ML14175B477
| ML14175B477 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/08/1987 |
| From: | Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B475 | List: |
| References | |
| 50-261-87-07, 50-261-87-7, NUDOCS 8706300355 | |
| Download: ML14175B477 (12) | |
See also: IR 05000261/1987007
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/87-07
Licensee: Carolina Power and Light Company.
P. 0. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson
Inspectio
d ct
April 6-9 and 20-24, 1987
Inspecto :
L,4
/
/Z5
J.
.py
Bat Signed
Approvl b
7
SJ./B ake, Section Chief
ate Signed
gi/eering Branch
i
sion of Reactor Safety
SUMMARY
Scope:
This routine, unannounced inspection was in the areas of licensee
actions on previous open matters (92701B),
inservice inspection (ISI) - review
of program
(73051),
review of procedures (73052),
observation of work
activities (73753) and review of recorded data and evaluations (73755).
Results:
One violation was identified
-
ISO Drawing
Discrepancy
paragraph 6.c.
8706300355 870619
ADOC:K 05000261
a
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- J. M. Corley, Acting General Manager
- A. R. Wallace, Manager, Technical Support
- E. M. Harris, Director, Onsite Nuclear Safety
- H. J. Young, Director, Quality Assurance/Quality Control (QA/QC)
.*D. A. Sayre, Acting Director, Regulatory Compliance
- S. W. Farmer, Performance Engineer
- S. A. Griggs, Regulatory Compliance
Other licensee employees contacted included construction craftsmen,
engineers, technicians, and office personnel.
Other Organizations
J. Hancock, Authorized Nuclear Inspector, Kemper Group
J. Campbell, ISI Coordinator, Westinghouse
B. Hughes, ISI Supervisor, Westinghouse
R. Muth, Project Engineer, Westinghouse
NRC Resident Inspectors
- H. Krug, Senior Resident Inspector
- R. Latta, Resident Inspector
- Attended exit interview on April 9, 1987
- Attended exit interview on April 24, 1987
- Attended exit interview on April 9, 1987 and April 24, 1987
2. Exit Interview
The inspection scope and findings were summarized on April 9 and 24, 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) Violation 50-261/87-07-01, ISO Drawing Discrepancy - paragraph 6.c.
On May 6, 1987, CP&L's Manager of Technical Support notified Region II by
telecon that a notation had been found in the Authorized Nuclear Inspector
log
(Kemper
Group Insurance Company)
dated August 6, 1984,
which
indicated that the licensee was aware of the drawing error reported in
the violation above, in 1984. The licensee also had requested and received
approval from the Authorized Nuclear Inspector to apply the calibration
2
block thickness tolerance of 1/4 inch which was approved in Code Case N-98
for a basic calibration block shown in figure T-533(2) of Article 5, of
Section V, to the 1974 Edition of the ASME Code.
The block depicted in
figure T-533(2) to the 1974 Edition of the ASME Code has side drill hole
reflectors in lieu of the less sensitive OD/ID notch reflectors currently
required by the ASME Code and CP&L's special procedure for the examination
of piping. The purpose of the telecon notification by the licensee was to
determine if this additional information would reduce the inspector's
above violation to an unresolved item.
The inspector informed the
licensee that the item would remain a violation for the following reasons:
-
The licensee had discovered the drawing was in error in 1984 but had
not revised the drawing to reflect actual plant conditions.
-
Special Procedure SP-681 and the ASME Code require that notched
calibration blocks be the same nominal thickness and diameter of the
pipe being examined. Code case N-98 does not apply for calibration
blocks with notches.
-
The Authorized Nuclear Inspector (ANI) does not have the authority to
allow calibration block tolerances to a less sensitive calibration
block.
If the licensee had requested to use the side drill hole
block in lieu of the notch block the examination would have been an
enchanced examination and the ANI could have approved the use of the
side drill hole block in accordance with Section V and Section XI of
the ASME Code.
Relief to ASME Code requirements can only be
approved by the NRC in accordance with 10 CFR 50.552(a)(3).
-
The licensee's UT procedure does not require thickness readings or
profiles be taken of the examination area.
When calibration blocks
have been manufactured to drawing requirements that are incorrect
the UT examiner could mis-interpret the reflectors and classify valid
indications as non-valid indications. In addition, if the calibration
standard is thinner than the pipe examined as in the situation reported
by the inspectors, the examination area scanned may be inadequate.
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 were not identified during this inspection.
.0
3
5. Independent Inspection Effort
The inspector conducted a general inspection of the reactor containment
building and the auxiliary building to observe construction progress and
construction activities such as welding, material handling and control,
housekeeping and storage.
Within the areas examined, no violations or deviations were identified.
6. Inservice Inspection (ISI)
The inspector reviewed CP&L's program for ISI, reviewed vendor examination
procedures,
observed ISI work activities, conducted a "hands on" audit
of examiner techniques using Region II equipment and reviewed record
data and evaluations from CP&L's spring 1986 outage to determine if the
present outage plan was incorporating followup examinations of reported
indications.
Unit 2 commenced commercial operation on March 4, 1971,
and is presently in the second 40 month period of the second ten year
ISI interval March 7, 1981 to February 19,
1992,
as permitted by ASME
Section XI subsection IWA-2400(c) due to the 349 day duration of the steam
generator replacement outage.
The applicable code for this 10 year
interval is the ASME, Boiler and Pressure Vessel Code,Section XI (77S78).
The ISI activities are being performed this outage by Westinghouse and the
authorized nuclear inspector services are provided by Kemper Group.
a. Review of Program (73051)
CP&L's ISI Program was reviewed in part, in Region II,
Inspection
Report No.
261/87-03.
The extent of the inspector's review this
inspection was focused on CP&L's ISI program., interfacing procedures
and the 10 year plan.
The inspector reviewed the ISI program and referenced documents to
ascertain whether adequate
QA plans and procedures have been
established (written, reviewed, approved and issued) to assure the
program is complete and in conformance with regulatory
requirements and licensee commitments.
The following documents were reviewed:
CP&L - "Second Ten Year Inservice Inspection Plan"
CP&L - PLP-025, Rev. 0, "Inservice Inspection Program"
CP&L - PLP-030 Rev. 0, "Independent Verification"
CP&L - PLP-032 Rev. 0, "Nuclear Safety Reviewer Qualification
Program"
CP&L - PLP-1024 Rev. 2, "Surveillance Test Procedure"
4
CP&L - AP-004 Rev.
18,
"Development,
Review and Approval of
Procedures, Revisions and Temporary Changes"
CP&L - AP-001 Rev. 3, "Plant Organization and Responsibilities"
CP&L - AP-006 Rev. 0, "Procedure Adherence"
CP&L - AP-014 Rev. 0, "Safe Handling and Storage of Chemicals"
CP&L - AP-030, Rev. 3, "NRC Reporting Requirements"
CP&L -
PLP-024 Rev.
11,
"Technical Specification Surveillance
Program"
CP&L - TMM-004 Rev. 12, "Inservice Inspection Testing"
CP&L - TMM-015 Rev. 4, "Inservice Inspection Repair and Replace
ment Program"
CP&L - OQA-101 Rev. 0, "Preparation, Review and Approval of OQA
Procedures"
CP&L -
OQA-103 Rev. 0, "Personnel
Indoctrination Training,
Qualification and Certification"
CP&L - OQA-201 Rev. 0, "Surveillance Program"
CP&L - QQA-202 Rev. 0, "Document Review"
CP&L - OQA-306 Rev. 0, "Stop Work Authority"
CP&L - OQA-310 Rev. 0, "Calibration of QA/QC Inspection and
Examination Equipment
CP&L - QQA-501 Rev. 0, "Quality Assurance Engineering Document
Review"
With regard to the inspection above,
the inspector noted the
following:
(1) The ISI program provides no guidance other than the assignment
of responsibility for the preparation of plans and schedules and
filing the same with appropriate regulatory authorities.
(This
comment was also noted in Region II Inspection Report 261/87-03).
(2) The "Second Ten Year Inservice Inspection Plan" is a ledger of
components and ISO drawings for the components. It provides no
specific guidance as to applicable calibration blocks augumented
inspections, relief requests or interfacing procedures, etc.
CP&L, however, is in the process of updating the 10 year plan into
5
a computer base document. During the week of April 20-24 the
inspector observed that the outage plan had been retrieved from
the computer. This plan listed the components by category and
item number, gave the calibration block number, drawing number
applicable to each item and had picked up items that were being
monitored for re-examination because of previously reported
indications.
The computer read-out for this outage was a
significant program improvement and an indicator that CP&L is
making progress in updating their second ten year inservice
inspection plan.
During the April 9, 1987, exit meeting the ISI performance
engineer committed to review the ISI program and ten year plan
and to upgrade these documents to address the inspector's
programmatic concerns.
b. Review Of Examination Procedures (73052)
The inspector reviewed the licensee's ultrasonic examination and
recording procedures listed below to determine whether the procedures
adequately covered all required aspects of the approved ISI program
and contained sufficient technical content to adequately examine the
welds required to be examined by the Code of Federal Regulations
Chapter 50.55a(g)(4).
The following procedures were
examined:
Procedure
Title
Manual Ultrasonic Examination
Rev. 0
of Welds (Westinghouse No. ISI
206 Rev. 1)
Manual Ultrasonic Examination of
Rev. 0
Welds in Vessels (Westinghouse
No. ISI-47 Rev. 4)
Preservice and Inservice
Rev. 0
Inspection Documentation
(Westinghouse No. OPS-NSD-101
Rev. 5)
With regard to the above review of CP&L Special Procedure SP-681
which is applicable to piping systems (.25 inch to 6 inch thick) and
vessel materials (.25 inch to 2 inch thick) in ferritic or austenitic
steels of either wought or cast product forms, the inspector had the
following editorial and technical comments:
(1) Paragraph 2.8.1 states that, calibration blocks shall be
fabricated from the same material specification as one of the
materials in the weld assembly to be examined. Alternatively,
for welds in austenitic materials, material of equivalent
P-number or P-number grouping may be used.
6
Inspector's Concern:
There is no material ultrasonically
equivalent to P-8 (austenitic) materials.
This P-number
material is always handled as a unique material in the ASME
Code.
(2)
Included in "Interpretation and Investigation," is paragraph
6.1.1 that states,
"valid indications are reflectors caused by flaws, such as
cracks, lack of penetration or fusion, inclusions and
porosity. All other indications are considered non-valid,
including those due to:
scanning noise, grain structure,
beam redirection, internal liquid levels, clad interface,
straight beam back surface and geometric reflectors."
paragraph 6.3 states,
"Other transducers, search units, frequencies, techniques,
etc., may be used to aid interpretation and investigation."
Inspector's Concern:
The licensee's procedure requirements are
weak for determining whether an indication is non-valid in
piping.
The procedure indicates that the examiner makes the
determination without verifying his analysis of the reflector by
reviewing the fabrication drawing or radiographs of the weld.
This weakness in evaluation to classify reflectors is further
complicated by the inherent technical weakness noted in this
procedure.
For instance, ID profiles or thickness readings
are not taken with this procedure to accurately identify where
counterbores are located or whether the material varies in
nominal thickness as to effect the plotting of indications. The
procedure does not require checking the angle of the transducer
in a material similar to that being examined.
This also will
increase the error in interpretation.
The ASME Code require
ments for classifying a reflector as geometrical in piping are
as follows:
"(a)
Ultrasonic indications that can be identified as
reflectors due to piping surface configuration (such as
weld root geometry)
or variations in metallurgical
structure of materials at interfaces (such as weld-to-base
metal interface) may be classified as geometric reflectors.
Such reflectors need not be characterized as indications or
compared with the allowable indication standards of
The presence of a geometric
reflector shall be noted for the record.
(b)
To qualify an ultrasonic indication as a geometric
reflector, the following requirements shall be met.
7
(1) The area containing the geometric reflector shall
be examined
and interpreted in accordance with
Appendix III.
(2) The presence of geometric reflectors shall be
confirmed either by review of the fabrication drawings
of the pipe weld edge preparation, the nondestructive
examination records,
or supplemental
examination
results.
(3) Supplemental examination methods shall be used,
if
necessary, to confirm the presence of geometric
reflectors."
The code notation of "shall be" in nearly every sentence above
indicates the importance the code attaches to this evaluation
process.
(3) Included in "Recording of Indications" is paragraph 7.4 that
states, "Non-valid indications,
and the absence of valid
indications shall be considered as, no indications and noted as
NI."
Inspector's Concern:
As noted in (2a) above, the code requires
that geometric reflectors in piping shall be noted for the
record. CP&L's procedure invokes this requirement by referring
the examiner to Special Procedure SP-679 for recording
examination results.
The two procedures appeared to have
contradictory requirements.
CP&L's Spring 1986 outage summary
reports were reviewed by the inspector to determine how the
ultrasonic examiners
implemented the requirements.
The
inspector found that four welds were noted to have geometry.
All four of the welds were examined using either a 410, 130 or
270 transducer.
Welds that require transducers with these
angles are unique and geometrical indication are common place.
However, during the 1986 outage numerous dissimilar metal welds
and pipe to fittings were examined and no interface signal,
counterbore or root configuration reflectors were documented.
CP&L's performance engineer for ISI agreed that the procedure
should be enhanced in the areas discussed above,
so that
examiners would not be confused as to the intent of the
requirements.
The engineer committed to have the procedure
revised by the next refueling outage.
The inspector will
review the revised procedure at that time.
8
c. Observation of Work and Work Activities (73753)
The inspector observed Westinghouse examiners during examination of
two pressure vessel welds.
The welds and the procedures used are
delineated below:
Weld ID
Component
Procedure
CSW-4
VCSW-A-1
Pulsation Damp Vessel
During the calibration of weld CSW-4 CP&L's surveillance examiner
inquired of an Westinghouse examiner if
he was going to check the
beam angle of the transducer since he had not observed the normal
calibration function.
The Westinghouse examiner stated that the
angle was checked when the transducer was manufactured.
The CP&L
examiner reminded the Westinghouse examiner that transducers that are
used on large pressure vessels wear and the angle changes increasing
his chance of error in plotting indications or determining if an
indication is valid or non-valid.
During the calibration for the
pulsation damp vessel, which is an austenitic steel the Westinghouse
examiners had a IIW block on the job to check the transducer beam
angle.
The inspector noted, however, that the IIW block they were
using was not an austenitic steel (stainless steel) block.
Trans
ducer beam angle can vary significantly between these two materials.
The inspector later found out that CP&L did not have a stainless
steel IIW block or a stainless steel rompas block on site.
As a
result, the inspector loaned the examiners one of the Region II
stainless steel rompas blocks to verify their transducer angle.
The
check revealed the beam angle to be satisfactory.
The inspector observed the examination of the above welds to
determine whether approved procedures were available and being
followed.
Examination
personnel
were knowledgeable of the
examination method and the test equipment; examination personnel with
the proper level of qualifications and certifications were performing
the various examination activities; and examination results were
being recorded as specified in the ISI program and nondestructive
examination procedures.
In addition to observing the work activities of the Westinghouse
ultrasonic examiners,
the inspector also examined their work by
"hands on" re-examination.
The ultrasonic examinations were
performed by the inspector using Region II equipment.
The objective
was to determine if
good techniques had been used in order to
identify and record reflectors within the inspection zone on
stainless steel piping.
The welds examined and the problems
encountered are delineated below.
Weld ID
Diameter of Pipe
Configuration
CPW-219-188
8 Inch
Pipe To Reducer
CPW-219-187
10 Inch
Reducer To Fitting
The inspector's re-examination of the 8" piping weld, CPW-219-188,
revealed that the Westinghouse examination of this weld was not
acceptable for the following reasons:
(1) Drawing notes on CPL-219 ISO indicated that the stainless steel
pipe was 8"diameter schedule 120.
Thickness readings taken by
the inspector prior to performing his examination indicated that
the pipe was schedule 160. This is a difference in thickness of
nearly 1/4".
CP&L's examination procedure SP-681 and the ASME
Code require that piping calibration blocks that contain notch
reflectors shall be of the same nominal diameter and nominal
wall thickness as the item to be examined.
(2) CP&L does not require thickness readings or ID profiles be taken
on weld joints. This has never been a requirement and CP&L does
not have an ultrasonic base line of "as-built" conditions for
the Robinson Unit 2 plant.
In addition to this inspector's
findings,
NRC Followup Item 261/84-48-03 "Stress ISOs weld
location", identifies a similar drawing discrepancy.
(3) The calibration block used by the Westinghouse examiners was
not in accordance with CP&L's Special Procedure SP-681 and CP&L
does not have a calibration block to use on welds for this size
piping.
(4) When welds are examined using an incorrect size calibration
block and thickness readings are not taken, as in this particular
situation, ID/OD positions on the examiner's ultrasonic
instrument are incorrect; consequently, the inspection coverage
may be inadequate and evaluations may be incorrect as to whether
an indication is classified as a valid or invalid indication.
In summary,
the findings identified above indicate drawings are
incorrect, inspection techniques are poor, weld coverage may be
inadequate and evaluations may be incorrect. The ASME Code recognizes
the inherent difficulty of examining ausenitic stainless steel and
recommends that enhanced procedures and techniques be used for this
material.
This position is further amplified in ASME Code Case N-335
where nearly every examination parameter has been tightened to insure
that plotting and classification of indications will be accurate.
The inspector reported the above finding to the licensee as a
violation of 10 CFR 50, Appendix B, Criterion V, and identified
the item as violation 261/87-07-01, ISO Drawing Discrepancy."
10
The inspector also held discussions with CP&L's Performance
Engineer for ISI activities.
Procedure weakness,
drawing
discrepancy and technique weakness were discussed in detail.
The engineer committed to the following corrective actions:
(a) Thickness reading will be taken
(b) Drawings will be reviewed for accuracy of requirements
(c) An 8" schedule 160 calibration block will be procured
(d) Procedure requirements for classifying geometrical
reflectors will be enhanced
(e) Transducer beam angles will be checked in stainless steel
(f) Weld CPW-219-188 will be re-examined next outage
d. Data Review and Evaluation (73755)
The inspector reviewed examination records in the licensee's summary
report for the spring outage of 1986 to ascertain whether the
licensee's disposition of adverse findings and subsequent
re-examination was consistent with regulatory requirements.
The
following weld examination records were:
Method of
Weld Identification
Inspection Method
Acceptance
CPL-107-A Weld 4
Surface Examination
IWB-3514.3(a)
CPL-118-A Weld 5
Surface Examination
IWB-3514.3(b)
accepted
scheduled to
be monitored
this outage
460-A&B
LCV-460-A&B
Visual Examination
Indication was
removed
CPL-118-A Weld 6
Surface Examination
IWB-3514.3(b)
accepted with
uled to be
monitored this
outage
CPL-118-A Weld
Surface Examination
IWB-3514.3(2)
The inspectors reviewed the licensee's disposition for each of the
reportable indications observed in the above welds.
The present
outage plan was also reviewed to insure that examination followup was
scheduled where required.
Within the areas examined, no violation or deviation was identified
except as noted in paragraph 6.c above.
7. Inspector Followup Items (92701)
(Closed) 50-261/87-03-01, RHR, HX, Surface Examination Relief Request. In
CP&L Letter NSL-84-167, the licensee requested relief from the volumetric
and surface examination requirements of IWC-2500 for the nozzle to vessel
welds on the residual heat removal
(RHR)
heat exchangers.
The basis of
the request for relief is as follow:
The nozzle-to-vessel welds of the
RHR heat exchangers are covered by a reinforcement ring and are not
accessible for examination as required by IWC-2500.
The geometric
configuration such that alternative NDE methods cannot be substituted.
The reinforcement ring covering the RHR heat exchanger nozzle-to-vessel
weld contain "Tell-Tale" holes such that visual examination can be
performed for evidence of leakage for evidence of leakage. The NRC Office
of Nuclear Reactor Regulation (NRR),
Division of Licensing, Operating
Reactors Branch #1 in their letter dated January 11,
1985,
concluded:
"Relief should be granted from performing vloumetric examination of two
nozzle-to-vessel welds among the RHR heat exchangers for each unit,
provided that:
a. Surface examination is performed on the reinforcement ring welds that
make the nozzle-to-vessel welds inaccessible.
b. Visual examination of the welds for leakage is performed during
periodic hydrostatic testing in accordance with IWC-5000.
The NRC letter of January 11,
1985, was silent on the subject of relief
from the surface examination requirements
of IWC-2500 for the
nozzle-to-vessle welds.
On April 7, 1987,
CP&L's Nuclear Licensing
personnel contacted the NRC Project Manager concerning this relief
request.
The Project Manager affirmed that CP&L's relief request was
granted as requested. This item is considered closed.
Within the areas examined, no violation or deviation was observed.