ML20149K155
| ML20149K155 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/23/1993 |
| From: | Latimer J AFFILIATION NOT ASSIGNED |
| To: | Demiranda O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20149K047 | List: |
| References | |
| FOIA-96-32 NUDOCS 9602210448 | |
| Download: ML20149K155 (80) | |
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MR. OSCAR DEMIRANDA P. O. BOX 845 / ATLANTA, GEORGIA 30301 DEAR SIR: ATTACHED YOU WILL FIND INFORMATION WHICH MAY HELP YOU WITH YOUR INVESTIGATION AT LEAST FROM MY VIEWPOINT. CERELY, i OHN LATIMER i I l
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9602210448 960201 % PDR FOIA / LATIMER96-32 PDR O. ")/
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i QUALITY CHECK PROGRAM - INDEPENDEffr INVESTIGATION (1) IN DECEMBER 1992, I WAS CALLED BY HERB CASANOVA, MANAGER-QUALITY CHECK WHO STATED I WOULD BE CONTAC' RED ABOUT THE QUALITY CHECK I FILED, BY SOMEBODY POSSIBLY FROM OUTSIDE THE COMPANY DUE 'ID THE NATURE OF MY , CONCERNS. ON JANUARY 7,1993 I COffrACTED CASANOVA TO FIND OUT THE STATUS. HE 'IDLD ' I M2 THE MATTER WAS IN THE LEGAL DEPARMEffr. ! ON JANUARY 22,'1993 I AGAIN CALLED CASANOVA WHO STATED SOME ONE FROM THE LEGAL DEPARME?ff WAS AT THE ROBINSON PIRfr ON JANUARY 15, 1993. WHEN < ASKED WHY THE LEGAL DEPARMEfff WAS INVESTIGATING, HE STATED THE QUALITY - CHECK WAS SE?fr TO LEGAL FOR THEIR EXPERTISE IN INVESTIGATION WITH THE i i CONCURRENCE OF CHARLIE DIETZ. (2) IN NOVEMBER 1992 I COffrACTED THE ROBINSON PERSONNEL DEPARMENT AND TALKED WITH DEWAYNE WALTERS WHO STATED MY TERMINATION HAD BEEN APPROVED BY THE PERSONNEL AND LEGAL DEPAR MENT. HE SEN* .'. :'.AND nRITTEN NOTE TC ME WHICH STATED MY TERMINATION HAD BEEN REVIEWED BY PERSONNEL AND LEGAL. EXHIBIT (1) . (3) WHEN I ORIGINALLY FILED THE QUALITY CHECK, I HAND WROTE A NCfrE ON THE BOTIDM F" QUESTING OTHER PERSONS NOT IN THE DIRECT CHAIN OF COMMAND BE CONTACTED FOR THEIR INPUT ON MY PERFORMANCE AT ROBINSON. I FOLI4WED i THIS UP ON NOVDiBER 23, 1992 WITH A LETTER TO CASANOVA NAMING SPECIFIC PERSONS TO BE CONTAUrED. EXHIBIT (2) (4)a THE INVESTIGATION WAS NOT DONE BY AN INDEPENDENT MUCH LESS OUTSIDE ORGANIZATION. IT WAS INVESTIGATED BY THE SAME LEGAL DEPARWDir WHO APPROVED MY TERMINATION ORIGINALLY. (4)b I WAS NEVER CONTAUTED FOR ANY ADDITIONAL INPUT AS PROMISED NOR GIVEN THE CHANCE TO REFUTE THE INFORMATION AND NEW CHARGES COffrAINED IN CP&Ls RESPONSE. (4)c '!O MY KNOWLEDGE AND AFTER A REVIEW OF THE CP&L RESPONSE, IT IS APPARENT NO PERSONNEL REQUESTED BY ME WERE EVER INTERVIEWED FOR THEIR INPUT. THE ONLY PERSONS HAVING INPUT WERE THE SAME PERSONS WHO APPROVED THE TERMINATION ORIGINALLY. THE PRIMARY PERSON BEING MY FORMER SUPERVISOR - WARREN FARMER.
QUALITY CHECK RESPONSE CP&Ls RESPONSE TO MY QUALITY CHECK CONCERNS WAS INCOMPLETE, NONFACTUAL, AND CONTAINED ALLEGATIONS NEVER BEFORE BROUGIR TO MY ATTE?RION. (1) EROSION / CORROSION PROGRAM - THE RESPONSE ALLEGES MISMANAGEMENT OF THE E/C COMPUTER PROGRAM PROJECT BY STATING THAT I FAILED TO VERIFY THE INFORMATION UtRIL THE END OF THE PROJECT AND THEN AT THAT TIME I FOUND ALL THE INPUTS WERE WRONG. THIS IS N T TRUE AS FARMER IS WELL AWARE. OUTPUTS AND INPUTS WERE VERIFIED OVER THE LIFE OF THE PROJECT. WHERE THE PREDICTED E/C RATE DIFFERED WITH ACTUAL FIELD RESULTS, THE INPUTS WERE DOUBLE CHECKED BY THE PROGRAttfER AND MYSELF AND CORRECTIONS IF REQUIRED WERE MADE. WHERE DIFFERENCES STILL EXISTED, THESE WERE BROUGHT TO THE ATTENTION OF FARMER. HE DISMISSED MY CONCERNS AND LABELED THEM AS A REFUSAL TO COOPERATE WITH MANAGEMENT DIRECTION. AT NO TIME DID I VERIFY ALL INPUTS WERE WRONG. TO THE CONTRARY, THE PROGRAMMER DID AN EXCELLE?R JOB CONSIDERING THE LIMITED INFORMATION AVAILABLE. ~ (2) THE WELDING ENGINEERING STAFFING REQUIREMENTS WERT NOT ADDRESSED FULLY. THE CP&L RESPONSE TO MY CONCERN WAS THAT BOTH HARRIS AND BRUNSWICK HAD ENOlXiH WORK TO JUSTIFY ONE FULL TIME WELDING ENGINEER. THE FACT THAT HARRIS HAS 1WO FULL TIME PERSONS AND BRUNSWICK HAS FOUR FULL TIME PERSONS WAS NOT ADDRESSED. EXHIBIT (3) (3) MY REQUEST TO TRANSFER WAS NOT EXPIDRED FULLY. THE CP&L STATEMENT THAT FARMER SIGNED THE TRANSFER REQUEST WAS AN ATTEMPT TO SHOW NO BIAS EXISTED ON HIS PART. THE FACT IS THAT HE WAS REQUIRED BY PROCEDURE TO SIGN THE REQUEST WHETHER HE AGREED WITH IT OR NOT. CHAMBERS DENIAL OF A TRANSFER OUTRIGHT IS A DIRECT CONTRADICTION OF A LETTER HE SIGNED ON 3/30/92 STATING AS AN ALTERNATIVE TO TERMINATION WOULD BE A TRANSFER. EXHIBIT (4). IT IS APPARENT THAT A TRANSFER WAS AN ~ OPTION BEFORE THE NRC AUDIT BUT NOT AFTER. IT IS INCONCEIVABLE THAT CP&L WOULD TERMINATE AN DfPI4YEE WITH COMMENDABLE RATINGS FOR 9 YEARS UNDER 6 DIFFERENT SUPERVISORS AND NOT GIVE HIM THE CiRNCE TO TRANSFER. MY REQUEST TO TRANSFER WITHIN TECH SUPPORT WAS ALSO NOT DISCUSSED IN THE CP&L FINDINGS. ALTHOUGH NO OFFICIAL SIBF IN MODIFICATION IMPLEME!UATION EXISTED AT THE TIME OF MY TRANSFER REQUEST, MY REASONS FOR THE TRANSFER OF THE WELDING ENGINEER SIUT WERE WELL STATED IN THE QUALITY CHECK REPORT AND THE NEED FOR MY EXPERTISE WAS STATED IN A MODIFICATION IMPLEME? RATION LETTER. EXHIBIT (5) ALSO AT THE TIME OF MY TERMINATION AND PRIOR TO, THERE WERE WELDING ENGINEERING SIDTS AVAILABLE IN THE CORPORATE OFFICE FOR WHICH I WAS WELL QUALIFIED. I DID NOT APPLY FOR THESE POSITIONS BASED ON CHAMBERS TRANSFER REFUSAL. l 1 1 1
IN RETROSPECT, I SHOULD HAVE SUSPECTED MY TERMINATION WAS A FORE GONE CONCLUSION SINCE NO HIGHER MANAGEMENT EVER REQUESTED _A MEETING TO HEAR MY SIDE BEFORE TERMINATION. ANY MEETINGS HELD WERE AT MY REQUEST AND IT SED 4ED WITH RELUCTANCE FROM HIGHER MANAGEMENT. THE LAST MEETING I HAD WAS IN OCTOBER 1992 WITH ' IRE NEW TECH SUPPORT MANAGER WHERE HE STATED THAT I WOULD BE THE PROJECT WELDI?G ENGINEER FULL TIME, A FACT NOT DISPUTED BY THE CP&L RESPONSE. IN MY MEE' TING, I ALSO RAISED ALLEGATIONS THAT FARMER WAS RESPONSIBLE FOR THE NEAR FAILURE OF THE SERVICE WATER PIPING AT THE INTAKE BECAUSE HE FAILED TO TAKE THE NECESSARY CORRECTIVE AND FOLLOW UP ACTION WHEN THE PROBLDi OF OD CORROSION WAS DISCOVERED SEVERAL YEARS AGO. I SUSPECT THIS WAS ALSO A FACIOR IN MY TERMINATION SIfCE FARMERS INACTION WAS APPARENTLY APPROVED BY CP&L HIGHER MANAGDfENT. (4) THE CP&L INVESTIGATION DID NOT ADDRESS THE MANPOWER REQUIRDfENTS FOR THE E/C PROGRAM. AS STATED IN THE NRC INSPECTION REPORT EXHIBIT (6), THE NRC SALP REPORT EXHIBIT (7), THE NAD REPORT EXHIBIT (9), AND
.SL LEI'rER EXHIBI7%10), ONE OF THE MAIN PROBLDfS OF THE E/C PROGRAM WAS THE LACK OF ADEQUATE MANPOWER.
IN ADDITION IN MY 3/7/92 APPRAISAL, FARMER USED THE SITE WORK TRACKING SYSTEM TO DEMONSTRATE THAT I HAD NO BACK LOG OF WORK AND THEREFORE MUST NOT BE USING MY TIME EFFECTIVELY. HE THFN STATED THAT MY LACK OF BACKLOG WAS DUE TO THE NATURE OF THE JOD. A?iER BEING CRITICIZED SEVERAL TIMES ABOUT THE AMOUNT OF WORK ON THE SWTS, I LISTED ALL WORK AND TIME SPENT REGARDLESS OF PROJECT OR ROUTINE STATUS. THE RESULT EXHIBIT (11) AND (12) SHOWS THAT THE LAST TWO QUARTERS OF 1992 WOULD REQUIRE 80 HOUR WORK WEEKS. FARMER WAS AWARE OF THIS WORK IDAD kHEN IN A MEETING ON 8/12/92 HE STATED I HAD A GOOD START ON LISTING ALL ITEMS OF RESPONSIBILITY ON THE SWTS. EXHIBIT (13). IN ADDITION TO THE INSUFFICIENT MANPOWER DEDICATED TO THE E/C PROGRAM, I WAS EXPECTED TO LEARN THE EPRI COMPUTER PROGRAM ON MY OWN WHICH I DID. REQUESTS TO ATTEND SEMINARS OR THE YEARLY EPRI MEETI?G WERE DENIED BY FARMER. IN FACT ALL TRAINING WHICH I REQUESTED FOR 1991 OR 1992 WAS DENIED OR WAS APPROVED TOO LATE TO GET A SLOT IN THE COURSE. TECH SUPPORT MANAGDfENT USED THE IDP AS WINDOW DRESSING TO SHOW THAT CP&L WAS COMMIT'TED TO TRAINING, BUT WHEN THE TIME CAME TO ALLOCATE FUNDS, THE COMMITMENT STOPPED.
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Reom: Dabyw Wa/hr^ As reguakd _ s COMPANY POLICY Carolina Power & Light Company is an equal opportunity employer. All personnel policies are administered without
/ discrimination on the basis of race, color, religion, . sex, ff[3 /
age, handicap, veteran status, or national origin. f@en'twelationspth-the.' Company is the" hg ,v - __ of.a#;*Q7danJf.~.an Individual to 3.; i M.jat Fthe3$idl5i57~ahif5Comjany decisi h
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e Cosipan~ys~ i sincere hope that each employment relationship will be a mutually rewarding and satisfactory h44W.4 I #' - p' experience which both the employee and the Company 8/fu will want to continue.
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W gM O It is required that all employees comply with Company policies, practices, and procedures. The policies,
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[ t practices, and procedures are not intended as a contractual commitment or obligation of Carclina Power JC 37,,yg dM & Light Company to its employees. Carolina Power & Light Company therefore reserves the right at any time to jg ig ,/g fg modify, amend, or rescind such policies, practices, and procedures. Exceptions may be required from time to time but will be permitted only with the approval of an A appropriate level of supervision. Questions should be discussed either with supervision or with a representative p ,,/ of the Employee Relations Department.
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i 1 b d. 4, b 1 1 NOVDfBER 23, 1992 l MANAGER-QUALITY CHECK CP&L (OSH 10) P. O. BOX 1551 RALEIGH, N. C. 27602 DEAR SIR: IN YOUR REVIEW, PLEASE j THIS IS IN REFERENCE 'IO QUALITY CHECK QCR NO.19506. COhTALT SUCH PERSONS AS JACK EPPERLY AND BRAD STARNES OF MOD IMPLDENTATION, LARRY LYhCH OF QUALITY CONTROL AND ANY QC INSPEC'IOR, ANY MAINTENANCE PLANNER, ANY MDiBER OF MOD PROJECTS UNDER MIKE HEATH, MALCOM REESE, RAY HANFORD, OR SUCH PERSONS IN TECH SUPPORT AS GREG BUSSELL OR SID NEITLES. 'INESE PERSONS CAN ATTEST 'IO MY PERFORMANCE AT ROBINSON PLANT. SINCERELY, JOHN LATIMER 1 + 6 J t - e
$1//W0V Assessment of msrP Weldino Procram 4p 4 Maior Issues y
Welding Material - Handling and Control
- Poor control over who writes requisitions (WMR).
- Lack of verification of proper information on requisition.
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- Is welder qualified for procedure required?
- Is correct welding material specified on WMR7
- Writing of WMR is delegated to long list of "other" authorized people who may not have responsibility.
- Weld Issue station attendant not performing any verification of ,
wolder's qualifications for listed procedures at issue station. j !' - Project Welding Engineer has no direct authority over those filling out WMR's. Project Welding Engineer- C C Ehk k e h d - M I - L-I
- currently not staffed for both Units down simultaneously for major workload. l
- Understaffed to handle all paperwork, supervise and operate test shop, monitor and follow all field welding.
- Project Welding Engineer can use some technical supervision on decisions involving materials and welding issues.
Wald Tes op
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- Needs significant improvement in handling of welding materials and supervision of testing welders.
. - Bins and racks need proper segregation and labeling for proper material control.
- office area should be separated from weld material issue station.
Corporate Welding Manual
- Corporate Welding Manual made no provisions for welding material handling and issue being outside the authority and control of the Project Welding Engineer. Manual revisions are necessary to address proper control by organizations other than the Project Welding Engineer or total responsibility must be transferred to
, him.
- - Thorough review of Corporate Welding Manual is needed, particularly the Welding Psocedure Specifications (WPS) and
, Procedure Qualification Records (PQR) for other errors.
- Findings on WPS and PQR records need immediate attention for corrective action.
- Corporate overview is needed of Corporate Welding Manual implementation at each plant by periodic independent
' a assessment of the welding programs. Corporate authority is - needed to insure that corrective measures are implemented at each plant in a timely manner. l
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CP&L sa. e 4 Carolina Power & Light Company ROBINSON NUCLEAR PROJECT DEPARTMENT Company Correspondence POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550
- Robinson Personnel File MEMORANDUM TO: J. Y. Latimer FROM: S. W. Farmer
SUBJECT:
Performance Expectations Purnose of Document This document explains areas of performanca ena- have been below required levels, and will detail expectations relating to several accountabilities. You will receive a copy of this document following this review, in order to ensure the fullest understanding of the information it contains. You are asked to sign the document, along with your management, to indicate that it has been reviewed with i you on this date. Reasons for Document The following items identify concerns that have resulted in this action:
- 1. Your performance was rated Unsatisfactory in several accountabilities in
, a November, 1991 interim evaluation. Your overall performance was rated as Satisfactory (Minus) in March _, 1992.
- 2. The primary areas of unsatisfactory performance involve:
- a. Personal time management and accountability,
- b. Working relationships / communication with others,
- c. Support of management initiatives,
- d. Being proactive in enhancing programs and implementing new methods in areas of responsibility.
For an experienced Senior Engineer, unsatisfactory performance in the general areas listed above is considered serious. Failure to demonstrate immediate, significant, and ongoing improvement will result in the consideration of stronger action, i.e. , demotion, transfer, or up to, and including, termina, tion.
i Memorandum to: J. Y. Latimer ) ' Serial: RNPD/92-0850 Page 2 Descrinrion of Areas Where Behavior is to Channe in an immediate. Sirnificant. and Onnoinn Mannar
! 1. Personal Time Management 1
l a. Using the Site Work Tracking System (SVTS), develop better time l t management skills in order to define workload and prioritize , individual work items, i b. Develop better work habits to maximize efficiency. Become more punctual. . c. Focusing more on program management, documentation, and overview.
- 2. Working Relationships / Communication with Others
- a. Develop better communications with management,
- b. Establish closer communication with Systems Engineering personnel, reporting and following up on potential plant problems.
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- c. Develop more informative program reports at the appropriate
; inte rvals .
j d. Develop a better working relationship with NED, being more j cooperative in interfaces with this organization. Discussions should center around issues, and not abilities of individuals or organizations. .
- e. Provide more support to outage planning efforts. Lass negative criticism of this group's efforts is needed.
- 3. Support of Management Initiatives
- a. Constructive comment with workable suggestions for improvement l should be offered. !
- b. More cooperation with Training personnel should be exhibited.
- c. Programs aimed at personal development should be supported.
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- 4. Being Proactive in Enhancing Programs )
- a. Computer operation skills should be developed further.
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- b. The EPRI Checmate Computer Program should be used to supplement current Erosion / Corrosion Program management methods. I i t. New ideas should be pursued, not discounted without due consideration.
- d. Program administration procedures should be developed and information shared with other plant groups.
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Memorandum to: J. Y. Latimer RNPD/92-0850
- Page 3 Conclusion The areas listed above should be given careful consideration. You are being given an opportunity to demonstrate in an immediate, significant, and ongoing manner, a level of performance that justifies your remaining in the position of Senior Engineer Technical Support. Management will continue to assist you in this effort, providing feedback on a monthly basis; however, continued performance below the expectations for your position will no longer be tolerated.
You are encouraged to ask any questions at this time to ensure you understand the performance improvements that are necessary. 4
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G Date I have read and understand the above. Employee Signature: _ Date Concurrence: ~ d[ 3/JiaNr
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O ll X _Q ////$ 4 V Form 244 _ Es b. + 5 Carouna Power & Ught Company R08 EPARTMENT POST OFFICE BOX 790 company correspondence HARTSVILLE, SOUTH CAROLINA 29550 September 29, 1992 MEMORANDUM T0: R. L. Barnett FROM: J. D. Epperly i
SUBJECT:
Dynamic Change We, the Modification Implementation Unit, in order to progress toward becoming a Premier Utility, have elected to initiate a dynamic cultural change. We feel this change is leading toward a total quality concept of Leadership / Management style, which is consistent with our Corporate Directives. This goal can be accomplished by reorganizing our unit into two levels of management with the quality teams as the main thrust of productive work being performed. This will not change the site API, but will change the we" te are doing business. This re-engineering of the MIU Functional Organization is aimed at improving all aspects of MIU's duties and responsibilities. MIU Personnel have developed the 4 first draft of the dynamic organization and are proceeding with final development. Attached with this correspondence is a copy of our Dynamic Functional Organization structure and a definitive description of our quality teams. Also, it is my understanding that John Latimer, the Project Welding Engineer at Robinson, has requested a transfer to our group. I have discussed this with John's supervisor, Warren Farmer, and have his concurrence with John's transfer. As you may be aware his current role as Project Welding Engineer / Erosion Corrosion Specialist will end within the next few months. The current E/C duties are transferred to another on-site individual full time in addition to some duties being assumed by corporate NDE and NED personnel. In the interim John will continue to provide support to the E/C program until transfer of the responsibilities is complete. This development will allow him more time to concentrate on welding engineering ! activitics at Robinson. He will also become more involved in planning, manpower determination, training requirements, modification review, resolution of field problems, and independent weld inspections by t.4e welding engineer. As you know, in the past we have needed the services of a full time . welding engineer, a function John was unable to fulfill due to the additional work load placed upon him by the erosion / control program and other duties assigned in the technical support unit. l l
Although the addition of a full time welding engineer assigned to the Modification Implementation Unit will not bring Robinson up to the welding staffing levels of Harris and Brunswick, it will greatly improve the level of needed service to our unit and will also match the organizational structure of the two other nuclear plants. John would continue to act as Project Welding Engineer for the entire site. However since 90-95% of the welding engineering duties and responsibilities are involved in MIU, it is in the Robinson Plant's best interest if he is transferred to the Modification Implementation Unit at the earliest possible date. I am fully supportive of this move and re-engineering effort as I believe it bill benefit John, our group, the Robinson Plant, and it will coincide with our total quality teams. The signatures below indicate 10b support of this effort. P k _ E
/' Jack D. Epperly/ ' M. Ba/ry Sullivan w/Brya f. Hearne e- u e at i
g Joseph R. Wilson [b /d William K.' King Richard L. Barnett
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John W. Noble Charlie R. Dietz 4 .L+ & I. Dale Prosser - Everett H. Sauls WAW '
) Braxton E. Starnes JDE/kdb cc: C. R. Dietz ,
_ ,. . . _ _ . . _ . . . .= -. . _ 1 i
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l DYNAMIC FUNCTIONAL ORGANIZATION JACK EPPERLY TEAM LEADER DALE PROSSER CONTRACTS & TRAINING TR AINING . OFFICE SERVICES
- JOHN LATIMER PLANT WELDING ENGINEER I WELD TEST SHOP . WDR / SWDR BRAD STARNES MOD MANAGER MECH.
b MODS . DISCIPLINE TE AMS . MECH SUPPORT BRYANT HEARNE MOD MANAGER ELECT. M ODS Ol8CIPLIN E T E AM S . TEM P. POWER , E LECT. SUPPORT BARRY SULLIMN MOD MANAGER CIVIL
- MODS . DISCIPLINE TE AMS . TEMP. FACILITIES CIVit SUPPORT .
JOHN NOBLE MECH. MODS MODS . SURVEY'S . FAS SHOP JOEY WILSON INFORMATION SERVICES __ INFORM ATION SERVICES . COMPUTERS WILLIAM KING MODS & SUPPORT L MODS. DisciPtiME 1E AM . SCArrOtDS. EOuiP.OPER ATORS M ATERI AL HANDLERS. PAINTERS EVERETT SAULS DRAFTING & SUPPORT DR AFTING. REPORTS. TR AINING KIM BAILEY SECRETARY
- SEE NEXT PAGE FOR FUNCTIONAL QUALITY TEAM CONCEPT
A O ~~ DYNAMIC FUNCTIONAL QUALITY TEAM CONCEPT . TEAM CONCEPT TYPICAL FOR ALL DISCIPLINES , PROJECT BRYANT HEARNE MOD MANAGER ELECT. -- MANAGER 1 ELECT. CORD. MECH. CORD. civil CORD. FOREMAN FOREMAN FOREMAN WORKERS WORKERS WORKERS
1 A/ 8 C I r s p e c.Ni A s p o t- vc> . yo. 2c //92- / 3 4 4// r/9 2.
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6 k. 4, l 5 6 i Within the areas examined violations or deviations were not I identified. i
- 3. Erosion / Corrosion - Induced Pipe Wall. Thinning Program.
4 1 l l In response to Generic Letter 89-08 requirements and the licensee's response dated July 21,1989 the inspector observed a scheduled l 4 examination on component, No.1HD24. This was a schedule 40,12x8 i' reducer in line number 8-HD-233 of the Heater Drain system. The observation included grid layout, instrument calibration, data acquisition i using a Panametrics 26DL Plus unit and downloading. Nominal material thickness was identified a 0.406 inches, with a minimum of 0.346 inches. ) i Following this field observation, the inspector reviewed the controlling document, identified as Maintenance instruction (MI) No. 010-1, Erosion / Corrosion Control Program dated June 10,1987 and discussed with j the cognizant engineer, administrative controls including: use of EPRI's l i codes Chec-NDE and Checmate, corporate involvement in terms of design i engineering support, and program management. Following this discussion, ) ! the inspector ascertained that the licensee has committed at best, only a , minimum amount of resources in this program. For example, there is no j i objective evidence of corporate involvement in the Robinson
- Erosion / Corrosion (E/C), program in terms of an approved corporate manual l to address, programmatic direction, decision making responsibilities, I
component replacement, data management etc. The program is presently ! directed by one engineer, on a part time basis, who decides what ! components are inspected, when they are replaced and what types of f replacement material is to be used. There are no program driven acceptance criteria based on projected wear rates or trending of systems and specific i components. The engineer relies heavily on personal experience and knowledge of system performance, as guidance to generate inspection ! scope (s) during outages. Some systems have been modeled after a j Checmate Computer Code, but predictions made by this program have been l l so increditably off the mark that the engineer has lost confidence in the ! system. Examples presented to support this position were, (1) Component j 4 between feedwater pump A to S/G "A", Checmate predicted failure 43K i ! hours ago but U/T thickness measurements show it to be within code i
- allowable limits, (2) component between heater drain "B" and heater drain I tank "B", Checmate predicted failure 134,015. hours ago but the component still meets code allowable limits. This poor reliability has !
j diminished confidence in this code to the point that it is not utilized or relied ! upon as a predictive tool. i j- ' l
' l The inspector ascertained that the heater drain lines have experienced the 1
greatest amount of wear. This system contains mostly carbon steel piping l
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I NRc r .specho- Repe d M .;o-ac,i/g2 w l 5 A L P RepwY gg, y ( 19 j
- A motor-operated valve (MOV) testing and surveillance program was developed for which only ,
portions adequately addressed the Generic Letter 3 l 89-10 recommendations. Strengths were noted in l l the program relative to training, the number of valves tested under differential pressure, design basis reviews for thermal overload sizing, and licensee industry involvement. Notwithstanding j these strengths, there were numerous problems J identified, especially with the plant implementing
- procedures. In addition, erroneous differential
- pressure calculations resulted in feedwater isolation valves being improperly adjusted so they would not have closed under certain accident i conditions. These problems indicated a lack of overall management attention and priority to the j MOV program.
l Engineering involvement has not been aggressive i nor extensive for the --asica/ corrosion (E/C) i program at Robinson. The licensee committed minimal site engineering resources to inspection
- and evaluation of B/C. There was no evidence of i corporate NED involvament in this program, as it I was dire cted by one engineer relying heavily on engineering judgement to determine inspection schedules, component replacement, and material 4
j selection. An effective licensed operator training program
- was demonstrated by the 100 percent pass rate on
- the initial examination administered in July 1991.
1 However, during the initial evamination some l
\ weaknesses were observed in crew communications, i inconsistent use of annunciator response
!. procedures, inconsistent methods for the removal l 1 of failed instruments from service, and slow l l analysis of safety injection flowpath problems. 4 Examination material provided by the facility was i adequate to support the evamination.
- The emergency operating procedures (EOP) and abnormal operating procedures (AOP) upgrade '
! projects progressed slowlf during this assessment j period. Some progress towards resolving EOP 1 program weaknesses (identified two assessment "
' periods ago) was made by the development j and_ upgrade of such progransnatic and administra- , l tive documents as the writers' guide and the verification and validation procedures. However, the resources allocated to the EOP and AOP upgrade i projects were insufficient to complete the actual J
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CP&L Carolina Power & Light Company g- - l l fah,h. F 8 \ HARRIS NUCLEAR PROJECT M February 24, 1992 k M s _ .\ Letter Number: MS-920185 (0) + , [
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MEMORANDUM TO: Mr. J. F. Nevill i 7 f,. ,1 . (, FROM: M. R. Craybeal
SUBJECT:
Erosion / Corrosion BACi<CROUND The phenomenon of pipe wall thinning due to erosion of corrosion products became an issue in 1986 when the EPRI SurryReport pipe rupture NP-39/4 resulted in severe damage and loss of life. described the situation and set forth a technique to anticipate and detect similar potential failures. EPRI produced several computer codes to assist this effort: CHEC-NDE to consistently record, display, and trend the results of inspections; and CHECMATE to help predict areas most susceptible to thinning. NRC Ceneric Letter 89-08 requested licensees and applicants to implement long-term erosion / corrosion mor.icoring programs. Recent events at Millstone, Catawba, Palo Verde, and Almaraz have brought increased attention to the subject and in some cases have caused the effectiveness of the programs currently in place to be questioned. As such, there is a new regulatory emphasis on erosion / corrosion. NRC personnel are currently being trained in both CHEC-NDE and CHECMATE so they can properly evaluate how they have been implemented at each site. NRC plant audits are scheduled to begin this spring. Because of this impending regulatory attention, EPRI conducted several " pre-audits" in 1991 to determine the current industry condition. Several common deficiencies were found: e Minimal manpower and resources committed.
- e Lack of Corporate involvement.
e Inconsistent implementation between units. , e Lack of communication between Corporate personnel and each plant, and between plants. MEM/MS-920185.0/1/051
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l Mr. J . F. Navii. Pcge 2 j February 24, 1992 l CURRENT CP&L SITUATION i HARRIS: o Selection of areas for inclusion in the program is based l on NUMARC guidelines, failure history, engineering jud ement, 5 and CHECMATE. (HNP has served as a piloc
- program f"r CHECMATE. )
e CHEC-NDE is utili:ed for data management and trending. j e Actual chickness measurements are taken in-house, d utilizing ISI personnel, loanees from other Technical s Support sub-units, and NDE. I BRUNSWICK e Selection of areas is based on engineering judgement utilizing NUMARC guidelines and industry experience. e NED is to assess _gli susceptible lines for inclusion. e NDE is taking all thickness measurements and providing
- data management.
1 ROBINSON
- Selection of areas is based on engineering judgement and plant experience. Some systems have been modeled in ;
CHECMATE, but a lack of confidence in some of the j parameters input causes the results to be questioned. 1 e NDE is taking all thickness measurements and providing data management.
! As can be seen, the lack of consistent implementation between units
. observed elsewhere in the industry is also present at CP&L. A good j argument could be made that the other common deficiencies are also 1
- present.
i PROPOSAL After returning from the CHECMATE User's Croup meeting where an I understanding of the industry situation was obtained, Greg Tucker j began developing a proposed method of bringing consistency to the ] CP&l. program. Concurrently, a meeting was instigated by NDE to ' , discuss this same subject. Representatives of NED-BESS, NED-HESS, ISI.HNP, and NDE met 1/16 at the HEEC. This was the first step to alleviate the communication and Corporate involvement problems. It was felt that NDE could be the best vehicle for consistency between
; units beginning with data management and trending by implementing CHEC NDE and performing th~ickness measurements at all sites. The next phase would be modeling of important systems in CHECMATE to'
, assist in inspection area selection. (It was emphasized ,that
- CHECMATE would be but one input to the selection process, and each j site would maintain autonomy over their program.) As a first step in accomplishing these goals, NDE personnel are currently on site at
- HNF learning CHEC-NDE and CHECMATE.
MEM/MS-920185.0/2/051 l
Mr. J . F. Novt . Pega 3 February 24, 1992-It is felt that periodic meetings should be held including ; representatives from the other sites to assure continued communication and consistency. Please discuss these proposals at the next Technical Support Managers meeting. Original Signec Sy M. R. GRAYBEAL l MRG: dew 3 1 d l I I f i 4 1 4 1 1 a MEM/MS-920185.0/3/osi
~
AEM-- t'4D Aepo<f R- S PP - 9 2- O! 7/29'/92. 6d <S.f 9 grinding and welding taking place to correct improper velds which were found on these same lines which had been cut and welded back during previous outages using the same welding process.
- 3. During walk through of the plant, found portable veld rod
" caddy" unplugged. Caddy was found at entrance to " pipe alley." Further investigation revealed that weld rods were cold to the touch. Based upon information found on weld rod issue receipt, the veld rods had been issued approximately three hours earlier. observer notified craft helper /firewatch in the area and the condition was corrected. Per the Corporate Welding Manual, the weld rods were still acceptable for use as long as they were unheated for less than four hours.
- 4. It was observed twice during the assessment, that welding was taking place on plant structures and components while being grounded through available remote plant grounding structure which was-more than 15 feet away. It could have been grounded within 2 to 3 feet of the welded area.
This practice has been determined to be potentially detrimental to plant rotating equipment and instru-mentation due to the potential for internal electrical arcing during the welding process. In the past on other facilities, it has been determined that instances of
- equipment failure have been attributed to electrical arcing during the velding process as a result of the
- improper grounding. Consideration of this problem should be incorporated into the Corpor, ate Wolding Manual.
C. Erosion Corrosion Program i
- 1. Reviewed the Corporate CP&L Procedure for Erosion /
Corrosion activities. Monitored the gridding and thickness readings being taken on several components to support the E/C program. Concurred with NRC Inspection Report regarding deficiencies of program in lack of definition of scope, lack of procedures, and lack of adequate manpower (Ref. NRC Inspection Report No. 50-261/92-13). D. Heat Treatment
- 1. The heat treatment procedure (SPP-008) was reviewed with no comments. There were no heat treatment processes 1
taking place during the period of this assessment. E. Freeze Plugging
- 1. There were no comments upon review of the freeze plugging procedures (SPP-001 and SPP-002). During the period of 7
m
.__.______..m____._. _ _ _ - _ _ _ . _
l l oCT 23 '92 09:02AM rAxe4 m.-
- Carolina Power & Light Company j Tarknical Services Department l l
^ l Company Correspondence New Hul, North Carollas October 23,1992 I a i
)
4
. TO: Mr. R. B. Starkey, Jr. ,
i i ] FROM: H. W. Bowles l i
SUBJECT:
Action Plan for Flow Accelerated Corrosion (FAC) Program
~ -
. i j l Attached is the action plan for work in the FAC program across the Nuclear Generation
- Group. The intent of this action plan is to move the CP&L FAC program toward a premier level j as rapidly as practicable. ABB/!mpell, a leading consultant in the FAC area, has been contracted
- to provide the technical expertise and manpower which will be necessary for the near term program
. work at the Brunswick and Robinson Projects. At the completion of ABB/Impell's work in 1 February, our FAC program at all 3 sites will conform to best industry practices, will have site-to-
- site consistency, and will be in a position to be carried on in the long term by CP&L staff.
- I l It is probable that our most significant challenge in attaining premier status in this area will '
. relate to staffing. Task 2 of the action plan will specifically address this area. However, it is j apparent at this time that, in general, more CP&L dedicated manpower, at a higher level of l expertise, will be necessary. Dave Meleg, Project Engineer NDE Services is serving as interim NGG coordinator for j the FAC program activities. Dave will be providing in-depth oversight and wdisation for all of j the action plan activities. Please contact me (362-3514) or Dave Meleg (362-3520) if there are any questions or 4
- concerns relatd to this plan.
I 1 N bWI~ ! H W Blase ' I Attachment I 1 c: Mr. R. M. Coats Mr. R. E. Helme ' Mr. A. M. Lucas Mr. T. Cleary I Mr. J. M. Waldorf Ms. L. Harrelson Mr. J. Curley Mr. T. Freeman 1 Mr. J. Nevil Mr. G. Tucker
l Es L L . F t I 4 Site Work Tracking system v3.11 aobinson Nuclear Project Hertsvitte, SC 29550 4 a ;- -- Requirements Date Printed: 08/11/92 for JONNL , Total Scheduled Nours For otr Ending Project Task $4 IW l# 09/30/92 12/31/92 03/31/93 06/30/93 Total J 92 02272 PROJECT 3.6 3.6 3.6 3.6 14.5 92 02273 PROJECT 9.8 9.8 9.8 9.8 39.5 i 92 02274 Pe0 JECT 2.3 2.3 2.3 2.3 9.5 92 02292 PROJECT 0.0 0.0 0.0 0.0 0.0 92 02311 PROJECT 1.0 0.0 0.0 0.0 1.0 Totals 1232.2 - 834.7 1663.9 1650.6 5381.5 I i, i i $ n
/
s j 4 5 a e S I 4 s .e 4
l Elte Work Tracking system v3.11 Robinson Nuclear Project Nortsville, SC 29550 ; Marpeuer Requirements Date Printed: 08/11/92 ' for JONNL Total Scheduled Nours For Str Ending Project Took S@ Is Is 09/30/92 12/31/92 03/31/93 06/30/93 Totet 91 038P1 PROJECT 220.2 220.2 0.0 0.0 440.5 91 050M P90 JECT 75.0 75.0 0.0 0.0 150.0 91 03992 PROJECT 0.0 0.0 0.0 0.0 0.0 91 06371 Pe0 JECT 0.0 0.0 0.0 0.0 0.0 91 06372 PROJECT 0.0 0.0 0.0 0.0 0.0 91 06574 PROJECT 75.0 75.0 0.0 0.0 150.0 91 06792 PROJECT 0.0 - 0.0 0.0 0.0 0.0 91-07074 2 0.0 0.0 0.0 0.0 0.0 91 00020 P90 JECT 0.0 0.0 0.0 0.0 0.0 92 00309 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00310 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00311 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00312 Pe0 JECT 0.0 0.0 0.0 0.0 0.0 92 00373 Pa0 JECT 0.0 0.0 0.0 0.0 0.0 92 00374 PA0 JECT 0.0 0.0 0.0 0.0 0.0 92 00375 *3 JECT
. 0.0 0.0 0.0 0.0 0.0 92 00380 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00524- PROJECT 0.0 0.0 0.0 0.0 0.0 92 00549 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00565 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00546 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00583 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00590 PROJECT 0.0 0.0 0.0 0.0 0.0 92 00619 PROJECT 0.0 0.0 0.0 0.0 0.0 92 01775 PROJECT 7.5 0.0 0.0 0.0 7.5 92 01776 PROJECT 20.0 0.0 0.0 0.0 20.0 92 01909 1 0.0 0.0 1250.0 1250.0 2500.0 92 01932 PROJECT 19.7 19.7 19.7 19.7 79.0 92 01933 PROJECT 8.0 0.0 0.0 0.0 8.0 92 01934 PROJECT 16.0 0.0 0.0 0.0 16.0 92 01935 PROJECT 8.0 0.0 0.0 0.0 8.0 92 01936 Pe0 JECT 0.0 8.0 0.0 0.0 8.0 92 01937 PROJECT 0.0 0.0 8.0 0.0 8.0 92 01938 PROJECT 0.0 0.0 0.0 8.0 8.0 92 01939 PROJECT 8.0 0.0 0.0 0.0 8.0 92 01960 PROJECT 0.0 8.0 0.0 0.0 8.0 92 01941 P40 JECT 0.0 0.0 8.0 0.0 8.0 92 01942 PROJECT 0.0 0.0 0.0 8.0 8.0 92 01946 Pe0 JECT 3.0 0.0 0.0 0.0 3.0 92 01947 Pa0 JECT 16.5 0.0 0.0 0.0 16.5 92 01968 Pe0JELT 20.0 0.0 0.0 0.0 20.0 92-01949 Pe0 JECT 0.0 20.0 0.0 0.0 , 20.0 92 01950 P90 JECT 0.0 20.0 0.0 0.0 20.0 92 01951 Pe0 JECT 0.0 20.0 0.0 0.0 20.0 92 01953 PROJECT 0.0 0.0 20.0 0.0 20.0 92 01954 Pn0 JECT 0.0 0.0 20.0 0.0 20.0 4
4 A f Site niork Trackins System v3.11 Robinson Nuclear Project Nortsville, sc 29550 nonpower RegJirements Date Printed: 08/11/92 For JONNL 1 Total Schedated Nours For otr Ending I Project Task Sub 18 Is 09/30/92 12/31/92 03/31/93 06/30/93 Total 92 01955 PROJECT 0.0 0.0 20.0 0.0 20.0 92 01956 PROJECT 0.0 0.0 0.0 20.0 20.0 92 01957 P90 JECT 0.0 0.0 0.0 20.0 20.0 92 01958 PROJECT 0.0 0.0 0.0 20.0 20.0 a 92 01963 PROJECT 32.0 32.0 32.0 32.0 128.0 3 92 01968 Pe0 JECT 18.0 18.0 18.0 18.0 72.0 92 01969 PROJECT 15.0 15.0 15.0 15.0 60.0 , 6.0 24.0 92-01970 PROJECT 6.0 - 6.0 6.0 92 01971 PROJECT 9.7 9.7 9.7 9.7 39.0 92 01972 PROJECT 12.7 12.7 12.7 12.7 51.0 9.7 39.0 92 01974 PROJECT 9.7 9.7 *7 92 01976 Pa0 JECT 34.5 34.5 34.5 34.5 138,0 a 92 01977 PROJECT 24.1 24.1 24.1 24.1 96.5 92 01978 PROJECT 110.5 0.0 0.0 0.0 110.5 92 01979 PROJECT 40.0 0.0 0.0 0.0 40.0 l 92 01980 PROJECT 13.3 13.3 13.3 0.0 40.0 j 92 01982 PROJECT 40.0 0.0 0.0 0.0 40.0 i 92 01983 PROJECT 17.:i 0.0 0.0 0.0 17.5 92 01964 PROJECT 9.6 9.6 9.6 9.6 38.5 92 01985 PROJECT 4.1 4.1 4.1 4.1 16.5 92 01986 Pe0 JECT 12.8 12.8 12.8 12.8 51.5 92 01987 PROJECT 8.0 0.0 0.0 0.0 8.0 I 92 01968 PROJECT 6.5 6.5 0.0 0.0 13.0 ) 92 01989 PROJECT 8.0 0.0 0.0 0.0 8.0 1- 92 01990 PROJECT 8.0 0.0 0.0 0.0 8.0 92 01991 PROJECT 5.0 5.0 5.0 5.0 20.0 92 01996 PROJECT 7.3 7.3 7.3 7.3 29.5 l 92 01997 Pa0 JECT 8.5 8.5 8.5 8.5 34.0 l 92 01999 PROJECT 8.5 8.5 8.5 8.5 34.0 92 02000 PROJECT 12.0 12.0 12.0 12.0 48.0 92 02001 PROJECT 2.3 2.3 2.3 2.3 9.5 1 92 02002 PROJECT 2.2 2.2 2.2 2.2 9.0 l 92 02003 PROJECT 25.0 25.0 25.0 15.0 100.0 92 02005 PROJECT 12.3 12.3 12.3 12.3 49.5 92 02023 PROJECT 4.1 4.1 4.1 4.1 16.5 92 02048 Pe0 JECT 0.7 0.7 0.7 0.7 3.0 92-02054 P90 JECT 29.0 0.0 0.0 0.0 29.0 92 02060 PROJECT 4.5 0.0 0.0 0.0 4.5 i 92 02061 Pn0 JECT 5,5 0.0 0.0 0.0 5.5 ) 92 02067 Pe0 JECT 4.3 4.3 4.3 4.3 17.5
'92 02001 Pa0 JECT 16.0 0.0 0.0 0.0 . 16.0 92 02002 PROJECT 4.0 4.0 0.0 0.0 8.0
' 80.0 92 02009 PROJECT 40.0 40.0 0.0 0.0 '
- 92 02209 Pe0 JECT 2.3 2.3 2.3 2.3 9.5 92 02221 P90 JECT 1.7 1.7 1.7 1.7 7.0 92 02226 Pe0 JECT 78.5 0.0 0.0 0.0 78.5 92 02271 PROJECT 3.7 3.7 3.7 3.7 15.0 4-
. n -. ,, .- .
Technier t St.oport SWT3 Itms Ostz: 07/17/92 07:55:38
$4damit: (PROG)
- Prejl0 Prl/Sig Sched Commit Description Current Status /Hi tory Teokid Status Finish Cross Reference Effort Effort Proj Cum 91-U5591 04 N 12/01/92 / / SETTER DEFINE EROS 10N/CORROS10N PROGRAM, f.e., BASES, DATA CONTROL, DATA REDUCTION CONTRACIOR 10 COME ONSITE TO ASSIST. 450.0 0.0 A PROCESS, INSPECTION INTERVALS, ETC.
THE PROJECTED EFF4T FOR JONNL FOR THIS PROJECT Effort this week 0.0 ASSUMES AN EFFORT OF APPRCKIMATELY 15 NR/ WEEK FOR THE REMAllOER OF 1992. 91,-03394 15 N 12/01/92 / / EXPAND TO ENSURE AREAS SUBJECT TO CD CORROSION ARE ER0510N/ CORR 05104 PROGRAM AS NECESSART ONG0 LNG. INE PROJECIED Ef f0RT FM J0MNL FOR 150.0 0.0 A INCLLSED. REVIEW SWS ALSO. THIS PROJECT ASSUMES AN EFFORT OF APPRONIMATELY 5 N"/WEEE FOR INE REMAINDER OF 1992. Effort this week 0.0 91-06574 04 N 12/01/92 / / GAIN PROFICIENCY IN INE USE OF CHECMAIE INis ACIlvlif WILL SE ACCOMPLISMED IN 150.0 0.0 A PROGRAM FOR PROGRAM TO THE POINTOF BEING SELF-SUFFICIENT CONJUNCTION WITN PROJECT 91-03891. THE MAINTENANCE. PROJECTED EFFORT FOR J0MNL FOR TNIS AcilVITY Effort this week 0.0 ASSUMES AN EFFORT OF APPRONIMATELY 5 NR/ WEEK FOR INE REMAINDER OF 1992. 91-07U74 / / 06/15/92 ~ PINNotE TNE PIPINGSIEAM FROM 68LEAK EXISIS FEEDWATER IN PIPING NEATER TO "S Watt O.F APPARENI CAUSAL FACIOR $NEET CWIPLETE. ACR 91-299 34.0 0.0 2 0 NEATER DRAIN TANK. Effort this week 0.0 92-01775 07/10/92 / / MEIN 0D TO CONIR0L FILES AND DAIA, FulURE DEVELOPMENT OF PROCEDURE THAT WILL 16.0 5.5 A ESTABLISM PROGRAM RESPONSIBIllilES. INCLtBES FILING OF COPY FILE. Effort this week 0.0 92-01776 07/24/92 / / Acil0N PLAN TO DEIERMiNE ACIl0N 10 SE TAKEN g ON CB CORROS10N OF THESE TWO SYSTEMS. INCLtBE 20.0 0.0 I Q AND NON-0 FOR SERVICE WATER. Effort this week 0.0 92-01909 12/30/93 / / laptement Errosion Corrosion Program PIR WRIIIEN FOR 1993 - Pla 92-200 FOR S250,000 improvements. Imlude Corporate involvement til-92 13-01-IFl 5000.0 0.0 1 0 in the program. Effort this week 0.0 V2-01932 07/07/93 / / UPDATE SilE WORK 1 RACKING STSIEM 100.0 13.0 A Effort this week 1.0 92-01933 09/07/92 / / DETERMINING TRAlWING REQUIREMENIS FOR PLANNERS IN THE PREPARATION OF WELD B.O 0.0 5 DATA REP 0 PTS. Effort this week L 92-01934 10/07/92 / / PREPARE RET 10 NED FOR GENERIC PlPE REPLACEMENT ON SECONDARY SIDE FOR 16.0 0.0 S EROSION / CORR 0510N PROJECT. INCLUDE SYSTEMS, PRESSURE, TEMPERATURE, ETC. Effort this week 0.0 92-01935 09/30/92 / / 1992 3R0 QUARIERLY REPORI E/C. B.O 0.0 S Effort this week 0.0 Page: 1 e T
~
V
Texhnic-t Sert SwtS Items D;ts: 07/1T/Q 07:55:45 Responsibt:: JOHNL + Sdamits (PROG)
- Projl) Prt/Sig Sched Caesait Description Current Status /Mletory Yeskij Status Finleh Cross Reference Effort Effort Proj Cue 92-01736 12/30/92 / / 1992 4TM OUARTERLV REPORT E/C.
5.0 0.0 Effort this week 0.0 92 01937 03/30/93 / / 1993 IST GUAtifaLY REPORI E/C. 5.0 0.0 l S Effort this week 0.0 92-01935 06/30/93 / / 1993 2ND QUARIERLf AEPORI E/C. 5.0 0.0 S Effort this week 0.0 92-01739 09/30/92 / / 1992 380 QUARTERLY REPORI WELD. 5.0 0.0 S Effort this week O.P 92-01940 12/30/92 / / 1992 4TM QUARTERLY REPORT WELD. ~ 5.0 0.0 S Effort this week 0.0 92-01941 03/30/93 / / 1993 151 QUARLTERLY REPORT WELD. 5.0 0.0 Effort this week 0.0 92-01942 06/30/93 / / 1993 2ND QUARIERLY REPORT WELD. 5.0 0.0 S Effort this week 0.0 92-01946 07/30/92 / / JULY 1992 CWM MEEllNG - REVIEW PROCEDURES
- ATTEND MEETING. TRAVEL TRIP REPORT 20.0 0.0 S
Effort this week 1.0 92-01947 05/30/92 / / AUGUST 1992 CWM MEEllNG - REVIEW PROCEDURES
- ATTEND MEETING. TRAVEL, TRIP REPORT 20.0 0.0 S
Effort this week 0.0 92-01945 09/30/92 / / SEPIEMBER 1992 Cm MEEllNG - REVIEW PROCEDURES, ATTEND MEETING, TRAVEL, TRIP 20.0 0.0 S REPORT Effort this week O.* 92-01949 10/30/92 / / OCiceER 1992 Clet MEEltNG - REVIEW FROCEDURES* ~ ' ATTEND MEETING, TRAVEL, TRIP REPORT 20.0 0.0 S Effort this week 0.0 92-01950 11/30/92 / / NOVEMBER 1992 CWM MEEilNG - REVIEW PROCEDURES, AliEND MEEitNG, TRAVEL, TRIP 20.0 0.0 S REPORT Effort this week 0.0 Page: 2
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Technic < t Samoort SWTS Ite" Deta 0T/17/92 0T:55:52 ] e,ggg m - Shits (P906) Descriptlart Current Status /Nietory Cross Reference Effort Effort Pri/Sig Sched Ceaust t pq g l*toJlt feeklj Status Finleh 3g,g ,,, 72-91T(c OT/W/V3 / / PLANT 1m2S Effort this week 6.0 45.0 0.5 FZ-Givre 07/95/93 / / UPDATE WELDER QUALIFICAll0N -EVERY TWO MONINS , AVERAGE, 8 NamS EACM, 48 Namt TOTAL Effort this week 9.0 i S N *O U*U 92-Oivre 07/05/93 / / IRAINING - TRAINING MOURS FROM IDP ALSO INTERNAL TRAINING - 18 ADDITIONAL MajRS ADDED Effort this week 1.0 S ITP REV. 1 - EPP.i FALL / WINTER E/C MEETING LOUISVILLE, K uluCKY - 40 NOURS RS - N0h0UIAGE, NON-MOD 2 NOURS 106.0 2.5 94-01977 07/06/93 / / R I Effort this week 3.0 120.0 0.0 92-017(5 10/15/92 / / REVIEW E/C DATA 1992 CUTAGE - INCLUDES FILING, COPYING FOR SECONDARY FILE, ANNOTATING, REVIEWING FOR TRENDS, DETERMINING Effort this week 0.0 S LIFE REMAINING, UPDATING AND RECORDING REPLACEMENTS, UPDAflNG DRAWINGS FOR MOD REPLACEMENTS, ETC. REQUIRED TO DE COMPLETE RT 10/15/92 10 GIVE l 1993 PLAN REFUELING PLAN 10 r&S 40.0 0.0 10/15/92 / / PREPARE 1993 GJI AGE E/C PLAN - DETERNINE 92-01977 NUMBER AND LOCAll0NS OF INSPECil0NS RASED ON MISTORY AND RESULTS OF 1992 OUTAGE Effort this week 0.0 S 40.0 0.0 03/01/93 / / PREPARE 1993 OUT AGE WR'S FOR E/C PROGRAM - 92-01950 SCAFFOLDING, INSULAfl0N REMOVAL, VALVE AND MANWAY REMOVAL Effort this week 0.0 S 40.0 0.0 10/13/92 / / DETERMINE E/C PIPE REPLACEMEN! - FROM RESULIS 92-01952 OF 1992 E/C DATA DETERMINE REQUIRED PIPE REPLACEMENT W11M ASSISTANCE Effort thle week 0.0 5 FROM THE SYSTEM ENGINEER, RECOBe9END REPLACEMENT MATERIAL 24.0 0.0 92-01953 05/05/92 / / REVIEW AND FILE WELDER QUALIFIC#i10NS RECORDS FOR 1992 OUTAGE Effort this week d.0 5 40.0 0.5 92-01954 07/05/93 / / PROVIDE Sui +0iil FOR WELO TEST SMOP - INCLUDES TESilNG AND TRAINING OF WELDERS AND COORDINATION OF WELDER TEST RESULTS WiiH Effort this week 0.5 S OTHER NUCLEAR SITES . Page: 4
Technicel Survort SwiS Itms tota: 07/17/92 07:55:55 54Aimi t: (PROG)
- Prejl0 Prl/Sig Sched Commit Description Current Status / history Taskij Status Finish Cross Reference Effort Effort Proj Cum 92-01945 07/05/V3 / / REVIEW ROUTED INFORMAllON FOR APPLICA4tLily, 1NCLISES E-MAIL AND PROFS 20.0 0.5 S .
Effort this week 1.0 92-01986 07/05/93 / / MONITOR flELD E LDING ACTIVITIES DURIRC NON OUTAGE - 1 NCUR PER WEEK AVERAGE , 52.0 0.5 i I Effort this week 0.0 92-01957 07/24/92 / / WRITE ACR PER WARREN FARMERS DIRECIl0N CW INCOMPLETE CastITTMENT TO NRC ON 5.0 0.0
$ INCORPORATING E/C PROCEDURE IN POM Effort this week 0.0 92-01955 12/31/92 / /
PROVIDE Mall NUMBER TO WARREN FARMEROF WDRS REVIEWED PER WEEK Bf E MON-Q WRS REvifdo (C7/06/92 - 07/10/92) 14 13*0 0'0 S Q WDRS REVIEWED (07/06/92 - 07/10/92) 7 NON-Q WRS REVIEWED (07/13/92 - 07/16/92) 74 0 WDRS REVIEWED (07/13/93 - 07/15/92) 18 Q-01959 05/07/92 / / 1992 2ND QUARTERLY REPORI E/C 5.0 0.0 5 Effort this week 0.0 92-01990 05/07/92 / / 1992 2ND QUARIERLY REPORI WELD 5.0 0.0 5 92-01991 07/08/93 / / SPECIFY NEAT OR LOT NUM6ERS FOR WELD ROD IF WONE EXIST. PER REVISION TO 20.0 0.0
$ CORPORATE WELDING MANUAL, ROD ROOM TO NOTIFT WHEN NEEDED. Effort this week 0.0 92-01996 07/09/93 / / INTERFACE WITH QC 30.0 0.0 I
Effort this week 0.5 92-01997 07/09/93 / / INTERFACE WlIH IECM SUPPORI I Effort this week 2.0 92-01999 07/09/93 / / IN1ERFACE WilH MAINIENANCE - S Effort this week 1.0 92-02000 07/09/93 / / INTERF ACE Wi1H MQ) IMPLEMENIAll0N 5 Effort this week 0.5 92-02G01 07/09/93 / / INIERFACE Wi1H P&S S Effort this week 0.0 Page: 5
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19" EROSION / CORROSION CHUG MEETINr TRIP REPORT l l My recent visit to Palo Alto, CA. To the EPRI (CHUG) meeting provided a fresh view on the issue of E/C degradation in Nuclear power plant piping systems. Being fully aware of the safety concerns involved with this issue, I've seen another interest of concern, which concerns us all, economics. The EPRI representatives along with other utilities sharing their problems and concerns, made me ever so mindful of just how significant the consequences would be, should a line ever rupture causing personal death, injury or even plant shutdown. The importance of a sound, consistent E/C program was never emphasized more. The recent events at Millstone, which required shutdown and a cost of $10M, support
, the immediate need of a sound, consistent E/C program within CP&L. The regulatory arena is becoming very concerned about the so-called E/C programs throughout the industry. They are currently receiving training on use of the EPRI codes (CHEC-NDE, CHECMATE) in order to verify sufficient E/C program implementation in the industry. NRC plant audits appear to be in the near future to accomplish this task. Insufficient programs / implementation are subject to derogatory actions to include possible plant shutdown. EPRI representatives performed several plant audits in 1991 to verify sufficient program implementation. They returned with several deficiencias commonly found. The most common area of concern was lack oE-management support to includa only one employee, utilizing a minimal amount of his time / responsibility to g/C program implementation. A lack of program commitment from management was commonly found
"-: rc. aced to lack of dedicated personnel for implementation. The other major finding was lack of corporate involvement / commitment that indicated within one company, with several units, no programmatic consistency exist. Each unit was doing business differently. Emphasis on management / corporate commitment and programmatic consistency was mutual among the EPRI representatives and regulatory authorities. It's time that we (CP&L) take whatever actions necessary to ensure .
that our E/C programs are sound, consistent and implemented correctly at all three Nuclear sites. This will take some initial time, cost, effort and support . from all parties involved to accomplish this great task. It's my responsibility l as the Harris E/C coordinator to initiate some sort of immediate action that will begin our race to becoming the front runner in E/C. program development / implementation. Due to the current industry awareness of E/C , potential in most Nuclear power plant piping systems and recent regulatory l interest in E/C programs, I will propose a plan to enhance our existing E/C l program as well as initiate program development / implementation at the i H. B. Robinson and Brunswick plants. This plan will direct us to a more consistent, systematic direction in our E/C program implementation efforts. Management support from all levels involved will be essential in the success of this plan. Based on my expertise, experience and involvement with E/C issues, i I'm confident this plan will benefit our company three-fold, sound systematic l programs, plant safety / reliability, reduce cost. . This plan is now in the draft / approval stages and will be out for review / comments at a later date. Attached you will find all handout materials that was given to utility representatives. The handouts will give you a detailed format of each days activities. Should you have any questions, please give me a call at (919) 362-2849. .
! ~
Grogurf N.'Tu der i HNP/ISI/E C Coordinator l MISC / TRIP-RPT.E C/1/OS1
CaroHne Pcwer & Light Company 1 i 1 February 17, 1993 Mr. John Y. Latimer 301 North Lae Street Bishopville, SC 29010
Dear Mr. Latimer:
Recently you submitted a concern through the Quality Check Program pertaining to your termination with CP&L. The Quality Check office has received a response from management, and at your request, it is hereby being provided to y you. ,' The following is the concern and response:
^
CONCLtN: 1 I feel I have been treated unfairly by being terminated for ' poor performance." CP&L apparently has the right to fire anybody for any reason and I certainly do deny that I did not do all the duties (on time) arsigne.d by my supervisor. ] I was originally hired in 1983 by CP&L as Welding Engineer in the old ) Construction Department for the Steam Cenerator Replacement Project. In 1 1986, I was transferred to Maintenance as Maintenance Engineer. My ) duties at that time consisted of Maintenance Welding Engineer and was l l put in charge of fully developing the Erosion / Corrosion (E/C) program. I < Shortly after, I resumed the duties of the Construction Department j Welding Engineer, becoming the Welding Engineer for the entire plant. . In 1989, I was assigned to the Technical Support Unit with the same functions. Shortly before or after I went to Tech Support, and with . increasing involvement with the Erosion / Corrosion Program, a PIR was written by me to provide additional manpower to computerize the E/C Program, i . In 1991, a contractor was finally hired to implement the PIR. As a result of the computer output, it was recognized that much additional I work was needed to fully computerize the program. The output indicated E/C occurring when none could be detected by Visual or UT inspection and also showed no E/C when the piping was scheduled to be replaced as a 4 result of actual measurements. l
. \
As a result of these inconsistencies, and more involvement in the actual I. replacement due _to E/C, I requested the contractor be held over to help during the 1992 outage. I was also becoming involved in welding as a result of several large modifications and needed someone to help with the planning and execution of the E/C work to be performed durin5 th* dit FayettevtMe Street e P. O Som 1551
- Asieten. N C. 27602
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Mr. Jchn Latimer Page 2 of 6 same time frame. My request was denied and the con. tractor was assigned other duties. In 1991, it was apparent the regulatory agencies and EPRI were becoming increasingly concerned with the manpower allocated to Erosion / Corrosion. I concurred with their concerns and requested additional help from my supe rvisor.' No help was given until the NRC audiced the E/C Program in
' June of 1992 and found "only a minimum amount of resources' dedicated to the Erosion / Corrosion Program."
Since then, my supervisor assigned an additional person full-time to direct the E/C Program and also contracte'd with an outside vendor to completely update the E/C Program to current standards. I fully agreed with this development and even made the first contacts with the vendor to get the contract in place. All the time these developments were caking place, my supervisor was giving me less than satisfactory ratings for poor performance. If my performance was poor, why does-it now take one full-time CP&L person and up to six contractors to upgrade the E/C Program, a task I was expected . to do part-time. In addition to my E/C duties, I was also expected to fulfill the duties as Project Welding Engineer, also on a part-time basis. Current manpower requirements, at least by CP&L standards, require a minimum of two persons full-time for the welding engineering duties and responsi-bilities. This is based on the number of personnel in the Welding Section at Harris (2) and Brunswick (3+1 in Maintenance). It also should be recognized that even though Harris is a bigger plant, it is a newer plant without the numerous modifications required at Robinson. Although the duties do differ somewhat, the ratio certainly not 2 to 1/2 (two full time at Harris to 1 part-time at Robinson). The four persons at Brunswick spparently are not enough during a two-unit outage since the Project Welding Engineer at Brunswick is authorized and plans to hire five additional persons during their present outage. I believe my termination results not from " poor performance" but from a personality conflict with my supervisor. My first appraisal under him was " Commendable" as have been all prior, as far as I remember or have copies of, under six different supervisors. As a result of this conflict, the growth of the Welding and
*rosion/ Corrosion programs, additional duties being assigned, and his j refusal to recognize that I had more than one person could be reasonably expected to do; he continued to give me appraisals of satisfactory (minus). Any request for help was dismissed.
It is now apparent to me, no matter what I tried to do to satisfy him, nothing would be enough and he would set rid of me one way or another. On several occasions during this period, I requested transfers 'out of j his section but still within the Tech Support Unit. None of these were l acted upon. l
Mr. Jchn Latimer Page 3 of 6 I finally requested a transfer back to the old Construction Unit (now MIU). I thought this request had a chance to be approved for several reasons:
- 1. The E/C Program was being taken over by a full time person.
- 2. I was told by the new manager of Tech Support that I would be full-time Project Welding Engineer.
- 3. MIU was willing and eager to get me back and also requested this change through their management.
- 4. The position would be reporting to the Outage Management Group which would be in line with the other two nuclear sites.
- 5. No further conflict with my supervisor would exist.
This request was denied by the head of my section because he would not approve a transfer for a person with " poor performance," even though the other section was willing to take me. The only reason I can come up with, which I find hard but not impossible to believe, is someone had to be a scapegoat for CP&L being cited by the NRC in the latest SALP Report on Erosion / Corrosion, especially since I was the one who spoke candidly with the NRC telling the inspector when asked of Robinson's programmatic weaknesses. After I was fired, apparently rumors spread around the plant as to why I was let go. The rumor I was told was that I was fired for insubordina- l I tion. Apparently no one could believe I was fired for " poor perfor-mance." I was also told a meeting was held with all personnel in Tech Support and they were informed that I was fired for " poor performance." i This is certainly unethical and I resent the circumstances of my i termination being aired with other personnel. It is, however, not unexpected considering the treatment I have received. I I feel sure if any of my " customers" are asked, not one will believe I was guilty of " poor performance." I feel positive that If I had a ' different supervisor, I would still be employed with CP&L. RESPONSE: i l
- 1. Poor Performance i
a) 10/91 - Interim Appraisal states that Latimer's performance was I
" unprofessional and unsatisfactory." l b) Latimer prepared written response to this appraisal in which he:
e agreed that he had been " highly :ritical of some of management's objectives" l e objected that his advice was not sought in a decision in- I volving E/C computer program; described himself as ,"the most i knowledgeable person on site" regarding E/C , 1 l l
Mr. Jthn Latimer Page 4 of 6
. admitted that he had not been " conforming exactly to" his work schedule and concluded with, "I also do not believe that efficiency can be judged by arrival or departure time."
c) 3/92 - Annual Appraisal and accompanying meno list four areas of ; unsatisfactory performance: (1) time management and accountabili-ty, (2) working relationships, (3) support of management initia-tives, and (4) failure to be proactive in enhancing programs and - implementing new methods. Appraisal states that failure to improve'will result in further action, possibly termination.
- 2. $capegoat for SALF Report from NRC a) When the NRC inspector questioned the effective use of the comput-er program during the 4/92 outage, he questioned Latimer as to what was going on with the program. By this time, Latimer had already received two appraisals (10/91 and 3/92) noting unsatis-factory performance and a memo stating that the performanca issue
, was sarious and could result in termination. It is clear from the sequence of these events that Latimer's termination was a strong possibility before the April 1992 on-site visit and well before the SALP report was issued in September 1992. j b) Furthermore, the proximity of the 9/92 appraisal date with the 1
, SALP report was coincidental. As demonstrated by previous ap- 1 praisal dates (10/91 and 3/92), management was following the I recommendations of the company's Effcetive Performance Management Program by evaluating Latimer approximately every six months. The I dates for Latimer's interim and annual reviews follow that pattern and are in no way related to the date of the issuance of the SALP l l report.
- 3. Erosion / Corrosion Program
, Latimer resisted using the computing system to identify problems in the E/0 program. He failed to complete a $75,000 upgrade of the system, even after being given almost a year to do it. Specifically, Latimer 4 failed to monitor the accuracy of the data being entered. At the end of ! the upgrade work by the contractor, Latimer finally verified the { information and found that all inputs were wrong. In addition to l correcting all of the data entry mistakes that were made due to Latimer's mismanagement of the project, management decided, in Octo-ber/ November 1992, to rebuild the entire system. ABB/Impell, a leading l consultant in the Flow Accelerated Corrosion area, was contracted to ! provide the technical expertise and manpower. Dave Meleg, Project j Engineer-NDE Services, was named to provide in-depth oversight and I coordination of the program. The estimated completion date is February 18, 1993.
- 4. Welding Engineer ' ,
Staffing needs at the three nuclear plants vary greatly. Direct I comparisons of staffing levels at the three sites are not realistic. For example, the Robinson Plant has only enough welding work to support j a
- __- . .- _ =.
Mr. Jchn Latimer Page 5 of 6 one part-time position. However, because the Brunswick Plant has two units, there is enough welding work to necessitate maintaining one full-time welding engineer. Finally, the Harris Plant, with its post-TMI design criteria, requires one full-time welding engineer.
- 5. Denied Opportunity to Transfer a) Warren Farmer, the supervisor with whom he claims to have a personality conflict, signed Latimer's transfer request. However, Ray Chambers, the Site General Manager, denied the request based on Latimer's poor performance as demonstrated by:
. . poor project management skills in E/C systems upgrade
. lack of required documentation of work e deficient time management / punctuality
. resistance to direction from management It is Mr. Chamber's practice not to transfer employees with
. performance problems to another supervisor. He views it as his responsibility to resolve performance issues internally.
b) With regard to the Modification Implementation Unit position that , Latimer claims he could have transferred back to, there was no , vacant slot for a welding engineer then or now. Also, no E/C work is done in MIU. Therefore, although Latimer states that they were "willing and eager to get me back," the issue is moot because no s1ce exists. C. Meeting to Discuss Termination i A unit meeting was held following the termination of Latimer's employ-ment in an effort to quell rumors and speculation. It was stated that the employment of Latimer had been terminated for performance reasons. Mana5ement did not provide the details of the performance issues to other employees in the unit. Conclusion It is evident from the information provided above that the reasons for the termination of Latimer's employment are based on the ongoing performance issues, which he failed to address despite repeated feedback and warnings from management. While Latimer may believe that he would still be employed with CP&L had he been reporting to a different supervisor, the facts regarding his performance indicate otherwise. IN keeping with the precepts of EPM, Latimer received feedback and an opportunity to improve. When improvement did not occur, a recommendation to terminate his employment was the logical and appropriate step. Mr. Latimer, the above response addresses your concern. However, shohld you have further questions regarding this matter, please feel free to contact me or any member of my staff.
l i i Mr. Jchn Latimer i Page 6 of 6 Thank you for taking the time to express your concern through the Quality Check Program. Sincerely,
//v WL &WW l H. L. Casanova i Manager - Quality Check
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CONFIDENT!A'. Form No.19N
.ROLINA POWER & LIGliT COMPA!
REOUEST FOR TRANSFER FULL NAME: DATE SSN: 0 Y ^ Y b Y* EMPIDYED:3/Nf}ti ,150.go- off5 PRESENT , SUPERVISOR: CLASSIFICATION: Ie,aeor 6 =g , ee< (4/. /~ m e as e e' PRESENT WORK DEPARTMENT SECTION UNIT LOCATION: {Eo bise se s P /a 1 Te e A. S.ss s as t REASON FOR To b
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ee < I would consider the following ~d*==* O Rotating Shift O Abnormal Work Schedule O Locados Change ! O Travel Ia me' g o'de I'*** * <*^ , '
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i 4 i i ' I This request will be considered current for 90 days. ! M b- ~ 9[2V 19 9 2 Signature [ Em loyee Yt[ 19 @ I Signature oQrvisor It is my understanding that is requesdag a transfer to another position i in the Company. 'this request will not jeopardize his/her present position in any way. I hereby grant permission for this transfer to be pr=*-4 I understand that appropriate levels of a ment will be kept informed as j j outlined in Transfer Procedures - Em i equested. ( 19 Approval of Department I i 19 Mof Personnel Reprdsentative
T l PRE EMPLOYMENT TEST 1NG OUALIFIES EMPLOYEE FOR: D Engineering Technician O Computer Programmer O Meter Reader O Fossil Operator O Nuclear Operator O Stenographer O I&C Technician O RT&C Technician O ' Typing O Mechanic, Electrician O Thurstone Only O Shorthand O Clerk ssmusamiaesiffigw2Wasassgetarassa h&
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i l i E. B. ROBINSON NUCLEAR PIJ0fT EROSION-CORROSION PROGRAM JANUARY 3, 1992 6/c Aga m , e i I r
. . - - - - - . - . - - . ~ . . - . . - . - - - - - - - - - - - . - - - . -- - -.
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- j. Background ,
- Over the years, nuclear power plants around the world have been ,
4 experiencing increasing rates of material wear in their secondary
; piping systems. These increased wear rates have caused operational , ; problems such as unscheduled plant shut-downs, emergency repairs and replacements, and personnel injuries.
i The wear is being caused by the combined effect of mechanical j (erosive) and electrochemical (corrosive) mechanisms, a phenomenon known as erosion-corrosion. Under conditions found in certain l single and dual-phase systems, the steel piping corrodes, forming j a thin layer of corrosion product (iron-oxide) which adheres to the
; surface of the metal. This layer protects the metal by separating j
it from the corrosive environment and the corrosion process ceases. If, however, a mechanical force (erosion) acts on the pipe to y remove some of this protective layer, the process occurs again.
! That is to say, the inside of the pipe corrodes enough to ' form an l
adherent layer of iron-oxide, mechanical forces cause the pipe to i arode, metal is exposed, and, the cycle beg _ns again. Obviously
- this cycle, if allowed to continue, will result in substantial material loss which will lead to a decrease in the piping's
- mechanical integrity and could ultimately lead to catastrophic failure.
) This wear has been shown to exhibit three fundamental features that i make accurate predictions extremely difficult. These are; 1) wear
- j. appears in seemingly random locations, 2) wear is dominant in tees, bands, and fittings, 3) wear rate varies with temperature. A i
l maximum waar rate has been found to occur at about 300 degrees F, l however, wear is limited at lower temperatures and at higher l temperatures which suggests that there are two competing mechanisms .
- which influence the temperature effect. As stated above, there are j two distinctive mechanisms that cause the wear associated with erosion-corrosion. The first of these, oxide dissolution
- (corrosion), is found in both single-phase and dual-phase flow,
- while droplet impact wear (erosion) is found only in dual-phase
- flow.'
l Industry and Regulatory Developments The Electric Power Research Institute (EPRI) in conjunction with the Nuclear Utility Management and Resource Council (NUMARC) have developed a recommended industry program to address the erosion-corrosion issue. NUMARC developed a set of guidelines for industry l to follow. These guidelines are; 1) conduct appropriate analyses i " Prediction and Mitigation o
'f Erosion-f NUREG/CR-5007 Corrosive Wear in Secondary Piping Systems of Nuclear Power Plants" i 1
-- - +- ,,- -
.- ..~ . . - . -. .- . -- . .- .. . -= - - - . . . - . - - -
i [ 4 l and baseline inspection of susceptible components, 2) determine the ' extent of thinning and repair or replace as necessary, 3) perform follow-up inspection and develop longer term corrective action. i EPRI developed a family of computer codes to help identify , susce and to help trend and evaluate collected l data.ptible components The original computer code, CHEC, was intended for use in single-phase flow systems. The computer code intended for dual-phase flow i usage is called CHECMATE. When the void fraction term in this code is zero, the results are equal to the results given by the CHEC code for single-phase flow. Therefore, the CHECMATE code can be used . for both single- and dual-phase flow, and is expected to become the code of choice. ; [ The CHECMATE program is intended to be used as a predictive tool, t- to aid in identifying locations susceptible to erosion-corrosion as well as to calculate erosion rates. This program was built on empirical equations utilizing data from both plants and laboratory i experiments covering the bounding parameters of conditions , conducive to erosion-corrosion. The parameters considered in this rog am are water chemistry: pH, oxygen, temperature; material ! chemistry: chromium, copper molybdenum; and hydrodynamics: velocity, geometry, steam quality. Specific plant inspection data
- is combined with the empirical model to refine the program to more accurately represent the particular plant for which it is being used. Based on this, predictions where no inspection data are available may be unreliable, and should be used for guidance or ranking purposes only. Also, when no inspection data has been
[ entered, the wear rates generated are predicted wear rates and
- l. should not be misconstrued as absolute wear rates.3 E. B. Robinson's Program j- The CHECMATE program at H. B. Robinson includes the piping within the Feedwater, condensate, Heater Drains and Vents, Main Steam,
! Extraction Steam, Moisture Separator Reheater and Turbine l Crossunder systems. l The bounding parameters used in selecting the initial components to
! be included in the program are as follows:
) Temperature between 200 and 450 J Components constructed of carbon steel Components greater than 1" diameter. 1 i 2 NUREG-1344 " Erosion / Corrosion-Induced Pipe Wall Thinning in j U. S. Nuclear Power Plants" , 3 CHUG Currents, Volume 3, Number 1, page 7. September 1991. , l 2 i n y , ,-
The lines which meet these criteria are identified in Attachment 1. As noted in that Attachment, many additional lines were also included in the program. These lines were included for various reasons some of which are; large pressure drops in the line, components downstream of orifices, steam traps or control valves, lines with geometrical configurations conducive to increasing velocity or mass transfer rate, and lines which have previously exhibited signs of erosion-corrosion (at Robinson or in the industry). Some of the lines not yet included in the database are inspected under the manual erosion-corrosion program currently in place. Some lines were chosen-for exclusion based on the results of inspection data. Others, which are slated to be included in the database, are a lower priority than those already included based on the consequences of a leak or rupture, such as location and whether or not the component can be readily isolated to preclude further leakage or personnel injury. Justification for the exclusion of a line is provided in Attachment 1, some of these lines are intended to be added to the program in the near future. The components in the lines selected were uniquely identified and entered into the database. Approximately 306D components have been entered to date. Attachment 2 is a punchlist of outstanding items. The items listed should be added to the erosion-corrosion program as soon as is feasible. There are other lines, not considered to be of paramount importance, that may eventually be included in the program in the interest of completeness.
SUMMARY
The erosion-corrosion program at H. B. Robinson is in general a better than fully adequate program. The inspections are performed on a basis frequent enough to preclude catastrophic failure. The grid size and placement facilitate consistent readings and cover the areas of concern. The use of the CHECMATE program will provide the continuity that is necessary in the nuclear industry. Over time, the CHECMATE program will allow the user to optimize the number of inspections performed while maintaining plant reliability and personnel safety. 3
i i l REFERENCES
- 1. NUREG/CR-5007. " Prediction and Mitigation of Erosion-Corrosive Wear in Secondary Piping Systems of Nuclear Power j Plants", Keck, R. G., Griffith, P., September 1987
- 2. CHUG Currents, Volume 3, Number 1, EPRI, September 1991.
- 3. "NUMARC Technical Subcommittee Working Group on Piping Erosion / Corrosion Summary Report", June 11, 1987. f 1
l
- 4. " Single-Phase Erosion-Corrosion of Carbon Steel Piping", Final Report, Jones, R. et al, Nuclear Power Division Electric Power Research Institute, February 19, 1987. .
- 5. " Inspection Planning to Address Erosion-Corrosion", Chexal, V.
K., et al, Nuclear Power Division Electric Power Research Institute, June 1989. - l
- 6. " Tackling the Single-Phase Erosion Corrosion Issue", Chexal, V. K., Layman, W. H., Horowitz, J. S., April, 1988. i 1
4
- 7. "How utilities monitor pipe-wall thinning at nuclear plants", 1 Lopriore, R. P., Power. August 1988. l 1
1 i l l a l i 1 e 4 er
-_____m_- __--_ _ _ -_ _ _ _
l Attachment 1 Page 1 of a LINES CONSIDERED IN THE EROSION-CORROSION PROGRAM FEEDWATER CONDENSATE EXTRACTION STEAM 20-FW-2 a,b,c 16-C'-1 b 16-ES-1 a,b,c 20-FW-3 a,b,c 16-C-2 b 10-ES-2 a,b 20-FW-4 a,b,c 22-C-3 b 10-ES-3 a,b,c 20-FW-5 a,b 20-C-4 b 20-ES-4 a,b,c . 20-FW-6 a,b,c 14-C-J b 14-ES-5 a,b,c 20-FW-7 a,b, 14-C-6 b 14-ES-6 a,b,c 16-FW-9 a,b, 22-C-7 b 18-ES-7 a,b,c 16-FW-10 a,b,c 16-C-8 b,c 18-ES-8 a,b
~
16-FW-11 a,b,c 16-C'-9 b,c 12-ES-9 a,b,c 24-FW-12 a,b,c 16-C-10 a,b 18-ES-10 a,b,c 4-FW-13 a,b, 16-C-11 b 12-ES-11 a,b 6-FW-14 a,b, 16-C-12 b 26-ES-12 a,b,c 4-FW-15 a,b, 16-C-13 a,b,c 18-ES-13 a,b 6-FW-16 a,b,c 16-C-14 a,b,c 26-ES-14 a,b,c 20-FW-17 a,c,e 16-C-15 a,b -ES-15 c 6-FW-18 b, 16-C-16 a,b,c 18-ES-16 a,c# 4-FW-20 b, 16-C-17 a,b 18-ES-18 a,c# 4-FW-21 b, 16-C-18 a,b,c -ES-27 c 4-FW-22 a,b, 16-C-19 a,b,c 6-ES-49 a,c 4-FW-23 a,b, 22-C-20 a,b,c 6-ES-50 a,c 4-FW-24 a,b 30-C-21 a,b,c 6-ES-51 a,* . 4-FW-25 a,b, 20-C-22 a,b,c 6-ES-52 a,* 4-FW-26 a,b, 20-C-23 a,b,c 14-ES-53 a,* 4-FW-27 a,b, 8-C-24 b,c 14-ES-54 a,b,c 20-FW-28 a,b,c 8-C-25 b 4-ES-55 a,g 20-FW-29 a,e,g 4-C-27 b 4-ES-56 a,g 20-FW-30 a,b 3-C-31 a,b 20-FW-31 a,e,g 16-C-32 a,b 4-FW-32 a,b, 1-C-33 a,b 4-FW-33 a,b, 16-C-34 a,b 4-FW-34 a,b, 6-C-35 a,b l 3-FW-35 a,g 4-C-40 b l l 3-FW-36 a,g 30-C-44 b 3-FW-37 a,g 6-C-50 b 2-FW-38 c,f 6-C-52 b 2-FW-39 c,f 4-C-52 b 2-FW-40 c 2-FW-43 c,f - 10-FW-56 a,g , a g
r a J Attachment 1 Page 2. of 1 HEATER DRAINS HEATER DRAINS HEATER DRAINS 10-MD-1 a,b,c 10-HD-47 a,b,c 8-MD-231 a,b,c , 10-HD-2 a,b 14-HD-48 a,b,c 8-HD-232 a,b,c 12-HD-3 a,b,c 3-HD-49 a,b,c 8-HD-233 a,b,c U-HD-4 a,b,c 3-HD-50 a,b,c 8-HD-234 a,b,c 14-dD-5 a,b,c 18-HD-51 a,b,c 14-HD-235 a,b,c 8-HD-6 a,b 30-HD-52 a,b 3-HD -2 3 9 a,d 8-HD-7 a,b,c 16-HD-53 a,b* 3-HD-240 a,d 6-HD-8 a,b 4-HD-55 c 3-HD-241 a,d 6-HD-9 a,b,c 4-HD-56 b,c 3-HD-242 a,d 6-MD-10 a,b 4-HD-57 b,c 10-HD-11 a,b,c 4-HD-58 b,c _ 12-HD-12 a,b,c 6-HD,-59 b,c 6-HD-13 a,b 8-HD-60 a,b 6-HD-14 a,b,c 6-HD-61 b,c 6-HD-15 a,b 8-HD-62 = b,c 10-HD-16 a,b,c 6-HD-63 a,b,c 8-HD-18 a,b 6-HD-64 a,b 12-HD-19 a,b,c 10-HD-66 a,b,c 8-HD-20 a,b 10-HD-67 a,b 12-HD-21 a,b,c 6-HD-68 a,b 8-HD-22 a,b, 10-HD-70 a,b,c 12-HD-23 a,b,c 4-HD-71 b 8-HD-24 a,b 4-HD-72 b,c 12-HD-25 a,b,c 4-HD-73 b 10-HD-26 b 6-HD-74 b 16-HD-27 b 6-HD-75 b 10-HD-28 b 6-HD-76 b 16-HD-29 b 6-HD-77 b i 10-HD-30 b 1-HD-82 a,b 16-HD-31 b 1-HD-83 a,b 10-HD-32 b 1-HD-84 a,b 16-HD-33 b 1.25-HD-85 a,b 12-HD-34 b 1.5-HD-86 a,b 16-HD-35 b 1.5-HD-87 a,b 12-HD-36 b 2-HD-98 a,b 16-HD-37 b 2-HD-99 a,b 12-HD-38 b -HD-114 c 16-HD-39 b -HD-116 c 12-HD-40 b -HD-192 c 16-HD-41 b -HD-196 c 24-HD-42 a,b,c -HD-197 c 16-HD-4J a,b* -HD-199 c - 16-HD-44 a,b,c -HD-200 c , 16-HD-45 a,b,c -HD-201 c 10-HD-46 a,b,c -HD-208 c
Attachment 1 Page 1 of;l TURBINE X-UNDER MAIN STEAM 45-CR-1 a,b 26-MS-1 b 45-CR-2 a,b 26-MS-2 b . 32-CR-3 a,b 26-MS-3 b 32-CR-4 a,b 72-MS-4 b , j 32-CR-5 a,b 32-MS-5 b 32-CR-6 a,b 32-MS-6 b 30-CR-7 a,g 16-MS-7 b 2 24-CR-8 a,g 16-MS-8 b 30-CR-9 a,g 6-MS-9 b 24-CR-10 a,g 6-MS-10 b 30-CR-11 a,g 6-MS-11 b,c 24-CR-12 a,g 6-MS-12 b,c 3J-CR-13 a,g 12-MS-13 b 24-CR-14 a,g 12-MS-14 b
.75-CR-15 a,b 3-MS-24 c .75-CR-16 a,b -MS-45 c .75-CR-17 a,b 1-MS-46 c 2 .75-CR-10 a,b 1.5-MS-94 c
- 1-CR-19 a,b 1.5-MS-96 c l 1-CR-20 a,b 1-MS-97 b*,c l
- 1-CR-21 a,b 1-MS-98 b*,c l I
' 1-MS-99 b*,c 1-MS-100 b*,c
-MS-113 c 3/S-MS-161 c 2-MS-166 c 2-MS-167 c 2-MS-168 c 6-MS-169 c l
a) within bounding parameters b) included in CHECMATE c) in HBR E/C program d) drawings / design information needed - e) inadequate flow , f) small pressure change g) infrequent use/ bypass
*) included as part of another line #) inside condenser o
J l Attachment 2 Page 1-of 1 1 j l PUNCHLIST 3-HD-239 - need drawings and design / operating information i 1 3-HD-240 - need drawings and design / operating information f i 3-HD-241 - need drawings and design / operating information i 3-HD-242 - need drawings and design / operating information 1.5-MS-161 - need drawings ; 1-MS-162 - need drawings i
- 3/4-MS isolable, but should incorporate downstream of I trap, need drawings 3/4-MS-119 - isolable, but should incorporate downstream of 1
trap, need drawings l 4 steam generator blowdown - already in manual E/C program, 1 should add to CHECMATE :
. update repaired / replaced items j y
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APA-339 Page 1 of Form No. 1722 CAROLINA POWER & LIGHT COMPANY ACCOUNTABILITY PER'*05EMANCE APPRAISAL Names John Y. Latimer Appraisal Period: 03/09/91 - 10/23/91 5:cial Security No.: 250-80-0585 Apriaisal Date: 10/23/91 Titles Senior Enaineer List the major accountabilities emphasized during the appraisal period and in priority order by number and key words as descrit<ec far the position. Evaluate the unployee on the work performed during the appraisal period and ccanent on each accountability separately. For each accountability listed, place an "X" to reflect the employee's performance level. If necessary, use additional sheet (s). Refer to ) Guide to Actatnisterina Emelovee Camoensel,i.e for Performance Rating definitions. PRINCIPAL ACCOUNTABILITY RATING CotOENTS l INTERIN PERFORMANCE APPRAISAL Ensure that assigned UNSATISF Mr. Latimer's performance aporaisal dated 2/23/91 functions ..e conducted contained the follo-6..w statements for this in compliance.with accountability: Tcchnical Specifications, QA and "In the area of department policy, Mr. Latimer regulatory should be more supportive of unit improvement I requirements, plant initiatives. He should not refrain from l precedures and constructive comments, but should choose the ! d:ptrtment policies. appropriate forum in which to make them. His 4 comments should be less abrasive, and he should focus on conveying his ideas in a more professional manner." Mr. Latimer was rated Satisfactory in this accountability in the 2/23/91 evaluation. 3 contrary to the above recommended change in I performance, Mr. Latimer has continued a pattern of resisting unit improvement initiatives and overall contempt of management decisions / directives. His comments in subunit meetings and more casual environments are not of the type expected from an employee in a professional, staff position. His comments are highly critical, and do not offer alternatives / recommendations that he is willing to pursue. His comment.s indicate that his attitude / approach to his job is not at the level expected of a Senior Engineer. Mr. Latimer resisted the improved plann,ing j techniques that were agreed to in the attached 1 Customer Improvement Agreement between the Programs and Planning and Scheduling groupe (Attachment 1). I l
t APA-339 l . Page 2 c:- 4 Porm No. 1722
- CAROLINA POWER & LIGHT COMPANY ACCOUNTABILITY PERFORMANCE APPRAISAL Came John Y. Latimer Appraisal Period: 03/09/91 - 10/23/91 83cial Security No.: 250-80-0585 Appraisal Date: 10/23/91 4
Titles senior rnaineer List the major accountabilities emphasized during the appraisal period and in priority order by number and key words as describe 6 l fir the positica. Evaluate the esployee on the work performed during the appraisal period and consent on each accountability j separately. For each accountability listed. place an "X" to reflect the employee's performance level. If necessary, use additional sheet (s). Refer to A Guirie to Administerina Emolovee Comnensation for Performance Rating definitions. 3 PRINCIPAL ACCOUNTABILITY RATING COMMENTS I I As a signatory to this document, Mr. Latimer
- committed as a professional to "... provide a
] detailed plan of activities by the outage scope j freeze date for each applicable sub-program 1 (MVMP,ISI, Erosion / Corrosion)." The plan for his activities was submitted, but only after many negative comments about the process and the need to i provide such detailed information for scheduling i purposes. His approach to the task was considered l l to be unprofessional. ! t Mr. Latimer has resisted the Technical Support Objective No. S that states l " Individual Development Plan developed for a minimum 50% of all Technical Support personnel by J ! December, 1991." { By attached E-mail (Attachment 2), dated 10/7/91,
- notice of pending issuance of the IDP packages was f given. An appeal was made to take the time l j necessary to complete the package as accurately as J
, possible. Later that week under separate cover, i the IDP packages were distributed with a purpose statement and instructions (Attachment 3). As evidenced by Mr. Latimer's reply shown on Attachment 4, he did not take the request seriously. He chose instead to use this solicitation for input on his career objectives as another vehicle to voice criticism of plant-management. , 4 w,
l APA-339 Page 3 o F.cra No. 1722 CAROLINA POWER & LIGHT COMPANY ACCOUNTABILITY PERFORMANCE APPRAISAL Names John Y. Latimer Appraisal Period: 03/09/91 - 10/23/91 Cecial security No.: 250-80-0585 Appraisal Date: 10/23/91 l l Titles senior unaineer l l List the mejor accountabilities siphastred during the appraisal period and in priority order by number and key words as describe j far the position. Evaluate the migloyee on the work performed during the appraisal period and comment on each accountabiltty separately. For each accountability listed, place an "X" to reflect the employee's performance level. If necessary, use additional sheet (s). Refer to A Guide to Actninisterino (molovee Ccrioensation for Performance Rating definitions. PRINCIPAL ACCOUNTABILITY RATING CONNENTS
~
Two points / considerations, in particular, make his response to the IDP request troubling. These are:
- 1. The IDP process is intended to match the employee's career goals to the objectives of the unit and company. From this development plan, training can be intelligently selected to ,
ensure those common purposes can be achieved. It is in the employes's best interests to take the time necessary to place the proper information into the process.
- 2. Lack of interest / participation in achieving stated objectives of the Technical Support Unit was shown.
This behavior is disruptive to the remainder of the unit personnel, and conflicts directly with the Technical Support Unit improvement initiatives. Given the Satisfactory rating in this accountability on 2/23/91, and the continued negative trend, an Unsatisfactory interim rating is warranted.
1
'APA-339 -
Page 4 o f Farm No. 1722 j j CAROLINA POWER & LIGHT COMPANY I ACCOUNTABILITY PERFORMANCE AFFRAISAL . 4 Names John Y. Latimer Appraisal Period: 03/09/91 - 10/23/91 k I Sccial Security No.: 250-80-0585 Appraisal Date: 10/23/91 1
Title:
Senior Enaineer i ; List the major accountabilities emphasized during the appraisal period and in priority order by number and key words as describe f:r the position. Evaluate the employee on the work performed during the appraisal period and comment on each accountability j separately. For each accountability listed, place an "X" to reflect the employee's performance level. If necessary, use
' additional shoot (s). Refer to A Guide to Administerino Emolovse Comnensation for Performance 8ating definitions.
- PRINCIPAL ;
AccocNEABILITY RATING casesENTS l Support increased plant UNSATISF Several general requests have gone out to Programs ! officiency, plant Subunit personnel to work the extra time necessary l operating requirements, to accomplish tasks within a given time frame. In l cnd regulatory assigning Mr. Latimer several tasks, he has ! commitments. commented that he did not have the time to accomplish these due to his workload. Several months ago, a trend of late arrivals and extended time in the Unit I cafeteria was noted. From -l . security records, the trend was verified. l Mr. Latimer was counseled on this matter and informed of the need to be more punctual and I efficient in the management of his time. i As shown on Attachment 5, Mr. Latimer requested the l alternate work schedule of 7:00 am - 3:30 pm when i the policy change was announced. With continuing evidence that no improvements in punctuality and , officiency were being made and that he was not l 4 adhering to his requested schedule, another review I of security records was recently made. This i - revealed a chronic pattern of late arrivals and l
- early depsrtures. !
- Mr. Latimer must learn to manage his time more ) i effectively. He needs to spend at least 8 work hours per day on site during his chosen schedule ) hours. He should accept additional work items . along with the casual overtime that these taske may require. , Given the comments on being overloaded to the point that new projects cannot be accepted sti a time when continuing unacceptable trends relating to time I management were being exhibited, an interim Unsatisfactory rating in this accountability is l warranted.
APA-339 CAROLINA POWER & LIGHT COMPANY 2 FIRM NO. 1722 (REVERSE) OVERALL PERFORMANCE APPRAISAL UNSATISFACTORY SATISFACTORY COMMENDABLE OUTSTANDING Summarize the employee's overall performance and outline accountability emphases for the coming year. J Tha trsnd of highly critical comments regarding plant / company initiatives has continued since ths 02/23/91 Performance Appraisal. Mr. Latimer's approach to his job indicates he is not interested in making continuous improvement in areas of responsibility. His work schedule is n:t being maintained , to the detriment of the Programs Subunit's overall efficiency. Th3 performance described herein is considered unprofessional and unsatisfactory. Careful cen3ideration of this Interim Performance Appraisal is recommended.
- Th3 level of performance in the other ucoun.tabilities listed in the 02/23/91 appraisal remnina essentially unchanged.
Irprovement in the areas listed below is expected within 90 days following review of this intcrim evaluation: A) Provide support for the Technical Support improvement initiatives. Provide 1 l constructive comments in the appropriate forum. B) Adhere to the work schedule chosen. Increase productivity by managing time more effectively. j I I Appraisal and comments by:
\ \
M
'L" Dates //I // i
/
Comments, if any, by supervisor base discussion of employee's rating. d cM* S 1 /# - tA -e 5 /- Ykd[ ykg 6 4 ba p < w s < h et % st( /*v</c o Y om a w v. 09 nta - a.f e ~ ~P w t o '
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I hnve reviewed the information on both sides of this form. Employee eignature: $e e et de e b S *4 S Date: Supervisor / Manager signature: Date:
n;;.ac..: e .: . Form 244 CaecHna Power & Lignt Company ose . .e. Company Correspondence CUSTOMER AGREEMENT TECHNICAL SUPPORT - PROGRAMS AND PLANNING AND SCHEDULING 1 In order to more effectively serve the Planning and Scheduling unit in planning refueling outages, the Programs subunit agrees to meet all applicable due dates established by P&S in the Precutage i Milestone Schedule and to provide a detailed plan of activities by the outage scope freeze date for each applicable subprogram (MVMP, ISI, Erosion / Corrosion.) T h.i s w i l l be done for all refueling outages.
; In addition, within four months '*"r completion of Refueling
- Outage 14, a basic plan of outage activities for Refueling Outages 15 and 16 will be provided to Planning and Sen'sduling. The scope ;
of this plan will include the major work items to be accomplished I and the potential impact on proposed outage lengths as specified in the 5 year plan. This plan will be a "living docur ant" which will be updated within four months following completion of subsequent refueling outages. i L j( wwA ug
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Attachment-2 To: DBG JYL WSM , SMP GJP RBW MLW Cc: Ccc: Fren: WARREN FARMEROPLANT9 CPL RNP 1
Subject:
Individual Development Plans Date: Monday, October 7, 1991 9:46:35 EDT Attach: Cortify: N Fcrwarded by: I will be issuing each of you packages to be used in determining what your
, c rcer goals are. An attempt will be made to match your career goals to the
! cc pany's business goals, then provide specific training in these areas.
- I will be getting packages out to you shortly. Please take time to complete
. the package as accurately as possible..
L i 4 d i 1 i 2 i
)
I 4 t l h a D as
Attach =en: 3 l DATE: October 7, 1991 TO: John Latimer FROM: Warren Farmer 1 SUBJ: Individual Development Plans (IDPs) One of our Technical Support Improvement Program objectives for 1991 is to develop employee IDPs that identify and plan long-term career goals and objectives. Our overall goal is to develop your I technical and personal capabilities and qualifications to match the I goals and objectives of the Unit and the Company. TSG-115 provides the guidance for IDP development. The first step ' ] in developing an IDP is for you to identify your technical and personal objectives for your_ present position and goals to prepare you for future positions. Your particular position requirements 1 , are included in your Position Description, TMM-001, and the various
'. 3Gs that define our System and Compen:nt Engineer Programs. For example, one goal that most people in Tech Support should have is
} to certify as a System Engineer. The attached " Example" IDP should help you when preparing your own plan. After you have prepared ; your IDP, I will discuss the plan with you before we get the Unit Manager's approval. ; I intend to discuss your IDP with you during the month of November, ! so you need to have your preliminary IDP developed by October 31, l I 1991. Additional IDP information and blank forms are attached. If you have questions, contact me. Wp & Attachments:
- Example IDP
- Blank IDP Forms
- TSG-115 (Info only) s e
, ?! -ber- '* 3 '. '. 5 Rev , 4 Page 1 of 3
< l 1 , \
] Technical Support Unic 1 Individual Development Plan ! 1 For
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Employee Data Subunit Manager Date i k
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AP4-16' Page 1 o Fcru No !?22
, CAROLINA POWER & LIGHT COMPANY ACCOUNTABILITY PERFORMANCE APPRAISAL
] j Name John Y. Latimar Appraisal Period: 02/23/91 - 03/07/92 S:cial Security No.: 250-80-0585 Appraisal Date: 03/07/92 4
Title:
Senior Eneineer
; List the major accountabilities emphasized during the appratsal period and in priority order by number and key words as describec 4 fer the position. Evaluate the egloyee on the work performed during the appraisal period and conenent on each accountability , separately. For each act.suntability Itsted, place an "X" to reflect the egloyee's performance level. If necessary, use i additional sheet (s). Refer to A Guide to Administerina Emolovee comoensatinct for Performance Rating definitions.
j FRINCIPAL ACCOUNTABII.ITY RATING CONMENTS Support increased plant casunend Mr. Latimer's support of the welding activities of officiency, plant the Modification Implementation Unit (MIU) and the
- cperating requirements, Maintenance Unit continues at a commendable level.
I and regulatory A survey of his customers has indicated a high
; requirements. degree of satisfaction with his support and 1- technical ability. His years of experience in this i specialized area has proven beneficial in many instances.
j His review of modification packages often goes
- beyond his defined scope, and often results in more j cost-effective ways to accomplish field activities.
- His efforts in implementing the Corporate Welding Manual have been commendable.
Mr. Latimer has a thorough knowledge of the codes
! and standards that govern the site welding program.
He has been involved in_ implementing changes to the Corporate Welding Program to better describe the j responsibilities of variou organizations. His 1 input in an effort to centralize storage of welding material should reduce OEM costs. l l More emphasis should be placed on training i Maintenance Planners and MIU personnel in the use l j of the procedures that govern the welding program. l
- This will allow Mr. Latimer to spend more time in overall program management, and will shift more l responsibility for day-to-day specifics to the appropriate groups.
1 4 l i a f I a. m p--e t-m -
APA-18 Pega 2 c I Farm No. 1722 I i i CAROLINA POWER & LIGHT COMPANf ACCOUNTABILITY PERFORMANCE APPRAISAL l l Name: John Y. Latimer Appraisal Period: 02/23/91 - 03/07/92 Srcial Security No.: 250-80-0585 Appraisal Date: 03/07/92 Titles senior Enaineer List the major accountabilities emphasized during the appraisal period and in priority order by number and key words as desertt for the position. Evaluate the employee on the work performed during the appraisal period and contnent on each accountability separately. For each accountability listed, place an "X" to reflect the employee's performance Icvel. If necessary. use addittoael sheet (s). Refer to A Guide to Adninisterino Emoloyee Comoensation for Performance Rating definittons. PRINCIPAL ACCOUNTABILITY RATING COMMENTS Prcvide technical and Satief - As stated above, Mr. Latimer has adequate command cdministrative support (Minus) of the technical aspects of the plant welding for plant program. However, improvements in description and j programs / contribute to control are needed in the erosion / corrosion esct-effoctive plant program. cperations. - l Mr. Latimer prefers to operate in a comfort zone i that lacks defined scope and responsibilities. In j this zone, he has not been receptive to change. I For most of this evaluation period, he has not been f lly supportive of an effort to use a computerized l database, developed by EPRI, that can predict areas prone to erosion / corrosion damage. His arguments against the system have some technical merit, but he has not msde the commitment to overcome the l obstacles ano use this new system to enhance and i He has communicated concerne upgrade the pr'agram. l regarding the smount of time required to implement ' and maintain the program. This also has merit, but has not been justified based on the current I workload and the little time he has spent with the ) program. ! Mr. Latimer has not taken the initiative to overcome startup concerns on the system, but rather ' has used several questionable outputs as justification to scuttle the project. These j startup problems appear to have easy remedies. i More commitment should be shown to work with the system and use it to supplement the manual data recording system now used. Two previous performance appraisals have stated the need to enhance and supplement the existing Erosion / Corrosion Program, using computerized techniques. Improvement in this area is necgosary to raise the rating in this accountability. T!.are have been some encouraging signs toward the ; and of the evaluation period that Mr. Latimer is willing to coaunit his full support to this project. It is believed that this coannitment is all that is required to move the RNP Program closer to' premier status. , , l
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t APA.18
\
i Form No. 1722 Pago 3 c' i CAROLINA POWER & LIGHT COMPANY
. ACCOUNTABILITY PERFORMANCE APPRAISAL 1
i Mame: John Y. Latimer Appraisal Period: 02/23/91 - 03/07/92 Cecial Security No.: 250-80-0585 Appraisal Dates _ 03/07/92 ) Titles senior Enaineer l List the major accountabilities emphastred during the appraisal period and in priority order by number and key words as deserte ) l' fsr the position. Evaluate the employee on the work performed during the appratsal period and conenent on each accountability i
. separately. For each accountability listed, place an "X" to reflect the enployee's performance level. If necessary, use l additional sheet (s). Refer to A Guide to Adninisterino Emolovee Comnensation for Performance Rating deeintttons. ! PRINCIPAL j ACCOUNTABILITY RATING COMMENTS Enrure that assigned Unsatief There have been no violations of regulatory functions are conducted requireaants or procedures in Mr. Latimer's areas in compliance with of responsibility. His approach to procedure 3'
Technical compliance continues to be at the level expected. Specifications, QA and j regulatory During the period, Mr. Latimer was given an
- - requirements, plant unsatisfactory rating in this accountability as
precedures, and part of an interim performance appraisal. The 4 d:partment policies. major issues involved his support of plant policies and objectives, and his personal work habits. Both of these areas center around the extent of one's personal commitment. , l ! In previous evaluations, it had been recommended l j that his level of support fot olant policies and j , objectives be raised to the level expected of an ; , individual in a professional staff position. l
! Mr. Latimer is expected to voice his opinion i tactfully, and with consideration of follow ,
- employees and supporting organizations. His '
viewpoints should be aimed more at resolving the , problem rather than a simple statement of l i' disapproval. The mark of an innovator is that, not only can problems be identified, but also - commitment can be made to implement rational improvement ideas. I Mr. Latimer's work habits and organization also require improvement. As stated previously, there is some resistance to documenting how time is spent. His use of the Site Work Tracking System l (SWTS) for this purpose has been limited. In fairness, the SWTS is relatively new, and all site i personnel are being indoctrinated on its use as a 4 planning tool. However, Mr. Latimer's commitment 1 to the system has been less than expected. He often states he does not have adequate time to , ! perform other routine tasks, but carries no major ' work backlog, and wetxe no inordinate amount of j overtime. The lack of backlog is due in part to i
- the nature of his job. However, the biggest I
contributor is his inability to prioritize and I control his activities. < i t , 1 l During most of this period, Mr. Latimer's l punctuality was below standards. As stated in the ) i interim evaluation, his late arrival and early I
- departure times, coupled with extended break !
periods, often left less than 8 hours of productive I time spent per day. To aid in reversing this l trend, he has changed his work hours to provide for ; a later start time. His punctuality has improved
-- since this change was implemented.
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- APA 16 Pags 4 c:
Farm No. 1722 CAROLINA POWER r. LIGHT COMPANY ACCOUNTABILITY PERFORMANCE APPRAISAL Name: John Y. Latimer Appraisal Period: 02/23/91 - 03/07/92 Sscial Security No.: 250-80-0585 , Appraisal Date: 03/07/92 Title Senior Enaineer List the major accountabilttles emphastzed during the appraisal pertod and in priority order by number and key words as describe
! fir the position. Evaluate the employee on the work performed during the appratsal period and conenent on each accountablitty l sicarately. For each accountability itsted, place an "X" to reflect the encio,ee's performance level. If necessary, use l <dditional sheet (s). Refer to A Guide to Administerino Emoloyee compensation for Performance Rating definittons.
< PRINCIPAL ACCOUNTABII.ITY RATING COMMENTS En ure that assigned (Cont'd) Commitment to one's company, and to one's functions are conducted specific job function is an important measure of a in compliance with professional employee. Lack of this commitment T;chnical cannot be substituted with technical ability alone. specifications, QA and Mr. Latimer needs to consider how he might improve regulatory in thie-accountability. It is suggested that requirements, plant concepts learned during the Managing Relationships procedures, and at Work course he recently attended be widely d:psrtment policies. applied. 1 considerable improvement is needed during the next appraisal period to raise the rating in this accountability. Behavioral change, as it relates < to the approach to the job, is suggested.
, Encure work is Commend Mr. Latimec routinely works in close proximity to
] performed in accordance high energy piping systems. As a welding engineer, 1
- with Company safety he is often exposed to the hazards associated with rules. shop and field activities. He conducts himself !
with the proper regard for the Company Safety
- Program. He is cognizant of the dangers present, and takes appropriate precautions.
His experience is helpful in work planning, to ) ensure hazards are identified and considered. ' i 1 .i I
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APA.16 Pago 5 o Parm No. 1722 , CAROLINA POWER & LIGHT COMPANY ACCOUNTABILITY PERPORMANCE APPRAISAL Names John Y. Latimer Appraisal Period: 02/23/91 - 03/07/92 social security No.: 250-80-0585 Appraisal Date: Titles senior Enaineer List the mejor accountabilities emphasized during the appraisal period and in priority order by number and key words as desertbe fer the position. Evaluate the employee on the work performed during the appraisal period and ccumnent on each accountability , separately. For each accountability listed place "X" to reflect the employee's performance level. If necessary. use additional sheet (s). Refer to A Guide to Administermo Emolovee Cannensation for Performance Rating definitions. FRINCIPAL ACCOUNTABILITY RATENG COMMENTS Maintain effective satief Many organizations are affected by Mr. Latimer's comununications. programs. More communication aimed at keeping ] these groups informed of corrective actions necessary to resolve specific problema'is needed. He should give more consideration to communicating d the ovocall impact his program is having/could have on plant systems. This will aid in ensuring the required level of informed support is available, if 4 needed. coannunications should be concise and i documented. All potential impacts of a problem 4 should be communicated, accompanied by a recommendation (s) for correcting the problem. He , should endeavor to keep his supervision more ; 4 4 informed on his routine activities. l Within the last month, a new system of
- communicating problems found through the Erosion / Corrosion Program has been implemented.
This method involves the SWTS. Mr. Latimer is expected to use this system to communicate real and
- potential problems, thereby ensuring no surprises i are encountered.
e 8 The plans submitted for RO-14 activities were much improved over previous efforts. This will allow P&S to schedule the work to the extent necessary to ensure all impacts known. However, Mr. Latimer initially objected to providing Planning &
- Scheduling this planning information. He felt erosion / corrosion activities should not be scheduled in detail. This is an example where effective communication is essential, but has not been provided in the past.
i f l
APA.10 i CAROLINA POWER & LIGHT COMPANA l FORM NO. 1722 (REVERSE) OVERALL PERFORMANCE APPRAISAL UNSATISFACTORY X SATISFACTORY - COMMENDABLE OUTSTANDING (MINUS) Summarize the employee's overall performance and outline accountability emphases for the coming year. Mr. Latimer continues to perform at a commendable level in the technical areas of Welding Engineer functions. His approach to the resolution of plant problems is sound. His years of experience have proien beneficial in many instances during the appraisal period. His support of plant customers has been at the expected level. Mr.-Latimer should widen his knowledge bace of plant operations and improve his computer skills. This will aid in broadening his knowledge, and will enhance the effectiveness of his programs. Mr. Latimer is a member of the Accident Assessment Team, and shoulders his responsibilities t the Emergency Response Organization. He understands and practices the plant policy of VOrbatim Procedure Compliance. There have been no regulatory item violations, radiation cafety violations, or other areas of non-compliance in his areas of responsibility. t Wh n Mr. Latimer's technical ability and program management skills are compared, a contradiction arises. He prefers to conduct his program activities with little or no dofinition. He has exhibited some resistance to detailing his workload, using the SWTS. His interface with Systems Engineering requires improvement. During the period, a lack of comm4*-=qt w.s noted in the area of personal tims managa-a-* . La appears to resist systems that will require accountability for time and performance. N:w approaches are often discounted as having no benefit before they are completely explored. As a Senior Engineer, Mr. Latimer should lead by example. His comments in open forums should bs positive, and aimed at improving plant processes. This has not been the case during most of the evaluation period. He is expected to conduct himself in a more professional manner, and be more supportive of plant initiatives. Mr. Latimer is a man of unfettered opinion. This is a valuable personal asset; however, undiluted opinion is only helpful to an organization if it is aimed at the problem, and reinforced with positive, workable suggestion for improvement. Mr. Latimer should become more receptive to change, and pro-active in seeking program improvement. He must not see his function as a covert operation, but rather seize every opportunity to make his program and its impacts visible. He has been rated Satisfactory - i (Minus) because his technical skills are not compensating for improvements needed in program l management skills and personal time management. This rating is expected to be only a ) temporary condition. Mr. Latimer has the potential to reverse the current trend, and to move his programs closer t prcmier status. As expectations regarding his performance increase, he should consider ways i of maximizing his work output. This will require some change, but not a wholesale transfusio of methods. Appraisal and comments by:
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\ Date: D l i
Comments, if any, by supervisor bahed An discussion of employee's rating. I l 1 l I have reviewed the information on both sides of this form. Employee signatures Dater supervisor / Manager signatures . Dates l l
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LAflMER.MTR rom No. In2A CAROLINA POWER & LIWfT COMPAfW B081N50N BRICLEAR PROJECT NIDYEAR PERFORNANCE APPRAISAL Page i of NAME: John f. Latimer APPRAISAL PERIOD: 03/07/92 - 09/07/92 SOCIAL SECURITY NO: rs0-80-Osas APPRAISAL DATE: 09/07/92 i TITLE: seaior Eno meer 8elow are expectations which wre developed at the beginning of the evaluation gerlod and comments on progress being made toward unisving each expectation. Expectations may be revised or additional expectations included as appropriate. I Accountability /
- tation Progrese/Caseent s Provide EFFECTIVE SUPPORT FOR PLANT PROGRAMS (PN. CORRECTIVE. An atteet to itst work activities via the SVT5 has been made.
l WELDING. ETC. PROPER WO ADMINISTRATION. More effort in prioritt2ing these activities is needed.
- No overdue SWTS, ACRs, corrective actions, RAIL ltems, etc. The evaluation of one ACR was assigned during the period.
e Expand use of SWTS, to include manpower estimates. More use of the SWT5 will preclude the repeat of several e issue 00 Corrosion Program request for input by 01/30/92, overdue items that were noted during the period. I a Develop quarterly report of Erosion / Corrosion and Welding Quarterly reports of Ercston/Corroston activities have not Program activities. First report due 02/15/92. been prepared on time. The first reports were prepared oy 4
- Develop method to comunicate, record and track E/C Proteam 2/15/92 but were of marginal quality. More emphasis should t:e concerns to responsible parties. The method needs to use placed on keeping management infomed of major program
< the SWT5 as a mintmum. Development to be completed by activities. 03/15/92. The SVT5 has been uset to comunicate several
- Rewten and recomend changes / enhancements to the Erosion /Corroston concerns to systen engineers. This precess Eroston/Corroston Program by 10/31/92. This should include should continue and be erpanded to include all potential l
a plan to accomplish the reconmendations. problon areas. Close connunication with System Engineertrg is needed. Recomendations for improvement to the Erosion / Corrosion ' Program have been coordinated with a recently named corporate factittator. An aggressive effort is needed to improve the program. Development of the 00 Corrosion Program has not progressed as expected. Mr. Latimer should be more aggressive in pursuing this project by obtaining more systes engineer involvement. Provide TECHNICAL 4 ADMINISTRATivt $UPPORT FOR PLANT PROGRAMS Training attendance has been at the expected level. The !TP IN TWE AREAS OF TRAINING. CONTRACTS. BUDGET STATUS aNC has been followed in that travel requests for scheduled i P90CEDURE t INSTRUCTION DEVELOPMENT. courses have been sutznitted on time.
- Ensure ITP is kept current and accurate. Use and understanding of the CHEC and CHECMATE programs has l
- No tr'atning "no shows" been hampered by the length and extent of R0 la and the forced l
- Achieve proficiency in use of the CHEC and CHECMATE outage caused by the foreign material found in the 51 system.
j Programs by 06/01/92. Ensure that AS$1GNED FUNCTIONS ARE CONOUCTED IN COMPLf ANCE No violations have been noted in areas of responsibility. One VITH TECHNICAL SPECS 0A. REGULATORY REQUIREMENTS. APPtlCABLE inspector followup item was opened on the adequacy of the taVS. COMPANY & DEPARTMENT POLICIES & PLANT PROCEDURES. controls used to manage the Eroston/Corroston Program. The
- No NRC violations in areas of program responsibility. SALP report recently issued also listed this program as
- Maintain knowledge of Technical Support guideltnes. needing aggressive attention.
Also, an ACR was generated during the period that documented a missed NRC comitment relating to development of an Eroston/ Corrosion program procedure. This is an example that indicates more suphasis on program manageient and control is i teedtately needed, and is indicative of unsatisfactory performance. 5% e ACA i Ensure that WRK IS PERTORMED AND EQUIPMENT AND WORK There have been no vehicle accidents or personal injuries l' ENvlRONMENT MAINTAINED IN aCC0eDANCE WITH THE COMPANY. PLAllT. reported during the period. Participation in the weekly and NRC. AND 05HA SAFETY RULES AND REGULATIONS AND A HIGH STANDARD monthly safety meetings has been at the expected level. OF HOUSEKEEPING 15 MAINTAINED IN AREAS OF SUPERVISION.
- No vehicle accidents.
l e to personal injuries, e Compilance to AP 010 housekeeping requirements.
- Attend. and partictpate in, weeltly and monthly safety j meetings.
l.ATIMER.MTR' i MIDYEAR PERFORMANCE APPRAISAL I MAME: John Y. Latiner Accountability / Expectation Progress /Caesants 4 Contribute to COST-EFFECTIVE PLANT OPERATIONS. IMPROVED PLANT More involvement in controlling costs of assigned projects is PR_0 GRAM $. AND IDENTIFICATIDs OF LONG-RANGE NEEDS. needed. A system of followup on actual and counttted costs -
- Ensure budget items are maintained within funding Ilmtts, should be developed.
- Meet all published milestones that relate to outage Outage plans require more detail and discussion of project planning. needs and impact.
- Provide basic plan to P&$ for RF0 15 and 16 by 10/15/92.
i Maintain EFFECTIVE C0fstUNICAff 0NS by coordinating the planning Formal reviews with major customers are not documented and and execution of work in area of responsibility with plant results shared with management. More concern for developing a groups; providing and securing infonnation to keep supervision high degree of custome.' satisfaction should be shown. 4 and others infonned; and providing effective interface with The welding support for Modification.1074 was noted by audit groups as required. customers as being connendable. ,
- Perfona formal, semi-annual review with asjor customers to Maintenance has requested training in the areas governed by determine their degree of satisfaction with our services. the Corporate Welding Manual. This training should be aggressively pursued. Fonnel reviews with major customers of 4 services provided may reveal the need for igrovenent in other 4
_ areas. Over conuunication should be the none in all areas of responsibility. ] This overall midyuse rating is provfdad as a general indicator of progress to data but does not reflect a ceplete appratsal evaluation as will be prwvided at the and of the annual review period. Overall Midyear Rating: (MINUS) ( ) LAISATI$ FACTORY ( I- ) SATI5 FACTORY ( ) ColgIENDASLE ( ) OUTSTANDias Appratsal and Coments By! # Date: Y l Coments, if any by supervisor based on discussion on egloyee's rating. i 1 3 i 5 4 i r I have reviewed the infonnetton on this fon Egloyee Signature: 84 e. f8SDoMSe Date: I Surarvisor 5tgnature:
- Date:
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i Rev. 8 Fage 64 of 63 i FI.F-026 _
AfiACp(w' :
. asVERSE CONDITION REP 0' :
i CONTINUATION PAGE ACR NO: 92 256 CONTINUATION FOR: 0 REGULATORT COMPLIANCE COMMENTS 0 ADVERSE CON 0lfl0N DESCRIPfl0N X EVALUATOR COMMENTS 0 IMMEDIATE CORRECTIVE ACTION TAKEN X NON*$lGNIFICANT EVALUAfl0N O OPERAfl0NS REPORTA81LITT BASIS 0 QTHER: > 0 REcuLATORT COMPLIANCE REPORTA5tLITT BA515 EWNT DESCRIPTION Generic Letter 89 08 was issued to the NRC on May 2, 1989, and required response to the NRC by July 21, 1989. The response was coordinated by the Nuclear Licensing Section for RNP, NNP, and SNP. Input for RNP's response was provided by Technical Sgport to Regulatory Compliance on June 28, 1989. This response stated "As an added enhancement, MsR2 Intends to incorporate the (Errosion corrosion) program into the Plant operating Manual." This statement was not provided by Technical Support,,but was inserted by the NLS Engineer responsible for the response during the response preparation. Ne identified this intended comunitment on en Outcoine Nec Corresoondecce Comi tmen t f0 form from NGGM Procedure 304-01. However, this casunitment was not acknowledged by the Techncial Support reviewers during site routing, and the Regulatory Congliance individual responsible for the docunent f allec. to capture the connitment on the RAIL. This is contrary to the regJirements of RP 007, which provides instructions j for comitment identification and tracking. ANALYSIS (CAUSE OFTERMINATION) The cause of this event is attributed to f ailure to follow the regJirements of RP 007. Contributing to this cause is the f ailure of the Technical Support reviewers to acknowledge by signature acceptance of the consnitment, tesEDI ATE costECTf W ACTION NRC tr.spection Report 92-13 has identified weeknesses in the errosion/ corrosion control program (R!! 9213 01 IFI). This item is now being tracked as RAIL 92R0230. Swis Item 92 01909 has been opened to incorporate the l Errosion/ Corrosion Control Program into the POM. l l l l PROPOSED ComeECT1W ACTiou . l The Outgoing Regulatory Correspondence Traveler will be modified to include the NGCM 304 01 process for comitment , i acknowledgement. This form will be evellable or. the LAN for Regulatory Compliance persormel to use as a tool to l f acilitate acknowledgement of ctunnitments try signature. This will be completed by Sept. 15, 1992. ) r PLP 026 Rev. 8 Page 65 of 63 4 l
AS REQUESTED BY YOUR LETTER OF AUGUST 13, 1993 EXCESS MAIN STEAM FROM MSRs TO CONDENSER AND NO. 6 HEATERS BLOWDOWN TO CONDENSER
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FEEDWATER T0' CONDENSER HEATER DRAIN FROM MOPS-SCRUPS TO HEATER DRAIN TANK B CHECK THE REPLACEMENT HISTORY ON THESE LINES TO VERIFY POOR' DESIGN. PICWD
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BY: I 8 # #I
/ '
RH .93- A - O /26 4
- O 1
l
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i ALLEGATION REVIEW SUPf(ARY REPANEL FACILITY NANE: ROBINSON ALLEGATION NO. RII-93-A-0125 DATE OF ARP: 9/2/93 PANEL NO. []l [/]2 []3 []4 DATE RCVD: 08/30/93 BC/SC: VERRELLI/CHRISTENSEN
SUBJECT:
SPECIFICS RECEIVED FROM ALLEGER ACTION: DRS/ENG (CROWLEY) INSPECT COR0SION/ EROSION ISSUES DETERMINE IF THERE ARE ANY SAFETY PROBLEMS. LOOK AT WHETHER THEY ARE FOLLOWING DESIGN REQUIREMENT AND IF THERE ARE ANY REPEAT FAILURES THAT HAVE NOT BEEN PROPERLY EVALUATED. ASSIGNED TO:
- DRS/ENG PANEL ATTENDEES:
ORA DRP DRS DRSS OI []EBNETER []MERSCHOFF []GIBSON []STOHR []VORSE []REYES [/] JOHNSON [/]JAUDON []MALLETT. [] [/]JENKINS []VERRELU []JUUAN [] CLINE [] [] EVANS []SINKULE []PEEBLES []COLUNS [/]DEMIRANDA []HERDT [/]BLAKE [] []IGNATONIS []CRLENJAK [/]CROWLEY [] . []TROJANOWSKI [/]CHRISTENSEN [] [] [] SLACK [] [] []
x.- . 1 OCT 2 91993 t ' o ) Docket No. 50-261 License No. DPR-23 i i Carolina Power and Light Company d ATTN: Nr. C. R. Dietz Vice President l H. 8. Robinson Steam Electric Plant Unit 2 4 P. O. Box 790 3. Hartsville, SC 29550-0790 Gentlemen: i
SUBJECT:
NOTICE OF VIOLATION
.- (NRC INSPECTION REPORT NO. 50-261/93-20) i l This refers to the inspection conducted by 8. Crowley of this office on
- September 13-17 and September 27 - October 1, 1993. The inspection included a review of activities authorized for your H. 8. Robinson facility. At the
- conclusion of the inspection, the' findings were discussed with those members
- of your staff identified in the enclosed report.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures ' . and representative records, interviews with personnel, and observation of .._ j activities in progress. i l i Based on the results of this inspection, certain of your activities appeared l
- to be in violation of NRC requirements,-as specified in the enclosed Notice of I Violation.
~ You are required to respond to this letter and should follow the instructions , specified in the enclosed Notice when preparing your response. In your ; 4 response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this . Notice, including your proposed corrective actions and the results of future l inspections, the NRC will determine whether further NRC enforcement action is ; necessary to ensure c upliance with NRC regulatory requirements. l In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room. j The responses directed by this letter and the enclosed Notice are not subject
> to the clearance procedures of the Office of Nanagement and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-511.
/
M5iiM62.2 2 4pp.
OCT 2 9 '993 Carolina Power & Light Co. 2 Should you have any questions concerning this letter, please contact us. Sincerely, t S i Caudie A. Julian, Chief Engineering Branch Division of Reactor Safety t
Enclosure:
- 1. NRC Inspection Report
- 2. Notice of Violation j i
' ' I cc w/encis: M. P. Pearson Plant Manager I H. B. Robinson Steam Electric Plant l P. O. Box 790 Hartsville, SC 29550 - H. W. Habermeyer, Jr. Vice President Nuclear Services Department Carolina Power & Light Company P. O. Box 1551 - Mail OHS 7 Raleigh, NC 27602 ; D. B. Waters, Manager - Regulatory Compliance l H. B. Robinson Steam Electric Plant P. O. Box 790 l Hartsville, SC 29550 . 4 Max Battiia, Chief . Bureau of Radiological Health Dept. of Health and Environmental ; Control 2600 Bull Street Columbia, SC 29201 (cc w/enci cont'd - See page 3)
d c ,. Carolina Power & Light Co. 3 OCT 2 9 593 (cc w/ enc 1 cont'd)
- Dayne H. Brown, Director ___
d Division of Radiation Protection N. C. Department of Environment,
- Commerce & Natural Resources
, P. O. Box 27687
- Raleigh, NC 27611-7687 McCuen Morrell, Chairman 1 Darlington County Board of Supervisor County Courthouse
< Darlington, SC 29535 H. Ray Starling -
Vice President - Legal Department
. Carolina Power and Light Co.
i P. O. Box 1551
! Raleigh, NC 27602 i Karen E. Long 4 Assistant Attorney General
~ State of North Carolina P. O. Box 629 Raleigh, NC 27602 4 Robert P. Gruber Executive Director Public Staff - NCUC
- P. O. Box 29520 l
Raleigh, NC 27626-0520 ! Public Service Commission
- State of South Carolina -
j- P. O. Box 11649 - j Columbia, SC 29211 (bec w/enci - See page 4) . t 4 4 i e
$ Carolina Power & Light Co. 4 OCT 2 91993 bec w/ encl: H. Christensen, RII B. Mozafari, NRR Document Control Desk NRC Resident Inspector U. S. Nuclear Regulatory Commission Route 5, Box 413 Hartsville, SC 29550 i i k t FILE NAME: S:/DRS/EB/R0893-20.BC I RII:DRS S RII:DRP [> BCrowley ake HC ristensen 10/)h/03 /Al/93 10/tN93
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ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power & Light Company Docket No.: 50-261
- H. B. Robinson License No.: DPR-23
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$ During an NRC inspection conducted on September 13-17 and September 27 - October 1,1993, a. violation of NRC requirements was identified. In ] accordance with the " General Statement of Policy and Procedure for NRC
- Enforcement Actions," the violation is listed below
10 CFR E0, Appendix B, Criterion V, requires, in part, that " Activities affecting quality shall be prescribed by documented instructions, procedures, and drawings of a type appropriate to the circumstances and shall be d accomplished in accordance with these instructions...." Paragraph 7.0 of Attachment 8.3 to Special Procedure SP-1240, Steam Generator . Eddy Current Testing During RF0 15, requires that, "All eddy current test j equipment provided by ABB Combustion Engineering shall be certified...... Documentation of calibration will be provided prior to the start of the inspections." . Contrary to the above, on October 1,1993, Eddy Current Testing was in process
- on all three steam generators. Onsite equipment certification / calibration
! documentation for equipment being used on steam generators "A" and "B" had expired and the equipment being used for steam generator "C" had not been i certified / calibrated. This is a Severity Level IV Violation (Supplement I). i You are required to respond to this letter and should follow the instructions ! r specified in the enclosed Notice when preparing your response. In your I i response, you should document the specif_ic actions taken and any additional . i actions you plan to prevent recurrence. After reviewing your response to this
- Notice, including your proposed corrective actions and the results of future 1 inspections, the NRC will detennine whether further NRC enforcement action is
- necessary to ensure compliance with NRC regulatory requirements. Pursuant to
- the provisions of 10 CFR 2.201, Carolina Power & Light is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory
- Commission, ATTN
- Document Control Desk, Washington, D.C. 20555 with a copy i to the Regional Administrator, Region II, and a copy to the NRC Resident l
. Inspector at the facility that is the subject of this Notice, within 30 days ' of the date of the letter transmitting this Notice et Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and l i should include for each violation: (1) the reason for the violation, or, if l contested, the basis for disputing the violation, (2) the corrective steps I that have been taken and the results achieved, (3) the corrective steps that , will be taken to avoid further violations, and (4) the date when full t compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be NllQOUR I G. !
i 2 Carolina Power & Light Company Docket No.: 50-261 H. B. Robinson License No.: DPR-23 issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time. Dated at Atlanta, Georgia this 29th day of October 1993 I i 4 i J s 1 1
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UNITED 5TATEs jc# ase%,t# NUCt. EAR REGUt.ATORY COMMISSION
, ;, REGloN N g ", 101 MARIETTA STREET, N.W.. SUITE 2500 t
5 J* ATLANTA. GEORGIA 303D4133 , ] Report Nos.: 50-261/93-20
- Licensee: Carolina Power and Light Company P. O. Box 1551 j Raleigh, NC,'27602 l Docket Nos.: 50-261 License No.: DPR-23 I Facility Name: H. B. Robinson Inspection Conducted: September 13-17 and September 27 - October 1, 1993 Inspectors:' . O f /d8 f5
- 8. R. Crowley g Date Signed a .
Approved by: /0 /
- . Blake, Chief Date Signed a rials and Processes Section ;
- En insering Branch. i Division of Reactor Safety i
StM1ARY j Scope: - t i This routine, announced inspection was conducted on site in the areas of: i (1) Inservice Inspection (ISI), (2) Flow Accelerated Corrosion (FAC), and (3) _ review of corrective actions for previou_s inspection findings.
- Results
i In the areas inspected, one violation - failure to follow procedures for calibration and certification of ET equipment - Paragraph 2.c.(7) - was l identified. No deviations were identified. In the area of ISI, weaknesses were identified relative to lack of details in administrative control procedures and caordination of examination preparation , and examinations. However, in general, the program appeared to be functiening 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.
4
-Relative to the FAC program, significant improvements were noted. Engineering Design Guidelines had been issued and Engineering was involved in the process.
f//CY$0 h ,, i
i i' 2 i 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 i 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 I analysis completed. An aggressive inspection program for the current outage had been implemented to obtain data to further improve the program and predict 3 future wear. u I d i 5 I i i i 1 e A
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i i
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l l l 2 REPORT DETAILS I. Persons Contacted Licensee Employees j *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 Specillist, Technical Services
- I. Simpson, Supervisor, NDE Services j P. Tingen, NED Technician i
*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 1 Services, Steam Generator Project Manager i
- S. Larson, Level III Examiner - Nuclear Energy Services (NES) i
! T. Roland, Modification Implementing Hanger (MIH) Coordinator - Power 1 1 Plant Maintenance (PPM) ! R. Valladares, Authorized Nuclear Inservice Inspector (ANII) - Hartford l Steam Boiler _ 1 Other licensee employees contacted during this inspection included engineers, QA/QC personnel, craft personnel, security force members, technicians, and administrative personnel. - l NRC Employees , i
*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.
t 5
11 RESULTS i In the areas inspected, one violation, as detailed in paragraph c.(7), was identified relative to use of non-certified SG tube ET equipment. I Weaknesses were identified relative to lack of details in administrative control procedures (paragraph a. above) and coordination of examination l l preparation and examinations (paragraph c. above). However, in general, 1 the program appeared to be functioning well. Examinations were being l 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) l 1
In response to Generic Letter (GL) 89-08, Erosion / Corrosion Pipe Wall ! 4 Thinning, licensee's have implemented long tern Erosion / Corrosion (E/C) or FAC programs. The licensee's FAC program was evaluated in an l inspection documented in NRC Inspection Report 50-261/92-13. During that ' inspection the inspector identified a weak program, specifically citing 4 lack of corporate involvement and organization of the program. The licensee acknowledged a weak program and indicated that improvements were 1 planned. The purpose of the current inspection was to evaluate the l status of the program and determine if an adequate program was in place. The following is a summary of the inspection activities and results: . l
- a. General Based on discussions with licensee personnel, review of the l documents listed in paragraph b. below, and observation of the l
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 i 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, l and perform a CHECMATE Pass 1 Analysis. i
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1 I l 12
- CP&L Nuclear Assessment Department (NAD) performed an
) assessment of the FAC program corporate wide, including 4 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 I ! CHECMATE analysis, plant experience, industry experience, and , 4 engineering judgement. The inspection results will be entered i j into the CHECMATE model to perform the Pass 2 analysis. i In addition to the above completed actions, the Site FAC Coordinator ! identified the follt. wing further program improvements planned to be completed in the next six Months: The NAD assessment noted that the Isometric Drawings are not l
- plant controlled drawings. The drawings will be converted tc
- plant controlled documents, errors corrected, and replacement ;
materials identified. ! The 1994 budget has budgeted funds to: develop Isometric j Drawings for unmodelled, susceptible piping; fund CHUG , participation, and perform additional inspections in small bore
- and isolable lines.
i Backup FAC Coordinator will attend CHECMATE training in j November. { - Modify Work Request (WR) computer program (AMS) to flag piping ,
- replacements in see.ondaryylant to help track replacements. .
The Chemistry Group belongs to EPRI water chemistry group. The Cycle 16 Plan includes raising Ph (additional hydrazine) and i consideration of ethanol amine treatment. - l Plans are to develop a budget for replacement of small bore i lines with stainless steel for turbine shell drains, crossunder i drains, and steam dump bypass (keep-warm) piping. '
; b. Review of Procedures
- The inspector reviewed the following documents which define the FAC
; program i i
t - - NED Design Guide DG-VII.5, Revision 0, Corporate Program for l Flow Accelerated Corrosion i 1 4
i e 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 , i
- AB8 Impe11 Corporation Calculation No. 0132-00142-02, H. B.
Robinson Unit'2 Systems Elimination Calculation
- PLP-051,, Revision 1, Flow Acceleratad Corrosion (FAC) monitoring Program
- RFO-15 Project Plan - Erosion / Corrosion Monitoring Program i
! - CP&L NAD Report NAD 93-504, Corporate Flow Accelerated Corrosion Assessment Report
- Technical Support Guideline TSG-210, Revision 0, FAC Program Implementation 3
- NDEP-427, Revision 0, Interim Change 1, Digital Ultrasonic l Thickness Measurement (Panametrics Model 26DL Plus) for i
Erosion / Corrosion Detection and Monitoring [
- NDEP-1012, Revision 0, Gridding of Components for
! Erosion / Corrosion i c. Observations and Reviews e l In addition to review of the above program, procedures, and plans, I ! the inspector observed in-process activities and reviewed other aspects of the FAC program as detailed below: l ' - In-process grid layout was observed for components FW 10-14, FW . 9-15, FW 11-17, FW 10-8, ind 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 j examiners who performed this work were reviewed.
d i - The inspector attempted to review records and determine the ! extent of previous problems with through-wall piping leaks due I to FAC. Records were not readily available to determine the i exact nuraber of through-wn'.1 leaks. However, based on l discussions with System Engineering personnel, since issue of i Revision 3 (early 1989) to the Temporary Modification j 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 i i
m :wem. 4 +. -.4A e -A-A# .w 5 mJ * -4.m 4 - 4A.,.__ _A .- mu Jt e.m- AA- h-M4 .h* -Jh-----+-4e-a +u--.-.----. -- v+h.2m,E Ea+ .-
*ml l
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- . i l were due to FAC. Based on this log, only one of these leaks )
i were in 6" diameter piping. The others were in small diameter i (less than 2") piping. Although not a complete picture, since this does not include piping thinned and replaced before l 1eaking, this does give some indication of previous FAC ) problems at Robinson. l 1
- The inspector examined licensee's past practice and future !
plans for material replacements for FAC degraded piping, i.e., l practices for replacing "like for like" or-upgrading to better i materials. Although the type material used for past replacements is not raadily 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 l materials: Ell.t Size and System Materialfsl Used 10/84 3" - Htr. Drains and Vents Carbon Steel (Reheat Excess Sta to No. 6 FW Heaters) 10/88 Carbon and Stainless 10/84 3" and 6" - Heater Drains Carbon Steel 11/88 Carbon and Stainless 1 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. Vivs. 5/92 Discharge on Heater Drain Carton Steel ' Pumps l From the above it is obvious that there was not always an ! attempt to upgrade materials for piping replacements. In the l past, the plant could replace "like for like" as long as the ! criginsi design was met. As noted above, in the past, the FAC ; program was relatively weak and it appeared there was not much l emphasis on upgrading materials. j I i
. . . 1
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2 . . i s ! j e l 15 l Today, the general policy is to replace small diameter FAC l degraded piping with Stainless Steel and large diameter with l
- 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 i
; material requires Engineering approval through the Modification <
l Process. The improved program should ensure that high priority l is given to material upgrades whenever materials are replaced. ' } , At the completion of the inspection,185 'of the 285 large bore i piping locations had been inspected. Forty-one of the 185 i , required NED evaluation (less than 0.875 X t.). However, l only 4 were predicted to be below minimum wall before the next !
- RF0. These are being evaluated for replacement. i RESULTS l
1 l No violations or deviations were identified. ; Significant improvements were noted in the FAC program. Engineering i < 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 i 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 4 susceptible piping walked down and Isometric Drawing prepared. The EPRI CHECMATE Model had been implemented and the Pass 1 analysis completed. L 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 l needed: i The Outage Plan needs more formal details on how the plan is - i 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 )
I working on procedure changes to provide more details for the Outage Plan. i i - Modification Procedures need to provide for-FAC Coordinator review l of modification and change documents for systems susceptible to FAC l to obtain his input and keep him informed of changes to the systems. I I
__ . . . .-. . .- .. .- . .- - - ~. .- - . -- 16 4 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 i continue to be implemented. , Corrective actions for the weaknesses identified in the NAD Assessment need to be completed, especially upgrading the Isometric j Drawings to plant controlled drawings.
- 4. Observation of Miscellaneous Work Activities (55050 and 37700) 4 During observation of ISI and FAC in-plant activities, the inspector examined the following work activities:
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- a. Modification M-1104, Pipe Support Work
! This Modification covers extensive re-work of pipe supports in i systems through-out the plant. The inspector discussed the work with the contractor (PPM). Completed Auxiliary Feedwater (AFW) l- system supports SS-2225 and SS-2228 in the Turbine Building were l inspected. In addition, the completed work packages, including i 4 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.
i ! Also, completed work packages for supports SS-2232, SS-2233, and SS-2234, which involved changing the length of the extension piece j on the pipe support struts by cutting and re-welding, were reviewed. l The records included drawings, weld records and detailed work ! instructions, including verification of transfer of identification l on the studs (weldless EYE) after cutting. l RESULTS
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i 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 i completed. I
- 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- l process documentation, the inspector reviewed supporting records for I the following: e i l
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ne49 UNITED STATES g4 NUCLEAR REGULATORY COMMISSION REGION H E .o 101 MARIETTA STREET N.W., SUITE 2900 i Es j ATLANTA, GEORGIA 303234190 January 11, 1994 k...+/ e MEMORANDUM FOR: 0. DEMIRANDA, REGIONAL ALLEGATION COORDINATOR $
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FROM: C. JULIAN, CHIEF ENGINEERING BRANCH, DRS I VIA: A. GIBSON, DIRECTOR DIVISION OF REACTOR SAFETY , p\gp
SUBJECT:
ALLEGED DISCRIMINATION FOR REPORTING EROSION / CORROSION i PROBLEMS TO THE NRC - ROBINSON - (CASE No. RII-93-A-0125) The DRS assignment for the subject case consisted of performing a technical . inspection of the Erosion / Corrosion (a.k.a. Flow Accelerated Corrosion) program and comparing the results of the inspection with the results of the inspection that was used to provide the input for the last SALP report. The Erosion / Corrosion program was ' inspected by Mr. N. Economos during an inspection on April 27 through May 1, 1992, as reported in Inspection Report < No. 50-261/92-13. The NRC assessment at that time was that licensee's program
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was not functioning well. This is the assessment that was reflected in the 1 SALP report. The flow Acclerated Corrosion program was again inspected, this . time by Mr. Crowley, during an inspection on September 13-17 and September 27 thru October 1, 1993, as reported in Inspection Report No. 50-261/93-20. The inspector who conducted the 1992 inspection, Mr. Economos, made the l critical assessment of the program based on his evaluation of the ongoing l activities at the site during that particular outage. His ins'pection did 1 involve discussions with the engineer that was assigned to the program, but it , is clear that his assessment would have been just as critical without input j from the engineer. ) The 1993 inspection report noted that significant improvements had been made in the area of Flow Accelerated Corrosion. These significant improvements were caused by the amount of management attention being directed toward this , area. The significant differences were tlat the site assignment apparently went from a part-time assignment for one engineer to a full-time position with ; an assigned back-up; and there is now evidence that management has been l providing technical support from contractors and corporate engineering. ! DRS considers the Robinson Flow Accelerated Corrosion program to be acceptable l at this time. This completes DRS action on this allegation. i
. Julian, i Chief Engineering Branch, DRS I encl: Report 50-261/92-13 excerpts j Report 50-261/93-20 excerpts '
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