ML14191B084
| ML14191B084 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/10/1989 |
| From: | Blake J, Economos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191B082 | List: |
| References | |
| 50-261-89-02, NUDOCS 8902280046 | |
| Download: ML14191B084 (8) | |
See also: IR 05000261/1989002
Text
UNITED STATES
2
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/89-02
Licensee:
Carolina Power and Light Company
P.O. Box 1551
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name: H.B. Robinson
Inspection Conducted- January 9-13 1989
Inspector: ____
,
Nick
o mos.,
/bad Signed
Approved by:
A).
Jero eBlake/
ief
_Date Signed
Mat rials OdProcesses Section
En i
neerir
Branch
D'vision of Reactor Safety
SUMMARY
Scope
This routine unannounced inspection was conducted in the areas of resistance
temperature detector (RTD) bypass elimination, service water piping replacement
modifications, main feedwater pump flow testing, steam generator (SG) tube eddy
current test (ET) results and previously identified inspection findings.
Results
Work on the service water pipe replacement and resistance temperature detector
(RTD) bypass elimination modification is essentially completed. Therefore, the
inspector reviewed the documentation packages and conducted a field inspection
to verify as-built conditions including pipe configuration, dimensions, eleva
tion, etc. Flow testing of the main feedwater pumps (FWP) was in progress using
an ultrasonic flow detection device produced by Controllatron.
Current and
previous flow test data was reviewed and discussed with cognizant personnel. A
review of FWP maintenance procedures and historical corrective maintenance
records disclosed that the approved procedure used to perform this activity was
inadequate and, therefore, a violation was issued.
8902280046
8902
1
F DR
O(5000261
0
REPORT DETAILS
1. Persons Contacted
Licensee Employees
S. B. Clark, Project Engineer Configuration Control
R. Cox, Modification Project Liaison Engineer
- J. M. Curley, Director, Regulatory Compliance
- R. H. Dufresne, Project Engineering Supervisor, Civil Engineering
W. Farmer, System Supervisor Technical Support
B. Harward, Principal Engineer Modification Projects
J. Latimer, Welding Engineer
- R. E. Morgan, General Manager
R. Munday, Engineering Technician I, Modifications Projects
- M. F. Page, Manager, Technical Support
- S. M. Pruitt, Inservice Inspection (ISI) Coordinator
- D. R. Quick, Manager, Maintenance
- D. Sayer, Senior Specialist Regulatory Compliance
H. J. Young, Director, Quality Assurance (QA)
Other licensee employees contacted during this inspection included
craftsmen,
engineers,
operators,
mechanics,
security force members,
technicians, and administrative personnel.
NRC Resident Inspector
- Attended Exit Interview
2. Follow-up on Inspector Identified Problems and unresolved Items (92701)
a. (Closed) Inspector Follow-up Item (IFI), 88-24-01 Setpoint Basis for
HVH Cooler Low Water Flow Alarm
This item was identified when the inspector ascertained that a remote
HVH flow indication was not available in the control room.
This
would preclude verification of HVH cooler operability in case of
emergency. There is a low setpoint alarm which activates when outlet
flow is 700 gpm.
Because the 700 gpm setpoint was determined by
analysis to be lower than the minimum required flow for full cooler
operability, the licensee revised upward the minimum set point to 750
gpm.
The new setting was established by analysis performed by
Westinghouse, Mechanical Equipment Design (MED),
and documented by
letter, S/N MED-FCE-6583, dated 9/9/88.
b. (Closed) Unresolved Item (URI), 88-24-02, UV/SW Relay Timing and the
Impact on Cooling Water Flows During Safety Inspection Sequel.
L
This item was identified following review of SAR Section 6.2.2.3.2
and Operation Surveillance Procedure OST-301 to determine availabilty
of full flow to the HVH cooler following a safety injection (SI)
signal.
The review indicated that full flow would probably not be
available to the HVH coolers for up to ninety (90)
seconds following
an SI signal.
At the time, the inspector of record felt that this
delay was in part due to diversion of water flow to non safety
related loads.
Moreover, the inspector reported that the licensee
could not determine at that time, July 25-29, 1988, the affect of
partial flow on the HVH coolers for the first ninety seconds of an SI
signal.
Following discussions with cognizant personnel, conducted
during this inspection, the inspector ascertained that by using
special procedure SP-814 Rev. 1, written to address Region II con
cerns on the service water system, the licensee demonstrated that
there would be sufficient flow to the HVH coolers following SI
initiation to allow them to perform their design function.
3. Eddy Current Examination
(ET)
of Steam Generator (S/G)
Tubes - Record
Review and Evaluation - Inservice Inspection (ISI) (73755)
Activities during this refueling outage included eddy current examination
of tubes in "A," "B" and "C" S/Gs. - Data acquisition and analysis was
performed by Westinghouse personnel using a multifrequency
ET technique
with the MIZ-18 system to analyze tube integrity.
The inspection was
performed per requirements of ASME Code Section XI (77S78) and Technical
Specifications (TS) 4.2.1., Inservice Inspection of Steam Generator Tubes.
At the time of this inspection, the ET examination was complete.
However
discussions with cognizant licensee personnel disclosed that a total of
626 tubes were examined in S/G "A", 627 tubes in S/G "B" and 643 tubes in
S/G "C".
In addition certain tubes, within each S/G,
were examined
through the U-Bend region.
The number of tubes examined per S/G in this
area included 17 in S/G "A",
16 in S/G "B" and 12 in S/G "C".
The
Licensee stated that one tube in S/G "C", located in Row 7, Column 92, had
exceeded the acceptance criteria of 47% thru-wall thickness and was
plugged.
The flaw was analyzed as a mechanically induced gouge.
The
licensee indicated that these were preliminary results.
The official
results will be included in the report on ISI activities performed during
this outage to be submitted to Region II at a later date.
No violations
or deviations were identified.
4. Design, Design Changes and Modifications (37700)
a. Service Water- System Piping Replacement Modification
This work effort was performed as a follow-up to that documented in
report 50-261/88-35. The work effort during this inspection included
the following:
(1) The inspector selected the following as-built drawings for
review and conduct of walkdown inspections to verify configura
tion, dimensions, elevations, instrument location and tie-in to
existing system:
3
858-2480 Rev. 0 HVH 2 Motor Cooler Line, Supply.
858-2481 Rev. 0 HVH No. 2 Motor Cooler, Return.
858-2494 Rev. 3 HVH 4 Supply Side
858-2501 Rev. 3 HVH 4 pipe to penetration @ containment.
858-2503 Rev. 0 HVH No. 4 Return Line
(2) Service Water Pipe Replacement Modification package MOD-858 was
reviewed to verify that certain line item sign-offs i.e., system
walkdown, FSAR changes and system turnovers had been completed
and signed as appropriate.
(3) Acceptance Test Procedure, Attachment 9, was reviewed to verify
that hydrostatic testing for each of the four, HVH 1 through 4,
trains had been performed at designated temperature and
pressure, with calibrated instruments and that it
had been
witnessed by trained personnel and the code inspector.
b. RTD bypass Elimination
At the time of this inspection, work on this modification had been
completed except for the hydrostatic test which will be performed
during plant start-up.
In that administrative controls and proce
dures on this modification were reviewed and the work effort docu
mented in Report 50-261/88-35, the
inspector discussed field work
activities and progress with cognizant personnel.
Field generated
records/documents selected for review included Westinghouse Field
Service Procedure MPII 2.7.2 CPL-1 Rev. 1, RTD Bypass Elimination for
H.B.
Robinson, field change requests CPL-88-001 through 005 and
nonconformance reports NR-CPL-88-00001 through 00004.
Three field
welds requiring volumetric examination (radiography) were shot using
procedure RT-101 Rev.
11,
and evaluated per ASME Code Section III,
1983 Edition requirements. The radiographed welds were as follows:
1-7A
3"d schedule 160
Crossover Leg nozzle
2-5Ac
"f
"t
"
3-5A
"1
I
The inspector reviewed the above identified radiographs to verify
that the welds and radiographic technique used met applicable code
requirements. The radiographs and the welds were found to be satis
factory. Within the areas inspected no violations or deviations were
identified.
5. Service Water Pumps - Performance and Corrective Maintenance (73756).
On an earlier Region II inspection, documented in report 50-261/
88-24, the inspector of record performed a design verification and
survey of the service water system.
Potential deficiencies were
identified with respect to system design. Two unresolved items were
identified.
One,
pertained to the timing of the closure signal to
the turbine building service water isolation valves, and another was
4
for the purpose of assessing the impact of the current throttle valve
alignment and associated controls.
Three inspector follow-up items
were identified to document inspector concerns in this area and to
allow.for documentation of their resolution. In order to address the
issues and concerns raised in the aforementioned report, the licensee
generated special procedure SP-814.
The service water system at
H.B. Robinson consists of four main service water pumps and two
service water booster pumps.
These pumps are included in the
licensee's pump and valve program which is governed by.ASME Code
Section XI (77S78) requirements. Relief requests to code required
tests for these pumps were documented in theTechnical Support
Management (TMM) Manual, under TMM-04 inservice inspection, Rev. 18
and were as follows:
5.2.1
Monthly Inservice Test per IWP-3400
5.2.2
Measurement of bearing Temperature (Tb) annually per
IWP-3300
5.2.3
Flow Rate Measurements per IWP-3000 Differential
Pressure (AP) Measurements per IWP-3000
In discussions held with the cognizant engineer in order to review
corrective actions on the two open items in paragraph 2 above of this
report, the inspector ascertained that lack of instrumentation precluded
direct measurement of WP and flow rate on these pumps.
It is the
inspector's understanding that part of the problem was due to the fact
that certain sections of these pipes were lined with concrete which made
installation of instruments difficult and impractical.
To overcome this
obstacle, the licensee has recently contracted the services of Controlla
tron, who uses an ultrasonic multipulse transitetime system to measure
flow through a pipe with a surprising degree of accuracy.
Also the
licensee indicated that flow measurements taken on systems supplied by
service water, as part of the effort to address concerns discussed in the
aforementioned report, revealed disparities between design requirements
and existing field conditions.
Specific plant components where flow
discrepancies were identified were as follows:
Component
Design Requirement
Measured Flow
(1) HVH 1-4 Motor Cooler
50 GPM
30.1 to 36.4 GPM
(2) "A" & B Diesel Cooling
600 GPM
564.5-591 GPM
(3) Steam Driven AFW Pump
9.0 GPM
5.65 GPM
(4) "A"&"B" Motor Driven AFW Pump
15 GPM
1.0 GPM
The licensee indicated that engineering was evaluating these problems in
order to resolve them prior to plant startup.
These items are being
followed more closely by the resident inspector(s) and will be discussed
further in Report 50-261/89-03.
Further discussions on the activities/
flow balance tests, which were in progress, disclosed that the main
feedwater pump head pressure was approximately 20% below reference curve
values even though the pumps had been checked and found to be satisfactory
in accordance with approved corrective maintenance (CM) procedure CM-010,
(II
Rev.
1, "Service Water Pump Overhaul."
Moreover, the licensee stated
these pumps had been operating for years in this degraded condition
without the licensee knowing the root cause of the problem. Upon further
discussion, the licensee stated that following consultations with the pump
vendor, Johnston Pump Company, and an in-depth review of Procedure CM-010,
Rev.
1, 11/7/83,
they determined that the pump shaft adjustment as
described in the procedure was incorrect and was therefore directly
responsible for the degraded pump performance experienced over the past
five to six years.
More specifically the procedural instruction applic
able to rotating assembly adjustment requires the pump shaft to be lowered
until the impeller rests on the pump bowl and subsequently raised enough
to provide for the shaft to turn freely. Following this step, the proce
dure calls for raising the shaft/impeller the height of an additional two
full turns of the adjusting nut.
Mistakenly, this in affect raises the
impeller approximately 200 mils instead of the 20 to 40 mils range recom
mended by the vendor.
The licensee therefore concluded that the addi
tional two full turns of the adjusting nut, called for in step 7.3.45 of
the procedure, should have read two flats of the adjusting nut instead of
"two full turns."
Performance data taken after the rotating assembly had
been adjusted to the new setting, raised the pump reference curves back to
normal output levels.
Following these discussions and the related dis
closure, the inspector performed an in-depth review of procedure CM-010,
Rev. 1, and associated records generated each time the procedure was
utilized, for corrective maintenance on these pumps.
Records reviewed
covered a period of about two years, dating back to 1986.
The stated
purpose of Procedure CM-010,
Rev. 1, was to address disassembly and
reassembly of the service water pumps.
This included the removal and
installation of the motor,
pump casing disassembly and reassembly, pump
rotating element repairs, pump replacement and lubrications. In reference
to the stated purpose, the inspector found the procedure inadequate in
that it:
a. Failed to identify the vendor's specific technical manual applicable
to these pumps.
The only reference to the vendor was that updated
technical information was
forthcoming.
The procedure contained no
other creditable reference except to state that it had been drafted
from technical notes taken by maintenance supervision during a
service water pump overhaul.
b. Lacked specific bolt torquing requirements with tolerances specified
by referenced vendor documents.
c. Lacked requirements for using, calibrated tools i.e. torque wrenches
dial indicators, micrometers or other specified materials, i.e.
gaskets, packing, and lubricants.
d. Contained no requirements for documenting field assembly information,
i.e. total indicated shaft runout, bearing clearances, torque values,
lubricants used, rotating element adjustments.
6
e. Contained no requirement for line item sign-offs by craft and/or QC
to verify adherence to procedural requirements.
The inspector outlined these procedural deficiencies to management and
stated that running these pumps in a degraded condition over the last five
or six years is more than sufficient evidence to verify the procedure's
inadequacy.
Following is a list of work requests issued for corrective maintenance to
be performed on these pumps in accordance with the aforementioned proce
dure over the last two years.
Work Request (W/R)
Date
Scope
W/R J 08 G - AIVJ1
10/27/86
SW pump "A" install
motor and set impeller
clearances
as
per
applicable steps
in CM-010
12/11/85
SW Pump "B" - pump
removed for maintenance
and
reinstalled.
Checked
for
proper
rotations.
1/8/86
SW pump "B" - Following
repairs install pump as
per CM-010.
W/R/J087-AFSI1
5/4/87
SW pump "B" - Adjust
pump per CM-010 correct
low discharge pressure.
These records were reviewed to ascertain to what extent procedural
requirements were followed and weather
field measurements taken by the
craft were documented.
In these cases, the inspector found that the
records outlined the work assignment, referenced applicable procedure,
CM-010, and the action taken to correct the existing problem but, provided
none of the information discussed above which made it impossible to audit
this maintenance activity. The inspector stated that the failure of the
procedure to contain provisions for documenting field measurements and
inspections and specifying applicable vendor manual and correct acceptance
criteria was in violation of 10CFR 50,
Appendix B, criterion V and the
licensee's accepted QA program, FSAR section 17.2.5. This violation was
identified as 50-261/89-02-01, Inadequate Corrective Maintenance Procedure
CM-010, Revision 1, Service Water Pump Overhaul.
Except for the violation identified above there were no deviations or
other violations identified.
7
6. Exit Interview
The inspection scope and results were summarized on January 13, 1989, with
those persons indicated in paragraph 1. The inspector described the areas
inspected and discussed the inspection finding listed below. Dissenting
comments were not received from the licensee. Proprietary information is
not contained in this report.
(Open) violation 261/89-02-01 Inadequate Corrective Maintenance Procedure
CM-010 Revision 1, Service Water Pump Overhaul (paragraph 5).
II