requirements and licensee commitments.
The n
applicable code for ISI is the ASME Boiler and Pressure Vessel (ASMEB&P)
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Code,Section XI, 1977 Edition, Summer 1978 Addenda.
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The inspectors emphasis this ins ction was directed to the Quality Assurance Program, the ten year rostatic testing program and the repair and replacement programs.
Proce ures listed below were reviewed by the
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inspectors to determine their compliance with ASME,Section XI requirements.
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3. QualityandAssuranceProgram
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The inspectors reviewed the licensee and ISI contractor's QA pr,ograms to verify the following:
procedures for the-maintenance of required ISI
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records; QA review includes assurance that plans and procedures have been
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reviewed by appropriate personnel and meet regulatory requirements; procedures are established for the corrective action of conditions adverse
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to quality as detected during examination including provisions to
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preclude repetition of such adverse conditio,ns audits or surveillance of
ISI activities are conducted by qualified Qd personnel to verify
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compliance with the ISI program;ivities concerned with ISI/ PSI.and procedures t
effectively oversee contractor act
a.
Hydrostatic Testing Program The inspectors reviewed the licensee's administrative and hydrostatic
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test 3rocedures listed below to verify that the requirements of
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Artic'e IWA-5000 of the ASME Code and NRC supplementary requirements are included or referenced.
During the review of Hydrostatic Test Procedure 149.087 which was used to hydro-test loop A of the Chilled Water System, the inspectors noted that Change A to the test procedure reduced the test boundaries.
However the task Cover Sheet for the procedure did not list any test deviati,ons and the procedure
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was sianed off as com)1ete.
Further review by the inspectors reveale'd that an aud'it )y the licensee had identified this same item.
Corrective action, taken by the licensee;ill Water Hydrostatic Tert,to the
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revise the test procedure for Loop B, Ch
to include the componants missed during the loop A hydrostatic test.
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The inspectors were concerned about the corrective action taken
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because it did not prevent the discrepancy from recurring.
Although i
the test procedure for the A loo) had been correctly revised to delete the components from the A :oop hydros, the B loop hydrostatic
test had not been revised to include these components.
The task l
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sheet for Loop A should not have been signed off as complete until i
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the components had been administrative 1y transferred to the B loop
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test procedure.
The deviation from the A Loop test boundaries should
also have been noted on the task sheet to flag the deviation and to
ensure its capture by another test procedure.
The inspectors
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discussed their concern with the licensee's cognizant engineers and i
the Plant Manager and were assured that adequate controTs would be j
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adcpted to ensure that, when test procedures are deWated from, they
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will be so noted on the task sheet.
With the exception of the
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inspectors concern addressed above, the licensee's program for
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hydrostatic testing appears to be very conservative and is being
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conducted at this point in a very effective manner.
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b.
Repair Program The inspectors reviewed the licensee's administrative and maintenance
procedures indicated in c. below, to verify that the requirements of Article IWA-4000 of the ASME Code, and NRC supplementary requirements, are included or referenced.
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c.
Replacement Program
The inspectors reviewed the licensee's administrative and maintenance
procedures listed below to verify that requirements of Article
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IWA-7000 of the ASME Code, and NRC supplementary requirements, are included or referenced.
During the review the inspectors noted that engineering responsi-
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bility for performing an evaluation of the suitability 'of replacement
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parts and components was not addressed in the licensee s Administra-tive F?ocedure for Design Control / Implementation and Engineering I
Interface SAP-133 Revision 4.
The licensee's verification of acceptability of replacement p' arts is addressed in Administrative
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Procedure SAP-601 Revision 4 Application Scheduling and Handling
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of Maintenance Activities"., SAP-601 requi,res maintenance personnel Maintenance Work Request (WMR) the i(ndividual does not have aNCN) if to generate a Nonconformance Notice preapproval disposition number for the item he is replacing.
The NCN will then be reviewed by engineering.
This method of achieving an engineering evaluation has apparently worked very well for the i
licensee.
The inspectors were concern not because the system for evaluation or replacement parts was not working satisfactory but i
because the engineering interface procedure did not define res,ponsi-
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bilities required by engineering or reference the maintenance procedure where this program appears.
The inspector discussed their
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concern with the licensee's cognizant engineering staff and were assured that this program enhancement be addressed in the next
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revision of SAP-133.
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DOCUMENTS REVIEWED
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Identification
Title
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SAP-145 Rev. 4
"Inservice Inspection"
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GAP-303 Rev.- 4 Change A
"Inservice Inspection
Nondestructive
Examination"
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"Operational Quality
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Assurance Plan,
Rev. 18"
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Identification
Title
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SAP-601 Rev. 4
"Ap)1ication,
Scleduling and
Handling of
Maintenance Activities"
STP-0149.087 Rev. 1
"Chilled Water Loop A"
STP-0149.066 Rev. 1
"Safety Indection, High
Headandlloron
Injection"
STP-0149.084 Rev. 1
"Servie.e Water to RBCU
Train-A"
STP-0149.033 Rev. 1
"Diesel Generator Fuel
Oil Storage Tank and
Piping"
QPS-201 Rev. 0
"Nuclear Operation
Records Accumulation
and Retention"
SAP-139 Rev. 10
"Procedure Development,
Review, Approval and
Control
SAP-300 Rev. 4
"Conduct of Maintenance"
QSP-201 Rev. 0
"Nonconformance Control"
SAP-133 Rev. 4
"Design Control /
Implementation and
Engineering Interface"
5AP-304 Rev. 3
ASME Code,Section XI
Repair Program
WM-1.0 Rev. 10
"Welding Manual
Procedure"
WM-2.0 Rev. 9
"Welding Materials
Procedure"
SAP-302 Rev. 3 Change A
"Administration of
Maintenance Welding"
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Identification
Title
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GTP-304 Rev. 2
"Inservice Inspection
System Pressure
Testing"
ES-416 Rev. 0
"Design Modification
Change Process and
Control"
Within the areas examined, violation or deviations worc not
identified.
4.
Inservice Inspection - Review of Procedures (73052)
The inspectors reviewed the most recent changes of the procedures listed
below to determine whether these changes were consistent with regulatory
requirements and licensee commitments.
The procedures and most recent
changes were also reviewed in the areas of proper approval
com)ilation of
required records and if applicable,if contractor personnel are involved indivisio
3etween the
licensee and contractor personnel
the ISI efforts.
All the recent changes were also reviewed for technical adequacy and
content, and conformance with applicable sections of the code.
Procedure
Revision
Addenda
UTL-MT-03
A
UTL-MT-01
B
UTL-PT-01
B
UTL-PT-02
B
UTL-VT-01
B
UTL-VT-02
A
UTL-VT-04
A
UTL-VT-01
B
UTL-UT-07
A
SCEG-GTP-108
A
Within the scope of this inspection no violatior.s or deviations were
identified.
5.
Observation of Work and Work Activities (73753)
The ins,pectors observed work activities and reviewed certification records
materials and NDE personnel which k id been and will be
of equipment lng the required ISI examinations, and thickness testing
utilized dur
related to NRC Bulletin 87-01 for the current,Jtage.
The observations
and reviews conducted by the inspectors are doc nented below:
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a.
The inspectors observed the PT examinations indicated below.
The
observations were compared with the applicable procedure and the code
in the following areas:
Specified method, penetrant materials
identified and analyzed for halogen and sulphur content; acceptable
surface ) reparation and cleaning; acceptable surface drying time;
acceptab'e penetrant application; ithin acceptable limits; pro,per
acceptable penetrant dwell time,
surface temperature checked and w
solvent removal; adequate surface drying time prior to application of
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developer; proper type of developer; proper application of developer;
proper evaluation of any indications, if any; proper reporting and
documentation of results.
Drawing No.
System
Weld ID
ILT 00495
Main Steam, Condensate Pot
MW1
Reactor Bldg, 463' Evaluation
MW2
MW3
MW4
MW8
The inspectors reviewed the below listed liquid penetrant materials
to ascertain if the proper documentation was on file, and if the
sulphur and halogen content was within acceptable limits:
Materials
Batch Number
Cleaner / Remover
46F4
Penetrant
21J47
Developer
45F6
b.
The inspectors observed the VT examination indicated below.
The
observations were compared with the ap)licable procedure and code in
the following areas:
specified methoc, evaluation techniques, and
reporting of examination results.
Item
Drawing
Description
System
MSH 059
04-4461-5-321-011
Pipe Support
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c.
The inspectors reviewed the certification records for the following
Ultrasonic equipment, and supplies listed below:
Description
Serial No.
Calibration Due
KB-USK-7 UT Instrument
'.7276-4663
05/27/89
KB-USK-7 UT Instrument
276-4687
08/30/89
Step Wedge Calibration Block UT-101
Not required
A36 Steel, 0.1"-1.25"
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The inspectors reviewed spectrum analysis data for the ultrasonic
transducer listed below:
KBA, 3.5 MHZ,.375"4 single element, serial G08230
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The inspectors reviewed the qua!ification docume1tation for the
examiners listed below in the foilowing areas:
employer's name;
person certified; activity qualified to perform; effective period of
certification; signature of employer's designated representative;
basis used for certification; and annual visual acuity, and color
vision examination, and annual recertification.
ASNT
Initials
Employer
Method
Level
Expiration
UTL
VT-1,3,4
II
09/15/01
HT;PT
II
03/22/91
UTL
VT-1,3,4
II
09/15/91
II
09/15/91
TH
UTL
II
09/15/91
WP
SCEG
VT-1 2,3,4
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10/18/88
RC
SCEG
III
11/19/89
UTL
II
09/09/88
II
09/08/91
II
09/12/91
UfL
II
2/24/991
II
JS
UTL
II
08/18/91
VT-1,2,3,4
08/16/91
CD
UTL
II
11/11/89
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09/30/90
PT;VT-1,2,3,4
II
03/12/90
II
11/01/89
Within the scope of this inspection no violations or deviations were
identified.
5.
(0 pen) NRC Bulletin 87-01: "Thinning of Pipe Walls in Nuclear Power
Plants" (92702)
This bulletin requested information concerni'.1g programs for monitoring
errosion-corrosion degradation in high-eneray carbon steel piping systems
carrying single and two phase flows.
The inspectors reviewed pertinent
procedures, witnessed work in progress, reviewed design engineering data
and calculations, and interviewed cognizant licensee personnel.
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At the time of the ins,pection, licensee personnel indicated that SCEG
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had elected to utilize the methods developed by EPRI for
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identification and evaluation of
to errosion/co,rrosion degradation. piping configurations susceptible
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It was found, ho' sever, in
reviewing the latest SCEG procedure for monitoring and avaluation for
errosion-corrsion damage
GTP-308 Revision 2 Change A, that this
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procedure did not include adequate means to ensure reproducible
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thickness test results over a period of time.
To this end, EPRI
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recommends application of a grid and permanent reference marks.
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This method allows close and controlled monitoring of specific
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locations on the selected configurations.
Licensee personnel
responsEle for ISI indicated that the Design Engineering Department
was responsible for providing guidance and procedures for gridding,
however, these procedures were not prepared at the time of the
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inspection,
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b.
The inspectors also witnessed ultrasonic thickness testing of the
following configurations:
Item
Drawing
Description
System
HD-12-T02
IMS-22-336
18"x12" conc. reducer
High
3ressure
eater
drips
HD-01-T10
IMS-22-362
24"x14" conc. reducer
Low
3ressure
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leater
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drains
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The above listed configurations were examined in accordance with the
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following procedures:
SCEG
3rocedure GTP-308 Revision 2, Change A:
"General Test
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Procecure; Corrosion /Errosion Detection and Evaluation Program"
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UTL Procedure UTL-UT-07 Revision 2:
"Ultrasonic Thickness
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Measurement"
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Additional details pertaining to the equipment, personnel, and
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supplies required for the ultrasonic thickness tests may be found
under paragraph 4, observation of work and work activities.
c.
To ascertain the validity of the data input to the EPRI CHEC program,
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the ins)ectors chose to review five configurations which were
selectec by the CHEC program for thickness examination.
The input
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data listed in the CHEC program, among other things, pressure,
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temperature, and mr.ss flow rate were compared to values listed in the
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flow diagrams for the selected configurations.
The inspectors then
determined if the respective values for the above-listed parameters
compared favorably.
The configurations, flow diagram data, and EPRI
CHEC program data are tabulated blow:
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PRESSURE,/
PSI MASS
TEMPERATURE, "F
Flow Diag.
FLOW
SCEG NO.
CONFIG. SYSTEM
Flow Diag./CHEC
/CHEC
LB/HR
Flow
Dia./
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CH C
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180" Bend
340/340
20/1720
4.07E06/
4.07E06
260-007
Orfice
106/106
250/250
4.37E06/
Condensate
2.3E06
T-23
Tee
338/338
449/338
3.05E06/
2.21E06
T-12
Reducing
435/435
20/1220
4.07E06/
Elbow S
4.07E06
Gen. 'I "team
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T-18
8"x10 Conc.
340/340
20/1720
^1.87E06/
Reducer
1.68E06
Note that there are two configurations listed above with flow-related
discrepancies; an orfice, No. 8260-C07 in the condensate sy) stem, at
the discharge of XPP-42A-00 (one of three condensate pumps
and a
TEE, Number T-23, located at the discharge of X?P-28A-FW, feedwater
booster pump.
During the inspection and at the exit meeting the licensee was
informed of these discrepancies and agreed to address the lack of
agreement between the flow diagram data and the values listed in the
CHEC program,
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d.
Following t?,, inspection, the licensee submitted an explanation of
the discrepancies to the regional office.
The licensee's response
indicates where EPRI takes data input for the CHEC program, gives
more details regarding the two configuration of interest,f the
and
specifies a flow correction factor which applies to one o
configurations (8260-C07 orfice).
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The calculations and explanations are reproduced below:
260-C07 ORFICE
2.336 x 106 lb/hr
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System Flow )iagram Input
8882.2 gal / min
=
22 gal / min
at 106 F converted to Ib/hr:
22 gal / min
x
8.2698 lb/ gal @ 110 F x 60 min /hr =
4.37 x 106 lb/hr
The licensee's response indicates that the orfice is oriented in the
discharge of one of three condensate pumas two of which run during
normal plant operating conditions.
The
EPkl CHEC program therefore
treats the orfice as part of a standby com)onent.
The EPRI CHEC
program models this situation by assuming tlat all three condensate
gumps run continuously and multiplies the mass flow rate input by a
flow adjustment factor."
Flow adjustment factors are considered
necessary due to the non-linear relationship between velocity and
wear rate.
Shown below is ti.e calculation performed as outlined per the CHEC
Computer Program User's Manual Technical Report, NSAC-112 dated
February 1988 (page 11-6).
Orfice 8260-007:
From General Electric Guarantee Heat Balance flow from 2 of 3
condensate pumps is 4,323,479 lb/hr x 0.55* = 2.33 x 106 il/hr.
The result is consistert with the input to the CHEC program for the
260-C07 orfice.
"The0.55istheflowadjustmentfactorusedbytheCHECprogram.
T-23 TEE
CHEC Flow Inaut = 12.21 x 106 lb/hr
System Flow )iagram Input = 3.05 x 106 lb/hr
The licensee indicated that this TEE is 1 of 4 TEES which tie into a
This TEE is located such that it is the
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last TEE in line and receives full flow.
Since there are 4
condensate pumps, each with an output of 3.05 x 106 the following
holds:
3.05 x 106 lb/hr x 4 = 12.21 x 106 lb/hr.
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This value is consistent with the General Electric Guarantee Heat
Balance, and the CHEC program input.
Based on the above data from the licensee's response.
The
discrepancies between the flow diagram data and the input to the CHEC
program have been resolved.
6.
Exit Interview
The inspection scope and results were summarized on September 30, 1988,
with those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection results listed
below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.