ML20141E806

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Insp Repts 50-321/86-05 & 50-366/86-05 on 860224-28. Violation Noted:Failure to Have Procedure for Conducting Acid Etch Exams on safety-related Components
ML20141E806
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 03/28/1986
From: Blake J, Coley J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141E766 List:
References
50-321-86-05, 50-321-86-5, 50-366-86-05, 50-366-86-5, NUDOCS 8604220388
Download: ML20141E806 (9)


See also: IR 05000321/1986005

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Report Nos.: 50-321/86-05 and 50-366/86-05

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Licensee: Georgia' Power Company

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P. O. Box 4545-

Atlanta, GA' 30302

Docket Nos.: 50-321 and 50-366

License Nos.: DPR-57 and NPF-5

Facility Name:

Hatch 1 and 2

Inspection Ccnducted:

February 24-28, 1986

Inspector:

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3-dR-8f

J. L

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Date Signed

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Approved by: - -'

J. J. Blalie, Section Chief

Date Signed

E gi eering Branch

iv sion of Reactor Safety

SUMMARY

Scope:

This routine, unannounced inspection entailed 40 inspector-hours on site

in the areas of inservice inspection, observation of work activities, data

review, and evaluation (Unit 1).

Results:

One violation was identified - Failure to have a procedure for

conducting acid etch examinations on safety-related components - paragraph 6.

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REPORT DETAILS

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1.

. Persons Contacted

Licensee Employees

  • J. Beckham, Vice President and General Manager - Nuclear Operations

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  • H. Nix, Site General Manager
  • D. Vaughn, Senior Quality Assurance Specialist
  • S. Tipps, Superintendent of Regulatory Compliance

G. Goode, Supervisor of Engineering

T. Huckaby, Inservice Inspection (ISI) Engineer

R. Harrington, Inspector Quality Control

Other Organizations

Southern Company Service (SCS)

-J. Agold, Supervisor or Coordination and Documentation

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G. Loftus, Lead Inspector-Level III

Bechtel Inc.

8. Miller, Test-Engineer

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NRC Resident Inspectors

  • P. Holmes-Ray, Senior Resident Inspector

G. Nejfelt, Resident Inspector

  • Attended exit interview

2.

Exit Interview

The inspection scope and findings were sumarized on February 28, 1986, 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.

(0 pen) Violation 321/86-05-01, Failure to Have a Procedure for

Conducting Acid Etch Examinations on Safety-Related Components,

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graph 6.b.

(0 pen) Unresolved Item 321, 366/86-05-02, NUREG-0619 Examinations, para-

graph 5.a.

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(0 pen) Inspector Followup Item 321/86-05-03, Licensee Review of ISI Plans,

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paragraph 5.b.

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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 are matters about which .r. ore information is required to

determine whether it is acceptable or may involve violations or deviations.

One new unresolved item identified during this inspection is discussed in

paragraph 5.a.

5.

Inservice Inspection - Observation of Work and Work Activities (737538)

(Unit 1)

The inspector observed the ISI activities described below to determine

whether these activities were being performed in accordance with regulatory

requirements and licensee procedures.

The applicable code is the ASME

Boiler and Pressure Vessel Code,Section XI,1980 Edition, W80 Addenda.

(See RII Report 50-321/85-35 and 50-366/86-02 for previous inspections in

this area).

a.

As noted in RII Inspection Report 50-321/85-35, the first 10-year

interval inspections are to be completed during the current outage.

The inspector compared the current outage plan for Class 2 components

and pipirg with the modified forty-year inservice examination plan for

Class 2 components to determine whether the first 10-year interval

requirements of the Technical Specifications, ASME Section XI, and the

ISI Program accepted by the NRC will be met during the current outage

in the areas of:

Number of items to be inspected

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Methods of examination

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Extent of examinations

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The inspector verified that the ASME Section XI requirements applicable

during each inspection period requirements had been implemented and

accomplished for the 10-year inspection interval by reviewing in detail

Category CC welded supports in five Class 2 piping systems.

The following systems / components were reviewed:

Main Steam Auxiliary System

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Core Spray System

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Residual Heat Removal Heat Exchangers

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High Pressure Core Injection

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Reactor Core Isolation Cooling

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ASME Section XI requirements for Category CF pressure retaining welds

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in piping were verified by selecting a sample based on a specific size

of pipe in six Class 2 piping systems.

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The pipe diameters indicated in the following systems were selected for

review:

System

Diameter of Pipe

Main Steam Auxiliary

24-inch diameter

Turbine Steam Bypass

16-inch diameter

Residual Heat Removal

16-inch diameter

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Core Spray

10-inch diameter

High Pressure Core Injection

10-inch and 14 inch diameters

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Reactor Core Isolation Cooling

8-inch and 10 inch diameters

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During the review of the modified inspection interval, the inspector

noted that weld No. IC11-2CRD-3-R-2 referenced a note in the plan which

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invoked the requirements of NUREG-0619.

NUREG-0619 required that,

during each refueling outage, the welded connection joining the

rerouted control rod drive return line (CRDRL) to the system which then

returns flow to the reactor vessel is to be inspected. The inspection,

using ultrasonic examination (UT), must include base metal to a

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distance of one-pipe-wall thickness or 0.5 inch whichever is greater,

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on both sides of the weld.

The modified inspection interval did not

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indicate that these examinations had been performed. The licensee also

could not find any examination reports on this weld, however, discus-

sions with Southern Company Service (SCS) cognizant personnel indicated

that the piping configuration at the Hatch plant was not exactly as

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that described in NUREG-0619 since Hatch utilizes a thermal tee fitting

in lieu of a weld-o-let.

SCS stated that, this issue had been discussed earlier in the interval

and a safety evaluation had been performed.

The SCS representative,

however could not find the documentation allowing the deviation.

This item was found near the end of the inspection and cognizant

licensee personnel were not at the site to discuss the matter or to

provide the necessary documentation; therefore, the issue was reported

as Unresolved item 50-321, 366/86-05-02, NUREG-0619 Examinations,

b.

During the inspector's review of the above modified inspection plan,

questions concerning how the plan was set up (four periods in lieu of

three), what code was being used in each inspection period, and how to

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coordinate the approved deviations into the plan during the review were

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discussed with the licensee.

The licensee's ISI personnel were unable

to answer the inspector's questions.

Several days after the inspector

arrived on site the licensee arranged a telephone call between the

inspector and a cognizant SCS representative in Birmingham, Alabama.

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In addition, the cognizant SCS represeatative from Birmingham arrived

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at the site near the end of the week to assist the inspector in

interpreting the modified program and plans and where the deviations

fit into these plans.

The SCS representative was a very knowledgeable;

individual and the inspector's question and concerns were answered in--

depth.

The inspector, however, was concerned that the licensee repre-

sentatives in the ISI section could not answer the inspector's program

and plan questions since the licensee is responsible for reviewing

vendor work and ensuring that the regulatory and code requirements are

properly implemented.

The inspector, however, did not discuss this

concern with site quality assurance personnel.

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The inspector will pursue this concern on a subsequent inspection and

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identified ~ it as Inspector Follow-up Item 50-321/86-05-03, Licensee

Review of ISI Plans. This was opened to track the inspector's concern.

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c.

The inspector observed the first 10-year interval ISI system pressure

test (P41-PT-2) for the service water system, division 1 pumps A&C.

This is a Class 3 system and was performed at normal operating pressure

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rather than 1.10 times the design pressure required by the code. The

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licensee had received approval for relief to the code requirements from

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NRC because this portion of the system had a butterfly valve as the

hydrostatic test boundary and butterfly valves are basically flow

control valves not intended to be block valves.

The inspector

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witnessed the pressure test to determine if the following requirements

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were met:

Approved procedures are available and are being followed.

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Examination personnel are knowledge of examination method and test

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boundaries.

Examination personnel with proper level of qualification and

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certification are performing the examination activities

Examinations results, evaluation of results, and corrective

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actions / repairs / replacements are being recorded as specified in

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the ISI program.

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Within the areas examined, no violation or deviation was identified.

6.

DataReviewandEvaluation(Unit 1)(737558)

The inspector reviewed ISI data and evaluations performed by the licensee to

ascertain whether NDE data covered the scope of examination required during

the current inspection period, data files are complete and within previously

established acceptance criteria, and the licensee's disposition of adverse

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findings and subsequent re-examination is consistent with regulatory

requirements.

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The applicable code is the ASME Boiler and Pressure Vessel Code,Section XI,

1980 Edition with addenda through W80.

The inspector performed the

following observations / reviews and compared the results with the applicable

procedures:

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Class 1 Components - Ultrasonic Examination of Jet Pump Beams

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0ne of the activities performed during the current refueling /mainten-

ance outage for Unit I was an inspection of the Jet pump beams pursuant

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to General Electric Service Information Letter (SIL) 330.

During the

ultrasonic examination of all 20 jet pump hold-down beams an indication

of cracking was found on the beam for jet pump No.16. The indication

was located on the top surface of the beam, at the minimum ligament

adjacent to the bolt hole.

The initial estimate of the crack depth was

150 mils.

The beam was replaced during the current outage and a new

base line examination was performed.

The inspector reviewed the

following nondestructive examination (NDE) records:

Examination results and data sheets

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Calibration data sheets

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Examination evaluation data

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Records on extent of examination

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Records on disposition of findings

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Re-examination data af ter repair work

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SCS Procedure UT-H-414 Revision 1 Ultrasonic Examination of Jet

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Pump Beams

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NDE personnel qualification and certification records

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In addition to the nondestructive test examination data, the inspector

reviewed Georgia Power Procedure No. 42 SP-INS-023-05, Revision 1 for the

replacement of the jet punp hold-down beam and witnessed a video tape

of the entire operation. Areas covered in the procedure and video tape

included the following:

Jet Pump Tensioner Setup

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Detention and Break Keeper Tack Welds

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Beam Bolt Retainer Cutting

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Installation of Jet Pump Beam

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Tensioner Installation and Operation

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Welding Equipment Setup

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Beam Bolt Keeper Weld Qualification Test

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Tack Weld of Keeper to Beam

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Inspection of Keeper Tack Welds

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Inspection of Keeper Tack Welds

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installation of Ultrasonic Fixture on New Beam

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The inspector also reviewed the General Electric Service Information

Letter SIL-330 to insure that recommendations made by General Electric

(GE) in the letter had been implemented for hatch Units 1 and 2.

The

-following recommendations were verified:

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UT examinations of the Deams performed.-curing each refueling

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outage and beams having crack indicatigns-replaced.

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Jet pump surveillance initiated for evaluation of pump performance

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Technical Specificatiohs modified for Units 1 and 2 to reflect

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alternative B approach delineated in GE's SIL-330

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Jet pump performance monitoring established

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b.

Reactor Pressure Vessel Welds - Reactor Pressure Vessel Longitudinal

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Welds Nos. C-3-B, C-3-A, and C-3-C

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The inspector reviewed records for the longitudinal welds identified

above to ascertain whether the following requirements were met:

The method, extent, and technique of examination comply with

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licensee's ISI program and applicable NDE procedure.

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The examination data are within the acceptance criteria as

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outlined in applicable NDE procedure and applicable code require-

ment.

The recordirg, evaluation, and disposition of '~inding 'are in

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compliance with the applicable NDE procedure end applicable code

requirements.

The method used for NDE was sufficient to determine the full

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extent of indication or acceptarice.

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Nondestructive test examiners were qualified and certified to

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perform the eximinations.

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As a results of previous inspections in this area by RII' inspectors,

the inspector was aware .that SCS was having difficultidF)n ?ocating

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the longitudinal welds because during the fabrication 5;tage of the

vessel, the outside diatneter of the vessel had been milled to ensure

its roundness.

This operation smoothed the welds to where they"could

not be distinguished from the base metal.

The licensee had rerformed

an acid etch examination and was unable to locate the welds. '

As a result, the licensee requested assistance from the Electric Power

Research Institute (EPRI) NDE Center in Charlotte, North Carolina and

sent an NDE examiner to the EPRI Center to learn how to perform the

examination correctly.

Discussions with the SCS Level III examiner

revealed that in addition to hands on acid etch training the following

recommendations were made by EPRI:

The metal su.rfaces to be etched must be polished brighter than

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first thought by SCS

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Fluorescent light should be used in lieu of incandescent light to

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enhance examination.

Acid strength improvement

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The inspector requested to see the procedure used to perform the acid

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etch examination of the reactor pressure vessel since this test is a

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controlled corrosive reaction and if not properly performed and cleaned

could have a detrimental effect on the reactor vessel.

Areas of

concern were acid strength, the time period acid is allowed to stay on

component, and the method of removing the acid after the test is

complete.

The SCS level III could not provide a procedure for the

inspector and indicated that the examinations were performed using trial

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and error methods.

However, later in the week a SCS representative

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from Birmingham, Alabama brought the inspector a draft procedure for

performing acid etch examinations on carbon and low-alloy steels.

Although this procedure was in a draft form it did not incorporate any

of the EPRI recommendations for performing the acid etch examination.

Failure to have procedures to perform examinations required for

surveillance testing on safety-related equipment is in violation of

Hatch, Unit 1, Technical Specifications paragraph 6.8.10.

This item

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was reported as Violation 321/86-05-01, Failure to Have a Proce-dure

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for Conducting Acid Etch Examinations on Safety-Related Components.

c.

Pressure Retaining Pipe Welds Within Reactor Coolant System

The inspector reviewed ISI records for pressure retaining welds

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Nos.1B31-1RC-128R-B-3 and 1831-1RC-28A-5A,

Records for these welds

were chosen because of the following:

The licensee had reported that UT had detected a 20 percent

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through-wall crack in weld 1831-1RC-12BR-B-3 during the pre-induc-

tion heat stress improvement (IHSI) examinations.

Liquid pene-

trant examinations performed after IHSI revealed several small

through-wall indications.

Subsequent, UT examinations were

perform by SCS and the results indicated that the through-wall

cracks were axial indications which could not be detected with the

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tangential scanning methods used in the approved UT procedures.

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The through-wall indications were not associated with the circum-

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ferential crack reported during pre-IHSI examinations.

During a walkdown inspection of the recirculation system, this

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outage, the licensee discovered that weld No. 1831-1RC-28A-5A had

been left off the vendor fabrication drawings and subsequently

left off the ISI drawings. The licensee planned to used construc-

tion radiographs for the base line examination and performed the

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10-year interval examination during the present outage.

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The inspector reviewed records for the above welds to determine whether

the following requirements were met:

The examination unit calibration data sheets show no ' major

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deviations between initial and final calibrations.

Collected examination data and any recordable indications are

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properly recorded to permit accurate evaluation and documentation.

Evaluation of examination data performed by a Level II or Level

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III examiner.

Evaluation of examination data complies with the procedure.

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Qualification and certifications records of examiners met codes

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and regulatory requirements.

Within the areas inspected, no violations, except as noted in paragraph 6.b,

or deviations were identified.