ML14178A393
| ML14178A393 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/21/1993 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A391 | List: |
| References | |
| 50-261-93-20, NUDOCS 9311080231 | |
| Download: ML14178A393 (21) | |
See also: IR 05000261/1993020
Text
CIV '$O
R~a'9'UNITED
STATES
o
NUCLEAR REGULATORY COMMISSION
- 1
REGION II
0 o
101 MARIETTA STREET, N.W., SUITE 2900
C
ATLANTA, GEORGIA 30323-0199
Report Nos.: 50-261/93-20
Licensee: Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC, 27602
Docket Nos.: 50-261
License No.:
Facility Name: H. B. Robinson
Inspection Conducted: September 13-17 and September 27 - October 1, 1993
Inspectors:
,-.
,-
4
- /
B. R. Crowley
Date Signed
Approved by:
[L--
fo
1
3
. J. Blake, Chief
Date Signed
at rials and Processes Section
Engineering Branch
Division of Reactor Safety
SUMMARY
Scope:
This routine, announced inspection was conducted on site in the areas of:
(1) Inservice Inspection (ISI), (2) Flow Accelerated Corrosion (FAC), and (3)
review of corrective actions for previous inspection findings.
Results:
In the areas inspected, one violation - failure to follow procedures for
calibration and certification of ET equipment - Paragraph 2.c.(7) - was
identified. No deviations were identified.
In the area of ISI, weaknesses were identified relative to lack of details in
administrative control procedures and coordination of examination preparation
and examinations. However, in general, the program appeared to be functioning
well.
Examinations were being conducted in a conscientious manner by
qualified personnel in accordance with approved procedures and required Codes.
Level III personnel were involved with the inspection process. Neat and
orderly records were being generated and maintained.
Relative to the FAC program, significant improvements were noted. Engineering
Design Guidelines had been issued and Engineering was involved in the process.
9311080231 931029
PDR ADOCK 05000261 1
0
&
2
Detailed site procedures and department guidelines had been issued to
implement the program.
All affected organizations, Operations, Maintenance,
Engineering, and Chemistry were involved in the program. A knowledgeable Site
FAC Coordinator was in place and ensuring that the program was properly
implemented. The Technical Support Department had a positive attitude about
implementing a good program. A Susceptibility Analysis of plant piping had
been performed and susceptible piping walked down and Isometric Drawing
prepared. The EPRI CHECMATE Model had been implemented and the Pass 1
analysis completed. An aggressive inspection program for the current outage
had been implemented to obtain data to further improve the program and predict
future wear.
REPORT DETAILS
1. Persons Contacted
Licensee Employees
- T. Cleary, Manager, Technical Support
- R. Crook, Senior Specialist, Regulatory Affairs
- C. Dietz, Vice President, Robinson Nuclear Power Division
- S. Farmer, Manager Inservice Inspection
C. Griffin, Senior Engineer, Nuclear Engineering Department
T. Freeman, Flow Accelerated Corrosion Coordinator
J. Lane, RCS System Engineer
- C. Osman, Principle NDE Specialist, Technical Services
I. Simpson, Supervisor, NDE Services
P. Tingen, NED Technician
- M. Vernon, Manager, NDE Services
D. Weber, Senior Inservice Inspection Specialist
Contractors
M. Baugh, QA/QC Welding Supervisor - Power Cutting Inc.
R. Brown, Manager, NDE Services - ABB Combustion Engineering Nuclear
40
Services, Steam Generator Project Manager
S. Larson, Level III Examiner - Nuclear Energy Services (NES)
T. Roland, Modification Implementing Hanger (MIH) Coordinator - Power
Plant Maintenance (PPM)
R. Valladares, Authorized Nuclear Inservice Inspector (ANII) - Hartford
Steam Boiler
Other licensee employees contacted during this inspection included
engineers, QA/QC personnel, craft personnel, security force members,
technicians, and administrative personnel.
NRC Employees
- C. Ogle, Resident Inspector
- W. Orders, Senior Resident Inspector
- Attended exit interview
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
2
2. Inservice Inspection (ISI)
The inspector reviewed documents and records, and observed activities, as
indicated below, to determine whether ISI was being conducted in accor
dance with applicable procedures, regulatory requirements, and licensee
commitments. The applicable code for ISI is the American Society of
Mechanical Engineers Boiler and Pressure Vessel (ASME B&PV) Code,
Section XI, 1986 Edition, except that the extent of examination for pipe
welds, category B-J, is the 1974 Edition, Summer 1975.
The third 10-Year interval started February 19, 1992 and ends February
19, 2002. This is the second outage of the first period of the third
interval.
The third 10-Year interval program was submitted in August, 1991.
Additional information was provided by letters dated February 13, 1992
and June 18, 1992. A total of 18 relief requests were submitted. The
NRC issued a Safety Evaluation Report (SER) on October 19, 1992. Relief
Request numbers 1, 2, 3, 5, 8, 12, and 18 were granted, number 13 was
granted with conditions, and all others were withdrawn by the licensee.
The site ISI organization in the Technical Support Department is
responsible for the 10-Year Program and issuing the Outage Plan. The
Corporate NDE Services Department is responsible for performing the
inspections. A contractor, presently NES, performs the NDE inspections
under the direction of the NDE Services Department. NDE procedures are
provided by the contractor and are issued under the licensee's program as
site procedures.
a. ISI Program Review (73051)
The inspector reviewed the documents listed below related to the ISI
program to determine whether relief requests had been approved by
NRR, the services of an Authorized Nuclear Inservice Inspector
(ANII) had been procured and the inspector was involved in ISI
activities, the plan had been approved by the licensee and to assure
that procedures and plans had been established (written, reviewed,
approved and issued) to control and accomplish the following appli
cable activities:
program organization including identification of
commitments and regulatory requirements, preparing plans and
schedules, and qualification, training, responsibilities, and duties
of personnel responsible for ISI; NDE personnel qualification
requirements; and guidance for identifying and processing relief
requests.
-
Carolina Power and Light H B Robinson Nuclear project Unit No 2
Third Ten year Inservice Inspection program Plan, Revision 0
-
CP&L PLP-025, Revision 25, In-Service Inspection Program
3
-
CP&L Examination Program Plan For Carolina Power and Light
Company H. B. robinson Unit 2 Inservice Inspection - Interval-3
Period-I Outage-2
-
CP&L SP-1235, Revision 0, Ultrasonic Linearity Verification
-
CP&L SP-1216, Revision 0, Calibration of Thermometers
-
CP&L SP-1221, Revision 0, Procedure for Certifying
Nondestructive Examination Personnel
-
NES 83A5464, Revision 1, Quality Assurance Program Plan For
Inspection and Related Services For Carolina Power and Light
Company
-
NES 80A9003, Revision 13, NES Document Control
-
NES 80A9022, Revision 10, Quality Assurance Audit Procedure
-
NES 80A9054, Revision 3, Calibration of Magnetic Particle
Examination Equipment
-
NES 80A9069, Revision 14, Certification of Visual Examination
Personnel
-
NES 809084, Revision 6, Nondestructive Examination Procedure
Qualification
-
NES 80A9099, Revision 8, Identification, Storage, and Retention
of Quality Assurance Records
Relative to review of programmatic controls, the inspector
identified the following weakness:
Administrative controls were not well defined procedurally in a
number of areas relative to the general operation of the ISI NDE
program. The following are examples of areas with weak procedural
details:
-
The overall description of how the program works, including
interface between the Site ISI Organization, Corporate NDE
Services Department, and the contractor.
-
Issue, control, and use of the outage plan.
-
Process for review and approval of inspection data, including
disposition of rejectable defects and sample expansion when
rejectable defects are found.
-
Reference system for identification and layout of welds.
-
Disposition of limited examinations.
4
Although these areas lacked procedural details, the inspector did
not identify specific problems resulting from this weakness.
b. Review of Procedures (73052)
The inspector reviewed the following NDE procedures to determine
whether these procedures were consistent with regulatory
requirements and licensee commitments. The procedures were reviewed
in the areas of procedure approval, requirements for qualification
of NDE personnel, compilation of required records, and division of
responsibility between the licensee and contractor personnel. In
addition, the procedures were reviewed for technical adequacy and
conformance with ASME, Sections V and XI, and other licensee
commitments/requirements.
-
SP-1217, Revision 0, Liquid Penetrant Examination Procedure
-
SP-1218, Revision 0, Magnetic Particle Examination Procedure
-
SP-1223, Revision 0, Ultrasonic Examination of Piping Welds and
Systems
-
SP-1230, Revision 0, VT-3 Visual Examination of Nuclear Power
Plant Components
-
SP-1220, Revision 0, PSI/ISI Examination Areas and Volumes
During review of the MT procedure, SP-1218, the inspector noted
conflicting requirements relative to verification of the strength of
Paragraph 8.2.2 requires verification at the beginning of
each shift.
Paragraph 9.1.1 states that daily verification is
recommended. Based on discussions with inspection personnel and
observation of inspections, the actual practice is verification
prior to each inspection. Therefore, the actual practice is more
conservative than the most conservative procedure requirement.
c. Observation of Work and Work Activities (73053)
The inspector observed work activities, reviewed NDE personnel
qualification records, and reviewed certification records of NDE
equipment/materials, as detailed below. The inspector verified:
availability of and compliance with approved NDE procedures, use of
knowledgeable NDE personnel, and use of NDE personnel qualified to
the proper level.
(1) Liquid Penetrant Examination (PT)
The inspector observed the in-process PT examinations as
indicated below. The observations were compared with the
inspection attributes of the applicable procedure and the ASME
B&PV Code to verify the performance of acceptable examinations.
5
Examinations Observed
Drawing
Welds/Component
CPL-125
1BC
CPL-125
3
CPL-125
4
(2) Magnetic Particle (MT) Examination
The inspector observed the in-process MT examinations as
indicated below. The observations were compared with the
inspection attributes of the applicable procedure and the ASME
B&PV Code to verify the performance of acceptable examinations.
Examinations Observed
Drawing
Welds/Component
CPL-205
6
CPL-212
7
CPL-212
7LS
(3) Ultrasonic (UT) Examination
The inspector observed the in-process UT examination of weld 7
on drawing CPL-212. The observations were compared with the
inspection attributes of the applicable procedure and the ASME
B&PV Code to verify the performance of acceptable examinations.
(4) Visual (VT) Examination
The inspector observed the in-process VT examinations as
indicated below. The observations were compared with the
inspection attributes of the applicable procedure and the ASME
B&PV Code to verify the performance of acceptable examinations.
Examinations Observed
Drawing
Support/Component
CPL-245
Hanger A
CPL-247
Hangers b, E, and G
6
(5) Eddy Current (ET) Examination
The Inspector observed the in-process ET data acquisition for
the steam generator (SG) tubes listed below. The data
acquisition was compared with the applicable procedure and the
ASME B&PV to verify acceptable data acquisition activities.
Examinations Observed
Tube Row/Column
A
R35/C38
A
R33/C38
A
R30/C38
A
R35/C38
B
R11/C38
B
R9/C38
B
R6/C38
B
R12/39
B
R16/39
C - observed calibration activities
In addition to these observations, the inspector reviewed the
scan plans and discussed the planned inspection program with
licensee and contractor personnel.
The planned inspection
will include BOBBIN coil inspection of approximately 45% of
tubes in each SG. This will complete BOBBIN coil inspection of
100% of all tubes since the SGs were replaced. In addition,
Rotating Pancake Coil (RPC) inspections will be performed on
any questionable tube and selected tubes previously identified
with manufacturing burnish marks.
(6) Personnel Qualification/Certification
The inspector reviewed personnel qualification documentation as
indicated below for examiners who performed the examinations
detailed in paragraphs (1),
(2), (3), (4), and (5) above.
These personnel qualifications were reviewed in the following
areas:
employer's name; person certified; activity qualified
to perform; current period of certification; signature of
employer's designated representative; basis used for
certification; and, annual visual acuity, color vision
examination, and periodic recertification.
Examiner Records Reviewed
Method
Level
Employer
Number
II
NES
5
I
NES
1
II
NES
4
II
NES
3
7
Examiner Records Reviewed
Method
Level
Employer
Number
II
NES
2
II
3
In addition, qualification documentation for 1 level III
examiner (PT, MT, and UT) was reviewed.
(7) Equipment Certification Records
Equipment/material certification records, as listed below, for
equipment/materials used in the inspections detailed in
paragraphs (1),
(2), (3), (4), and (5) above were reviewed to
ensure compliance with applicable requirements.
Equipment Type
Equipment Identification
Penetrant Cleaner
Batch 92D02P
Penetrant
Batch 93E01K
Penetrant Developer
Batch 92A01P
Magnetic Particles
Batch 83L067
UT Transducer
Serial M12411
UT Transducer
Serial E18404
UT Instrument
Serial 27276-3702
UT Instrument
Serial 27276-749
UT Instrument
Serial 27276-807
UT Couplant
Batch 093001
ET Calibration Standard
Serial Z-8554
ET Calibration Standard
Serial Z-8555
ET Calibration Standard
Serial Z-8556
ET MIZ-18A RDAU
Serial 020
ET MIZ-18A RDAU
Serial 023
ET MIZ-18A RDAU
Serial 056
During review of the above certification records, the inspector
noted that the on site certification records for the MIZ-18A ET
equipment at the job site had expired for two sets of
equipment. Three sets of equipment (serial numbers 023, 056
and 195), one in each steam generator, were being used. After
further investigation, the ET contractor located the current
certification for equipment serial numbers 023 and 056 off-site
at their offices. However, certification records for equipment
serial number 195 could not be found. Attachment 8.3,
paragraph 7.0 of CP&L Procedure SP-1240, Revision 0, Steam
generator Eddy Current Testing During RFO 15, requires that the
MIZ-18A equipment be certified and that documentation of
calibration be provided prior to the start of the inspection.
Failure to follow procedure requirements for calibration and
certification of ET equipment is in violation of 10 CFR 50,
Appendix B, Criterion 5, and is identified as Violation (VIO)
261/93-20-01, Failure to Follow Procedures for Calibration and
8
Certification of ET Equipment. As immediate corrective action,
the ET contractor replaced equipment serial number 195 with a
set of qualified/certified equipment and re-inspected the SG
tubes that had been inspected with serial number 195 equipment.
Also, certification of UT characteristics for transducer serial
number M14135, used for inspection of weld 7 on Drawing CPL-212
was not available at the site. Although not a code requirement
to have this certification, it is industry practice to obtain
this certification from the transducer manufacturer to ensure
proper sound characteristics and repeatability of inspection
results. The licensee stated that they will obtain the
certification or, if not available, determine the transducer
characteristics and certify the transducer.
(8) Steam Generator Feedwater Nozzle to Reducer Welds
During a previous inspection (See NRC Inspection Report 50
261/92-92-14), the NRC inspector questioned the UT inspection
of the "C" SG Feedwater nozzle to reducer weld. The weld had
been re-examined to look for thermal fatigue cracks based on
cracking being found at another utility. Based on concerns of
the inspector relative to disposition of indications as
geometry in the area where cracking would be expected, the weld
and base material were re-inspected at the time of the 92-14
inspection. In addition to UT using a number of different
transducers, the weld and adjacent base material were
radiographed (RT).
Based on the additional UT inspection of
the questionable areas (16" to 32" clockwise looking toward the
SG), and comparison of the RT film to the original fabrication
RT film, it was concluded that the indications were caused by
geometry.
During the current inspection, the following UT inspections
were performed:
-
Loop A - Welds 1 (Reducer to Nozzle), 2 (Elbow to
Reducer), and 4 (Pipe to Elbow) were inspected using 00,
450 shear wave, and 600 shear wave transducers.
The
inspections included the entire surface of the reducer and
half of the elbow base material inspecting for thermal
fatigue cracking.
-
Loops B and C - The entire surface of the reducers and
half of the surface of the elbows were UT inspected using
0o, 450 shear wave, and 600 wave transducers inspecting
for thermal fatigue cracks. These inspections included
welds 1 and 2.
9
-
Loop C - The questionable area noted above (16" to 32"
clockwise) was inspected using 450 L-Wave and 600 L-Wave
transducers.
-
Techniques and personnel with demonstrated capability to
detect thermal fatigue cracks were used for these
inspections.
The inspector reviewed the UT shear wave inspection data and
observed the UT L-Wave inspections on the "C" loop. In
addition, the original fabrication RT film and the RT film from
the 1992 inspection were reviewed. Apparently the indications
have not changed since the last inspection. It appears that
the indications are geometric reflections from the reducer
counterbore. The RT film show a machining groove at the
intersection of the counterbore and counterbore taper. The
licensee plans to continue to inspect these areas during future
outages. In addition, the licensee has contacted Structural
Integrity Associates to: (1)
make a proposal for monitoring the
effectiveness of their control of the thermal fatigue cracking
in the feedwater piping, and (2)
determine the best
alternatives for material and configuration for pipe
replacements.
During observation of examination activities, the inspector noted a
general weakness relative to coordination of examinations and
preparation (scaffold erection, insulation removal, cleaning,
determination of Health Physics (HP) requirements, etc.) and
performance of examinations. The following are examples:
-
In attempting to inspect the pipe hangers identified in
paragraph (4) above, the examiners found that the required
clearances between the hangers and the pipe could not be
verified because the insulation had not been adequately
removed. Also, a significant amount of time was spent locating
the hangers.
-
About 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> was spent inside the radiation control area (RCA)
to perform PT inspection of the 3 welds identified in paragraph
(1) above. These are 2" diameter welds and are located in a
high radiation area. The cleaners entered the RCA to clean the
welds at the same time as the NDE examiners entered the RCA to
perform the inspection. HP did not swipe the area and
determine the full dress requirements until the cleaners and
examiners were ready to enter the high radiation area.
Requirements were added for paper outer clothing after everyone
was dressed, inside the RCA, and ready to enter the high
radiation area. Although the full 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> was not spent in the
high radiation area (much of the time was spent waiting in low
dose areas), the time inside the RCA could have been decreased
significantly with better planning.
10
-
During MT and UT examination of Main Steam system weld 7 on
drawing CPL-212, the inspector noted that other welds in the
same area required the same inspection, but could not be
inspected because of lack of cleaning, insulation removal, or
scaffold erection. This caused repeated calibrations and/or
entries into the RCA.
d. Inservice Inspection Data Review and Evaluation (73755)
In addition to review of in-process data for the inspections
observed in paragraph c. above, the inspector reviewed P-Scan UT
inspection data for SG girth weld 5 on SG "A".
As noted in NRC Inspection Report 50-261/92-13, UT indications were
identified in girth weld 5 for SGs "A" and "C" using manual UT
equipment in 1990. The indications appeared to be fabrication
flaws, but some exceeded the criteria of ASME Section XI, IWB-3500.
Based on flaw specific analysis, the indications were found to be
acceptable for the next 18 month operation cycle. Because of the
severe access restriction in obtaining reliable manual UT data, in
refueling outage (RFO) 14 in 1992, the licensee contracted with
Siemens Nuclear Power Services Inc. (SNPS) to perform a
mechanical/semi-automated P-Scan UT inspection of selected
indications in both SGs. This inspection was considered more
reliable, accurate, and repeatable than the manual inspection
because of the severe access restriction. This inspection showed
the indications to be smaller than thought based on the manual
inspection. Using the more accurate sizing of the P-scan
inspections, the indications met ASME Section XI, IWB-3500 without
the requirement for analysis. In addition to the P-Scan UT
inspection, the licensee MT inspected some of the inside of the SG
"A" weld at some of the indication locations which appeared to be
open to the surface. Only minor fabrication type flaws were found.
During the current outage, the licensee had SNPS re-perform the P
Scan UT examination on 5 selected indications in the "A" SG girth
weld to verify that the flaws have not changed. Although there was
some small changes in the indication sizes (some dimensions slightly
larger and others slightly smaller), the licensee concluded that the
changes were within the accuracy of the inspection method and setup.
The final conclusion was that the indications are acceptable
fabrication flaws and do not warrant further special inspection
monitoring. These welds will revert back to the normal inspection
schedule.
The inspector reviewed the preliminary P-Scan data and inspection
results for the current outage and a comparison with the previous
inspection results. It appears that licensee action for the SG
girth weld indications has been appropriate.
RESULTS
In the areas inspected, one violation, as detailed in paragraph c.(7),
was identified relative to use of non-certified SG tube ET equipment.
Weaknesses were identified relative to lack of details in administrative
control procedures (paragraph a. above) and coordination of examination
preparation and examinations (paragraph c. above).
However, in general,
the program appeared to be functioning well.
Examinations were being
conducted in a conscientious manner by qualified personnel in accordance
with approved procedures and required Codes.
Level III personnel were
involved with the inspection process. Neat and orderly records were
being generated and maintained.
3. Flow Accelerated Corrosion (FAC) Program (49001)
In response to Generic Letter (GL) 89-08, Erosion/Corrosion Pipe Wall
Thinning, licensee's have implemented long term Erosion/Corrosion (E/C)
or FAC programs. The licensee's FAC program was evaluated in an
inspection documented in NRC Inspection Report 50-261/92-13. During that
inspection the inspector identified a weak program, specifically citing
lack of corporate involvement and organization of the program. The
licensee acknowledged a weak program and indicated that improvements were
planned. The purpose of the current inspection was to evaluate the
status of the program and determine if an adequate program was in place.
The following is a summary of the inspection activities and results:
a. General
Based on discussions with licensee personnel, review of the
documents listed in paragraph b. below, and observation of the
inspections listed in paragraph c. below, the following actions have
been completed by the licensee:
-
A full time individual had been assigned as the Site FAC
Coordinator. A full time position at the corporate level has
been posted in the Nuclear Engineering Department (NED).
-
Corporate Design Guides have been issued to define the program
and site implementing procedures and guides have been issued.
Corporate is involved in defining the program and resolving
inspection findings.
-
ABB Impell was contracted in late 1992 through early 1993 to
walkdown systems, perform a susceptibility analysis for plant
systems, provide isometric drawings for susceptible systems,
and perform a CHECMATE Pass 1 Analysis.
12
-
CP&L Nuclear Assessment Department (NAD) performed an
assessment of the FAC program corporate wide, including
Robinson. Their report, NAD 93-504 was issued on September 9,
1993. The assessment identified a number of weaknesses in the
program. The weaknesses have been corrected or plans are in
place for correction.
-
For the current outage, the Robinson inspection plan includes
approximately 285 inspection locations in large bore piping
plus approximately 65 locations in small bore piping. The
selection of locations for inspection was based on the Pass 1
CHECMATE analysis, plant experience, industry experience, and
engineering judgement. The inspection results will be entered
into the CHECMATE model to perform the Pass 2 analysis.
In addition to the above completed actions, the Site FAC Coordinator
identified the following further program improvements planned to be
completed in the next six Months:
-
The NAD assessment noted that the Isometric Drawings are not
plant controlled drawings. The drawings will be converted to
plant controlled documents, errors corrected, and replacement
materials identified.
-
The 1994 budget has budgeted funds to: develop Isometric
Drawings for unmodelled, susceptible piping; fund CHUG
participation, and perform additional inspections in small bore
and isolable lines.
-
Backup FAC Coordinator will attend CHECMATE training in,
November.
-
Modify Work Request (WR) computer program (AMMS) to flag piping
replacements in secondary plant to help track replacements.
-
The Chemistry Group belongs to EPRI water chemistry group. The
Cycle 16 Plan includes raising Ph (additional hydrazine) and
consideration of ethanol amine treatment.
-
Plans are to develop a budget for replacement of small bore
lines with stainless steel for turbine shell drains, crossunder
drains, and steam dump bypass (keep-warm) piping.
b. Review of Procedures
The inspector reviewed the following documents which define the FAC
program
-
NED Design Guide DG-VII.5, Revision 0, Corporate Program for
13
-
NED Design Guide DG-VII.6, Revision 0, CHECMATE Modelling
Guideline
-
NED Design Guide DG-VII.7, Revision 0, Guideline for FAC
Component Selection, Sample Expansion, and Evaluation
-
ABB Impell Corporation Calculation No. 0132-00142-02, H. B.
Robinson Unit 2 Systems Elimination Calculation
-
PLP-051,, Revision 1, Flow Accelerated Corrosion (FAC)
monitoring Program
-
RFO-15 Project Plan - Erosion/Corrosion Monitoring Program
-
CP&L NAD Report NAD 93-504, Corporate Flow Accelerated
Corrosion Assessment Report
-
Technical Support Guideline TSG-210, Revision 0, FAC Program
Implementation
-
NDEP-427, Revision 0, Interim Change 1, Digital Ultrasonic
Thickness Measurement (Panametrics Model 26DL Plus) for
Erosion/Corrosion Detection and Monitoring
-
NDEP-1012, Revision 0, Gridding of Components for
Erosion/Corrosion
c. Observations and Reviews
In addition to review of the above program, procedures, and plans,
the inspector observed in-process activities and reviewed other
aspects of the FAC program as detailed below:
-
In-process grid layout was observed for components FW 10-14, FW
9-15, FW 11-17, FW 10-8, and FW 11-20 on Isometric Drawing FW
02.
In addition, UT thickness measurement were observed for
components FW 9-14 and FW 9-15 on Isometric Drawing FW-02.
Personnel qualification and certification records for 5 NDE
examiners who performed this work were reviewed.
-
The inspector attempted to review records and determine the
extent of previous problems with through-wall piping leaks due
to FAC. Records were not readily available to determine the
exact number of through-wall leaks. However, based on
discussions with System Engineering personnel, since issue of
Revision 3 (early 1989) to the Temporary Modification
procedure, MOD 18, any repair to a leak with liquid sealant
would require issue of a Temporary Modification. Therefore,
the inspector reviewed the Temporary Modification Log to obtain
some indication of the past through-wall leaks due to FAC.
This indicates something less than 10 through-wall leaks in the
last 4 to 5 years. It is not clear that all of these leaks
14
were due to FAC. Based on this log, only one of these leaks
were in 6" diameter piping. The others were in small diameter
(less than 2") piping. Although not a complete picture, since
this does not include piping thinned and replaced before
leaking, this does give some indication of previous FAC
problems at Robinson.
The inspector examined licensee's past practice and future
plans for material replacements for FAC degraded piping, i.e.,
practices for replacing "like for like" or upgrading to better
materials. Although the type material used for past
replacements is not readily available without extensive review
of modification and maintenance history records, the Site FAC
Coordinator had performed some records reviews of past pipe
replacements and recorded the information on the Isometric
Drawings. A review of this data indicated use of the following
materials:
Date
Size and System
Material(s) Used
10/84
3" - Htr. Drains and Vents
Carbon Steel
(Reheat Excess Stm to
No. 6 FW Heaters)
10/88
"
Carbon and Stainless
10/84
3" and 6" - Heater Drains
Carbon Steel
11/88
"
Carbon and Stainless
5/87
8" - Heater Drains
Carbon Steel
-
Feedwater Recirc Piping
Stainless
-
Steam Generator Blowdown
Stainless
Piping
1990
High Pressure Extraction
2-1/4 Cr-Mo
Steam Piping
5/87
Feedwater Heater Drains
Carbon Steel
Downstream of Cont. Vlvs.
5/92
Discharge on Heater Drain
Carbon Steel
Pumps
From the above it is obvious that there was not always an
attempt to upgrade materials for piping replacements. In the
past, the plant could replace "like for like" as long as the
original design was met. As noted above, in the past, the FAC
program was relatively weak and it appeared there was not much
emphasis on upgrading materials.
15
Today, the general policy is to replace small diameter FAC
degraded piping with Stainless Steel and large diameter with
Cr-Mo material.
The improved FAC program requires input from
Technical Support (FAC Coordinator) and NED on dispositioning
FAC degraded piping and pipe replacements. Any change in
material requires Engineering approval through the Modification
Process. The improved program should ensure that high priority
is given to material upgrades whenever materials are replaced.
-
At the completion of the inspection, 185 of the 285 large bore
piping locations had been inspected. Forty-one of the 185
required NED evaluation (less than 0.875 X tnam).
However,
only 4 were predicted to be below minimum wall before the next
RFO. These are being evaluated for replacement.
RESULTS
No violations or deviations were identified.
Significant improvements were noted in the FAC program. Engineering
Design Guidelines had been issued and Engineering was involved in the
process. Detailed site procedures and department guidelines had been
issued to implement the program.
All affected organizations,
Operations, Maintenance, Engineering, and Chemistry were involved in the
program. A knowledgeable Site FAC Coordinator was in place and ensuring
that the program was properly implemented. The Technical Support
Department had a positive attitude about implementing a good program. A
Susceptibility Analysis of plant piping had been performed and
susceptible piping walked down and Isometric Drawing prepared. The EPRI
CHECMATE Model had been implemented and the Pass 1 analysis completed.
An aggressive inspection program for the current outage had been
implemented to obtain data to further improve the program and predict
future wear.
The inspector noted the following areas where further improvement is
needed:
-
The Outage Plan needs more formal details on how the plan is
developed, issued, controlled, and implemented, especially the
interface with NDE Services and the flow of data and inspection
results. Before the end of the inspection, the FAC Coordinator was
working on procedure changes to provide more details for the Outage
Plan.
-
Modification Procedures need to provide for FAC Coordinator review
of modification and change documents for systems susceptible to FAC
to obtain his input and keep him informed of changes to the systems.
16
A draft interface procedure for Corporate and Sites had been
written, but not issued. This procedure needs to be issued to
define interface agreements and assure that Design Guides will
continue to be implemented.
Corrective actions for the weaknesses identified in the NAD
Assessment need to be completed, especially upgrading the Isometric
Drawings to plant controlled drawings.
4. Observation of Miscellaneous Work Activities (55050 and 37700)
During observation of ISI and FAC in-plant activities, the inspector
examined the following work activities:
a. Modification M-1104, Pipe Support Work
This Modification covers extensive re-work of pipe supports in
systems through-out the plant. The inspector discussed the work
with the contractor (PPM).
Completed Auxiliary Feedwater (AFW)
system supports SS-2225 and SS-2228 in the Turbine Building were
inspected. In addition, the completed work packages, including
Seismic Weld Data Reports, for these supports were reviewed. In
process work (layout work and preparation for fitup) was observed
and in-process records were reviewed for AFW Support SS-2288.
Also, completed work packages for supports SS-2232, SS-2233, and
SS-2234, which involved changing the length of the extension piece
on the pipe support struts by cutting and re-welding, were reviewed.
The records included drawings, weld records and detailed work
instructions, including verification of transfer of identification
on the studs (weldless EYE) after cutting.
RESULTS
The completed supports were painted and detailed inspections of
welds were not possible. However, general workmanship of the
supports and welds appeared to be very good.
All work documents reviewed were detailed and had many QC hold
points and inspections required. All required sign-offs had been
completed.
b. Welding
The inspector observed fitup and tack welds on Service Water System
piping weld FW-9 on Weld Map HVH-1-6-CW22. The work was being
performed by contractor PCI.
The weld is an ASME Class 3 weld and
the applicable code is the ASME B&PV,Section III, Subsection NC.
In addition to observation of the in-process work and review of in
process documentation, the inspector reviewed supporting records for
the following:
17
-
Welding Material Test Reports
3/32" ERNiCrMo-3 -
Heat # PCI-1357
1/8" ERNiCrMo-3 - Heat # PCI-1358
-
Welder Qualification Records
Welders M255 and M289
-
Visual (VT) Qualification Records
1 VT Examiner Who Inspected the Fitup
Within the areas inspected, no violations or deviations were identified.
5. Licensee Action on Previous Inspection Findings (92701, 92702)
a. (Closed) IFI 261/92-13-01, Erosion/Corrosion Program Improvement
This item involved concerns relative to a poor FAC program. The FAC
program has been significantly improved and now appears to be moving
toward a first class program. See paragraph 3. above for details of
inspection efforts in this area.
b. (Closed) IFI 261/92-09-02, Corrosion on Exterior Surfaces of Service
Water Lines at the Intake Structure
See NRC Inspection Report 50-261/92-13 for documentation of a
previous inspection of this item. As noted in report 92-13, the
licensee evaluated the damage to the subject Service Water lines and
determined that the lines should be replaced in RFO 14. During the
92-13 inspection, the inspector observed the degraded condition of
the piping and noted the licensee had no preventive maintenance
program to monitor the condition of the subject exposed piping.
During the current inspection, the inspector visually observed the
newly installed piping as well as other service water piping nearby.
The piping was painted and appeared to be in good condition. Based
on discussions with System Engineering personnel, the previous
piping had been insulated, which allowed moisture to collect between
the piping and the insulation since the piping is an outside
environment. This contributed to the corrosion degradation of the
piping. The insulation has been deleted which should preclude
moisture collection and also allow easy access for monitoring the
condition of the piping.
The licensee has also implemented a PM
Task for periodic monitoring of the piping for coating and corrosion
damage. This periodic monitoring requirement (WR/JO 94HSE001, Route
2 S 82 001) was reviewed by the inspector. Also, Licensee Technical
Support personnel pointed out that an External Corrosion Program is
planned which will cover monitoring this type piping for
degradation.
18
c.
(Open) IFI 265/90-24-01, Welds not Identified on Inservice
Inspection Isometric Sketches
This item concerned missing welds on ISI Isometric sketches used to
identify configuration, weld location and weld population in the ISI
program.
The licensee's letter of response, dated December 20,
1990, indicated that corrective actions will include verification of
the accuracy of the Isometric Drawings by physical walkdown and
other appropriate means and drawing revisions as necessary. This
action is to be completed by the end of the first period of the
third 10-Year interval or June, 1995. The inspector discussed the
status of this action with the Site Senior ISI Specialist. He
indicated that the work is about 65% complete.
6.
Exit Interview
The inspection scope and results were summarized on October 1, 1993, with
those persons indicated in paragraph 1. The inspector described the
areas inspected and discussed in detail the inspection findings. The
violation listed below was found after the exit interview and was
identified to Regulatory Affairs personnel as an Unresolved Item (URI)
before the inspector left the site. After further review in Region II
Offices and after additional information was provided by the licensee,
licensee Regulatory Affairs Specialist (D. Crook) was contacted by phone
and informed that the URI would be changed to a Violation. Proprietary
information is not contained in this report. Dissenting comments were
not received from the licensee.
(Open) Violation 261/93-20-01, Failure to Follow Procedures for
Calibration and Certification of ET Equipment.
7. Acronyms
ANII
Authorized Nuclear Inservice Inspector
American Society of Mechanical Engineers
CrMo
E/C
Erosion/Corrosion
Electric Power Research Institute
Eddy Current Examination
GL
Generic Letter
Health Physics
Inservice Inspection
Magnetic Particle Examination
NAD
Nuclear Assessment Department
NED
Nuclear Engineering Department
NES
Nuclear Energy Services
NRC
Nuclear Regulatory Commission
Nuclear Reactor Regulation
19
PCI
Power Cutting, Inc.
PLP
Plant Procedure
Power Plant Maintenance
Liquid Penetrant Examination
Quality Assurance
Quality Control
Radiation Control Area
RDAU
Remote Data Acquisition Unit
Refueling Outage
RH
NRC Region II
RPC
Rotating Pancake Coil
R&R
Repair and Replacement
Safety Evaluation Report
SNPS
Siemens Nuclear Power Services, Inc.
Special Procedure
TI
Technical Instruction
tnom
Nominal Pipe Wall Thickness
TS
Technical Support
Unresolved Item
Ultrasonic Examination
Visual Examination
Violation
Work Request