ML20106D454
| ML20106D454 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/05/1992 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N92142, NUDOCS 9210090379 | |
| Download: ML20106D454 (10) | |
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,,<.sn OCT 0 51992 11LR-119214 2 United States fluclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO 110TICE OF DEVI ATIOli IllSPECTIoli REPOP.T 110. 50-354/92-11 IlOPE CREEK GEllERATIlia STAT 10!i DOCKET 110. 50-354 Public Service Electric and Gas Company (PSE&G) is in receipt of your letter, dated September 2, 1992, which transmitted a liotico of Deviation associated with the Hope Creek Erosion / Corrosion monitoring program.
This letter was received by PSE&G on September 4,1992.
In accordance with the directions provided in your letter, our response to this 11otice of Deviation is provided in Attachment 1.
Your letter also identified Unresolved Item 354/92-11-1 and requested that PSE&G address this item in our Deviation Response.
This response is included in Attachment 2.
Sincerely, ts), d fwfL &c1< %
o S.
LaBruna Vice President -
liuclear Operations Attachmentr.
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Document Control Desk 2
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00T 051992 NLR-N92142 C
Mr. T. T. Martin, Administrator - Region I O.
S.
Nuclear Regulatory Commission 475 Allendale Road l
King of Prussia, PA 19406 t
Mr. J.
Stone, Licensing Project Manager U.
S.
Nuclear Regulatory Commission One White Flint North 11555-Rockville Pike i
Rockville, MD 20852 Mr.
T. P. Johnson (S05)
USNRC Senior Resident Inspector
'I Ms. A.
Keller U.
S.
Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 ffr. K. Tosch, Chief NJ Department of Environmental Protection Divicion of Environmental Quality
-Bure'4u of Nuclear Engineering CN 415 L
Tren:on, NJ 08625 1
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i ATTACHMEliT 1 REPLY TO NOTICE OF DEVIATION-INSPECTION REPORT 110. r>0-354/92-11
!! OPE CREEK GENERATI1 STATION DOCKET NO. 50-354 i
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r NLR-H92142 J.
INWBODUCTLQH mn I inspector conducted an inspection
.t the Hope An 41 J C
.F dng Station from August 3 through 7, 2992.
The inspection was the Hope Creek Erosion /Currosion subjt
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(E/")
, prograw.
The inspector reviewed the Hope Crook
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E/C mo..a
- cgram to ensure that the program was being 6:
accomplis?
accordance with the PSE&G responses to Bulletin 37-03,
- k try of Pipe Walls in Nuclear Power Plants" and 89-08, " Erosion / Corrosion Induced Pipe Wall Gener/r n*
r Thinning.
inspector reviewed systems and components lk p
selected lur
.tranonic (UT) p.ipe thickness measurement, UT data results, PSEkb s analysis of the data and disposition of the ompone '.cs.
During the inspection the NRC inspector identified a ueviation from previous ccmmitments and issued the Notice of Deviation below.
bk II.
FOTICE OF DEVIATION "The respcnse tr Generic Letter 89-08 included a c-n"lb ant to implement a program addrassed in yoer engineering es _;ation which provides deta' 1:
5e measurement technique to determine the extent c' wall tc ing.
The engineering evaluation for the ueling outage 3 specifies under paragraph 4.3 that Hope Creek '+
a grid size f one inch shall be used for ultrasonic examination x
of pipe sizes six inc.ns in diameter and under.
6 kI Contrary to this, the field data shcwed that a grid size of two inches was used for examination of six-inch diameter pipes and below.
'Ihis is a deviation from the engineering evaluation provide: in response to NRC Generic Letter 89-08."
[
III. PSEbG RESE9NSE TO NOTICE OF DEVIATION PSE&G does not dispute this Notice of Deviation except to clarify that the field data in question was limited to one pipe spool nnd taken during the Hope Creek.ucond refueling outage as opposed to the third refueling outage.
Per PSE&u staff notas taken during the inspection, the NRC inspector identified a 6 X 4 inch pipe reducer (1-AF-202"SO3-T3) on the feedwater system as having been ultranonically exami ed us ing a two inch grid.
Tnis pipe spool was not examined during tha first Hope Creek refueling outage but was added as a new component during the second refueling outage.
PSE&G Engineering Evaluation H-1-VAR-MEE-0301-1, Paragraph 1.3 specifics the following grid sizes for new examination poi;.
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NLR-N92142 1 inch grid size Pipe sizes 6 inch and less Pipe sizes 8 to 12 inches
-2 inch grid size Pipe sizes 14 inches and over - 4 inch grid size Consequently, using a two inch grid on 6 X 4 inch pipe reducer 1-AF-202-S03-T3 was not in conformance to Paragraph 4.3.
This is a deviation from PSE&G Engineering Eva'.aation H-1-VAR-MEE-0301-1.
It should be noted that the UT data indicated this component had experienced l'*tle or no wall thickness reduction.
For existing examination points, i.e.,
those components ultrasonically examined during previous refueling outages, Paragraph 4.3 states that " Grid sizes used (2, 4 and 6 inch) on Ne pipe fittings initially examined during the first Hope Creek acling outage shall be maintained for repeatability."
erefore, grid sizes used on pipe components ultrasonically
/
.amined during the first Hope Creek refueling cutage were
..aintained unchanged during the second and third refueling outages to ensure repeatability.
PSE&G personnel revieked the UT field data from the second and third Hope Creek refueling outages and determined that, except for reducer 1-AF-202-S03-T3, the component UT grid sizes were established in accordance with PSE&G Engineering Evaluation H-1-VAR-MEE-0301-1, Paragraph 4.3.
A.
Reason for Deviation This deviation was an isolated event caused by human errot.
Neither the PSE&G Inservice Inspection Supervisor nor the Ergineering & Plant Betterment engineer reviewing the UT field data identified this single instance of the use of an incorrect grid B.
Corrective Steps Taken and Results Achieved PSE&G has-investigated this Notice of Deviation.
The result achieved is that it was determined that the deviation was isolated to the incorrect grid size on one pipe reducer.
The UT data for this reducer ind_cated little or no wall thinning and-consequentiv, the use of a two inch-grid size was not safety significant.
PSE&G has reemphasized to personnel irc olved in these measurements the importance of attention to detail and assuring compliance with requirements during each phase of the E/C monitoring. program.
Tne result achieved is that both PSE&G management and personnel have an increased sensitivity to E/C program requirements.
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NLR-N92142 9
C.
Corrective Steps to be Taken to Avoid Further Deviations.
PSE&G had previously committed to upgrading the administrative control of the PSE&G E/C monitoring program with the issuance of a Programmatic Star.dard by Septenbor 30, 2992.
This has occurred.
The E/C Programmatic Standard and associat- ' detailed procedures describe the E/C program review tsgliremens and responsibilities in graater detail.
Included are specitic instructions regarding UT grid size, examination, data t
review / approval and analysis.
These procedures provide the necessary technical guidance and review requirements to avoid further E/C program deviations in the future.
E.
Date When Corrective Steps Will be Completed All corrective steps have been completed.
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. i ATTACHMENT ~2-
' j RESPONSE TO UNRESOLVED ITEM-334/92-11-1 INSPECTION REPORT NO. 50-354/92-11 HOPE CREEK GENERATING STATION DOCKET NO, 50-354
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NLR-N92142 UNRESOLVED ITEM 354/92-11-1 During an inspection of the Hopo Creek Erosion / Corrosion (E/C) monitoring program from August 3 through 7, 1992, the NRC inspector identified an open item concerning Hope Creek CHEC E/C computer records.
(CHEC is the EPRI developed computer program PSE&G utilived to assist in selecting components for E/C monitoring.)
Specifically, the inspector stated the following in Inspection heport 354/92-11:
"The licensee's analysis for selection of components for ultrasonic thickness measurement was to be based on the EPRI CHEC computer program along with engineering judgement.
This was a commitment in response to NRC Bulletin 87-01 and Generic Letter 89-08 and was reflected in the program.
The licensee stated that selection of components for erosion / corrosion measurements was performed in accordance with these commitments.
During the inspection, however, the EPRI CHEC analydis for the condensate, the feedwater and the extraction steam systems were not available for inspector's review.
ihe licensee was unable to provide documentation of having met the above commitments on the condensate, feedwater and extriction steam systems; therefore, this item is unresolved penning recovery of the_ records (URI 354/92-11-1).'
In the cover letter to NRC Inspection Report 354/92-11, PSE&G was reques+;cd to advise the NRC when these CHEC records will be available for their review.
This is provided in the following:
ESEGG RESPONSE During the NRC inspection PSE&G files contained handwritten CHEC input sheets and the printouts of the CHEC output analysis for the feedwater and condensate systems.
The output sheets contained an echo of the input data.
The extraction steam system contains two phase flow.
Since the CHEC program is limited to single phase flow modeling, enoineering judgment and industry experience were used to select extraction steam components for UT examination.
The CHEC output analysis qualitatively ranked the pipe components based on susceptibility to E/C.
It also predicted the time tc minimum wall thickness.
However, the pipe component identifiers appearing in the CHEC ou*put analysis were not the identifiers used on PSE&G isometric drawings and UT field data sheets.
Consequently, the NRC inspector was not able to confirm whether the feedwater or condensate pipe components ranked by CHEC as PAGE 1 OF 3 l
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.NLR-N92142
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i h ghly suscept ble to E/C degradation were the components.
selected for UT examination.
The missing analyses referred to by the inspector'in Inspection Report 354/92-11 are understood to be the isometric drawings annotated with the identifiers used in the CHEC analyses.
PSE&G personnel have reconstructed the major part of the CHEC feedwater and condensate system analyses using computer files, the available documentation and plant system knowledge with the H
following results:
i Feedwater System:
The feedwater isometric drawings were recreated and re-labeled with both the assigned CHEC component identifiers and the pipe component identifiers used in the UT field data sheets.
Twenty-one feedwater components were modeled in CHEC.
Five components were predicted as undergoing a HI-RATE of E/C.
These five components were UT examined with satisfactory results.
The remaining sixteen components were ranked by CHEC to be in the PROBABLE, category.
Three of these components were UT examined with satisfactory results.
Also, the eight feedwatcr components that were UT examined included five of the top six components predicted by CHEC to have the shortest time to minimum wall thickness.
Condensate System:
Twenty-five condensate system components were modeled in CHEC with all being listed in the PROBABLE category.
Four ov' of the twenty-five CHEC idsntifiers could not be located on isometric drawings.
The condensate system ~isotaetric drawings were re-labeled with the twenty-one_ assigned CHEC component identifiers and the pipe component identifiers used in the UT field data sheets.
Eight of these condensate components were UT examined with satisfactory results.
The eight condensate components that were UT examined included the top four components predicted by CHEC to have the shortest time to minimum wall thickness.
These files are akallable for review.
PSE&G is working to complete verification efforts with regard to CHEC data input and inspection history in the near future.
PSE&G management has recognized that increased control of E/C program documentation is necessary.
An E/C programmatic standard and implementing procedures have been issued requiring that E/C program model inputs / outputs be controlled in much the same way as a PSE&G calculation.
This will provide increased control over PAGE 2 OF 3
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E/C model analyses to ensure this documentation is maintained and retrievable in the future.
-Also it should-be.noted that PSE&G is remodeling Hope Creek pipe systems 11ncluded in the-E/C program using the latest version of CHECMATE, Version 1.1B.
This remodeling is being performed in-accordance with the upgraded documentation and control standards in.the E/C Programmatic Standard.
Consequently, thi<. CHECMATE analysis, and not the CHEC-analyses reviewed by the NRC p,
inspector, will be-used as the basis for identifying components to be UT examined during future Hope Creek refueling outages (fifth refueling outage and beyond).
Finally, it should be noted that PSE&G has complete UT field data documentation from previous Hope Creek outages for these three sistems.
This data indicates that these pipe components have experienced minimur aoar and their structural integrity has been maintained.
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