IR 05000400/1987027
| ML18022A550 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/29/1987 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18022A549 | List: |
| References | |
| 50-400-87-27, NUDOCS 8708100457 | |
| Download: ML18022A550 (19) | |
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UNITEO STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323 Report No.:
50-400/87-27 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
July 6-10, 1987 Inspector:
W. P.
K einsorge Approved by: A5, JC J. J.
B a e, Section i f Engineering Branch Division of Reactor Safety License No.:
NPF-63 Date Signed 7/'p/rP Date Signe SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of In-service Inspection ( ISI) (73051)
(73052)
and inspector follow-up items.
Results:
No violations or deviations were identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. A. Watson, Vice President Harris
- E. L. Betz, Principal Nondestructive Examination Specialist
- M. M. Pugh, Technical Support - ISI
- S. M. Pruit, Technical Support - ISI
- M. Wallace, Regulatory Compliance Other licensee employees contacted included engineers, technicians, and office personnel.
NRC Resident Inspectors
- G. Maxwell, Senior Resident Inspector
- S. Burris, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were suomarized on July 10, 1987, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
(Open)
Unresolved Item 50-400/87-27-01:
"Special Process Record Storage Requirements
" paragraph No. 5a(3)(a).
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items are matters about which information is required to determine whether they are acceptable or may involve violations or deviations.
One new, unresolved item identified during this inspection is discussed in paragraph 5a(3)(a).
5.
Inset vice Inspection (ISI)
The inspector reviewed procedures, interviewed licensee/contractor personnel and reviewed-records to determine whether the licensee's program pertaining to the ISI is complete and in conformance with regulatory requirements and the licensee's commitments, as indicated below.
The applicable Code for Preservice Inspection (PSI)
was ASME Boiler and Pressure Vessel (ASME BSPV)
Code Section XI 1980 Edition, Winter 1981 Addenda (BOW81).
The= licensee has not submitted their inservice inspec-tion program/plan to the Commission as of this writing; therefore, there is no commitment for an ISI Code of record.
The plant which commenced commercial operation on May 2, 1987, is in the first 40 month period of the first ten year ISI interval.
The licensee informed this inspector that they intend to submit the ISI program/plan to the Commission by October 1, 1987.
The first ISI will be performed during the first scheduled refueling outage planned for August 1988.
The licensee intends to commit to the 83S83 Edition Addenda of ASME BSPV Code Section XI with.inspection Program B of IWA-2420.
Review of Program (73051)
(1)
Program Approval The inspector interviewed personnel and reviewed documents indicated below to determine whether requirements were met in the following areas:
ISI program, including examinations and tests, in conformance with relevant ASME Code Section XI editions and addenda, and Code cases proposed for use as part of the plan; services of an Authorized Nuclear Inservice Inspection (ANII) have been procured and the ISI plan has been reviewed by the ANII in accordance with Article IWA-2120 of the ASME Code; and the ISI plan has been reviewed by the licensee's site'uclear safety review committee, or equivalent licensee review and approval has been documented.
The inspector substantiated that the licensee has procured the services of an ANII.
The remainder of this area cannot be examined until the licensee submits their, inservice program/
plan.
(2)
Program Organization As discussed above, this area could not be examined because the ISI program/plan has not been submitted to the Commission.
(3)
guality Assurance Program The inspector reviewed the licensee and ISI contractor's gA programs to verify the following:
procedures for the mainten-ance of required ISI records; gA review includes assurance that
plans and procedur'es have been reviewed by appropriate personnel and meet regulatory'requirements; procedures are established for the corrective action of conditions adverse to quality as detected during examination, including provisions to preclude repetition of such adverse conditions; audits or surveillance of ISI activities are conducted by qualified QA personnel to verify compliance with the ISI program; and procedures are established to effectively oversee contractor activities concerned wi,th ISI/PSI.
With regard to the examination above, the inspector noted the following:
(a)
The procedure for maintenance for required ISI records,
-CP8L-RMP-006 Rev. I specifies the following environmental requirements for records:
temperature range of 32'F to 70'F and 30% to 70K relative humidity.
"Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plants" dated 1974 states;
"5.4.3.
Special Processed Records.
Special processed records (such as radiographs, photographs, negatives, and microfilm) which are light-sensitive, pressure sensitive or temperature sensitive shall be packaged and stored as recommended by the manufacturer of these materials."
The licensee was unable to provide Objective Quality Evidence (OQE) that the values indicated above are consistent with the recommenda-tions of the manufacturer of radiographic film, photo-graphic image mediums, audio tape, strip charts, computer diskettes and microfilm.
The licensee indicated that they would contact the manufacturers of the above special process record mediums to substantiate the adequacy of the procedural environmental requirements.
Pending NRC review of the manufacturers's responses, this matter will be identified as Unresolved Item 50-400/87-27-01,
"Special Process Record Storage Requirements."
(b)
The current ISI program does not include the following:
provisions to effectively oversee contractor activities; and adequate specific guidance for review of responsibilities for ISI plans, programs and procedures.
The licensee indicated that they would make appropriate changes to the ISI program plan and procedure revisions now in process.
(4)
Repair Program The inspector reviewed the licensee's administrative and mainten-ance procedures indicated be'low to verify that the requirements of Article IWA-4000 of the ASME Code, and NRC supplementary requirements,'re included or reference (5)
Replacement Program The inspector reviewed the licensee's administrative and maintenance procedures indicated below to verify that require-ments of Article IWA-7000 of the ASME Code, and NRC supplemen-tary requirements, are included or referenced.
Records (8)
The inspector reviewed procedures and records indicated below to determine whether provisions for the maintenance and retention of records, including inspection, examination, test reports, repair and replacement, gA, and NDE records have been estab-lished in the ISI program.
This matter is discussed in para-graph 5a(3)(a)
above.
qualification of Personnel The inspector review procedures indicated below to determine whether the ISI program specifies personnel qualification-requirements consistent with ASME Code, plant Technical Specifications (TS),
and other applicable documents.
Reporting Requirements The inspector reviewed procedures indicated below to determine whether the licensee's ISI program includes the ASME Code and plant TS requirements for submittal of written reports of ISI results, repairs, and replacements.
The current ISI program does not have adequate specific guidance for reporting requirements.
The licensee indicated that they would make appropriate changes to ISI plans, program and procedures revisions now in process.
Relief Requests The inspector reviewed. procedures indicated below to determine whether the licensee's program contains guidance regarding the identification and processing of requests for relief from ASME Code requirements.
The current ISI program does not have adequate specific guidance for the "identification and processing relief requests.
The licensee indicated that they would make appropriate changes to the ISI plans, programs and procedure revisions now in proces (10)
The following documents were reviewed for the above examinations.
Identification Title CP8L Contract No. XM160330000 with Contract Amendment No.
CP&L-ISI-101, Rev.
CP8L-AP-'006, Rev.
CP&L-RMP-001, Rev.
CP8L-RMP'-006, Rev.
Contract with Lumbermens Mutual Casualty Company for inservice services Inservice Inspection Program (ISI)
Procedure Review and Approval Filling Index and Instructions Records Storage Area CP&L-PLP-605, Rev.
CP8L-PLP'-603, Rev.
CP8L-MMM-013, Rev.
ASME Boiler and Pressure Vessel Code Section XI Repair and Replacement Program Plant Performance
'rogram Maintenance History Records CP8L-NDEP-10, Reve9 CP&L-NDEP-20, Rev.
Training qualification and Certification of Nondestructive Examination Personnel Training qualification and Certification of Visual Examination Personnel for Inservice Inspection
CP8L-O(A-103, Rey.
CPSL-OgA-201, Rev.
b.
Review of Procedures (73052)
( 1)
Program Requirements Personnel Indoctrination Training qualification and Certification Surveillance Program The inspector reviewed the licensee's commitments in the SAR, Technical Specification (TS),
and approved ISI program to ascertain whether ISI procedures adequately cover all areas specified in the licensee's commitments for ISI and PSI require-ments.
(2)
Procedure Approval The inspector reviewed the below listed procedures to determine whether the ISI procedures have been approved by authorized licensee personnel and by the Authorized Nuclear Inservice Inspection (ANII) where applicable.
Identification Documents Examined Title CPSL-NDEP-10, Rev.
Training, gualification and Certification of Nondestructive Examination Personnel CP&L-NDEP-20, Rev.
Training, gualification Certification of Visual CPSL-NDEP-50, Rev.
gualification of Nondestructive Examination Procedures CPEL-NDEP-101, Rev.
CPSL-NDEP-201, Rev.
CPSL-NDEP-202, Rev.
Radiographic Examination Liquid Penetrant Examination (Visual Dye, Solvent Removable)
Fluorescent Penetrant Examination
CP8L-NDEP-301, Rev.
CP8L-NDEP-302, Rev.
CP8L-NDEP-303, Rev.
Magnetic Particle Examination (Dry Powder, Prods and Yoke)
Magnetic Particle Examination (Dry Powder, Coil of Cable Wrap)
Wet Magnetic Particle Examination CP8L-NDEP-611, Rev.
CPSL-NDEP-612 CP8L-NDEP-613, Rev.
CP8L-NDEP-614, Rev. '6 VT-1 Visual Examination of Nuclear Power Plant Components VT-2 Visual Examination of Nuclear Power Plant Components VT-3 Visual Examination of Nuclear Power Plant Components VT-4 Visual Examination of Nuclear Power Plant Components With regard to the review above, the inspector noted that the ANII had not reviewed any of the current revisions of the above procedures.
The ANII had, however, reviewed previous revisions of all the above procedures.
The licensee indicated that the above procedures are currently under reviSion and will be reviewed by the ANII.
(3)
Nondestructive Examination (NDE)
(a)
Procedure Review The inspector reviewed the procedures indicated in para-graph (b)
below to determine whether requirements are specified and agree with licensee's coranitments including specified or referenced acceptance levels; qualifications of NDE personnel are specified in accordance with the licensee's approved ISI program; methods of recording, evaluating, and dispositioning findings are established and reporting requirements are in compliance with applicable Code requirements; and procedures delineate the scope of work and division of responsibilities between the licensee and the contracto (b)
Technical Content Visual Examination The inspector reviewed the below listed visual examination procedures to determine whether they contain information or reference to a
general inspection procedure or supplementary instructions sufficient to assure that all parameters are specified and controlled within the limits permitted by the appli-cable Code and other additional specification require-ments; all essential examination variables are defined and whether these variables are controlled, within the limits specified by the applicable Code and other additional specification/contract requirements.
Specific areas examined were:
method; application; how visual examination is to be performed; type of surface condition; method or tool for surface prepara-tion, direct or remote viewing; special illumination, instruments, or equipment; sequence of performing examination; data to be tabulated; acceptance criteria are specified consistent with the applicable Code and report form or general statement to be completed.
Procedures Examined NDEP 611 NDEP 612 NDEP 613 NDEP 614 2)
Liquid Penetrant Examination The inspector reviewed the below listed liquid penetrant examination procedures to determine whether they contain information or reference to a general inspection procedure or supplementary instructions sufficient 'to assure that all parameters are specified and controlled within the limits permitted by the applicable Code and other additional specification requirements; all essential examination variables are defined and whether these variable are controlled within the limits specified by the applicable Code.and other specification/contract requirements.
Specific
'reas examined were:
specified test method is consistent with applicable Code requirements; brand names and specific types (number or letter designation if available of penetrant, penetrant remover, emulsifier and developer are specified; penetrant materials used for nickel base alloys ape required by
procedure to be analyzed for sulfur using the method prescribed by the applicable Code; penetrant materials are required by procedure to be analyzed for total halogens using the method prescribed in the applicable
'ode; method for acceptable pre-exami nation of surface preparation are specified and consistent with the applicable Code, area to be cleaned is consistent wi th applicable requirements, cleanliness acceptance requirements are consistent with applicable Code requirements; procedure established a minimum drying time following surface cleaning; method of penetrant application and penetration (dwell) time are specified and that the penetration time is consistent with the penetrant manufacturer's recoranendation; examination
.
surface is specified and is consistent with the applicable Code; procedures (when applicable)
specify acceptable methods for removing water-washable penetrant consistent with the applicable Code; method of applying emulsifier (when app'licable)
and the maximum emulsification time is specified and consis-tent with the applicable Code; methods for removal of solvent removable penetrant (when applicable)
are specified; method and time of surface drying prior to developing is specified; type of developer to be used, method of developer application and the time interval between penetrant removal and developed application specified; examination technique is specified and the permitted time interval during which the "final interpretation" is performed within the range of 7-30 minutes after developer application; minimum light intensity at the inspection site is prescribed; technique for evaluation of indications is specified, acceptance standards are included and these are consistent with applicable Code and specific contract requirement; reporting requirements are specified; and procedure requires requalification when changes are encountered.
Procedures Examined
.NDEP-201 NDEP-202 Magnetic Particle Examination The inspector reviewed the below listed magnetic particle examination procedures to determine whether they contain information or references to a general inspection procedure or supplementary instructions sufficient to assure that 'all parameters are specified and controlled within the limits permitted by the applicable Code and other additional specification
requirements; each essential examination variable is defined and whether these variables are coritrolled within the limits specified by the applicable Code and other specification/contract requirements.
Specific areas examined were:
method - continuous; surface preparation; particle contrast; surface temperature; light intensity; coverage; prod spacing; magnetizing current yoke pole spacing; and acceptance criteria are specified consistent with the applicable ASME Code Section and specific contract requirements.
Procedures Examined NDEP-301 NDEP-302 NDEP-303 Radiographic Examination The inspector reviewed the below listed radiographic examination procedure to determine whether it contain information or references to a
general inspection procedure, or supplementary instructions sufficient to assure that all parameters are specified and controlled within the limits permitted by the applicable Code and other additional specification
,requirements; all essential examination variables are defined and whether these variables are controlled within the limits specified by the applicable Code and other specifi-cation/contract requirements.
Specific areas examined were:
material and weld surface condition requirements; types of material to be radiographed; material thickness range; type of radiation source, effective focal spot or effective source 'size, X-ray equipment voltage rating and equipment manufacturer, as applicable; file brand or type and number of films in cassettes; minimum source to film distance; blocking or masking technique, if used; type and thickness of intensifying screens and filters; exposure conditions for procedure qualification, if applicable; radiographic film require-ment; quality of radiographs; film density limits for single and composite viewing; use of densitometers for assuring compliance with film density requirement; system of radiograph identification; use of location markers; records for showing film and source location'ith reference to the part being radiographed; use of intensifying screens; methods of reducing and testing for backscatter; description of or reference to the welding procedure; material type thickness restriction for isotope radiography; geometrical unsharpness
limitations; selection and use of penetramenter including penetrameter design, selection of essential hole, penetrameter* thickness including special require-ments for single and double wall viewing, penetrameter placement including special requirements for single and double wall viewing, number of penetrameter, radiographic technique requirements for doub'le wall viewing; qualification of radiographic procedure; requirements for evaluation and disposition of radiographs; and records requirements.
Procedure Examined
, NDEP-101 With regard to the examination above, the inspector noted the following discrepancies.
NDEP 303 and 202 do not address that fluorescent examiners sha11 be in a
darkened area for at least five minutes prior to performing the examination to enable his eyes to adjust to dark viewing and not be photo sensitive'.
This is contrary to good industry practice.
The ASME has added this as a requirement to the 1983 Edition of Code Section V.
NDEP 202 does not specifically require the use of a
calibration light meter for ultraviolet light intensity measurements.
The licensee indicated that they would make appropriate changes to the procedure revisions now in process.
(4)
Code Repair and Replacement Procedure Review The inspector reviewed repair and replacement procedures indicated below to ensure that the elements of the procedures are consistent with the applicable areas of the ASME Code and the approved ISI program.
The specific elements examined were:
Repair:
identification of the NDE method that revealed the flaw and the description of the flaw; description of the flaw removal method; procedure for weld and postweld heat treatment, if applicable, including review of procedures for welding prior to authorization of the repair and review provisions for using the services of an Authorized Inspec-tion Agency when making a weld repair, as well as for having the ANI review and approve the repair procedure
before used after the repair is completed; and delinea-tion of the scope, of work and division of responsibilities between the licensee and contractor, if a contractor is used.
Replacement:
provisions to verify that the replacements met the requirements of the edition of the Construction Code to which the original component/part was constructed, the provisions of later editions of that same Code, or Section III of the ASME Code; provisions to ensure that the replacements ordered as spares met the requirements of the appropriate Construction Code used for the part/
component it was intended to replace, the provisions of later editions of that Code, or Section III of the ASME Code; justification, consistent with NRC guidelines, for not requiring a
Code Stamp; evaluating of the suitability of the replacement prior to authorizing its installation; retention of reports and records as required by the Construction Code and ASME Code Section XI; and performance of a PSI prior to the return to service of the replacement component or part in accordance with the applicable code.
Work Packa es Reviewed S-RC-03-01 P84 ICS024 SIJ201 Within the areas examined, no violations or deviations were identified.
6.
Inspector Follow-up Items (Closed)
Item 50-400/86-29-016;
"Intervals guality Release" This item concerns the fact that during the 86-29 inspection the inter'vals
'quality release was not available for review.
The licensee has now made the quality release available to the inspector.
This item is considered closed.
Within the areas examined, no deviations or violations were identified.