IR 05000445/1989038
| ML20247B906 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/17/1989 |
| From: | Harris R, Kerch H, Oliveri M, Stronsnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247B840 | List: |
| References | |
| 50-445-89-38, 50-446-89-38, NUDOCS 8909130177 | |
| Preceding documents: |
|
| Download: ML20247B906 (15) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. ' 50-445/89-38 50-446/89-38-Docket Nos. 50-445 i
.50-446 License Nos. CPPR-126
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CPPR-127 Licensee: _ Texas Utilities Generating
.2001 Bryon Tower Dallas, Texas 75201 Facility Name:
Comanche Peak' Units 1 and 2
' Inspection.At: Glen Rose, Texas Inspection Conducted: July 17 through 27, 1989
Inspectors-
- AM/f W.~ Kerch, Senior Reactor Engineer date-8/t7/rf
. Har is, NDE Technician date 8//7///
/.j. Oliveri NDE Technici,an date F
A Approved by:-
8//7/47
. R. Strosnider, Chief, Materials and.
date Processes Section, EPB, DRS, Region I Inspection Summary and Conclusions: A routine unannounced inspection was conducted at Comanche Peak Nuclear Power Station on July 17 through
' July 27,1989, Report No. 50-445/89-38.
Areas Inspected: This inspection focused on preservice inspection activities, licensee. disposition of deficiencies reported, and the licensee's erosion / corrosion
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program.
. Summary and Conclusion: Three violations and three unresolved items were
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- identified during this inspection. Necessary corrective actions for significant deficiencies were not promptly identified and resulted in inappropriate correc-tive action by site engineering.
Preservice ultrasonic examination data of piping weldments are of poor quality and will not be of benefit during Inservice Inspections.
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DETAILS 1.0 1 Persons Contacted (30703)
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Texas Utilities Generating (TUGCO)
S.'G. McBee,-NRC Interface Susan Palmer, Stipulation Manager Fred W. Madden, Mechanical Engineer David L. Foken, Mechanical Engineer Ken Pointer, Licensing Engineer-J. T.' Maxwell, Quality Control Manager W. G. ' Guldemond, Manager Site Licensing '
S. L. Ellis, Test Manager._.
J. W.- Muffett, Manager, Engineering
- W. J. Cahill, Jr., Executive Vice President f
' Stone & Webster Engineering Corp. (SWEC}
Roger' Smith, Engineering h
li. P. Holland, Lead Structural Engineer T. W. Houston, Group Supervisor Citizens Association for Sound Energy (CASE)
Billie Gerde, CASE. Attorney T
U.S. Nuclear Regulatory Commission, Comanche Peak Division LA Sr H.Livermore,desidentInspector Resident Inspector R. M.. L a t t E,',
P; F. McKee, Deputy Director CPPD J. S. Weike, Reactor Engineer R. F. Warnick, Reactor Engineer
.The above listed personnel were present'at the exit meeting. The
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inspector-also contacted other administrative and' technical personnel during the inspection.
2.0 Independent Measurements - NRC Nondestructive Examination and Quality
. Records Review During the period of July 17 through July 27, 1989 an onsite independent inspection was conducted at Comanche Peak Nuclear Power Station. The inspection was conducted by NRC regional based inspectors. The objectives of this inspection were to assess the adequacy of the
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licensee's preservice inspection program, welding quality control program,
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and-erosion / corrosion program.
The licensee's actions regarding verification of'the "As-Built" configuration of pipe hanger / supports and the licensee's actions to disposition identified construction deficiencies were evaluated.
Examinations required of _ the licensee by regulations and codes were reper -
formed by-the NRC inspectors.
2.1 Nondestructive Examinations (NDE)
Visual Examination of Pipe Welds (57050)(nns o)
Forty-two safety related pipe weldments and adjacent base material (1/2 inch on either side of the weld) were visually examined in accordance with:NRC procedure NDE-10, Rev. O, Appendix A, and associated site QC documents isometrics and as-built drawings.
Included in this inspection were ASME Class 1 and 2 pipe weldments selected from the Safety Injection (SI) and Chemical Volume Control (CS) Systems. This examination was performed specifically to
. identify any crack: or linear indications, gouges, leakage, arc strikes with craters, or corrosion, which may infringe upon the minimun, pipe wall thickness Results The welding and overall workmanship inspected were satisfactory. Ne violations were identified.
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Visual Inspection of Hangers / Supports (57050)
During this inspection fifty-six safety related hanger / supports were visually inspected per NRC procedure NDE-10, Rev. 0, Appendix A and B in conjunction with site QC. documents, isometric / drawings.
Included in this inspection were hanger / supports selected from the
. Safety Injection (SI), Chemical Volume Control '(CS), Reactor Coolant (RC) and Residual Heat Removal (RHR) Systems.
In the areas of welds, the accessible surface area and adjacent base metal for a distance of one-half inch on either side of the weld was examinated.
- In the area of component integrity specific ' attributes looked for were proper installation, configuration or modification of supports, evidence of mechanical or structural damage, corrosion and bent, missing or broken members.
Results Welding and surface conditions were satisfactory, no violations were identified.
Liquid Penetrant Examination (57060)
Forty safety related pipe weldments and adjacent base material (1/2 inch on either side of the weld) were examined using the visible L-
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dye, solvent removable method per NRC procedure NDE-9, Rev. O, in conjunction with the licensee's procedure QCI-3.12,.Rev. 4.
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' Included in this~ sample were ASME class 1'and 2 pipe.weldments
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selected from the Safety Injection (SI) and Chemical Volume Control
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~(CS).
Results
. W'elding 'and surf' ace conditions were ' satisfactory,.no violations 'were.
' identified.
U1trasonic Examination'(57080)
Six safety related pipe weldments were ultrasonically examined using a Sonic Mark 1 ultrasonic flaw detector.
These examinations were performed in accordance with NRC procedure NDE-1, Rev. O and associated site drawings, procedures and ultrasonic -
test data reports. The instrument calibration.(vertical ~and amplitude linearity) was performed per NRC procedure NDE-2, Rev. O.
A distance-amplitude correctior,. curve (DAC) was constructed using the licensee's-calibration blocks, TBX-9 and.TBX-5. To ensure repeatability of the ultrasonic examination, the instrument setting and-search unit (transducer) were matched as near as' possible to those indicated by the licensee's ultrasonic data reports.
Results An ultrasonic examination of weld.7, TBX-2-2523; in the-safety injection system revealed an indication which was greater than 50% 'of the DAC.
In accordance with the.ASME Boiler and Pressure Vessel Code ~,Section XI,
~ 1980 Edition, paragraph IWA 2232(b)(c) for examination of welds, reflectors that produce a response greater than 50% of the reference.
. level 'shall be recorded. The reflector that was identified by the NRC was confirmed by the utility as being over 50% of DAC.-
However, the PSI Ultrasonic data report did not show this reportable reflector.
As discussed 'in Section 3.0, further investigation by the inspector revealed that this deficiency was the result of an improper procedure.
Erosion / Corrosion Examination (57080)
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Seven grid locations were selected for independent erosion / corrosion
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examinations by the NRC inspectors.
Included in this examination i.
were piping from the Condensate (Co) and Feedwater (FW) systems (grid numbers C003, C010, 0013, C014, C016, FW13, and FW29). A Nova D-100 l-digital thicknev, gauge was used to acquire the data in accordance with NRC procedure NDE-11, Rev. O and the Comanche Peak " Corrosion Monitoring Plan." The software for data storage and analysis was also reviewed during this inspection.
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Results-The NRC acquired. data showed no discernible. difference from the' data m
.taken by technicians from Comanche Peak.
The grids were marked on components in a way to ensure repeatable data collection.
The data storage and analysis' software is developed to engineering in identify-ing minimum' wall violations and help establish erosion / corrosion wear rates'in:the future.
Service Water Erosion / Corrosion Unit 1~(92701)
The. inspectors performed a follow-up inspection on the previously E
identified problem.of sandblast coating. removal, corrosion and remote v.isual inspection of.the 10" piping.of the Unit I service water system.
NRC inspection reports' 88-47, 88-48 and 89-44 and Texas Utilitier.
Engineering Report.ER-ME-19, dated. September 21, 1988 were reviewed.
These reports documented the' licensee's corrective actions to assure that minimum wall thickness requirements were satisfied for the service water piping.
These. actions included replacement of some spool pieces'and additional inspections. Also, at discussed below,
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.the procedures for. ~ removal of coating and visual. examinations were modified for' Unit 2 to avoid the type of problems that occurred'at Unit 1.. The inspector had no further concerns regarding this issue and considers the Service Water 10" piping issue closed for Unit 1.
Service' Water Erosion / Corrosion Unit 2 (92701)
During this inspection, the licensee was performing removal of coatings by sandblasting and remote visual examinations'of the Unit'2 Service Water piping system. Several procedures dealing with these operations (included in Attachment 3) were reviewed by the inspectors and found
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to be acceptable.
3.0. Review of Site NDE Procedures and Manuals (57050)(S7 o lo)
The procedures listed in Attachment 3 were reviewed in the regional office -
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during this inspection period for compliance to the licensee's FSAR commit-
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ments and applicable codes, standards and specifications.
Results Westinghouse procedure, Manual Ultrasonic Examination of Welds Section 7.0, reads in part that valid flaw indications which provide a response equal to or greater than 50% of primary DAC shall be considered a recordable indication. 'Section 6.0 of the procedure, interprets valid indications to be reflectors cause by flaws, such as cracks, lack of penetration or fusion, inclusions and porosity.- This is not in accordance with ASME Code Section XI,1980 Editior which in part reads, all reflectors that produce a response of 50% or greater shall be recorded.
This procedural deficiency is a violation of 10CFR 50, Appendix B, Criterion IX (50-445/89-38-04). As indicated in Section 2.1 of this report, independent NRC inspection identified a Code recordable indication that was not recorded because of this procedural deficiency.
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.4.0 Preservice Inspection (PSI) Program '(73055)'(73051) (73053)(75cr2[
The Comanche Peak Unit 1 preservice inspection.has been completed, Comanche Peak's program was prepared and implemented by Westinghouse.
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The PSI program incorporates the requirements of the ASME Boiler and Pressure Vessel Code,Section XI 1980 supplemented by additional
requirements of USNRC Reg. Guide 1.150. The 1icensee has requested relief from specific ASME Code requirements applicable to'this program,.
which they feel are impractical.
Such requests with technical
' justification for relief have been submitted to the NRC for review.and approval.
Reviews-The inspector reviewed the following to ascertain. compliance with applicable ASME code requirements, license commitments, and' regulatory requirements.
The preservice inspection program
Personnel certification records for qualification of PSI contractor
personnel PSI examination-data reports
NDE procedures
In addition, the inspectors witnessed a liquid penetrant PSI examination reperformed by the licensee. The NRC inspectors reperformed visual, 14 quid penetrant and ultrasonic examinations on a selected sample of welds.
Listed below are concerns that were identified during these inspections.
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The volume of weld examined by the licensee was not adequately
documented (no plots existed to assure proper ultrasonic coverage, only estimated percentages were provided on final NDE reports).
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Examination limitations were not properly' documented.
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Ultrasonic examination reports of record did not have dispositions
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as to the acceptability of examination results.
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Improper documentation of reflectors greater than 50% of DAC.
- Results Because of deficiencies in the documentation of preservice ultrasonic examination data the licensee's PSI program has riot provided a good baseline for future inservice inspections (ISI).
The lack of good documentation will complicate the evaluation of ISI data.
The licensee should ensure that data taken during ISI are adequate to provide a good baseline for future examination.
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This item is unresolved pending licensee action and NRC review (Unresolved Item 50-445/89-38-01).
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PSI Calibration Blocks The licensee does not have as-built drawings of the site preservice inspection calibration blocks.
There are approximately 44 calibration blocks. Because of the lack of as-built drawings it could not be verified that the blocks satisfy the 1980 ASME Section XI PSI requirements or the 1986 ASME Section XI requirements applicable to future inservice inspections.
This item is considered unresolved pending licensee action to verify accept-ability of the calibration blocks (Unresolved item 50-445/89-38-02).
PSI Procedure OPS-NSD-101, Rev. 5 dated April 8, 1975 Forms used during the PSI examinations were different than the ones contained in the procedure ann the explanation in the procedure of what information needs to be incl Ned on the forms was inadequate for the ultrasonic data taken during che PSI. This issue is unresolved pending licensee action and NRC review (Unresolved Item 50-445/89-38-03).
PSI Reactor Vessel Nozzle Inner Radius (73055)
During the review of PSI data two concerr.s was idenu tied regarding the reactor sessel nozzle inner radius preservice inspections.
1.
The inspector discussed the rationale for performing manual ultrasonic examinations from the inner surfaces of the reactor vessel nozzles, when radiological conditions will prohibit manual examination during inservice.
It was determined that during the PSI, the automatic equipment was unable to perform the maneuvers required to completely examine the nozzle inner radius and manual examination was needed as a supplement.
Since that time the capability of the automatic equip-ment to provide the required examination coverage has been developed and a completely automated preservice exam has been completed.
2.
There was no evidence of the required approvals for PSI procedure 151-155, Manual Ultrasonic Examination of Nozzle Inner Radius, by the authorized inspection agency nor the 1icensee. Documentation was found that indicated the procedure had received a review. To supplement this the licensee is resubmitting 151-155, Rev. O procedure to the authorized Nuclear Inservice Inspector and the licensee's NDE Level III for review in order to have evidence of proper reviews of acceptability.
Result The inspector has no further concern and considers these subjects closed.
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- 5.0'. Electrical penetrations (92706)
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The' licensee. identified by deficiency report DR-C-88-02376, dated
< October. 25, 1988, that the electrical penetrations (full penetration weld-ments) did not have the ASME code required radiography examination performed during the construction phase. The containment structural integrity test had been. performed and fuel load was scheduled in approximately 70 days at the time of this report. The Comanche Peaks Unit I FSAR~ requires that the 77 ' electrical penetrations meet ASME Boiler and pressurize-Vessel Code,Section III, Division I, Subsection NE, 1971 through and including the
.1973 Summer addenda for the full penetration Class II welds.
In addition, Gibbs and Hill's Specification 2323-S5-14, Rev. 4 requires these electrical penetrations to be fully examined in accordance with the examination methods of NE-5120 of Section III of the ASME Boiler and Pretsure Vessel code.
The inspector reviewed the actions taken by the licensee to resolve this nonconformance. The licensee stated that they had performed a stress analysis of 'the subject penetrations and that a change to the FSAR to eliminate the code required volumetric examination of the welds planned to be submitted to the NRC. The inspector performed a walkdown of the electrical penetrations.and concluded that radiography was not suitable at this time, however, the code required volumetric examination of the penetra-c tions could be met by performing ultrasonic examination.
Stress analysis is not a. substitute for the performance of nondestructive. testing that is intended to verify the acceptable quality of fabricated components.
It was evident that' adequate engineering corrective action had not taken place and the disposition was inadequate. This is a violation of NRC requirements (50-445/89-38-06).
At the conclusion of this inspection, the licensee was preparing to perform ultrasonic examinations of.the electrical penetrations.
6.0 Fuel' Transfer Tube penetration Sleeve Weldments (92706)(ri c)9 o')
The licensee identified in deficiency report DRC-88-02376, dated October 25,.1988, that the fuel. transfer tube penetration sleeve did not have the ASME Section III code required radiography examinations for the full penetration Class II weldments (IA, 18, 2A and 28). DRC-88-02376 required the fuel transfer tube weldments to be radiographer. Nonconfirmance report number 89-04023, Rev.1, dated April 4,1989, was initiated and these welds were radiographer on June 3,1989 and rejected for gross welding defects in accordance with site radiographic procedure AQP-10.4.
NRC review of this deficiency revealeo the following:
DCA-6500 issued March 19, 1980 did not incorporate on the DCA drawing
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the required engineering design (wald symbol) for the required full penetration weldments.
This DCA also did not contain the NDE require-ments for 100% radiography for these weldments. The requirements for
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full penetration welds and for 100% radiography were established in FSAR Section 3.8.1.2.3, through reference to the ASME Boiler and Pressure Vessel Code,Section III, Division I, Subsection NE,1971 through and including the 1973 Summer Addenda. Gibbs and Hill's site specification for containment Stee? Liner 2323-SS-14, Section 10.2.3 also specified the requirement for full penetration welds and 100%
radiographic inspection.
The control, verification and site quality requirements for this
Field Design change were not in accordance with site procedures CP-EP-4.6, CP-EP-4.5 and CP-EP-4.0.
These deviations were not promptly identified.
- The disposition of NCR-89-04023, Rev. I accepted "as-is" the Class III
weldments (IA, IB, 2A and 28) with rejectable radiographic indica-tions. This is not an appropriate in that an adequate corrective action is to repair the radiographic rejected areas in accordance with ASME Section III requirements and post repair magnetic particle examinations and radiography in accordance with ASME Section III,
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i NE-5120 and as required by site specification 2323-SS-14. This is a violation of NRC requirements (50-445/89-38-05).
7.0 Attachments Attachment No.1 is a tabulation of specific pipe weldments and components examined. Attachment No. 2 is a tabulation of specific hanger / supports e,xamined. Attachment 3 is a list of the NDE procedures reviewed.
8.0 Unresolved Items i
Unresolved. items are matters about which more information is required in order to ascertain whether they are acceptable items or violations.
Three unresolved items appear in paragraph 4.0.
9.0 Management Meetings (30703)
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Licensee management was informed of the scope and purpose of the j
inspection at the entrance interview on July 5, 1989. The findings of the inspection were discussed with the licensee representatives during the course of the inspection and presented to licensee management at the exit interview (see paragraph 1.0 for attendees).
At no time during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involveo within the scope of this inspection.
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ATTACHMENT 3 Westinghouse Nuclear Services Division (NDIS)
-Procedure Title Number / Revision Westinghouse Preservice and Inservice Examination
' Documentation INT-ISI-101, Rev 0 Magnetic Particle Examination INT-ISI-70, Rev 0 Liquid Penetrant Examination INT-ISI-11, Rev 0 Visual Examination INT-ISI-8, Rev 0 Manual Ultrasonic Examination of Welds in Vessels INT-ISI-47, Rev 0 Manual. Ultrasonic Examination of Welds INT-ISI-206, Rev 0
. Reactor Vessel Inspection Program Preparation and Documentation RV-ISI-01, Rev 1 Preservice Inspectien Reactor Vessel 151-154, Rev 1 Manual VT Examination-of Reactor
.
Nozzle Inner Radius 151-155, Rev 0 Manual VT Examination of Full Penetration Circumferential and Longitudinal Butt Welds ISI-205, Rev 2 Magnetic Particles ISI-70, Rev 2 Texas Utilities Generating Company (TUGCO)
Corrosion Monitoring Program Ultrasonic Measurements NQA 3.09-8.47, Rev 0 Visual Examination VE-I, Re~v1 Radiography RT-ANSI-831.1, Rev 0 Coating Removal of 10" Piping
.QCP-2, Rev 0 Quality Personnel for Abrasive Blast Removal DCA 8S609, Rev 2 Remote Visual of 20" Piping After Plastic Removal 2 PPT-40.9 Remote Visual of 10" Piping Prior to Plastic Removal 2 PPT-40.8 Design Verification CP-EP-4.5 Field Design Change Control Procedure CP-EP-4.6 Design Central General CP-EP-4.0
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ATTACHMENT 3
.
i Procedure Title Number / Revision Oliver B. Cannon, Coating Removal by Abrasive Blasting CSPVL339 (QCP-1, Rev 2 Brown and Root Remote Visual Examination AQP-10.11 Radiographic Examination AQP-10.4 Stone and Webster Engineering Qualification for Remote Spin Blast for 10" Piping SW-TP-ME-03, Rev 1 Qualification for Handheld Blast for 24" and 30" Piping SW-TP-ME-02, Rev 1 Gibbs and Hill Design Specification for Containment Steel Liner 2323-55-14
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