ML14175B306
| ML14175B306 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/11/1985 |
| From: | Blake J, Kleinsorge W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B304 | List: |
| References | |
| 50-261-85-22, NUDOCS 8508080384 | |
| Download: ML14175B306 (11) | |
See also: IR 05000261/1985022
Text
C1jptREG&j4
UNITED STATES
o
NUCLEAR REGULATORY COMMISSION
4o
REGION II
o 0101
MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.: 50-261/85-22
Licensee:
Carolina Power and Light Company
411 Fayetteville Street
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson
Inspection Conducted:
June 24 - 28, 1985
Inspector:
<'E
_I__
__7
11
_
_
W. P. Keinsorge
Date Signed
Approved by: & ,e.
-7,1 5
J. J. Blake, Section Chie
V
Date Signed
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection entailed 42 inspector-hours on site
in the areas of Licensee action on previous enforcement matters (92702B), Service
Water Piping degradation (92706B),
Inservice Testing of Pumps and Valves,
and
Inspector Followup Items.
Results:
One violation was identified - "Failure to Perform IST in accordance
with ASME Section XI - paragraph 7a.
No deviations were identified.
8508080384 850717
ADOCK 05000261
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- R. E. Morgan, Plant General Manager
- J. Curley, Manager of Technical Support
- D. Stadler, Director of Regulatory Compliance
- W. Farmer, Sr. Engineer - Inservice Inspection
C. Hawley, Project Engineer - Plant Engineering
Other licensee employees contacted included engineers, technicians, and
office personnel.
NRC Resident Inspectors
- H. Krug
- H. Whitcomb
.
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on June 28,
1985, with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection findings listed
below. No dissenting comments were received from the licensee.
(Open) Violation 50-261/85-22-01: "Failure to Perform IST in Accordance with
ASME Section XI - paragraph 7.a.
(Open)
Unresolved Item 50-261/85-22-02:
"Allowable Delta P Range"
paragraph 7.b.
The licensee did identify as proprietary materials provided to and reviewed
by the inspectors, however, this material is not discussed in this report.
3. Licensee Action on Previous Enforcement Matters (92702)
a. (Closed) Violation 261/84-11-01: "Procedure Inadequate for Segregation
of Weld Rods with Exposure Time"
Carolina Power and Light (CP&L) letters of response dated June 8 and
July 24,
1984 have been reviewed and determined to be acceptable by
Region II. The inspector held discussions with the responsible
engineer and examined the corrective actions as stated in the letters
2
of response. The inspector concluded that CP&L had determined the full
extent of the subject noncompliance, performed the necessary survey and
follow-up actions to correct the present conditions and developed the
necessary corrective actions to preclude recurrence of similar circum
stances. The corrective actions identified in the letters of response
have been implemented.
b. (Closed) Violation 261/84-27-01: "Failure to Identify Valve Status"
CP&L letter of response dated September 14, 1984 has been reviewed and
determined to be acceptable by Region II.
The inspector held
discussions with the responsible engineer and examined the corrective
actions as stated in the letter of response. The inspector concluded
that CP&L had determined the full extent of the subject noncompliance,
performed the necessary survey and follow-up actions to correct the
present conditions and developed the necessary corrective actions to
preclude recurrence to similar circumstances. The corrective actions
identified in the letter of response have been implemented.
c. (Closed) Violation 261/84-27-02: "Failure to Follow RT Code"
CP&L letter of response dated September 14, 1984 has been reviewed and
determined to be acceptable by Region II.
The inspector held
discussions with the responsible engineer and examined the corrective
actions as stated in the letter of response. The inspector concluded
that CP&L had determined the full extent of the subject noncompliance,
performed the necessary survey and follow-up actions to correct the
present conditions and developed the necessary corrective actions to
preclude recurrence to similar circumstances.
The corrective actions
identified in the letter of response have been implemented.
d. (Closed) Violation 261/85-12-01: "Failure to Provide Adequate IST
Procedure"
CP&L letter of response dated April 9, 1985 has been reviewed and
determined to be acceptable by Region II.
The inspector held
discussions with the responsible engineer and examined the corrective
actions as stated in the letter of response. The inspector concluded
that CP&L had determined the full extent of the subject noncompliance,
performed the necessary survey and follow-up actions to correct the
present conditions and developed the necessary corrective actions to
preclude recurrence to similar circumstances. The corrective actions
identified in the letter of response have been implemented.
e. (Closed) Unresolved Item 261/84-11-02: "Uncontrolled Copy of Cooperheat
QA Manual"
This item concerned the fact that at the time of the 261/84-11
inspection, Cooperheat did not have a controlled copy of their Quality
Assurance (QA) Manual onsite. The licensee determined that no work was
performed to an uncontrolled cooperheat QA Manual.
The manual was an
3
information copy of the latest revision - July 1983.
The July 1983
revision was in effect at that time and it
is also the current
revision. There are no copies of the Cooperheat QA manuals on site now
to verify the above, therefore, this matter is considered closed.
4. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia
tions. New unresolved items identified during this inspection are discussed
in paragraph 7b.
5. Independent Inspection Effort (92706B)
The inspector conducted a general inspection of the protected area to
observe activities such as welding, material handling and control, house
keeping and storage.
Within the areas examined, no violations or deviations were identified.
6. Service Water Piping Degradation (92706B)
a. Background
The degradation of the service water system is described in RH Report
No. 261/84-45. Additional inspection in this area is reported in RH
Report Nos. 261/84-48 and 261/85-12. This inspection is a continuation
of the inspection described in the above reports.
The licensee committed in CP&L letter RESP/84-1267,
dated January 4,
1985, to an inservice monitoring program to include 15 service water
welds that would represent a variety of configurations, lengths of
corrosion (microbiological attack) and sleeved as well as nonsleeved
joints. These joints were to be radiographed (baseline) prior to start
up and re-radiographed (inservice monitoring) in six weeks +/- one week.
Should no further attack be identified the next radiographic examina
tion would be scheduled three months +/- two weeks later.
The licensee radiographed fifteen weld joints (baseline)
on
December 12, 1984, (except for weld 2SO3-2 radiographed on November 19,
1984), re-radiographed the same 15 weld joints on February 26,
1985,
and re-radiographed the same 15 weld joints between May 31,
1985 and
June 14, 1985.
In addition two more welds 3-SO3-3 and 3-SO3-5, were
added to the sample.
b. Inspections
The inspector reviewed the radiographs that had been taken, 17 joints
(baseline) and the same 17 joints (inservice monitoring). The licensee
informed the inspector that the above radiographs were for information
only.
Therefore,
no attempt was made to provide code quality
4
radiographs, as only corrosion growth was required to be determined.
The inspector reviewed the radiographs to determine whether there had
been any corrosion growth between the baseline radiographs of 12/28/84,
and the inservice monitoring radiographs of 5/31 - 6/14/85, the results
of this examination are shown below.
Weld No.
Location
Type/Configuration
Remarks
4-SPA-5
Auxiliary Building
Not Sleeved
1-RPA-4
Auxiliary Building
Not Sleeved
4-RPA-4
Auxiliary Building
Not Sleeved
3-RCH-1
Auxiliary Building
Not Sleeved
Increment 1-2 of
the 5/31/85 radio
graphs was moved
during the expo
sure thereby
obscuring the
images and pro
viding question
able data
3-SCH-2
Auxiliary Building
Not Sleeved
---
3-RCA-2
Auxiliary Building
Sleeved Welded Wet -------
2-RCH-8
Auxiliary Building
Not Sleeved
3-SCH-5
Auxiliary Building
Not Sleeved
Increment 1-2 of
the 5/31/85 radio
graphs has some
of the corrosion
indications
obscured by the
image of the
lead number joint
identification
thereby providing
questionable data.
3-SO3-1
Containment
Sleeved Welded Wet Increment 1-2 of
the 5/31/85 radio
graphs has pro
cessing marks and
scratches
that
obscure a portion
of the area of
5
interest on all
four films. Cor
rosion indica
tions are present
in the 5/31/85
radiographs that
are not visible
in the 12/28/84
radiographs due
to poor sensi
tivity and defi
nition of the
12/28/84 radio
graphs and also
not visible in
the 2/26/85 radio
graphs because
the
corrosion
location is
obscurred by the
image of the lead
number joint
identification
of the 2/26/85
radiographs.
2-N-33
Containment
Not Sleeved
A portion of
increment
1-2
and 2-1 of the
5/31/85 radio
graphs are to
dark to inter
pret
(density
5+).
Increment
2-1 exhibits the
backscatter
lead letter "B".
These radiographs
provide only
questionable
data.
30-2
Containment
Sleeved Welded Wet
20-1
Containment
Sleeved Welded Wet
6
2-N-32
Containment
Not Sleeved
A portion of
increment
1-2
and 2-1 of the
6/14/85 radio
graphs are too
dark to inter
pret (density
4+) thereby
providing
questionable
data.
2-S03-2
Containment
Sleeved Welded Wet
2-SO3-2
Containment
Sleeved Welded Dry
Increment 1-2 of
the
6/14/85
radiographs
exhibit the
backscatter lead
letter "B" in
all four films.
thereby pro
viding question
able data.
3-SO3-3
Containment
Sleeved Welded Dry
Increment 3-1
of the 6/14/85
radiographs
exhibit
the
backscatter
lead letter "B"
in all four
films.
Due to
a difference
in technique
(error in cen
tering), indica
tions visible
in 12/84 radio
graphs are not
visable in the
6/14/85 radio
graphs, thereby
providing ques
tionable data.
3-S03-5
Containment
Sleeved Welded Dry ---
7
The inspector could not identify any indications of corrosion that had
increased in size from the baseline radiographs of 12/28/84, to the
inservice monitoring radiographs of 5/31 - 6/14/85 (The only exception
was the 3-SO3-1 radiograph of 5/31/85 which showed corrosion
indications not seen in the 12/28/84 and 2/26/85 radiographs.
This
difference is explained by poor technique and placement of lead
identification in the earlier radiographs).
There are ten examples of
obscurred, improperly processed, backscattered and excessively dense
(too dark)
radiographs which provide questionable data for the
determination of corrosion growth.
These ten examples were caused by
poor workmanship on the part of the radiographers as acceptable
radiographs of the joints in question were produced during the first
inservice monitoring inspection in February of this year.
With a
little more attention to details, the above 10 problem radiographs
could have been corrected.
The above 10 increments represent only
approximately 10% of the radiographs (baseline and inservice moni
toring) that were made. In view of the fact that the remaining 90% did
not exhibit any corrosion growth over the second inservice monitoring
period, there appears to be an acceptable margin of safety for the
safety of the service water system integrity at the present time. The
licensee indicated that at present, plans are under way to re-radio
graph the inservice monitoring sample during the refueling outage
planned for late 1985/early 1986 and to replace the pipe during the
following refueling outage late 1986/early 1987.
Within the areas examined, no violations or deviations were identified.
7. Inservice Testing of Pumps and Valves (92706B)
The inspector reviewed procedures and records as described below, to
determine whether applicable code, procedure,
and regulatory requirements
were being met. The applicable code for Inservice Testing (IST) of pumps
and valves is ASME Boiler and Pressure Vessel (B&PV) Code Section XI, 1977
Edition with Addenda through Summer 1978.
The inspector reviewed the below listed procedures in the following areas:
general technical and administrative adequacy; plant equipment status;
description of hydraulic circuit; location and type of each measurement for
each quantity; allowable ranges for test quantities; minimum flow and/or
pressure for pump to fulfill safety function; minimum system operation time;
realignment of hydraulic circuit; plant equipment status changes properly
identified; review of test results and recording requirements.
Procedures Reviewed
Procedure No.
Title
0s
OST-201, Rev. 11
"Auxiliary Feedwater System
Component Test (Monthly)
8
OST-302, Rev. 8
"Service Water System Component
Test (Monthly)
a. With regard to the inspection above, the inspector noted that the
Baseline test data for Vibration ampitude of the service water pumps
varied from 0.86 mils to 3.4 mils. The established allowable ranges as
specified in CP&L Procedure OST-302 for vibration amplitude (based an
operational evaluation - a CP&L value of 3.0 mils) are:
Acceptable
Range - less than or equal to five mils; Alert Range - greater than five
mils, but less than six mils; and Required Action Range - equal to or
greater than six mils.
This is clearly contrary to ASME B&PV Code,
Section XI, Table IWP-3100-2 which specifies the following ranges for a
pump with vibration of 0.86 mils; Acceptable Range - zero to two mils;
Alert Range - two to three mils; and an Required Action Range - over
three mils. Therefore, the licensee's values are not in compliance
with the Code.
The inspector further noted that for the below listed gauges the ratio
of range to reference value exceeded the requirement of ASME B&PV Code
Section XI,
paragraph IWP-4120 which states "the full scale range of
each instrument shall be three times the reference value or less."
Pressure Gauge
No., System and
Average
Ratio of
and IST
Range
Operating
Range to
Procedure No.
Pressure PSIG
Pressure
Component Cooling
0-100
16.9
5.92
Water-PI-639A
OST-908
Component Cooling
0-100
15
6.67
Water-PI-639B
OST-908
Component Cooling
0-100
16
6.25
Water-PI-639C
OST-908
Diesel Fuel Oil
0-60
7.43
8.07
Transfer PI-1964A
OST-403
Diesel Fuel Oil
0-60
6.78
8.85
Transfer PI-1964B
OST-403
Residual Heat
0-600
157
3.82
Removal PI-600
OST-251
Resident Heat
0-600
156
3.85
Removal PI-601
OST-251
The above examples indicate that the licensee was not performing
inservice testing of pumps in accordance with ASME
Code,
Section XI.
Failure to perform inservice testing of pumps,
whose
function is required for safety, to verify operational readiness, is a
violation of Title 10 Code of Federal Regulations, Part 50.55(g). This
violation will be identified as 261/85-22-01: "Failure to Perform IST
in Accordance with ASME Section XI."
b.
With regard to the inspection above, the inspector noted that the
acceptance criteria for Delta P for the motor driven Auxiliary Feed
Pumps in Procedure OST-201 was not consistent with the ranges specified
in ASME B&PV Code Section XI, Table IWP-3100-2. The ranges were much
wider than allowed by the Code.
The licensee indicated that they had
identified this matter and were in the process of amending all such
affected procedures. The inspector stated that it could not be readily
determined whether the excessively large ranges in the procedures
allowed the pumps to operate in an Alert Range without increased
testing or in a Required Action Range without declaring the affected
pump inoperable. Pending the resolution of the above, this matter will
be identified as unresolved item 261/85-22-02:
"Allowable Delta P
Range".
Within the areas examined,
no violations or deviations were identified
except as noted in paragraph 7a above.
8. Inspector Followup Items (92701B)
a. (Closed)
Inspector Followup Item 261/83-30-01:
"Welding Program
Review"
This matter concerns a Corporate Welding Program Manual that was in the
review cycle at the time of the 261/83-30 inspection.
This manual is
still in the review cycle; however, the site has instituted a new
welding program for H.B. Robinson Plant.
The plant welding program is implemented by CP&L Procedure MMM-007,
Rev. 0 "Control
of Welding,
Brazing and Heat Treating",
which
implements the Special Process Procedures
(SPP)
SPP-001 through
SPP/GWS-WEC contained in Volume 4, Part 8 of the H.B.
Robinson SGE
Plant Operating manual,
and PMC-011 contained in Volume 2, part 3 of
the same manual.
The inspector reviewed the above and has no further
questions. This matter is considered closed.
b. (Closed) Item 261/84-27-05: "PT Procedure Revision Requirements"
10
This item concerns the fact that Westinghouse (W) Procedure W-ISI-11
did not address the requirements of ASME B&PV Code,
Section XI,
paragraph T-632.2 requirements. These requirements are addressed in an
internal W procedure which the inspector reviewed.
The inspector has
no further questions in this area. This matter is considered closed.
c. (Closed)
Inspector Followup Item 261/84-33-01:
"ISI
QA Program
Approval"
This item concerns the unavailability of documented evidence of CP&L
Approval of the Babcock and Wilcox and Westinghouse QA programs for
Inservice Inspection.
The licensee made the approval documentation
available. This matter is considered closed.
d. (Closed)
Inspector Followup Item 261/84-48-02:
"Water Filled Pipe
Welding"
This concerned the licensee's lack of documentation of welding sleeves
on the Service Water System with water in the piping.
The licensee
issued a "Temporary Repair" that completely documents the service water
repair welding program.
The inspector has no more questions in this
area. This matter is considered closed.
e. (Open) Item 261/84-45-01:
"Service Water Degradation"
This matter was further examined during this inspection and is
discussed in paragraph 6 of this report. This item remains open.