ML18033A682

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Insp Repts 50-259/89-05,50-260/89-05 & 50-296/89-05 on 890130-0202.No Violations or Deviations Noted.Major Areas Inspected:Generic Ltr 88-01 & NUREG-0313,Rev 2 Program Implementation,Procedure View & Observation of Work
ML18033A682
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 02/21/1989
From: Blake J, Coley J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18033A681 List:
References
RTR-NUREG-0313, RTR-NUREG-313 50-259-89-05, 50-259-89-5, 50-260-89-05, 50-260-89-5, 50-296-89-05, 50-296-89-5, GL-88-01, GL-88-1, NUDOCS 8903200346
Download: ML18033A682 (9)


See also: IR 05000259/1989005

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, NN'.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/89-05,

50-260/89-05,

and 50-296/89-05

Licensee:

Tennessee

Valley Authority

6N 38A Lookout Place

1101 Market Street

Chattanooga,

TN

37402-2801

Docket Nos.:

50-259,

50-260

and 50-296

License Nos.:

DPR-33,

DPR-52,

and

DPR-68

Facility Name:

Browns Ferry 1, 2,

and

3

Inspection

n

ct d:

January

30

February 2,

1989

t

tnspecto

,.LJ.

L. Coley

Approved by:

Blake, Chief

a erials

8 Processes

Section

E gineering

Branch

Division of Reactor Safety

D te Signed

D te

igned

SUMMARY

Scope

This routine

unannounced

inspection

was

in the areas

of (Generic Letter 88-01

and

NUREG-0313,

Rev.

2) program implementation,

procedure

view, observation

of

work activities,

and review and evaluation of completed data.

Results

Programmatic

weaknesses

were identified in the licensee's

responsiveness

to

NRC

initiatives

and

resolution

of Technical

issues

from

a safety

standpoint

as

delineated

in Unresolved

Item 50-259,

260, 296/89-05-01.

(paragraph

2. a.)

In the areas

inspected,

violations or deviations

were not identified.

REPORT DETAILS

Persons

Contacted

Licensee

Employees

"R. Boyd, Licensing

  • J. Baxter,

Licensing

  • C. Eubanks,

Engineer

  • F. Froscello, guality Assurance/guality

Control

  • M. Gothard,

Engineer,

Nondestructive

Examination

  • E. Hartwig, Project

Management

"L. Leonard,

Examiner,

Nondestructive

Testing

  • J. Swindell, Plant Support Superintendent
  • W. Thomison,

Technical

Support

Other

licensee

employees

contacted

during

this

inspection

included

engineers,

technicians,

and administrative personnel.

Other Organization

AMDATA:

  • L. Reaves,

Site Supervisor,

and L-III Ultrasonic Examiner

G. Terning, L-III Ultrasonic Examiner

NRC Resident

Inspector

"E. Christnot

"Attended exit interview

Inservice

Inspection

Generic Letter 88-01

and

NUREG 0313,

Revision

2

(73051,

73052,

73753,

73755)

On January

25,

1988,

NRC

issued

Generic Letter 88-01,

"NRC's Position

on

IGSCC in

BWR Austenitic Stainless

Steel

Piping."

This letter also

forwarded

NUREG-0313,

Revision 2, "Technical

Report

on Material Selection

and

Processing

Guidelines

for

BWR Coolant

Pressure

Boundary

Piping."

NUREG-0313,

Rev.

2, describes

the technical

bases for the staff positions

on materials,

processes,

and

primary

coolant

chemistry

to

minimize

and control

intergranular

stress

corrosion

cracking

(IGSCC)

problems.

Inspection

schedules

and

inspection

sample

sizes

are

based

on

the

susceptibility

of weldments

to initiation

and

propagation

of

IGSCC.

Inspection

schedules

are

comparable

to those

specified

in Section

XI of

the

ASME Boiler and

Pressure

Vessel

Code

in

cases

where

the

piping

material is

IGSCC resistant.

Varying amounts of augmented

inspections

are

specified for piping with

a greater

susceptibility

to cracking,

where

there

is

less

certainty

about

the effectiveness

of mitigation measures

used,

or in cases

where repairs

have

been

performed.

When improved water

chemistry control with hydrogen

additions is implemented,

less

augmenta-

tion of inspection

schedules

is required.

The

purpose

of the

Generic Letter 88-01

was

to

seek

information

regarding

implementation

of the

new staff positions

covering

these

technical

areas.

The Generic Letter

applied

to all boiling water

reactor

(BWR) piping

made

of austenitic

stainless

steel

that

was four inches

or larger in nominal

diameter

and

contained

reactor

coolant

at

a

temperature

above

200~F

during

power

operation

regardless

of Code classification.

It also applied to reactor

vessel

attachments

and

appurtenances

such

as jet

pump

instrumentation

penetration

assemblies

and

head

spray

and vent components.

The staff continues

to believe

that

replacing

susceptible

piping with

IGSCC resistant

materials will provide the greatest

degree

of assurance

against

future cracking

problems.

However,

the staff

recognizes

that,

if the staff positions of this Generic

Letter are

implemented,

adequate

levels of piping integrity and reliability can

be achieved.

The staff

believes

the

Generic

Letter,

together with the revision of NUREG-0313,

will be of use

to licensees

in making

sound decisions

regarding

IGSCC,

in that

each

weldment

can

be evaluated

considering its material,

heat

treatment

history,

stress

level,

chemical

environment,

and

surveillance

program.

This will provide

a basis for

a reasonable

judgment

regarding

the

long-term acceptability

of that

weldment.

Considering

that

each

piping

system

has

many weldments

and each plant has

many piping systems,

the entire problem must be evaluated

in an integrated

way.

The

Commission

has

determined

that,

unless

appropriate

remedial

actions

are taken,

BWR plants

may not be in conformance with their current design

and

licensing

bases,

including

10 CFR 50,

Appendix A,

General

Design

Criteria 4,

14,

and

31.

Accordingly, pursuant

to

10 CFR 50.54(f),

BWR

operating reactor licensees

or construction

permit holders

were

requested

to furnish

under

oath

and affirmation their current

plans relating to

piping replacement,

inspection,

repair,

and leakage detection.

On January

30

February 2,

1989,

Region II inspected

TVA's program for

austenitic stainless

steel

piping covered

under

the

scope of this letter.

Procedures,

examination

work activities,

personnel

and

equipment qualifi-

cation

records,

and

completed

examination

data

were

reviewed.

Details

and results of the inspection

are described

below:

a

~

Program

Review

The licensee's

program for austenitic

stainless

steel

piping covered

under the

scope of Generic Letter 88-01

was delineated

in TVA letters

of response

to

NRC dated

August 1,

1988,

and January

12,

1989.

The

program

as described

in TVA letter of response

dated August 1,

1988,

identified

71

welds

that

had

not

been

ultrasonically

inspected

following induction heat stress

improvement (IHSI) on Unit 2.

TVA's

supplemental

response

dated

January

12,

1989,

informed

NRC that

a

post-IHSI weld examination project

had

been initiated to examine the

remaining Unit 2 welds that

had not received

a post-IHSI ultrasonic

0

inspection.

The inspector

re'viewed the letters of response

from the

licensee

to ascertain

whether

the

program pertaining

to austenitic

stainless

steel

piping was

complete

and in conformance with regula-

tory requirements

and the licensee's

commitments.

The inspector also conducted

walkdown inspections

of systems

contain-

ing

reactor

coolant

outside

the

containment,

reviewed .drawings

of systems

for material

type

and temperature,

and held discussions

with cognizant

licensee

engineers.

As

a result,

the

inspector

concluded that TVA's response

to Generic Letter 88-01 is inadequate

in that

TVA has

not addressed

the

6 inch,

5 inch or 4 inch diameter

reactor

pater

cleanup

(RWCU)

system

piping

outside

the

drywell

penetrations.

This piping operates

at

temperatures

far exceeding

200'F

and

is

nonconforming

stainless

steel.

Approximately

450

unexamined

w'elds are involved for the three Units.

TVA's August 1,

1988, letter of response,

paragraph

1. 1.0,

subpara-

graph one,

stated,

in part, that wrought austenitic

stainless

steel

piping

considered

to

be

susceptible

to

IGSCC

according

to

the

guidelines

given.

in

Generic Letter 88-01

stopped

at

the first

isolation

valve outside

the dry well penetration.

In addition,

in

paragraph

1, 1.0,

subparagraph

three, of the response,

TVA stated that

"A review of all

stainless

steel

piping

systems

was

conducted

in

order to investigate

the possibility

of

IGSCC

susceptibility

in

balance-of-plant

systems.

No

such

systems

were

found to meet

the

susceptibility criteria as stated

in Generic Letter 88-01."

The

inspector

informed

the

licensee

that

an

amended

response

to

the

Generic

Letter

should

be

submitted

to the Office of Nuclear

Reactor Regulation

(NRR) to list, schedule,

and categorize all welds

regardless

of Code Classification

which are susceptible

to

IGSCC in

accordance

with the Generic Letter.

In addition,

the

licensee

was

requested

to address

in their response

why 71 welds were identified

to

be

examined

on Unit 2 in both of their letters of response

and

only

66 welds

are

scheduled

to be examined.

This item was reported

to

the

licensee

as

Unresolved

Item

50-259,

260,

296/89-05-01,

"Amended

Response

to the Office of Nuclear Regulations,

Required for

Generic Letter 88-01."

Subsequent

to the

inspection,

Region II has notified

NRR of the

problem described

above

and resolution

of this finding

has

been

transferred

to the Special

Projects Division of NRR.

Review of Procedures

(Unit 2)

The inspector

reviewed

the procedures

delineated

below to ascertain

whether

the

licensee's

procedures

.pertaining

to

IGSCC

detection

and sizing

conformed to the ultrasonic training

courses

for

IGSCC

examinations

developed

by

the

Electric

Power

Research

Institute

(EPRI), Nondestructive

Examination

(NDE) Center,

in Charlotte,

North

Carolina,

and

demonstrated

effective

by ultrasonic

examiners

in

qualification efforts at the Center.

The following TVA procedures

were

reviewed

for approval,

calibration

requirements,

and

scanning

sensitivities

acceptance

levels,

NRC personnel

qualification require-

ments,

technical

content,

methods

of recording,

evaluating

and

dispositioning of findings.

Procedure

Number

Title

N-UT-25 Rev.

7

N-UT-42 Rev.

0

(Including

PCR ¹89-15)

N-UT-39 Rev.

0

"Ultrasonic Information of Austenitic

Metal

Welds for

IGSCC Using

Manual

UT

Technique"

"Ultrasonic

Examination

Using

the

Intraspect

98 System for the Detection

of

Intergranular

Stress

Corrosion

Cracking in Piping Weldments."

"Manual

Ultrasoni c

Si zing

of

Pl anor

Flows"

QMP-102. 4 Rev.

2

"Qualification

and

Certification

Requirements

for DNQA NDE Personnel"

Observation of Work and Work Activities (Unit 2)

The

inspector

observed

work activities

involved in the

automated

(Intraspect

I/98

System)

and

manual

ultrasonic

examinations

of

stainless

steel

welds after

IHSI.

TVA had

contracted

AMDATA to

perform the ultrasonic

examination activities.

AMDATA was working

under

TVA's Quality Assurance

Program

and

using

TVA's examination

procedures.

The inspector

reviewed

AMDATA's NDE Personnel

Qualifica-

tion

and Certification

records

for the

following

EPRI

qualified

examiners:

Examiner

G. Terning

J. Wolf

C.

Lasoya

M. Worby

Level of Certification

UT-L-III

(IGSCC)

UT-L-II

(IGSCC)

UT-L-II

(IGSCC)

UT-L-II

(IGSCC)

Job Title

I/98 Analyst

Sizing and Manual

I/98 Analyst

I/98 Operator

I/98 Operator

The

inspector

observed

the

examiners

in the field calibrating

and

taking data to ensure

that

approved

procedures

were

available

and

being

followed,

specified

nondestructive

examination

equipment

was

being

used,

and

examination

personnel

with the

proper

level

of

qualification

and

certification

were

performing

the

various

examination

activities'.

Data

Review and Evaluation (Unit 2)

The

inspector

reviewed

the

completed

ultrasonic

examination

and

calibration reports for the welds listed

below to ascertain

whether

the data

was within the previously established

acceptance

criteria

and if the methods

used for examination

were sufficient to determine

the full extent of acceptance.

The following records

were reviewed:

Weld Number

GR-2-63

GR-2-29

KR-2-24

KR-2-47

GR-2-57

GR-2-58

RR-2-48

GR"2-3

R-1160

R-1155

R-1159

R-1157

R-1153

R-1156

R-1154

R-1158

C-0274

C-0270

C-0274

C"0270

C-0270

C-0270,

C-0273

C-0271

C-0274,

C-0275

Automated Examination

Calibration Sheet

Number

Manual

Examination

DSCS-2-1

DCS-2-4

C-0269

C-0269

Within the areas

examined,

violations or deviations

were not identified.

3.

Exit Interview

The inspection

scope

and results

were

summarized

on February 2,

1989, with

those

persons

indicated in paragraph

1.

The inspector described

the areas

inspected

and discussed

in detail

the inspection

results

listed

below.

Proprietary

information is

not contained

in this report.

Dissenting

comments

were not received

from the licensee.

(Open)

Unresolved

Item

259,

260,

296/89-05-01,

Amended

Response

to the

Office of Nuclear

Reactor

Regulations,

Required for Generic Letter 88-01

(paragraph 2.a.)