ML20149K173
| ML20149K173 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/13/1994 |
| From: | Blake J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Uryc B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20149K047 | List: |
| References | |
| FOIA-96-32 NUDOCS 9602210471 | |
| Download: ML20149K173 (4) | |
Text
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ptv.a8?og UNITED STATES i
g gs v
NUCLEAR REGULATORY COMMISSION
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REGION 11 gCg E
o 101 MARIETTA STREET, N.W., SUITE 2000 E
if ATLANTA, GEORGIA 3EI234199 E OI g7
...../
s.
December 13, 1994 i
MEMORANDUM T0:
- 8. URYC, DIRECTOR ENFORCEMENT AND INVESTIGATION COORDINATION STAFF FROM:
J. BLAKE, CHIEF Mh ERIALS AND PROCESSES SECTION, DIVISION OF REACT R SAFETY VIA:
A. GIBSON, DIRECTOR, DIVISION OF ACTOR SAF
SUBJECT:
ALLEGED DISCRIMINATION FOR REPORTING EROSION / CORROSION PROBLEMS TO THE NRC - ROBINSON - (CASE No RII-93-A-0125)
DRS has completed a review of the 01 transcript (Interview with the concerned individual (CI) by 01 on February 3, 1994,) related to the subject concern.
The results of this review are summarized in the attached allegation evaluation report.
This concludes the DRS review of Case No. RII-93-A-0125.
Attachment:
As stated cc: w/enci
- 0. DeMiranda A
\\'
/
9602210471 960201 PDR FOIA LATIMER96-32 PDR
ALLEGATION EVALUATION REPORT ALLEGATION NUMBER RII-93-A-0125 HARASSMENT FOR REPORTING EROSION / CORROSION PROBLEMS CAROLINA POWER AND LIGHT H. B. ROBINSON DOCKET NUMBER 50-261 1.
STATEMENT OF ALLEGATION The concerned individual (CI) was interviewed by 01 and the transcript provided to DRS for review.
In addition to the discussions about the circumstances of his removal from his position at H. B. Robinson, the CI provided information involving one other matter of potential technical concern.
0I also identified a discussion about Service Water System problems which started on page 82 of the transcript L;...ther matter of potential technical concern.
DRS was asked to review the transcript for potential technical issues and to evaluate the two identified concerns.
DRS reviewed the transcript and did not identify any technical concerns which had not been previously investigated. A discussion concerning the two concerns identified by 01 follows.
The first matter involved a typed statement that was provided by the CI in response to questions about whether there were any additional technical issues at H B Robinson that the NRC should be aware of. This concern is as follows:
During the 1992 Spring outage as a result of the erosion / corrosion inspection, it was discovered that the base metal adjacent to the weld on the steam generator nozzle to the feedwater reducing elbow was signifi~cantly below minimum wall (based on the design pressure of the feedwater system) on the elbow (carbon steel) side.
The base metal on the nozzle side was acceptable due to a higher strength of the P-3 material nozzle.
Subsequent investigation revealed the elbow had been counterbored to match the Westinghouse nozzle.
An engineering evaluation was prepared by the Corporate Nuclear Engineering Department that concluded the remaining wall thickness of the elbow was 0.015" above the minimum wall required based on the design pressure of the steam generator.
The assumption was made that the pressure at the weld could not exceed the pressure of the generator since no valve was between this weld
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and the generator.
This assumption is flawed because the generator and FW piping are under dynamic pressure not static pressure.
If static
)
pressure exists, no flow would occur.
The direction of flow is l
A-2 into the generator, through the ring header, and out the J-nozzles.
For flow to occur, the pressure at the weld would have to be several hundred pounds higher than the internal pressure of the steam generator.
If a higher pressure (Required for dynamic flow) was used for the determination of minimum wall, the margin (.015") of safety quickly disappears.
In addition, no investigation was done i
to' determine if seismic conditions had been satisfied due to the i
reduced wall.
1 The other matter of potential technical concern involved a discussion about the condition of the Service Water System that starts on page 82 of the transcript.
The CIs discussion about the service water problems is as follows:
This involved the service water placket (sic) at the intake.
When the NRC came in on a normal inspection, I guess, during the 1992 spring outage, they went down to the intake and found that the down comers, coming off the pumps, going into the big service water headers, were corroded from the outside, and it was further evaluated that it needed to be replaced, and they were replaced at that same outage.
Tht, also looked at the header pipe and found some areas that had some OD corrosion on that too.
And they also made i
comments of that in their exit interview and, I think, their final report.
1 And when I talked to Mr. Cleary about that, I told him that the person at that time that was responsible for the service water 3
pipe was Warren Farmer.
And Warren Farmer apparently didn't do j
what he should have done, because the header pipe had no preventative maintenance done on it, no follow-up done on it.
I
,I believe it probably got a coat of paint and -- but it was never rechecked after that initial time.
And that being kind of protected should have made him realize that the header pipe, which l
was exposed to the rain, atmosphere, or whatever, could have been in worse condition.
That was never checked, i
l 2.
SUMMARY
OF CONCERNS Concern 1:
Feedwater piping that was found to be below minimum wall thickness was not analyzed properly.
Concern 2: At the same time that the NRC identified problems with the erosion / corrosion program, they also found problems with a lack of maintenance of Service Water System piping.
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~
A-3 3.
EVALUAfFON Concern 1: The CI states that the design assumption that the pressure of the feedwater piping would not exceed the pressure of the steam generator was flawed.
The CI states further that the system was under dynamic pressure and for feedwater to be forced into the steam generator, the pressure in the feedwater piping would have to be several hundred pounds higher than that of the steam generator.
The C1 apparently did not consider the fact that while feedwater is being pumped into the steam generators, an equivalent amount of steam is being drawn off to the turbine, or being dumped to the atmosphere through relief valves.
The system is of course a dynamic system, but the pressure boundaries, (i.e.,
the piping and the steam generator walls,) see essentially the same differential pressure between the internal of the system and the surroundings.
l The methodology for calculating the required pipe wall thickness t;ased on the design pressure of the attached steam generator is acceptable for determining operability.
(The concern is also alleviated by the consideration tt:at the
%sig., pressure of the steam generator is consider e higner than the operating pressure of the system.)
y Concern 2:
This discussion appears to be the CI's report that he had 1
approached Mr. Cleary to point out the fact that Warren Farmer had been responsible fo.' the lack of preventive maintenance and the resulting NRC 4
identified deterioration of the Service Water Header Piping during the same time frame that the CI had been responsible for the NRC identified problems with the Erosion Corrosion Program.
The NRC did in fact raise some issues about the condition of the Service Water System during inspections in 1992; these problems were discussed in the Maintenance / Surveillance Section of the same SALP report that reported that engineering involvement the Erosion Corrosion Program was not aggressive in the Engineering / Technical Support Section.
(It should be noted that the discussion about the Erosion Corrosion Program was included in the summary of the report, while the discussion about the Service Water System only appeared in the body of the report; therefore there would have been more management attention focused on the Erosion Corrosion Program.)
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4.
CONCLUSIONS Concern 1:
This concern was not substantiated.
The licensee's method of
.alculating piping oparability for the feedwater piping was appropriate.
Concern 2:
This concern was not substantiated in that it did not introduce a new technical issue.
The statements about the Service Water System problems in the transcript appear to be an example of how another person was not treated as harshly as the CI was when the NRC found serious problems in the system that the other person was responsible for.
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